Epstein Secrets

rest, exceed $45 million. Introduction 2. At all times relevant to the claims stated herein, Claimant FTC was a corporation owned and managed by Jeffrey Epstein ("Epstein"), a wealthy and successful investor. At all times relevant to the claims stated herein, Claimant COUQ was a private foundation managed by

million. Introduction 2. At all times relevant to the claims stated herein, Claimant FTC was a corporation owned and managed by Jeffrey Epstein ("Epstein"), a wealthy and successful investor. At all times relevant to the claims stated herein, Claimant COUQ was a private foundation managed by Epstein.

imant FTC was a corporation owned and managed by Jeffrey Epstein ("Epstein"), a wealthy and successful inv

ld by both the High-Grade and Enhanced Funds. Had Mr. Epstein been made aware of the true nature of what was t

and correct copy of the foregoing instrument has been served by email and first class mail, this 16th day of September, 2009, on: Gabrielle Gould KRAMER LEVIN NAFTAILIS & FRANKEL LLP 1177 Avenue of the Americas New York New York 10036 E-mail: David B. Anders Meredith L. Turner WACHTELL, LIPTON, ROSEN & KATZ 51 West 52nd Str

individual subscribed on or after the date of Claimants' purchase of any limited partnership interest or other ownership interest in the Funds: (a) Jeffrey Epstein, (b) Harry Beller, (c) Darren Indyke, and (d) Lesley Groff. Response: FTC objects because this request seeks information that is not calculated to

lead to the discovery of relevant information and is overly burdensome. Subject to the forgoing, FTC will produce documents sufficient to show Mr. Epstein's educational and employment history to the extent such documents are readily available to FTC. 24. Documents sufficient to show Claimants' (a) ov

ete educational and employment background of (a) Jeffrey Epstein, (b) Harry Beller, (c) Darren Indyke, and

g, FTC will produce documents sufficient to show Mr. Epstein's educational and employment history to the exten

a true and correct copy of the foregoing instrument has been served by email and first class mail, this _th day of May, 2010, on: Gabrielle Gould KRAMER LEVIN NAFTAILIS & FRANKEL LLP 1177 Avenue of the Americas New York, New York 10036 E-mail: 21 David B. Anders Meredith L. Turner WACHTELL, LIPTON, ROSEN & ICATz. 51 West 5

is ___ day of August 2011 (the "Effective Date"), by and among (i) Financial Trust Company, Inc. ("FTC"), The C.O.U.Q. Foundation, Inc. ("COUQ") and Jeffrey Epstein (together, "Claimants") and (ii) The Bear Steams Companies Inc. (n/k/a The Bear Steams Companies LLC), Bear, Steams & Co. Inc. (n/lcia J.P. Morgan S

e C.O.U.Q. Foundation, Inc. ("COUQ") and Jeffrey Epstein (together, "Claimants") and (ii) The Bear Steams

FTC"), The C.O.U.Q. Foundation, Inc. ("COUQ") and Jeffrey Epstein (together, "Claimants") and (ii) The Bea

201 94.0 Avenue SWTLL. vimaamotow 00 101-3000 (206) SI 6-3880 DIRECT On FAX (71 31 654.6686 E-MAIL issus.,450s.A.004wArce.om Stephen M. Sinaiko KRAMER LEVIN NAFTAILIS & FRANKEL LLP 1177 Avenue of the Americas New York, New York 10036 Re: Settlement of Financial Trust Company, Inc. et al v. The Bear Stearns Companies, Inc.,