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

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 Street New York New York 10019 E-mail: E-mail: Stephen D. Susman 968107 20 EFTA00300222

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

MER 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 52nd Street New York, New York 10019 E-mail: E-mail: Stephen D. Susman 997243v11011543 EFTA00731200

-3- EFTA00314492 legal basis to hold Bear Stearns responsible for these losses — much less to hold Mr. Spector personally responsible. FACTS A. Jeffrey Epstein's Long History with Bear Stearns. According to the Amended Statement of Claim (cited herein as "Am. St. Claim"), Jeffrey Epstein joined Bear Steams a

rust Company, Inc. ("FTC") and The C.O.U.Q. Foundation, Inc. ("COUQ") (collectively, "Claimants"), are retail investors managed by Jeffrey Epstein. Epstein, a very wealthy individual and a former partner at Bear, Steams & Co., Inc. ("Bear Steams"), is a long-standing customer of Bear Steams and a sophis

y, "Claimants"), are retail investors managed by Jeffrey Epstein. Epstein, a very wealthy individual and a

nd that Claimants be directed to pay the costs, fees and expenses incurred in connection with this prorPnding. Dated: New York, New York WACHTELL, LIPTON, ROSEN & KATZ December 4, 2009 By: David B. Anders Meredith L. Turner 51 West 52nd Street New York. New York 10019 Attorneys for Respondent Wa