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agement. 4. Mr. Spector's responsibilities included providing investment advice to certain valuable Bear Stearns clients. One of those clients was Jeffrey Epstein. Mr. Epstein was a former Bear Steams partner and subsequently became a successful investor who invested substantial sums based on advice given by
ctor's responsibilities included providing investment advice to certain valuable Bear Stearns clients. One of those clients was Jeffrey Epstein. Mr. Epstein was a former Bear Steams partner and subsequently became a successful investor who invested substantial sums based on advice given by Bear Steams.
e Bear Stearns clients. One of those clients was Jeffrey Epstein. Mr. Epstein was a former Bear Steams pa
lients. One of those clients was Jeffrey Epstein. Mr. Epstein was a former Bear Steams partner and subsequentl
p with the idea to create the Enhanced Fund, which would utilize the same strategy as the High-Grade Fund only with leverage. 9. In order to make the Enhanced Fund viable, investors in the High-Grade Fund had to be convinced to roll-over their investments into the Enhanced Fund. Mr. Spector was charged with co
create the fiction that he was not involved. 5. In the 1990s, at a time when I trusted Warren, I introduced him to my friend and former colleague Jeffrey Epstein. I introduced him as someone Jeffrey could trust. I now regret both the trust I put in Warren and my introduction of him to Jeffrey. 6. Over time
5. In the 1990s, at a time when I trusted Warren, I introduced him to my friend and former colleague Jeffrey Epstein. I introduced him as someone Jeffrey could trust. I now regret both the trust I put in Warren and my introduction of him to Jeffrey. 6. Over time I observed that Jeffery relied upon W
rey became friends. EFTA00725242 7. Warren was not worthy of the trust that Jeffrey placed in him. [DOES JC HAVE KNOWLEDGE OF WARREN SEEKING OUT JE FOR THE FUNDS? IF SO, WE SHOULD AMPLIFY HERE] 8. It is now apparent that the Funds were not properly managed from the outset. It is also clear th
ed him to my friend and former colleague Jeffrey Epstein. I introduced him as someone Jeffrey could trust.
om me and others on Bear Steams' Board of Directors. As an example of his dishonesty, Warren secretly invested $25 million of Bear Stearns' money in the Enhanced Fund. This unauthorized investment resulted in almost a total loss. When confronted with irrefutable evidence of his duplicity at a meeting of the Board
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
esponsive documents. 54. All documents concerning the allegation on page 3 of the Amended Statement of Claim that "in reality, Respondents created the Enhanced Fund as part of a scheme both to alleviate the looming liquidity problems that the High Grade Fund begun to encounter and to 13 997243vI/011543 EFTA00
ultants and attorneys thereof 6. The term "Claimants" means and includes (a) Financial Trust Company, Inc.; (b) The C.O.U.Q. Foundation, Inc.; (c) Jeffrey Epstein; (d) any of their past and/or present employees, directors, representatives, agents, officers, consultants, attorneys, predecessors, successors or
All documents concerning the allegations on page 4 of the Amended Statement of Claim that "Respondent Spector ... personally solicited FTC, through Epstein, to invest in the Enhanced Fund, providing clearly misleading and false assurances about the Fund and its investment safety . . . [and] bolstered t
ny, Inc.; (b) The C.O.U.Q. Foundation, Inc.; (c) Jeffrey Epstein; (d) any of their past and/or present em
nd punitive damages. 54. All documents concerning the allegation on page 3 of the Amended Statement of Claim that "in reality, Respondents created the Enhanced Fund as part of a scheme both to alleviate the looming liquidity problems that the High Grade Fund begun to encounter and to facilitate fraudulent manip
Entities connected to both Jeffrey Epstein and the Enhanced Fund

Lesley Groff
PERSONDarren Indyke
PERSON
United States
LOCATION
Stephen Hawking
PERSONHarry Beller
PERSON
Les Wexner
PERSON
Bear Stearns
ORGANIZATION
Jimmy Cayne
PERSON
Spector
PERSONIra Zicherman
PERSON
Ralph Cioffi
PERSONBear Steams'
ORGANIZATIONCo-Chief
ORGANIZATIONGuide
LOCATIONthe High Grade Fund
ORGANIZATIONFranklin Collins
PERSONThe Bear Stearns Respondents'
ORGANIZATIONThe Wexner Children's
ORGANIZATIONthe Fund Managers
ORGANIZATIONthe Respondents or Fund Managers
ORGANIZATION