Epstein Secrets

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

ar Steams and billions of dollars of losses to firms around the world. The two Bear Steams executives most directly involved in managing the funds, Ralph Cioffi and Matthew Tannin, have been indicted for repeatedly lying to investors about the Enhanced Fund's condition from February to June 2007, when the F

evin Naftalis & Frankel LLP Marshall H. Fishman Stephen M. Sinaiko Gabrielle L. Gould 1177 Avenue of th

f any of them. 12. "Fund Managers" means any person involved, directly or indirectly, in the management of the Funds, including without limitation Ralph Cioffi, Matthew Tannin, Colin Gordon, and Franklin Collins. 13. The term "Bear Steams Fund" means any hedge fund, mutual fund, private equity fund or ot

Respectfully submitted, SUSMAN GODFREY L.L.P. Stephen D. Susman 654 Madison Avenue, 5th Floor New Yor

information relevant to the subject matter of the Amended Statement of Claim. Response: Jeffrey Epstein, Harry Beller, Warren Spector, James Cayne, Ralph Cioffi, Matthew Tannin, Colin Gordon, and Franklin Collins. 3. Identify each person relevant to the subject matter of the Amended Statement of Claim. R

?, USA TODAY, Mar. 24, 2009, at 1A. IS See e.g., Stephen Labaton, Scramble Led to Rescue Plan on Mortgages

Further, to the extent Claimants somehow attempt to connect their baseless allegations • . about the creation of the EL Fund to the indictment of Ralph Cioffi and Matthew Tannin, the portfolio managers of the HG Funds, it must be noted that Messrs. Cioffi and Tannin were acquitted of all charges on Novemb