Epstein Secrets

Kramer Levin Naftalis & Frankel LLP By: By: Stephen D. Susman Stephen M. Sinaiko Counsel for Claima

ndent Releasees, including Representative Claims and any Claims that any Claimant asserted or could have asserted in the Arbitration, the Action; or the Consolidated Action, that in any way arise out of, are connected with or relate to: (a) any of the HG Funds or the ABS Funds (together, the "Funds"); (b) any BSCI Secu

s. Dated: August 2011 Susman Godfrey LLP By: Stephen D. Susman 560 Lexington Avenue, 15th Floor New

7 Civ. 11633 (AKH) (S.D.N.Y.); Navigator Capital Partners, LP. v. Bear Stearns Asset Management Inc., et at, No. 07 Civ. 7783 (AKH) (S.D.N.Y.); and the Consolidated Action. 1.6 "Respondent Released Claims" means and includes all Claims of every nature, character and description, known and unknown, that Respondents, o

71 31 654.6686 E-MAIL issus.,450s.A.004wArce.om Stephen M. Sinaiko KRAMER LEVIN NAFTAILIS & FRANKEL LLP

Civ. 11633 (AKH) (S.D.N.Y.); Navigator Capital Partners, L.P. v. Bear Stearns Asset Management Inc., et at, No. 07 Civ. 7783 (AKH) (S.D.N.Y.); and the Consolidated Action. 1.6 "Respondent Released Claims" means and includes all Claims of every nature, character and description, known and unknown, that Respondents, o

s. Dated: August 2011 Susman Godfrey LLP By: Stephen D. Susman 560 Lexington Avenue, 15th Floor New

Civ. 11633 (AKH) (S.D.N.Y.); Navigator Capital Partners, L.P. v. Bear Stearns Asset Management Inc., et al., No. 07 Civ. 7783 (AKH) (S.D.N.Y.); and the Consolidated Action. 1.6 "Respondent Released Claims" means and includes all Claims of every nature, character and description, known and unknown, that Respondents, o