Epstein Secrets

tional 968107 6 EFTA00300208 Association of Securities Dealers, Inc. or, if the transaction which gives rise to such controversy is effected in another United States market which provides arbitration facilities, before such other facilities." The NASD is now known as the Financial Industry Regulatory Authority

rved 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 Street New York New York 10019

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

he following Definitions and Instructions, on or before February 5, 2010, at the offices of Kramer Levin Naftalis & Frankel LLP, 1177 Avenue of the Americas, New York, New York 10036. Definitions and Instruction 1. The term "Amended Statement of Claim" means the Amended Statement of Claim, filed in 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

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 52nd Street New York, 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

ully submitted, KRAMER LEVIN NAFTALIS & FRANKEL LLP B ki tatE Marshall H. Fialun f an Stephen M. Sinaiko Gabrielle L. Gould 1177 Avenue of the Americas New York, New York 10036 Attorneys for Respondents The Bear Steams Companies, Inc., Bear, Stearns & Co. Inc., and Bear Steams Asset Management In

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