Epstein Secrets

mended statement of their claims against The Bear Steams Companies, Bear Stearns & Co., Bear Steams Asset Management ("BSAM"), and Warren Spector ("Spector") (collectively "Bear Steams"). These claims arise out of the collapse in the summer of 2007 of a group of hedge funds managed by Bear Stearns. Cla

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

dents" means and includes (a) The Bear Steams Companies, Inc., Bear, Steams & Co. Inc., and Bear Steams Asset Management Inc., and Warren Spector ("Spector") collectively or individually; (b) any of their past and/or present employees, directors, representatives, agents, officers, consultants, attorneys

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

levant information, is overly burdensome and vague, and is calculated to harass Claimants. 34. All documents concerning Respondent Warren Spector ("Spector"). Response: FTC objects because this request is not calculated to lead to the discovery of relevant information, is overly burdensome and vague.

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

f investors, and he was several reporting lines removed from the valuation, oversight and monitoring of the Funds. Epstein's decision to single out Spector as the responsible individual is puzzling at best. Second, Epstein's narrative ignores that, prior to investing with BSAM, he received extensive wri

"oversaw the management of the Funds" nor represented that he oversaw the Funds. Am. St. Claim 1 16. Indeed, Epstein admits as much, conceding that Ralph Cioffi and Matthew Tannin — not Spector — were "[t]he two Bear Steams executives most directly involved in managing the funds." Am. St. Claim 1 9. Epstein'

xchange Act (Against the Officer Defendants) 214 COUNT III For Violations of Section 20A of the Exchange Act (Against Defendants Cayne, Schwartz, Spector, Molinaro, Greenberg, and Farber) 215 vi EFTA00316720 Case 1:08-cv-02793-RWS Document 102 Filed 02/27/09 Page 8 of 347 PRAYER FOR RELIEF 116

dit Quality. Cayne: James E. Cayne, a director, Chairman of the Board and Chief Executive Officer of Bear Stearns during the Class Period. Cioffi: Ralph Cioffi, the Bear Steams trader who started and managed the High Grade Fund, a Managing Director of BSAM and a Director of BSC. CDOs: Collateralized debt o