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

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 E-mail: E-mail: Stephen D. Susman 968107 20 EFTA00300222

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.

MER 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 York 10019 E-mail: E-mail: Stephen D. Susman 997243v11011543 EFTA00731200

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

nd that Claimants be directed to pay the costs, fees and expenses incurred in connection with this prorPnding. Dated: New York, New York WACHTELL, LIPTON, ROSEN & KATZ December 4, 2009 By: David B. Anders Meredith L. Turner 51 West 52nd Street New York. New York 10019 Attorneys for Respondent Wa