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

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

ution and/or allocation of the Settlement Payment between and among the Claimants and/or their counsel. 3. Releases and Waivers by the Parties and Spector. 3.1 In consideration of the Settlement Payment and the release by Respondents provided for in paragraph 3.2, Claimants hereby release and forever

Bear, Stearns & Co. Inc. and Bear Stearns Asset Management Inc. - 2- KL3 , . 1. 1C7-2211112.1 EFTA00316036 Wachtell, Lipton, Rosen & Katz By: David B. Anders Counsel for Warren Spector - 3- I KL32*,1.1‘2.3aallatil EFTA00316037 Exhibit B UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x

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.

_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 York 10019 E-mail: E-mail: Stephen D. Susman 997243v110

ution and/or allocation of the Settlement Payment between and among the Claimants and/or their counsel. 3. Releases and Waivers by the Parties and Spector. 3.1 In consideration of the Settlement Payment and the release by Respondents provided for in paragraph 3.2, Claimants hereby release and forever

s Inc., Bear, Steams & Co. Inc. and Bear Stearns Asset Management Inc. KU " 1' 1 c.1=2•2 - 2- EFTA00615396 Wachtell, Lipton, Rosen & Katz By: David B. Anders 51 West 52nd Street New York, New York 10019 (212) 403-1000 Counsel for Warren Spector - 3- I KU ' .1.1. " 6=1= EFTA00615397 Exhibit B UNITE

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

s, 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 Warren Spector -30- EFTA00314519

ution and/or allocation of the Settlement Payment between and among the Claimants and/or their counsel. 3. Releases and Waivers by the Parties and Spector. 3.1 In consideration of the Settlement Payment and the release by Respondents provided for in paragraph 3.2, Claimants hereby release and forever

Stearns Companies Inc., Bear, Steams & Co. Inc. and Bear Stearns Asset Management Inc. - 2 - EFTA00283111 Wachtell, Lipton, Rosen & Katz By: David B. Anders 51 West 52nd Street New York, New York 10019 (212) 403-1000 Counsel for Warren Spector - 3 - EFTA00283112 Exhibit B UNITED STATES DISTRICT C

ution and/or allocation of the Settlement Payment between and among the Claimants and/or their counsel. 3. Releases and Waivers by the Parties and Spector. 3.1 In consideration of the Settlement Payment and the release by Respondents provided for in paragraph 3.2, Claimants hereby release and forever

ies Inc., Bear, Stearns & Co. Inc. and Bear Stearns Asset Management Inc. KU 23311357i - 2 - EFTA00586194 Wachtell, Lipton, Rosen & Katz By: David B. Anders 51 West 52nd Street New York, New York 10019 (212) 403-1000 Counsel for Warren Spector - 3 - KU 23311357i EFTA00586195 Exhibit B UNITED STA