Epstein Secrets

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

Bear, Steams & Co. Inc. (BS&Co.), and Bear Steams Asset Management Inc. ("BSAM") (collectively, the "Bear Steams Respondents"), by their attorneys, Kramer Levin Naftalis & Frankel LLP, hereby request that Claimants produce the documents and information specified herein, pursuant to the following Definitions and Instructions, on o

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

fees and costs, pursuant to Rule 12700 of the Code of Arbitration Procedure for Customer Disputes. Dated: kflyikugust , 2011 Susman Godfrey LLP Kramer Levin Naftalis & Frankel LLP By: By: Stephen D. Susman Stephen M. Sinaiko Counsel for Claimants Freshfields Bruckhaus Deringer US LLP By: Marshall H. Fishman Gabrielle

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

2011 Susman Godfrey LLP By: Stephen D. Susman 560 Lexington Avenue, 15th Floor New York, New York 10022 (212) 336-8330 Counsel for Claimants Kramer Levin Naftalis & Frankel LLP By: Stephen M. Sinaiko 1177 Avenue of the Americas New York, New York 10036 (212) 715-9100 Freshfields Bruckhaus Deringer US LLP By: Marshall

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

2011 Susman Godfrey LLP By: Stephen D. Susman 560 Lexington Avenue, 15th Floor New York, New York 10022 (212) 336-8330 Counsel for Claimants Kramer Levin Naftalis & Frankel LLP By: Stephen M. Sinaiko 1177 Avenue of the Americas New York, New York 10036 (212) 715-9100 Freshfields Bruckhaus Deringer US LLP By: Marshall