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

Statement of Claim that "in reality, Respondents created the Enhanced Fund as part of a scheme both to alleviate the looming liquidity problems that the High Grade Fund begun to encounter and to facilitate fraudulent manipulations of fund portfolio values already taking place in the High Grade Fund." 55. All docu

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.

tatement of Claim that "in reality, Respondents created the Enhanced Fund as part of a scheme both to alleviate the looming liquidity problems that the High Grade Fund begun to encounter and to 13 997243vI/011543 EFTA00731192 facilitate fraudulent manipulations of fund portfolio values already taking place in t

h and every allegations in the foregoing paragraphs of this Complaint as if fully set forth herein. This claim is asserted against Cayne, Schwartz, Spector, Molinaro, Greenberg, Alix and Farber ("the Officer Defendants"). 824. Bear Steams is a primary violator of Section 10(b) and Rule 1013-5, promulga

sly underrepresented the Company's true losses, including its losses on the worthless collateral it had received under the repurchase agreement with the High Grade Fund and the devalued and illiquid retained interests that it continued to carry on its books, as set out at paragraphs 212 to 216 above. 186 EFTA0031