Epstein Secrets

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

artners, agents, shareholders, members, directors, officers, employees (including:-without-tiolita(ioa7 Michael Alix, James Cayne, Ralph R. Cioffi, Jeffrey M. Farber, Alan Greenberg, Raymond McGarrigal, Samuel Molinaro, Alan Schwartz, Warren Spector and Matthew M. Tannin), attorneys, accountants, auditors, affili

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

B. Alan D. Schwartz 115 C. Samuel L. Molinaro. Jr. 116 D. Warren J. Spector 120 E. Alan C. Greenberg 121 F. Michael J. Alix 123 G. Jeffrey M. Farber 124 H. Corporate Scienter 125 iii EFTA00316717 Case 1:08-cv-02793-RWS Document 102 Filed 02/27/09 Page 5 of 347 VI. ADDITIONAL ALLEGATIONS

atements false and misleading. D. Warren J. Spector 482. As Co-President and Co-Chief Operating Officer and a director of Bear Steams, Defendant Spector participated in the issuance of, signed and certified as accurate and complete as required by Sarbanes-Oxley, Bear Steams' materially false and misl

ated, and far below the industry average, even as Bear Steams' concentration of risky ABS was the highest in the investment banking community. G. Jeffrey M. Farber 500. As Senior Vice President of Finance and Principal Accounting Officer since February 2007, and Controller of the Company since January 2004, D