Epstein Secrets

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

s; it claims to be an agency-only company. (So much for that concept.) 260. Bove's chagrin was shared by the Company's lenders. On March 6, 2008, Rabobank Group, one of Bear Stearns' European lenders, told the brokerage that it wouldn't renew a $500 million loan coming due later that week. That meant Raboban

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

arties to refuse to lend to the Company. 470. Moreover, as the Company's CEO, Schwartz knew or was reckless in not knowing that on March 6, 2008, Rabobank Group, one of Bear Stearns' European lenders, told the brokerage that it wouldn't renew a $500 million loan coming due later that week. C. Samuel L. Mol

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

een a problem. 792. At the time he made this statement, Schwartz, as the Company's CEO, was aware that on March 6, 2008, more than a week earlier, Rabobank Group, one of Bear Stearns' European lenders, told the brokerage that it would not renew a $500 million loan coming due later that week. He also knew tha