Epstein Secrets

areholders, 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, affiliates, parents a

Cayne, Ralph R. Cioffi, Jeffrey M. Farber, Alan Greenberg, Raymond McGarrigal, Samuel Molinaro, Alan Schwa

s; and/or (I) the ownership at any time of any BSCI Securities. 1.7 "Respondent Releasees" means and includes Respondents, M. Morgan Chase & Co., Deloitte & Touche LLP, and each of their past, current and future predecessors, successors, assigns, limited and general partners, agents, shareholders, members, directo

l partners, agents, shareholders, members, directors, officers, employees (including 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, affiliates, parents an

Cayne, Ralph R. Cioffi, Jeffrey M. Farber, Alan Greenberg, Raymond McGarrigal, Samuel Molinaro, Alan Schwar

; and/or (j) the ownership at any time of any BSCI Securities. 1.7 "Respondent Releasees" means and includes Respondents, J.P. Morgan Chase & Co., Deloitte & Touche LLP, and each of their past, current and future predecessors, successors, assigns, limited and general partners, agents, shareholders, members, directo

l partners, agents, shareholders, members, directors, officers, employees (including 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, affiliates, parents an

Cayne, Ralph R. Cioffi, Jeffrey M. Farber, Alan Greenberg, Raymond McGarrigal, Samuel Molinaro, Alan Schwar

; and/or (j) the ownership at any time of any BSCI Securities. 1.7 "Respondent Releasees" means and includes Respondents, J.P. Morgan Chase & Co., Deloitte & Touche LLP, and each of their past, current and future predecessors, successors, assigns, limited and general partners, agents, shareholders, members, directo

ger.' According to the Amended Statement of Claim, Epstein began his career at Bear Stearns in 1977 after being personally recruited as a trader by Alan Greenberg ("Greenberg"), Bear Stearns' former Chairman. (ASOC ¶ 18). At Bear Stearns, Epstein traded options and served in the "special-products division," ad

o the Amended Statement of Claim, Epstein began his career at Bear Stearns in 1977 after being personally recruited as a trader by Alan Greenberg ("Greenberg"), Bear Stearns' former Chairman. (ASOC ¶ 18). At Bear Stearns, Epstein traded options and served in the "special-products division," advising some

not transfer its legal claims" is belied by the clear language of the assignment agreement between COUQ and YLK. In W R. Huff Asset Mgmt Co., LW v. Deloitte & Touche LLP, the Second Circuit held that, under the standing doctrine, "the minimum requirement for an injury-in-fact is that the plaintiff have legal title t

l partners, agents, shareholders, members, directors, officers, employees (including 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, affiliates, parents an

Cayne, Ralph R. Cioffi, Jeffrey M. Farber, Alan Greenberg, Raymond McGarrigal, Samuel Molinaro, Alan Schwar

s; and/or 0) the ownership at any time of any BSCI Securities. 1.7 "Respondent Releasees" means and includes Respondents, J.P. Morgan Chase & Co., Deloitte & Touche LLP, and each of their past, current and future predecessors, successors, assigns, limited and general partners, agents, shareholders, members, directo

t 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 DEMAND FOR JURY TRIAL

O: Chief Operating Officer. COSO: Committee of Sponsoring Organizations of the Treadway Commission. CSE: Consolidated Supervised Entity. Deloitte: Deloitte & Touche LLP, the external auditor for Bear Steams during the Class Period. Dimon: JPMorgan CEO Jamie Dimon. D&L AAG: The AAG for Depository and Lending Institu