Epstein Secrets

' VaR was far below the industry average, even as Bear Steams' concentration of risky ABS was the highest in the investment banking community. E. Alan C. Greenberg 487. As a director and Chairman of the Executive Committee of Bear Stearns, Defendant Greenberg participated in the issuance of Bear Steams' mater

in the investment banking community. E. Alan C. Greenberg 487. As a director and Chairman of the Executive Committee of Bear Stearns, Defendant Greenberg participated in the issuance of Bear Steams' materially false and 121 EFTA00316849 Case 1:08-cv-02793-RWS Document 102 Filed 02/27/09 Page 137 o

and 10-K. 124 EFTA00316852 Case 1:08-cv-02793-RWS Document 102 Filed 02/27/09 Page 140 of 347 501. The quarterly and annual reports signed by Farber repeatedly touted the Company's risk management, including its use of internally-developed models to derive the fair value of the Company's financi

mpliance Inspections and Examinations ("OCIE") 117 EFTA00316845 Case 1:08-cv-02793-RWS Document 102 Filed 02/27/09 Page 133 of 347 to Defendant Farber, who reported directly to Molinaro. The disclosure controls and procedures that Molinaro purportedly put in place should have informed him that the

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

to applicable clients and firm professionals. The ARAs are included in the AICPA's annual Audit and Accounting Manual ("AAM"). 345. In particular, Farber, Bear Steams' Senior Vice President-Finance and Controller, had previously been a partner with Deloitte. Accordingly, Farber should have had familia

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 218 vii

ccount (as nl 12/220/51 pursues to the b.mar's Capital AC C unuiLilifia Plan for Scrum Managing Directors 'CAPPlank exempt under Rule I Mu Remarks: kJ Greenberg, Alan C. [123/2005 „ Signature of Reporting Person Dale Reminder: Report en a separale Inc Ice each class al securities beneficially owned al eCt

rt to more accurately measure risk of loss." 726. In fact, the Company had undertaken no such review, and its Controller and Principal Accountant, Farber, had been repeatedly warned by government regulators that the Company's VaR models were inaccurate and out of date. According to the 2008 OIG Report

ed by, among others, 193 EFTA00316921 Case 1:08-cv-02793-RWS Document 102 Filed 02/27/09 Page 209 of 347 defendants Greenberg, Cayne, Schwartz, Farber and Molinaro. The Form 10-K made misrepresentations regarding the Company's financial results, risk management practices, exposure to market risk,