nced Funds were using proper valuation techniques and were managing their risk by prudently hedging. 7. Mr. Spector continually reassured me that the High-Grade Fund and subsequently the Enhanced Fund were using proper valuation and risk management techniques. 8. During 2006, the managers of the High-Grade Fund

wk." 4. In the summer 2006, Mr. Spector made another unsolicited call on Mr. Epstein soliciting Mr. Epstein to transfer FTC's entire investment in the High-Grade Fund into the Enhanced Leverage Fund. Once again, Mr. Spector specifically told Mr. Epstein that Mr. Spector would be investing his own money in the En