Attached are two Timelines (a comprehensive version and also a more narrow
version dealing with facts relevant to our case) received today from Jason Levin
of Steve Storch's firm.
Please review the shorter timeline version to make sure that it is
consistent with the information you gave Steve. Specifically, on pages
1,4,5 and 6 there are bracketed requests for "[Client to review
sequence]". Apparently, Steve and Jason are uncertain of the timing of
some of the conversations between you and Jimmy and Warren. In addition,
the information regarding the Board meeting at which Warren admitted to
transferring BS money to the fund -- do you know when that Board meeting
happened (according to Steve's notes it was around the time when the fund
tanked, but that means it could have happened any time between March 2007 and
June 2007) and do you know when Warren transferred the BS money to the
fund? Finally, I understand that you explained to Steve that you
initially mentioned possibly investing $50 MM, but Warren said you should only
invest $25 MM. Without more explanation that conversation does not run in
our favor. Did Steve misunderstand? Was it that you suggested
putting in $50 MM but Warren told you that because of the incredible demand for
subscriptions you were only able to invest (they could only accommodate) $25
MM?
The timeline is helpful, but it continues to lack force. We need
Steve to provide specific statements of allegations that Steve is going to make
to Bear's attorneys so that you and I can make them more forceful. I have
therefore asked that Jason and Steve prepare by tomorrow a script of the points
Steve intends to make during the Teleconference with Bear Stearns'
Attorneys. Jason just told me (at 6:00 PM) that he and Steve should be
able to complete the script by tomorrow, but did not want to do a super rush job
because it is so important, so he could not say by what time tomorrow the
script would be finished. I told Jason that this would obviously be
a first draft of the script and would require improvement, but to get it to us
as soon as they could.
Darren K.
Indyke
Attorney-At-Law
457 Madison Avenue
4th Floor
New York, New
York 10022
Tel: 212-750-1176
Fax: 212-750-0381
e-mail: dkiesq@aol.com
------------------------------
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| From: | Jason Levin <jlevin@samlegal.com> | |
| Subject: | Bear Stearns- timeline | |
| Date: | Tue, 15 Apr 2008 15:46:14 GMT | |
| To: | DKIESQ@aol.com | |
| Cc: | Steven Storch <sstorch@samlegal.com> | |
Darren,
As per our discussion, attached please find the detailed
timeline of relevant events. The timeline consolidates information pulled from
various sources, including Mr. Epstein, FTC and COUQ's files, several
complaints filed against Bear Stearns, and news reports. For your convenience,
we highlighted the more pertinent entries on the timeline. Also attached is a
document that contains only the highlighted entries. Please advise whether any
entries need to be supplemented or revised.
Regards, Jason
Jason Levin
Storch Amini & Munves PC
2 Grand Central Tower, 25th
Floor
New York, New York 10017
Tel: 212.490.4100
Direct: 212.497.8218
Fax: 212.490.4208
Confidentiality Notice:
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Thank you.
Chronology.Apr15.highlight.ShortForm.doc 61 KB
Chronology.Apr15.highlight.doc 120 KB