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Homechevron_right Emailchevron_right Privileged and Confidential - Bear Stearns
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Privileged and Confidential - Bear Stearns

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?
DKIESQ@aol.com Apr 15, 2008 10:20 PM
To
<jeeproject@yahoo.com>
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
 
------------------------------
IRS Circular 230 Legend: Any advice contained herein was not intended or written to be used, and cannot be used, for the purpose of avoiding U.S. federal, state, or local tax penalties. Unless otherwise specifically indicated above, you should assume that any statement in this email relating to any U.S. federal, state, or local tax matter was written in connection with the promotion or marketing by other parties of the transaction(s) or matter(s) addressed in this email. Each taxpayer should seek advice based on the taxpayer's particular circumstances from an independent tax advisor.
================================================================= 
Confidentiality Notice: This communication and any attachments contain information from Darren K. Indyke, Esq. that constitute attorney work product or that are otherwise confidential and/or privileged. Except for personal use by the intended recipient, or as expressly authorized by the sender, any person who receives this information is prohibited from disclosing, copying, distributing, and/or using it. If you have received this communication in error, please immediately delete it and all copies, and promptly notify the sender at the above telephone number or electronic mail address. Nothing in this communication is intended to operate as an electronic signature under applicable law.
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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: The information contained in this e-mail and any attachments may be legally privileged and confidential. If you have received this e-mail in error, please notify the sender and permanently delete the e-mail and any attachments immediately. You should not retain, copy or use this e-mail or any attachment for any purpose, nor disclose all or any part of the contents to any person. Thank you.

 

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Chronology.Apr15.highlight.ShortForm.doc 61 KB
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Chronology.Apr15.highlight.doc 120 KB
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1419 files from the DOJ Epstein case media release. All files are public records from justice.gov.

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