Epstein Data Wiki

Bear Stearns

Properties2
tagsentity, finance, broker-dealer, new-york, employment, grand-jury, finra, jpmorgan-chase
aliasesBear, Stearns & Co. Inc., Bear Stearns & Co., The Bear Stearns Companies Inc., The Bear Stearns Companies, Bear Stearns Securities Corp., Bear Stearns Asset Management Inc., BSAM, Bear Stearns International Ltd, The Bear Stearns Companies LLC, Bear Sterns, Bear Steams

57 min read

What this page is, and what it is not

This is a page about an employer and a bank: what Bear Stearns asked before it hired Jeffrey Epstein, what it recorded while he worked there, how it ended his employment, what it did for him as a client long afterwards, and what it produced when a federal grand jury and a securities arbitration asked it for records.

Five different companies used the Bear Stearns name on documents read for this page, and they are not interchangeable. A statement issued by one, a subpoena addressed to another and a settlement naming a third are three separate facts. This page names the company each document actually concerns, every time, and where two documents name different companies for the same event it says so rather than choosing.

Nothing from any account number, routing instruction or identity number appears here, in whole or in part. Where a document read for this page carries a home address, a telephone number, or a medical or family detail, none of it is reproduced. No sentence here describes any mark a producing party has placed on any sheet.

The files that carry this name also include an investigative file of the Palm Beach Police Department and a docket of pseudonymous civil plaintiffs. Three documents were removed from this page’s sources on reading them, and nothing from any of them appears here in any form: not quoted, not summarised, not characterised, not counted.

What it wasA New York investment bank. Its parent was The Bear Stearns Companies Inc., a Delaware corporation at 383 Madison Avenue; Bear, Stearns & Co. Inc. was its brokerage arm and Bear Stearns Asset Management Inc. its asset-management arm1
Who cleared the tradesAccount statements name Bear, Stearns & Co. Inc. as the office servicing the account and print, directly beneath it, “CLEARED THROUGH ITS WHOLLY OWNED SUBSIDIARY” and the name and Brooklyn address of Bear Stearns Securities Corp.23
In LondonBear Stearns International Ltd, 1 Canada Square, London E14 5AD, “Regulated by the Security & Futures Authority”, issued a statement for Epstein’s own account for the period 26 January to 22 February 20024
Epstein’s employmentHired 15 March 1976 as a Trainee in the Floor Dept.-AMEX at $225.00; Associate in N.Y. Options from 16 August 1976; a Limited Partner by 198156
How it endedOn 12 March 1981 the Executive Committee fined him $2,500 for a Regulation T violation and suspended him for 60 days. The same day he resigned as a Limited Partner, effective immediately. The firm’s profit-sharing plan then recorded the distribution reason as “DISMISSAL WITH CAUSE” and forfeited half the balance768
Who held the account laterStatements print Alan C. Greenberg, whom the 2009 pleading calls the firm’s former Chairman of the Board of Directors, and James E. Cayne, whose name is on Epstein’s 1979 salary memoranda, as the named account executive on accounts of Epstein and of entities associated with him23910
What it gave a grand juryOn 7 September 2007 Bear, Stearns & Co. Inc. sent the U.S. Attorney’s office in West Palm Beach Epstein’s personnel file and a CD of statements for six named accounts11
How the dispute endedA FINRA arbitration alleging fraud settled in August 2011 for $9,200,000, with no admission of liability. Claimants’ counsel then certified that they had “received no documents or other materials from Respondents during discovery in this matter”1213
SuccessorThe settlement names The Bear Stearns Companies Inc. (n/k/a The Bear Stearns Companies LLC) and Bear, Stearns & Co. Inc. (n/k/a J.P. Morgan Securities LLC)12

Bear Stearns was both Jeffrey Epstein’s employer and, long afterwards, his broker. It hired him in March 1976 into a department its own card names “Floor Dept.-AMEX”, disciplined him in March 1981 and recorded his departure two different ways in its own files, and carried accounts for him and for entities associated with him at least from 2001 to 2007. The records that survive are therefore of an unusual kind: not a bank’s view of a customer, but a personnel department’s file on an employee, produced to a federal grand jury thirty-one years after it was opened.1114

Those records answer a narrow question precisely. They show what the firm asked, what it was told, what it wrote down, and what it did about the answers. Twice its own paper contradicts itself or contradicts what it told somebody else, and both times both sides are in the same file.

The five companies, and why the distinction decides things

The parties to the 2009 arbitration set the structure out themselves. The claimants’ amended statement of claim pleads that The Bear Stearns Companies “was a corporation organized under the laws of the State of Delaware with its principal place of business located at 383 Madison Avenue, New York, New York, and was the parent of Bear, Steams & Co. Inc. and BSAM”; that Bear, Stearns & Co. Inc. “was the investment banking, securities trading and brokerage arm of Bear Stearns”; and that BSAM “was the asset management arm of Bear Stearns and an SEC-registered investment advisor”. The sheet prints the surname both ways, and this page quotes each clause as it stands.1

Two further companies appear on the statements themselves, and neither is either of those three.

Bear Stearns Securities Corp. is named as the clearing broker, at One Metrotech Center North, Brooklyn. Bear Stearns International Ltd, at 1 Canada Square, London E14 5AD, and described on its own statement as “Regulated by the Security & Futures Authority”, issued a statement for Epstein’s own account for the period 26 January to 22 February 2002. Its account-executive field names Ira Zicherman.4

The distinction decides at least two things on this page.

A federal grand jury commanded one company and the answer came on the letterhead of another. The subpoena of 15 August 2007 is addressed, against a printed “TO:”, to the custodian of records of Bear Stearns Companies, Inc., the two lines stacked one above the other.14 The reply of 7 September 2007 is on the letterhead of BEAR, STEARNS & CO. INC. at 320 Park Avenue and is subscribed over that company’s name.11

Account statements name two companies on the same line. The block headed “OFFICE SERVICING YOUR ACCOUNT” gives Bear, Stearns & Co. Inc. at 245 Park Avenue on some statements and at 383 Madison Avenue on others; the block beside it reads “CLEARED THROUGH ITS WHOLLY OWNED SUBSIDIARY” over the name of Bear Stearns Securities Corp. at One Metrotech Center North, Brooklyn.23 The quarterly notice about duplicate statements is in the name of Bear Stearns Securities Corp. and nobody else.15

Hiring, 1976

What the firm asked

The file opens with the forms. A standing notice to all new employees, on the firm’s letterhead, told them that “we intend to conduct, through a service agency and through our own inquiries, an investigation as to your character, reputation, mode of living, educational experience, litigations, previous employments, and any public records”.16

The “Stock Exchange Firm Employee Information Record”, which states on its face that it will be preserved for three years after termination of employment under Rules 17a-3 and 17a-4 of the Securities and Exchange Commission and Rule 345.19 of the New York Stock Exchange, asked whether the applicant had ever been bonded or refused a bond; whether he had ever been “suspended, expelled or otherwise disciplined by any regulatory body”; whether transactions under his attention had “ever been the subject of complaint or legal proceedings”; whether he had “ever been arrested, summoned, arraigned, indicted or convicted of a felony of any kind, or of a misdemeanor except minor traffic offenses”; and whether he had “ever been known personally by any other name, used an alias, or have you ever conducted business or carried brokerage or bank accounts in any other name than that shown above”. The answers on that sheet are handwritten ticks and this page does not state what they say.17

A second attestation set out the firm’s rule on its own employees’ securities dealings. It states the firm’s policy “that no employee may maintain an account with another firm, effect securities transactions through a bank or obtain a loan from a bank collateralized by securities without the permission of the firm”, and required the employee to attest that he had no outside brokerage accounts and no bank loans collateralised by securities.18

The personnel department’s own new-hire checklist lists what it was supposed to collect: a bonding application, the stock exchange form, the security accounts form, the Fair Credit form, fingerprint cards, background letters, a school reference, a telephone verification, and a line reading “Background check: Letters / Other”.19

What it was told

The reference letters went out the day after he started work. His date of employment is recorded as 15 March 1976.5 On 16 March 1976 the firm’s Personnel Director, Stephen A. Lacoff, wrote to the Registrar of Cooper Union that he “has applied to us for a position claiming attendance at your school from 9/66-6/70 BS degree”, and asked for “any information you can as to scholastic standing, personality, background, etc., of this applicant”. The reply is typed at the foot of the same sheet, over the signature of the Dean of Admissions & Records:

The above Jeffrey E. Epstein did not graduate Dates of Attendance: Sept. 1969 to Jan 1972

The dates the letter says he claimed and the dates the school recorded begin three years apart and end at different times.20

On 23 March 1976 the Recording Office of New York University’s Graduate School of Arts and Science wrote to Lacoff at 55 Water Street. It certified that he had been registered as a non-degree student in the Department of Music from September 1971 to May 1974, and then stated two things plainly:

Mr. Epstein did not receive a degree from New York University.

and

In the Spring 1974 semester, Mr. Epstein had issued an invalid check to our Bursar’s Office.

It is signed in ink by the Recorder.21

The firm then cancelled the background investigation. A supplemental report from the investigative agency Fidelifacts, dated 30 July 1976, four and a half months after he began work, verified his employment at the Dalton School and recorded what an administrative assistant there had said: that he “was employed as a Physics and Math teacher”, that he “did a good job”, that he “had a good attendance and punctuality record and was dependable, cooperative and honest”, and that he “was laid off due to a personnel cutback, but is eligible for rehire”. It also recorded, in one line:

He said he was a college graduate, but no furhter details were indicated.

The misspelling is the report’s own. The final line of the report reads: “The above lead was completed prior to client’s cancellation of this case.”22

Nothing read for this page records what the firm did about any of this, and he remained in its employment until March 1981.

Pay, 1976 to 1979

The firm’s own employee card carries the ladder. Trainee in the Floor Dept.-AMEX from 15 March 1976 at $225.00, a figure the card states without a period; Associate in N.Y. Options from 16 August 1976, the current-salary column then reading 300.00 against an annualised 15,600; merit increases to $24,000 from 25 April 1977, to $32,000 from 24 April 1978 and to $36,800 from 14 August 1978; and a transfer to the Customers Room from 1 May 1979.5 A memorandum of 3 June 1977 from Lewis Rabinowitz to John Duggan asks him to raise the salary “to $24,000 per year”, and a memorandum of 4 August 1977 from Elliot K. Wolk moves “all expenses including salary” to New York Retail retroactive to 1 May 1977.2324

Two of the salary instructions come from James E. Cayne, who became the firm’s chief executive. One, dated 13 June 1979 and addressed to the personnel department, reads: “Effective today, and retroactive to May 1, 1979, please increase the salary of Jeffrey Epstein to $42,000./year”. A second, of 15 August 1978, directs that “Effective immediately, Jeffrey Epstein is to receive a $400./mo salary increase.” A $400 month is $4,800 a year, and the card’s merit increase of 14 August 1978 is 4,800, taking the salary to $36,800.10255

A salary certified to a third party, and the salary on the firm’s own card

On 26 February 1979 the firm’s Personnel Director wrote to a real-estate firm and stated a figure that its own records do not carry. The letter is one paragraph:

Please be advised that Mr. Jeffrey Epstein is employed at Bear, Stearns & Co. at a salary of $75,000.00 a year.

It is addressed to Mr. Bennett at Douglas, Elliman, Gibbons & Eves and subscribed over the typed name of Stephen A. Lacoff.26

At that date the firm’s employee card recorded his current salary as $36,800, set by the merit increase of 14 August 1978 and unchanged.5 Cayne’s memorandum of 13 June 1979 carries a handwritten annotation reading “Present Salary $36,800 py”, which is visible only at the page image and does not appear in the released text of that sheet at all.10

The figure in the letter and the figure on the card differ by $38,200, and the letter’s figure is roughly twice the card’s. No document read for this page reconciles them, states what the letter was for, or records that anyone at the firm questioned it. This page prints both figures and resolves nothing.

The discipline and the departure, 12 March 1981

Two documents in the file bear the same date, and a third describes what they record differently.

The first is a letter on the firm’s letterhead at 55 Water Street. Its addressee block, four lines stacked, is Epstein’s own name over the firm’s own name and the firm’s own address, and the salutation is “Dear Jeffrey:”. The body is quoted here in full:

The Executive Committee has fully reviewed the matter referred to herein and after extensive deliberation has decided the following:

  1. You have advised us that you made a loan to a customer for the purpose of his buying securities. This constitutes a violation of Regulation T. Taking into consideration your voluntary disclosure and the fact that it was a single instance, we find you $2,500.00.

  2. For failing to comply with the spirit of the NASD Regulations with respect to new issue distribution, we suspend you from active employment at Bear Stearns for a period of 60 days, effective immediately.

It is subscribed “Yours very truly,” over “EXECUTIVE COMMITTEE” and “BEAR, STEARNS & CO.” on separate lines. No individual signs it. The sheet prints “we find you $2,500.00”, and that is how the paper reads; this page does not repair it.7

The account of 1981 this site has previously carried records a fine and says nothing about a suspension, and it rests on two secondary texts rather than on any instrument; it is set out at Warren Eisenstein. The firm’s own letter imposes both sanctions.

The second document is on his own letterhead, dated the same day, and addressed “TO THE EXECUTIVE COMMITTEE:”. Its body is one sentence:

With this letter and accompanying statement, I hereby resign as a Limited Partner of Bear, Stearns & Co., effective immediately.

It carries his signature in ink.6 The accompanying statement is not in this run and nothing read for this page establishes what it said.

The third document is the firm’s profit-sharing plan record, run on 30 April 1981 with an effective date of 1 April 1981 and a date of entry of 1 May 1976. Its reason field reads:

DISTRIBUTION REASON: DISMISSAL WITH CAUSE

The plan’s total value is given as $6,429.73, of which $3,214.86 is marked “FORFEITED”, leaving $3,214.87 payable.8

So the firm’s own file records a resignation and a dismissal with cause on the same termination, and the record that calls it a dismissal with cause is the one that forfeits half the plan balance. Nothing read for this page explains the difference, and this page does not choose between them.

The client, 2001 to 2007

The relationship after 1981 is documented here mainly by account statements, and the statements’ most consequential field is the smallest.

Alan C. Greenberg is printed as the account executive. The statement for Institutional Interests A/C #2 for the period 29 November to 31 December 2003 names GREENBERG, ALAN C. in the account-executive field. The account is registered care of Financial Trust Company at the Red Hook Quarter address in St Thomas. Its “Your Portfolio at a Glance” panel gives net equity for the period as 0, net equity at the last statement as 21,616,835, and the change since the last statement as −21,616,835.2 Statements for the same account under the same name run back to December 2001.27

James E. Cayne is printed as the account executive on others. The statement for Heritage Interests for the period 31 March to 27 April 2001 names CAYNE, JAMES E. It sets out, under the heading “Premise or Third Party Repurchase Agreements with Bear, Stearns & Co. Inc. outstanding as of date of statement”, a single open agreement with a start date of 24 April 2001, a purchase price of $8,905,769.07, a pricing rate of 4.370000, accrued repurchase interest of $6,347.83 and a net amount of $8,912,116.90.3 That is the same name that appears on the salary memoranda of 1979.10

A third class of statement carries no individual at all. Statements for Financial Trust Co Inc across 2006 and 2007 print the words SPEC CUSTOMER in the account-executive field.28

The claimants in the later arbitration put the relationship in their own words:

Epstein’s relationship with Bear Stearns began 32-years ago when he was personally recruited as a trader by Bear Stearns’ former Chairman of the Board of Directors, Alan Greenberg. After leaving in 1981, Epstein continued to do business with Bear Stearns.

and

Epstein was considered a “VIP” client of Bear Stearns. In order to assure that Epstein was kept fully informed of both ongoing and potential future investments, Spector was assigned the role of liaison between Bear Stearns and Epstein.

Those are a pleading’s allegations and this page carries them at that weight. The firm’s own hiring record describes the position he was recruited into as “Trainee” in the floor department, and dates it to 15 March 1976 rather than to the 1977 that “32-years ago” implies in a 2009 filing.95

What the firm did with the statements

A quarterly notice printed on the December 2005 statement for the International Charitable Interests II account records a standing arrangement:

Pursuant to your previously issued instructions, Bear Stearns Securities Corp. provides duplicate monthly statements and/or transaction confirmations to the third parties listed on the cover page of this statement. If you wish to modify or cease distribution to any of the recipients indicated, please contact your Account Executive. This reminder notice will continue to be provided to you on your quarterly statements.

The recipients are named on the statement and this page does not reproduce them.15

What the firm accepted as proof of ownership

On 30 March 2007 at 10:51 a.m. Epstein’s attorney Darren K. Indyke wrote to “Zicherman, Ira (Exchange)” at Bear Stearns certifying the ownership chain of two Virgin Islands corporations:

This is to certify that Financial Trust Company, Inc. … is the sole stockholder of Jeepers, Inc. … As you know, Jeffrey E. Epstein … is the sole stockholder of Financial Trust Company, Inc. and, through his holdings of Financial Trust Company, Inc. stock, is the beneficial owner of Jeepers, Inc.

Four minutes later the message was forwarded inside the firm, from one named officer to another, under the subject “FW: Jeepers, Inc.”29 What the firm did with the certification beyond circulating it is not recorded on any sheet read for this page.

The grand jury, August and September 2007

On 15 August 2007 the United States District Court for the Southern District of Florida issued a subpoena in grand jury matter FGJ 07-103(WPB)-Tues./No. OLY-71. It is addressed to the Custodian of Records of Bear Stearns Companies, Inc. Both boxes on its face are ticked: it is a subpoena for a PERSON and for DOCUMENTS OR OBJECT[S]. It commands an appearance in the Grand Jury Room of the United States District Courthouse at 701 Clematis Street, West Palm Beach, on 4 September 2007 at 1:00pm.14

Its attachment contains two requests. The first runs from 1 January 2001 and asks for

All documents referring or relating to Epstein, including but not limited to correspondence, e-mails, calendars reflecting meetings or telephone conferences, tax records, tax preparation documents, records of any loans or payments made to Epstein, records of any loans or payments received from Epstein, minutes of meetings or telephone conferences in which Epstein participated or was discussed, records of transactions made or requested by Epstein (whether on his own behalf or on behalf of any business entity or client), account statements for any and all accounts owned or managed by Epstein, (whether on his own behalf or on behalf of any entity or client), and information relating to any bank or financial institution used by Epstein to transfer money to Bear Sterns or to receive money from Bear Sterns.

The second has no date limitation at all:

All documents referring or relating to the employment of Epstein, including but not limited to employment applications, employment reviews, pay stubs, and documents related to termination of employment.

The attachment prints the firm’s name as “Bear Sterns” in its instructions and in its first request, and as “BEAR STEARNS COMPANIES, INC.” in its heading. That is what the paper says.30

The answer came by overnight mail on 7 September 2007, three days after the commanded appearance date. It is on the letterhead of BEAR, STEARNS & CO. INC. at 320 Park Avenue, addressed to the U.S. Department of Justice at West Palm Beach for the attention of A. Marie Villafana, and signed in ink by Sharon D. Ceres, Legal Assistant:

In response to the Grand Jury Subpoena dated August 15, 2007 with regard to the above-referenced matter, enclosed please find the personnel file for Jeffrey Epstein as well as CD containing account statements for Jeffrey Epstein as well as the following accounts in which Mr. Epstein has some relationship:

It then lists six accounts: Epstein Interests, Financial Trust Co. Inc., Institutional Interests, Heritage Interests, International Charitable Interests, Health & Science Interests. It ends with an undertaking: “If I find any other accounts that are responsive to your subpoena, as I continue my search, I will forward the statements to you under separate cover.”11

Whether any custodian appeared before the grand jury, and whether anything was later forwarded under separate cover, is not established by any document read for this page.

The covering letter sits in the same run as the personnel records. The 1981 Executive Committee letter, the resignation, the profit-sharing record, the school replies and the salary letter are all in that run, before and after the letter that describes a personnel file as its enclosure.11768

The funds, the arbitration, and what the firm produced

What was alleged

The amended statement of claim pleads that in August 2006 Financial Trust Company moved its investment into the Bear Stearns High-Grade Structured Credit Enhanced Leverage Fund and that the fund collapsed ten months later. It puts the transfer at $20,155,344.25 on 1 August 2006, a further $10,000,000 into the ABS Fund on 29 November 2006, and $10,000,000 invested by The C.O.U.Q. Foundation in Bear Stearns Asset Backed Securities Overseas, Ltd. in 2004, of which $3,000,000 was redeemed in February 2007. It puts the claimants’ base damages with interest at more than $45 million.31

The claim alleges, among much else, that the firm’s own compliance department “imposed a moratorium on all transactions between the Funds and Bear Steams because of a complete failure by the Funds’ managers to observe proper procedures” in 2006, and that this was not disclosed to investors; and, in a footnote, that Warren Spector caused the firm to invest a further $25 million in the Enhanced Fund “without receiving the proper internal authorizations” and hid it from the firm’s board of directors. Every one of those is an allegation in a pleading. No document read for this page independently establishes any of them, and the respondents denied liability.3212

Fourteen months before the claim was filed, a settlement negotiation was already running. On 11 July 2008 counsel wrote that an offer of “three million re High Grade Fund with release carve out so you could pursue stock and Asset backed claims” had been made and that he was “Still waiting to hear from you as to whether I can engage in discussion with Spector’s attorney”. The reply the next day, from an account writing in the first person as the client, instructed him to say “that we will subpoena the entire risk committee”, and asserted that Spector “put monehy in the fund with out the commitees approval”, that he “solicited me”, and that “he was admonished by he committee or putting the firms money in without asking”.33 Those assertions reappear in substance in the pleading filed in September 2009. This page does not identify the sender of the reply.

What each side asked for

The respondents’ first request for documents, dated 4 December 2009 and returnable 5 February 2010, runs to fifty-eight document requests and thirteen information requests. Its first paragraph, read at the image, is made by “Respondents The Bear Stearns Companies, Inc. (“BSC”), Bear, Stearns & Co. Inc. (BS&Co.), and Bear Stearns Asset Management Inc. (“BSAM”) (collectively, the “Bear Stearns Respondents”), by their attorneys, Kramer Levin Naftalis & Frankel LLP”. Warren Spector is not among the clients it names; the proof of service on the amended claim shows him served separately through Wachtell, Lipton, Rosen & Katz.3435

The requests reach well beyond the funds. They seek documents sufficient to show the complete educational and employment background of Epstein, Harry Beller, Darren Indyke and Lesley Groff; every brokerage and bank account in which the claimants held any interest since 2001; all documents concerning investments made on behalf of or as trustee for any third party, “including without limitation The Wexner Children’s Trust II”; and, in the last of the information requests, the title of every periodical and newspaper to which each of those four individuals subscribed.34

The claimants’ response of 25 May 2010 objects to most of them as “overly broad, vague, and unduly burdensome” and, to four consecutive requests including the two that name Ira Zicherman, as “not calculated to lead to the discovery of relevant information”; it agrees to produce documents relating to the funds.36

What the firm produced

No record of any production by the respondents appears in the files read for this page. The settlement agreement’s paragraph 5.1 required the claimants’ counsel either to return or destroy the documents the respondents had produced or to certify that they had received none. On 29 August 2011 Harry P. Susman of Susman Godfrey L.L.P. wrote to counsel for the respondents and took the second limb:

Pursuant to Paragraph 5.1 of the Settlement Agreement, I certify on behalf of Claimants that we received no documents or other materials from Respondents during discovery in this matter.

Paragraph 5.2 imposed the mirror obligation on the respondents’ counsel. The query shape is proved able to return a certification of this kind, because it returns the claimants’ own; it returned no certification by the respondents’ counsel. That is a statement about this search and not about what the release holds.1337

So an arbitration of nearly two years in which the respondents demanded fifty-eight categories of documents from the claimants ended with the claimants certifying that they had been given none. Whether the respondents withheld anything, produced nothing because nothing was requested of them, or were never asked, is not established by any document read for this page.

What it cost, and who the respondent had become

The execution copy of the settlement agreement is dated “this __ day of August 2011”, with the day left blank and every signature line empty. Its first paragraph names the parties:

The Bear Stearns Companies Inc. (n/k/a The Bear Stearns Companies LLC), Bear, Stearns & Co. Inc. (n/k/a J.P. Morgan Securities LLC) and Bear Stearns Asset Management Inc.

Paragraph 2.1 provides that “Respondents shall pay the sum of $9,200,000 (the ‘Settlement Payment’) to Claimants”, by wire transfer to the attorney trust account established by Darren K. Indyke PLLC. The agreement recites that the parties resolve the disputes “without any admission of liability, and Respondents specifically deny any liability whatsoever”. Jeffrey Epstein is named as a claimant in his own right, alongside Financial Trust Company, Inc. and The C.O.U.Q. Foundation, Inc.12

It also records that the arbitration was not the only proceeding: Financial Trust Company had commenced an action in the District of the Virgin Islands which the Judicial Panel on Multidistrict Litigation transferred to the Southern District of New York, where it was consolidated into In re The Bear Stearns Cos., Inc. Securities Litigation.12

After the merger: a claim against JPMorgan

The claim survived the firm. The pleading records that “On May 30, 2008, a wholly-owned subsidiary of JPMorgan Chase & Co. merged with and into The Bear Steams Companies, with The Bear Steams Companies continuing as the surviving corporation and as a wholly-owned subsidiary of JPMorgan Chase & Co.”1

By May 2011 it was being discussed directly between Epstein and officers of JPMorgan. On 30 May 2011 Epstein wrote to Mary E. Erdoes under the subject “fyi”; the header quoted inside her reply names Jes Staley as a second addressee. Most of that message concerns a different dispute and is not set out here. One sentence concerns this one:

I expressed in no uncertain terms in talking with Condren that I view this as a dispute ( Me vs JPM , in the Bear STearns case) as a family disagreement,. hopefully not discounted , by my well stated desire , never to file suit. that should not be a factor in a fair resolution of both issues.

Erdoes answered the same day: “Yes, we are going to have Condren step in here on this issue as well as the Bear issues. We will have everyone get together this week, if possible. and then we will see what to do from there.”3839 The two messages carry their times in different fields and different forms, and no interval between them is derived here. Messages of the following day arrange a conference call with Condren.40

The settlement agreement is dated the following August.12

The last document on this page is the other end of the same custody. On 16 October 2019, two months after Epstein’s death, JPMorgan Chase’s National Subpoena Processing unit in Fort Worth wrote to the Federal Bureau of Investigation at 26 Federal Plaza, New York. The case-name field on the letter reads:

Case Name : BEAR STEARNS AND CO (US)

The body is one line: “Here is the information that fulfills your request on the matter referenced above.”41

What these documents do not establish

  • No document read for this page alleges any criminal conduct by the firm or by any of its officers in connection with Epstein’s employment, and this page makes no allegation and records none. The 1981 sanction is an internal disciplinary decision by his employer.
  • The fraud allegations are a pleading’s, not this page’s. The amended statement of claim is an advocate’s document. The respondents denied liability expressly, the arbitration was settled with no admission, and no tribunal made any finding about any of its allegations against any of the three companies or against Warren Spector.
  • The two accounts of the 1981 departure are not reconciled here. A resignation letter and a profit-sharing record that reads “DISMISSAL WITH CAUSE” are both in the firm’s file. This page prints both and resolves neither.
  • The salary discrepancy is not explained. No document read for this page states what the February 1979 letter was for, or whether $75,000 referred to something other than the salary the employee card records.
  • The account-executive field is a field. That a statement prints one of those names in it is a fact about the firm’s records and nothing more. Nothing read for this page shows either man taking any decision about any of these accounts, and the only instruments read for this page that carry either name are two salary memoranda of 1979.
  • Nothing here establishes what anyone at the firm knew about Epstein’s conduct. The grand jury subpoena of August 2007 asked for employment and account records and nothing else, and the reply enclosed employment and account records and nothing else.
  • The 2007 production is the firm’s account of what it held. It is not a measurement of what existed, and the letter itself says the search was continuing.
  • This page reads no statement run. Six statements are cited, for what their own fields say. The release holds thousands of sheets of them and none of the rest is reproduced, summarised or counted here.

Timeline

DateEventSource
15 Mar 1976Date of employment: Trainee, Floor Dept.-AMEX, $225.00EFTA01337179 p.325
16 Mar 1976The Personnel Director writes to Cooper Union; the school replies on the same sheet that he did not graduateEFTA01337179 p.1720
23 Mar 1976New York University certifies that he received no degree and had issued an invalid check to the Bursar’s OfficeEFTA01337179 p.1821
1 May 1976Date of entry, Bear, Stearns & Co. Profit Sharing PlanEFTA01337179 p.128
30 Jul 1976Fidelifacts supplemental report; “client’s cancellation of this case”EFTA01337179 p.1122
16 Aug 1976Associate, N.Y. OptionsEFTA01337179 p.325
3 Jun 1977Memorandum raising the annual salary to $24,000EFTA01337179 p.723
14 Aug 1978Merit increase to $36,800EFTA01337179 p.325
26 Feb 1979The Personnel Director states a salary of $75,000.00 a year to a real-estate firmEFTA01337179 p.1526
13 Jun 1979James E. Cayne directs an increase to $42,000 a year; the sheet is annotated “Present Salary $36,800 py”EFTA01337179 p.910
12 Mar 1981The Executive Committee fines him $2,500 for a Regulation T violation and suspends him for 60 daysEFTA01337179 p.27
12 Mar 1981He resigns as a Limited Partner, effective immediatelyEFTA01337179 p.16
1 Apr 1981Profit-sharing distribution, reason “DISMISSAL WITH CAUSE”; $3,214.86 of $6,429.73 forfeitedEFTA01337179 p.128
24 Apr 2001Open repurchase agreement with Bear, Stearns & Co. Inc., $8,905,769.07 principal at 4.370000EFTA01322014 p.73
26 Jan – 22 Feb 2002Statement issued by Bear Stearns International Ltd, 1 Canada Square, LondonEFTA01324774 p.194
29 Nov – 31 Dec 2003Institutional Interests A/C #2, account executive Alan C. Greenberg: net equity 21,616,835 to 0EFTA01322192 p.22
Dec 2005Quarterly notice: Bear Stearns Securities Corp. sends duplicate statements to third parties on standing instructionEFTA01322808 p.215
1 Aug 2006$20,155,344.25 transferred into the Enhanced Fund, as later pleadedEFTA00300203 p.1431
30 Mar 2007Indyke certifies the Jeepers ownership chain to Zicherman at 10:51 a.m.; forwarded inside the firm at 10:55 a.m.EFTA01655049 p.129
5 Aug 2007Spector forced to resign as President and Co-Chief Operating Officer, as later pleadedEFTA00300203 p.99
15 Aug 2007Grand jury subpoena to Bear Stearns Companies, Inc., returnable 4 September 2007EFTA00186986 pp.2, 41430
7 Sep 2007Bear, Stearns & Co. Inc. produces the personnel file and a CD of statements for six accountsEFTA01337179 p.3111
30 May 2008JPMorgan Chase merger completed, as later pleadedEFTA00300203 p.81
11–12 Jul 2008A $3,000,000 offer on the High Grade Fund, and the client’s instruction in replyEFTA01826861 p.133
16 Sep 2009Amended statement of claim filed and served, FINRA case 09-00979EFTA00300203 pp.1, 203135
4 Dec 2009The Bear Stearns respondents’ first document request, returnable 5 February 2010EFTA00724436 pp.1, 8, 1734
25 May 2010Claimants’ responseEFTA00731180 p.1036
30 May 2011”Me vs JPM , in the Bear STearns case”; Erdoes: Condren to “step in here on this issue as well as the Bear issues”EFTA01871110 p.138 · EFTA01301084 p.139
Aug 2011Settlement agreement, $9,200,000, no admission of liabilityEFTA00615375 pp.1, 612
29 Aug 2011Claimants certify that they received no documents from the respondents in discoveryEFTA00283089 p.113
16 Oct 2019JPMorgan Chase answers an FBI request under the case name “BEAR STEARNS AND CO (US)“EFTA01577529 p.141

How this page is scoped

A firm’s name in these files is not one string, and this one is not seven. A search of the released files for "bear stearns" returns 1,702 documents. Seven standard forms together return 1,737. That union is a floor, and twenty-nine further forms break it, most of them damaged spellings.

The largest single gap is an optical misreading. The released text routinely renders the letter pair rn as m, so "bear steams" returns 759 documents, of which 263 are reachable by no other form tested here. Adding the firm’s own subsidiary and successor names and the rest of the damaged spellings takes the union to 2,057 documents. Reading the residue of the bare surname added a further 12, for a population of 2,069 documents, itself a floor. A page scoped on "bear stearns" alone would silently drop 367 of them.

The bare surname was tested by reading, not by assumption. "stearns" on its own returns 1,780 documents. Forty-five of them fall outside the union above, and all forty-five were read. Twelve are this firm, reached only through a damaged or split spelling: a courier waybill addressed to the firm, an incoming credit naming the asset-management company, an e-mail about money-market funds, two pieces of financial press, a magazine page reproduced five times in another released series whose two-column layout puts the two words on different lines, and two wire credits where the column layout puts an amount between the two words of the name so that no phrase search can join them. The other thirty-three are not this firm. Thirty-two carry a different bearer and none is a close call: a Florida law firm on a bankruptcy service list, a county court in Minnesota, a mattress brand, a boating-goods company, an artist, a music critic, a dance critic, a convention delegate, a Kentucky post office, a sheriff’s officer and a Ninth Circuit case citation; the thirty-third is a phone-bill line too damaged to assign to any bearer at all. None of the thirty-three is on this page.

The acronym was not mined. "bsc" returns 372 documents. The respondents’ own 2009 filing uses it as the abbreviation for The Bear Stearns Companies, Inc.,34 and it is also the firm’s ticker symbol and an ordinary abbreviation for many other things. 109 of those 372 documents are already in the population above because they also carry a full name. The other 263 were not added, were not read, and their bearer is not established here: they are untested rather than cleared.

The firm is a party to about one document in seven. Measured from each sheet’s own addressing fields and salutations rather than from this project’s document-type labels, the firm issued the document in 169 cases, is addressed in a sending or receiving field or a salutation in 137, and appears in neither in 1,763. Those three figures sum to 2,069. No document-type figure is relied on anywhere above: one of the documents cited on this page is a two-paragraph settlement letter that this project’s classifier labels a plea agreement, which is what that label is worth here.

The act count this page can show is far smaller than 306. Most of the 169 the firm issued are account statements, which are the same arrangement set out again every month. About twenty decisions are set out above, and they are what this page rests on: the questions the hiring forms put, two school replies, one cancelled background investigation, four salary memoranda, one salary letter to a third party, one disciplinary decision, one resignation accepted, one plan distribution, three account-executive assignments, one standing disclosure arrangement, one certification of ownership accepted, one production to a grand jury, one document demand, one settlement and one certification of non-production.

Sheets read at the page image. Twenty-one sheets were opened at the served file’s native resolution of 96 pixels per inch and read: eleven of the personnel file, two of the subpoena, four statements, the settlement’s first page, the certification, one sheet of the statement of claim and the caption of the document request. Every money figure the page’s central findings turn on was read on one of them, and the two salary memoranda quoted only from released text are marked as such in their notes. The released text of several of these sheets is wrong in ways that matter: it reports a handwritten salary annotation nowhere at all, it renders “distribution” and “quarterly” as other words, and it reports the firm’s own name with the wrong letters on sheets where the paper prints it correctly. Where a rendered sheet’s foot band carries no printed Bates stamp, this page cites the document and its served page and derives no stamp.

Sheets read only in the released text. The remaining citations are to text this page has not checked at the image: the balance of the amended statement of claim, the document request and the response, the 2008 and 2011 correspondence, the Jeepers certification and the 2019 letter. Those are quoted from the released text and are marked as such in their notes.

Three documents were removed on reading them. One is a docket of pseudonymous civil plaintiffs; two are long runs whose later sheets carry an investigative file about complainants. Nothing from any of the three appears here, and the one procedural fact this page wanted from them is not asserted anywhere above.

Not read. Of the 2,069 documents, this project tags 588 as message headers and 396 as bank statements. Those were not opened beyond the sheets named in the notes, and they are untested rather than cleared. No document was excluded from this population by its document-type label; the three that were set aside were set aside after reading them.

Notes

Footnotes

  1. Amended statement of claim, Financial Trust Company, Inc. and The C.O.U.Q. Foundation, Inc. v. The Bear Stearns Companies, Bear Stearns & Co., Bear Stearns Asset Management, and Warren Spector, FINRA case 09-00979, caption and paragraphs 15 to 17. Released text only; not read at the page image. https://epstein-data.com/EFTA00300203 pp.1 and 8 of a twenty-sheet run. The claimants’ own caption gives the three companies without “Inc.” and without the comma in “Bear, Stearns & Co.”; the respondents’ own filing gives all three with them. Both forms are quoted as each sheet prints them and neither is corrected to the other. ↩ ↩2 ↩3 ↩4

  2. Bear Stearns account statement for Institutional Interests A/C #2, statement period 29 November 2003 through 31 December 2003, last statement 28 November 2003. Read at the page image at 96 pixels per inch; printed stamps SDNY_GM_00352730 and EFTA_00225422. https://epstein-data.com/EFTA01322192 p.2 of an eighty-eight-sheet run. The account-executive field names Alan C. Greenberg. The servicing-office block gives Bear, Stearns & Co. Inc. at 383 Madison Avenue, New York, New York 10179; the block beside it reads “CLEARED THROUGH ITS WHOLLY OWNED SUBSIDIARY” over Bear, Stearns Securities Corp., One Metrotech Center North, Brooklyn, New York 11201-3859. The account is registered care of Financial Trust Company at 6100 Red Hook Quarter, Suite B-3, St Thomas. The portfolio panel gives net equity this period 0, net equity last statement 21,616,835 and change since last statement −21,616,835. Nothing else from this statement is reproduced here in any form, and this page says nothing about any mark on it or on any other sheet. ↩ ↩2 ↩3 ↩4 ↩5

  3. Bear Stearns account statement for Heritage Interests, statement period 31 March 2001 through 27 April 2001, last statement 30 March 2001. Read at the page image at 96 pixels per inch; printed stamps SDNY_GM_00352557 and EFTA_00225249. https://epstein-data.com/EFTA01322014 p.7 of a sixteen-sheet run. The account-executive field names James E. Cayne. The servicing-office block gives Bear, Stearns & Co. Inc. at 245 Park Avenue, New York, New York 10167, over the same clearing-subsidiary block. The repurchase-agreement arithmetic reproduces exactly: principal $8,905,769.07 plus accrued interest $6,347.83 gives the net amount $8,912,116.90. The end date is given as OPEN. Nothing else from this statement is reproduced here in any form, and this page says nothing about any mark on it or on any other sheet. ↩ ↩2 ↩3 ↩4 ↩5

  4. Bear Stearns account statement for the period 26 January 2002 through 22 February 2002, whose servicing-office block names Bear Stearns International LTD over the words “Regulated by the Security & Futures Authority” and a London address, the four lines stacked. This page quotes only the regulator clause and describes the rest of the block rather than joining its lines. The clause is one sentence set over two lines of a narrow column and is quoted as one sentence; no other line of the block is joined to it. Read at the page image at 96 pixels per inch; printed stamps SDNY_GM_00356131 and EFTA_00228823. https://epstein-data.com/EFTA01324774 p.19 of a thirty-six-sheet run. The regulator’s name is given exactly as the sheet prints it. The account is in Epstein’s own name and the account-executive field names Ira Zicherman. No figure from this statement is carried on this page: its own summary panel does not reconcile to the dollar, and nothing here turns on it. ↩ ↩2 ↩3

  5. Bear, Stearns & Co. employee information record. Read at the page image at the served file’s native resolution of 96 pixels per inch; the sheet carries the printed stamps SDNY_GM_02770758 of the SDNY_GM series and EFTA_00257566 of the EFTA_ series, which are different numbering systems from the identifier that addresses the document and from each other. https://epstein-data.com/EFTA01337179 p.32 of a fifty-seven-sheet run. This page takes from the card only the date of employment, the position, department and salary rows and the previous employer, and nothing else from it in any form. The salary rows read: 3/15/76 Trainee, Floor Dept.-AMEX, $225.00; 8-16-76 Associate, N.Y. Options, increase 75.00, current 300.00; 4-25-77 merit increase 8400 to 24,000; 4-24-78 merit increase 8000 to 32,000; 8-14-78 merit increase 4800 to 36,800; and a transfer to the Customers Room dated 5-1-79. The rows are not in date order on the card and this page gives them in the order the card prints them. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9

  6. Letter on Jeffrey E. Epstein’s own letterhead, 12 March 1981, headed “TO THE EXECUTIVE COMMITTEE:”, signed in ink. Read at the page image at 96 pixels per inch; printed stamps SDNY_GM_02770727 and EFTA_00257535. https://epstein-data.com/EFTA01337179 p.1. The body is quoted in full above. The letter refers to an “accompanying statement” which is not in this run; nothing is asserted about its contents. ↩ ↩2 ↩3 ↩4 ↩5

  7. Letter on Bear, Stearns & Co. letterhead at 55 Water Street, 12 March 1981, subscribed “Yours very truly,” over “EXECUTIVE COMMITTEE” and “BEAR, STEARNS & CO.” on three separate lines. Read at the page image at 96 pixels per inch; printed stamps SDNY_GM_02770728 and EFTA_00257536. https://epstein-data.com/EFTA01337179 p.2. The two numbered paragraphs are quoted whole and nothing is elided between them. The addressee block is set as four stacked lines and this page therefore describes it rather than quoting it as one line; an earlier draft joined two of those lines with a comma this page had supplied, and that is removed. The sheet prints “we find you $2,500.00” and this page reproduces it exactly; no word is repaired, completed or supplied. No individual’s name or signature appears beneath the committee’s. The foot of the sheet gives the firm’s offices in 1981 as New York, Atlanta, Boston, Chicago, Dallas, Los Angeles and San Francisco. ↩ ↩2 ↩3 ↩4

  8. Bear, Stearns & Co. Profit Sharing Plan distribution record, run date 04/30/81, effective date 04/01/81, date of entry 05/01/76. Read at the page image at 96 pixels per inch; printed stamps SDNY_GM_02770738 and EFTA_00257546. https://epstein-data.com/EFTA01337179 p.12. The distribution-summary arithmetic reproduces exactly: total value $6,429.73 less forfeiture $3,214.86 leaves cash payable $3,214.87. The line marked “FORFEITED” is the second of two company-account rows. ↩ ↩2 ↩3 ↩4 ↩5

  9. Amended statement of claim, paragraphs 16, 18 and 19. Read at the page image at 96 pixels per inch; the foot of the sheet carries the filing’s own document-management number and its own folio 9, and no printed Bates stamp, so this footnote cites the document and its served page. https://epstein-data.com/EFTA00300203 p.9. The two quoted paragraphs are quoted whole. The same sheet pleads that Warren Spector “until he was forced to resign on August 5, 2007, was President and Co-Chief Operating Officer of Bear Stearns” and a member of its executive committee and board. The sheet’s paragraph numbering runs 16, 18, 19, with no paragraph 17. ↩ ↩2 ↩3

  10. Memorandum on a Bear Stearns memo form, to Steve Lacoff of the personnel department, from James E. Cayne, dated 13 June 1979. Read at the page image at 96 pixels per inch; printed stamps SDNY_GM_02770735 and EFTA_00257543. https://epstein-data.com/EFTA01337179 p.9. The typed sentence is quoted whole. The annotation “Present Salary $36,800 py” is handwritten and is therefore absent from the released text of this sheet altogether; it was read at the image, as were the handwritten date 6/13/79 and the word “File”. The subject line is blank. ↩ ↩2 ↩3 ↩4 ↩5

  11. Letter on the letterhead of BEAR, STEARNS & CO. INC., 320 Park Avenue, New York, 7 September 2007, “VIA OVERNIGHT MAIL” to the U.S. Department of Justice at 500 S. Australian Avenue, 4th Floor, West Palm Beach, for the attention of A. Marie Villafana, re “FGJ 07-103(WPB)-Tues./No. OLY-71”, signed in ink by Sharon D. Ceres, Legal Assistant, and marked “Encl.” Read at the page image at 96 pixels per inch; printed stamps SDNY_GM_02770757 and EFTA_00257565. https://epstein-data.com/EFTA01337179 p.31. The quoted span is the first sentence of the body, quoted whole, and the six account names are quoted as the letter lists them. The covering letter sits inside the same fifty-seven-sheet run as the personnel records it describes, which is what establishes that the enclosure and the file are the same papers. ↩ ↩2 ↩3 ↩4 ↩5 ↩6

  12. Settlement agreement and release, execution copy, dated as of a blank day of August 2011. Read at the page image at 96 pixels per inch for the first sheet; the foot band carries the drafting firm’s own document-comparison string and no printed Bates stamp. https://epstein-data.com/EFTA00615375 pp.1, 2, 6, 8, 9 and 16 of a twenty-nine-sheet run; pp.2, 6, 8, 9 and 16 are released text only. The parties clause and paragraph 2.1 are quoted whole. The agreement names Jeffrey Epstein personally as a claimant alongside the two companies, recites the parallel federal action and its consolidation, and assigns to BSAM any further claims the claimants might have. Every signature line on its execution page is empty and the day of the month is blank. This page quotes the execution copy and nothing else. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7

  13. Letter from Harry P. Susman of Susman Godfrey L.L.P. to Gabrielle Gould and Marshall H. Fishman at Freshfields Bruckhaus Deringer US LLP and to Stephen M. Sinaiko at Kramer Levin, 29 August 2011, re the settlement of the arbitration, signed in ink. Read at the page image at 96 pixels per inch; the foot band carries the firm’s own document-management string and no printed Bates stamp. https://epstein-data.com/EFTA00283089 p.1 of a twenty-nine-sheet run. The operative sentence is quoted whole. The sheet prints one of the two firm names with a letter transposed and this page does not reproduce that spelling. The re-line gives the case caption as Financial Trust Company, Inc. et al v. The Bear Stearns Companies, Inc., et al. The 2009 document request was signed by three lawyers at one firm; this letter of 2011 addresses two of them at a different firm and the third at the first. That is what the two address blocks record and this page draws nothing further from it. ↩ ↩2 ↩3

  14. Subpoena to testify before grand jury, United States District Court for the Southern District of Florida, FGJ 07-103(WPB)-Tues./No. OLY-71, addressed to the Custodian of Records, Bear Stearns Companies, Inc., dated 15 August 2007. Read at the page image at 96 pixels per inch; the foot band was rendered and carries no printed Bates stamp, so this footnote cites the document and its served page and derives none. https://epstein-data.com/EFTA00186986 p.2 of a fourteen-sheet run. Both of the “SUBPOENA FOR” boxes are ticked at the image. The addressee is set as a stacked block and this page therefore describes it rather than quoting it as one line; an earlier draft joined the two lines with a comma this page had supplied, and that is removed. The place, room, date and time are quoted as the form gives them. Nothing is taken from any other sheet of this run except p.4, and this page states nothing about any other sheet. ↩ ↩2 ↩3 ↩4

  15. Quarterly third-party notice printed on the Bear Stearns account statement for International Charitable Interests II DTD 08/30/94, statement period 1 December 2005 through 30 December 2005. Read at the page image at 96 pixels per inch; printed stamps SDNY_GM_00353984 and EFTA_00226676. https://epstein-data.com/EFTA01322808 p.2 of a sixty-four-sheet run. The notice is quoted whole. The released text of this sheet renders two of its words wrongly and the image settles them; the quotation above follows the image. The third-party block beneath the notice is not reproduced here in any part, and this page says nothing about any mark on this sheet. ↩ ↩2 ↩3

  16. Notice to all new employees on Bear, Stearns & Co. letterhead, headed “TO ALL NEW EMPLOYEES:” and carrying a printed date of 8 April 1971 as a form. Released text only; not read at the page image. https://epstein-data.com/EFTA01337179 p.3. The quoted clause is quoted whole from the first paragraph. The form carries a signature and date line. ↩

  17. “STOCK EXCHANGE FIRM EMPLOYEE INFORMATION RECORD”, form 110 (12/75), which states on its face that information disclosed on it “will be held in strictest confidence and will be preserved for three years after termination of employment in accordance with Rules 17a-3 and 17a-4 of the Securities and Exchange Commission and Rule 345.19 of the New York Stock Exchange”. Released text only; not read at the page image. https://epstein-data.com/EFTA01337179 p.4. The quoted spans are the questions as the form prints them. The answers are handwritten, are not legible in the released text, and this page states nothing about them. ↩

  18. “EMPLOYEE SECURITIES TRANSACTIONS” attestation. Released text only; not read at the page image. https://epstein-data.com/EFTA01337179 p.5. The quoted spans are the policy statement and the attestation’s own wording. The completed answer is handwritten and is not reproduced. ↩

  19. Personnel department new-hire checklist. Released text only; not read at the page image. https://epstein-data.com/EFTA01337179 p.19. This page lists only the printed item names on the form and takes nothing from the handwritten ticks and dates beside them. ↩

  20. Letter from Stephen A. Lacoff, Personnel Director, Bear, Stearns & Co., to Cooper Union, Attn: Registrar, 16 March 1976, signed in ink, with the school’s typed reply at the foot of the same sheet over the signature of the Dean of Admissions & Records. Read at the page image at 96 pixels per inch; printed stamps SDNY_GM_02770743 and EFTA_00257551. https://epstein-data.com/EFTA01337179 p.17. The two quoted spans are the firm’s claim-of-attendance clause and the school’s reply, each quoted whole, and nothing else from this sheet is reproduced in any form. The firm wrote to the Dalton School on the same day on an identical form, at p.16 of the same run. ↩ ↩2

  21. Letter from the Recording Office, Graduate School of Arts and Science, New York University, to Mr. Stephen A. Lacoff, Bear, Stearns & Company, 55 Water Street, 23 March 1976, signed in ink by the Recorder. Read at the page image at 96 pixels per inch; printed stamps SDNY_GM_02770744 and EFTA_00257552. https://epstein-data.com/EFTA01337179 p.18. The two quoted sentences are quoted whole. The registration facts in the sentence before them are given in this page’s own words from the same paragraph; nothing else from this sheet is reproduced in any form. ↩ ↩2

  22. Supplemental report of the investigative agency Fidelifacts, date of report 30 July 1976, supplementing a report of 3 May 1976. Read at the page image at 96 pixels per inch; printed stamps SDNY_GM_02770737 and EFTA_00257545. https://epstein-data.com/EFTA01337179 p.11. The quoted spans are quoted whole, and the misspelling “furhter” is the report’s own and is not repaired. The report gives the applicant’s claimed Dalton School dates as 9/74 to 3/15/76 and the school’s reported dates as 9/74 to 6/11/76. Nothing else from this sheet is reproduced in any form. The Dalton School employee who gave the information and the supervisor she named are not named on this page, because naming either changes no conclusion. A further report of the same agency is in the same run and nothing whatever is taken from it. ↩ ↩2

  23. Memorandum on a Bear Stearns memo form, to John Duggan, from Lewis Rabinowitz, subject “Jeff Epstein”, 3 June 1977. Released text only; not read at the page image. https://epstein-data.com/EFTA01337179 p.7. The one-sentence body asks the recipient to raise the annual salary “to $24,000 per year”; one word of it is damaged in the released text and is not reproduced. ↩ ↩2

  24. Memorandum on a Bear Stearns memo form, from Elliot K. Wolk, 4 August 1977, directing that all expenses including salary be moved to New York Retail retroactive to 1 May 1977. Released text only; not read at the page image. https://epstein-data.com/EFTA01337179 p.8. Two of the three names in the addressee block are damaged in the released text and are not reproduced. ↩

  25. A second memorandum on the same form to the same recipient from James E. Cayne, dated August 15, 1978. Read at the page image at 96 pixels per inch; printed stamps SDNY_GM_02770740 and EFTA_00257548. https://epstein-data.com/EFTA01337179 p.14. The quoted sentence is quoted whole and the paper prints “mo” in lower case; an earlier draft of this page capitalised it and the image corrected it. The date is on the paper and is absent from the released text of this sheet, as is a handwritten annotation reading 8-14-78 and 4800 yr., which is what ties this instrument to the card’s merit-increase row of 14 August 1978. The sheet carries two signatures in ink. ↩

  26. Letter from Stephen A. Lacoff, Personnel Director, to Mr. Bennett at Douglas, Elliman, Gibbons & Eves, 26 February 1979. Read at the page image at 96 pixels per inch; printed stamps SDNY_GM_02770741 and EFTA_00257549. https://epstein-data.com/EFTA01337179 p.15. The operative sentence is quoted whole. No signature appears above the typed block. The letter gives no reason for the enquiry and names no transaction. ↩ ↩2

  27. Statements for the same account under the same account-executive name for the period 1 December 2001 through 31 December 2001 and for periods in 2002 and 2003. Released text only; not read at the page image. https://epstein-data.com/EFTA00197608 p.2 of a seventy-sheet run. This footnote establishes only that the name recurs across those periods; nothing else is taken from that document. ↩

  28. Bear Stearns account statements for Financial Trust Co Inc for periods in 2006 and 2007, whose account-executive field reads “SPEC CUSTOMER”. Released text only; not read at the page image. https://epstein-data.com/EFTA00196351 p.2 and p.9 of a run of the same statements. This footnote establishes only what that field prints; no figure and nothing else is taken from those statements. ↩

  29. Message of 30 March 2007, sent at 10:51 a.m. to “Zicherman, Ira (Exchange)” under the subject “Jeepers, Inc.” over Darren K. Indyke’s signature block, and forwarded within the firm at 10:55 a.m. under the subject “FW: Jeepers, Inc.” between two other named recipients. Released text only; not read at the page image. https://epstein-data.com/EFTA01655049 p.1, a single-sheet item; a further copy at https://epstein-data.com/EFTA00038693 p.1. The quotation is broken by ellipses at three points and nothing is supplied at any of them. Nothing else from either copy is reproduced here in any form, and this page says nothing about any mark on either. The letter and its forward are set out more fully at Ira Zicherman and at Financial Trust Company, Inc.. ↩ ↩2

  30. The attachment to the subpoena, headed over two stacked lines with the words “ATTACHMENT TO SUBPOENA” above the company’s name and the matter number. Read at the page image at 96 pixels per inch; the foot band was rendered and carries no printed Bates stamp. https://epstein-data.com/EFTA00186986 p.4. Both requests are quoted whole. The spelling “Bear Sterns” is what the paper prints in the instructions and in request #1, and it is reproduced here unrepaired; the heading of the same sheet prints the name correctly. The instructions define “Epstein” as “Jeffrey Epstein and any entity owned or operated by Jeffrey Epstein” and limit request number 1 to the period from 1 January 2001. A blank business-records certification form naming Bear Stearns Companies, Inc. follows at p.5 of the same run. ↩ ↩2

  31. Amended statement of claim, paragraphs 4, 13, 14, 39 and 48. Released text only; not read at the page image. https://epstein-data.com/EFTA00300203 pp.2, 7, 14 and 18. The figures are the pleading’s own and are not independently established by anything read for this page. ↩ ↩2 ↩3

  32. Amended statement of claim, paragraphs 30 and 38 and the footnote to paragraph 45. Released text only; not read at the page image. https://epstein-data.com/EFTA00300203 pp.12, 15 and 17. The quoted span is from paragraph 38 and is quoted whole from its own clause. These are allegations by a party and nothing read for this page corroborates any of them. ↩

  33. Message of 12 July 2008, Sent: Sat 7/12/2008 5:53:29 PM, subject “Re: Bear Stearns”, answering a message of 11 July 2008 quoted inside it. Released text only; not read at the page image. https://epstein-data.com/EFTA01826861 p.1, a single-sheet item. Both quoted spans are quoted exactly as the sheet prints them, misspellings included, and no word is repaired or supplied. This page does not identify the sender of the reply. The earlier message is signed in the body by Steven G. Storch; the reply answers counsel who had written that he would “speak with client and respond”. This page asserts nothing about the role of the person the earlier message names as having made the offer, and does not connect him to any other person named on this page. ↩ ↩2

  34. “The Bear Stearns Respondents’ First Request for the Production of Documents and Information to Claimants Financial Trust Company, Inc. and The C.O.U.Q. Foundation, Inc.”, dated 4 December 2009, returnable 5 February 2010. Read at the page image at 96 pixels per inch for the caption sheet; the foot band was rendered and carries the filing’s own document-management string and no printed Bates stamp, so this footnote cites the document and its served page. https://epstein-data.com/EFTA00724436 pp.1, 8, 10, 14 and 17 of a seventeen-sheet run; pp.8, 10, 14 and 17 are released text only. Document Requests 6 and 7, which name The Wexner Children’s Trust II, are on p.8. The caption, read at the image, names the respondents as “THE BEAR STEARNS COMPANIES, INC., BEAR, STEARNS & CO. INC., BEAR STEARNS ASSET MANAGEMENT INC., and WARREN SPECTOR”, and the first paragraph abbreviates the first three as “BSC”, “BS&Co.” and “BSAM”. The same paragraph dates the amended statement of claim as “filed in this arbitration on September 16, 2009.” The periodical-subscription request is Information Request 13. Several of the requests ask the claimants to identify accounts by number, and this page reproduces no such value from any source. ↩ ↩2 ↩3 ↩4

  35. Proof of service on the amended statement of claim, certifying service by email and first class mail on 16 September 2009 on counsel at Kramer Levin Naftalis & Frankel LLP and at Wachtell, Lipton, Rosen & Katz. Released text only; not read at the page image. https://epstein-data.com/EFTA00300203 p.20. The signature block on p.19 of the same run gives the month and year and leaves the day of the month blank. The date given in the timeline above is the date the proof of service certifies, and the respondents’ own later filing gives the same date as the filing date.34 ↩ ↩2

  36. “Claimant’s Response to The Bear Stearns Respondents’ First Request for the Production of Documents and Information”, timestamped 25 May 2010. Released text only; not read at the page image. https://epstein-data.com/EFTA00731180 pp.1, 3 and 10 of a twenty-one-sheet run. The quoted objection wording is quoted whole from the responses it belongs to. The identical objection answers four consecutive requests on p.10, of which two name Ira Zicherman. ↩ ↩2

  37. Settlement agreement and release, paragraphs 5.1 and 5.2. Released text only; not read at the page image. https://epstein-data.com/EFTA00615375 pp.8 and 9. Paragraph 5.1 binds the claimants’ counsel and paragraph 5.2 the respondents’ counsel, in mirror terms. A search of the released files for the certification wording returns one document, which is the claimants’ certification itself; the same query shape therefore does return a letter of that kind when the files hold one, and that is a statement about what this search returned and not about what the release holds. ↩

  38. Message of 30 May 2011 to Mary E. Erdoes under the subject “fyi”, carrying the sender name Jeffrey Epstein. Released text only; not read at the page image. https://epstein-data.com/EFTA01871110 p.1, a single-sheet item. The quoted span is quoted exactly as the sheet prints it, spacing and punctuation included, and no word is repaired or supplied. The remainder of the message concerns a separate dispute with other parties and is not reproduced, summarised or characterised here; it is set out at Financial Trust Company, Inc. and at Glenn Dubin. ↩ ↩2

  39. Reply from Mary E. Erdoes, 30 May 2011, copying a third officer, quoting the message above inside it. Released text only; not read at the page image. https://epstein-data.com/EFTA01301084 p.1, a single-sheet item. The quoted span is quoted whole. The two messages carry their times in different fields and in different forms, so no interval between them is derived here. ↩ ↩2

  40. Messages of 31 May 2011 arranging a conference call with James Condren, including a request to a named officer at the bank for his contact details and a reply fixing the call for 5:00 p.m. Released text only; not read at the page image. https://epstein-data.com/EFTA02188937 p.1 and https://epstein-data.com/EFTA02188898 p.1, single-sheet items. This page establishes only that the call was arranged through the bank’s own staff and asserts nothing about his role or title. No dial-in number or contact value from either sheet is reproduced here. ↩

  41. Letter from JPMorgan Chase National Subpoena Processing, 14800 Frye Road, Fort Worth, Texas, to the Federal Bureau of Investigation at 26 Federal Plaza, New York, dated 16 October 2019, signed over the printed name and title of an operations manager. Released text only; not read at the page image. https://epstein-data.com/EFTA01577529 p.1, a single-sheet item. The quoted case-name line is quoted whole. The sheet carries two production stamps of two different series. No file number, telephone number or other value from the letter is reproduced here. ↩ ↩2

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