EFTA00722200.pdf

Timcstamp: 1/27/2010 9:51 AM CST Questions to Be Answered In Writing By the Arbitrator Candidates 1. Please identify any professional associations of which you were a member during the last ten years, including any sections and committees thereof, and any positions held in any such associations, sections or committees. Examples of such professional associations include but are not limited to the American Bar Association, the Securities Industry and Financial Markets Association, the Public Investors Arbitration Bar Association, the Midtown Regulatory Group, and the Federalist Society. 2. If there are fewer than seven publicly-available arbitration decisions identified on your Arbitrator Disclosure Form, please identify your experience as an arbitrator during the last five years for any arbitration organization other than FINRA, including the general nature of the case(s) arbitrated and, to the extent you believe permissible, (i) the parties thereto, (ii) a general description of the issues in dispute and (iii) the outcome of the dispute, including damages or other relief awarded. 3. The parties in this case are Claimants Financial Trust Company, Inc., which is wholly- owned by Jeffrey Epstein, The C.O.U.Q. Foundation, Inc., The Bear Steams Companies, Bear Steams & Co., Bear Steams Asset Management, and Warren Spector. To the extent not previously disclosed in your Arbitrator Disclosure Form, please describe any professional or social relationship or dealings you have had during the last ten years with these parties and any of their current or former officers, employees, or agents. (Please include in your answer any such business or social relationships you are aware of involving members of your immediate family). 4. The law firms involved in this case are Wachtell, Lipton, Rosen & Katz; Kramer, Levin, Naftalis & Frankel; and Susman Godfrey, L.L.P. To the extent not previously disclosed in your Arbitrator Disclosure Form, please describe any professional or social relationship or dealings you have had during the last ten years with these law firms and any of their current or former partners, associates, or agents. (Please include in your answer any such business or social relationships you are aware of involving members of your immediate family). 5. This case involves investments in three hedge funds called the Bear Steams High-Grade Structured Credit Fund, L.P., the Bear Steams High-Grade Structured Credit Enhanced Leverage Fund, L.P., and Bear Steams Asset Backed Securities Partners, L.P. As well, Mr. Epstein is a former Bear Steams partner and has spent the previous 20-years as a well-known investor; however, in 2008, Mr. Epstein plead guilty to one count of solicitation of prostitution and one count of procurement of a person under 18 for prostitution in Palm Beach County, Florida. Do you know anything regarding these funds or Mr. Epstein, or is there any reason why you would have a hard time being objective given the subject-matter of the case? If so, please tell us what you heard, read, discussed or otherwise learned, from whom, and when, or why your objectivity might be effected by the subject-matter. 6. Within the last ten years, have you written any books, articles or periodicals dealing with securities, the markets, investing, or other financial-related issues? If so, please tell us the title, name and year of publication. 1002039v la)11543 EFTA00722200  Timcstamp: 1/27/2010 9:51 AM CST 1002039vO)11543 EFTA00722201