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11. This request is a continuing one. If, after producing the requested documents, you
obtain or become aware of any further documents responsive to this request, you are required to
produce such additional documents. Supplemental responses should be served within thirty (30)
days after such information or documents become known to you.
REQUESTS FOR PRODUCTION OF DOCUMENTS
The Debtors request that the Federal Reserve produce the following documents in its
possession, custody or control:
1. All documents concerning, or communications with, Washington Mutual with
respect to any entity's efforts to acquire all or part of Washington Mutual, and/or any of its
substantial assets.
2. All documents concerning communications with or among JPMC, the FDIC, the
media, ratings agencies, investors, and/or any third party concerning Washington Mutual.
3. All documents concerning any meetings and/or communications between
Washington Mutual and any Government Unit, including the FDIC, OTS, OCC, the U.S.
Department of the Treasury, Federal Reserve, and the SEC, including (a) any meetings between
OTS and WMI on or about April 5, 2008, (b) any meetings between Washington Mutual, OTS,
and the FDIC on or about July 31, 2008, and/or (c) any communications with or among U.S.
Treasury Secretary Hank Paulson and WMI Chairman and CEO Kerry Killinger and/or JPMC
President and CEO Jamie Dimon regarding Washington Mutual.
4. All documents concerning any potential or actual regulatory and/or supervisory
actions, ratings, or examinations directed toward or taken with respect to Washington Mutual by
any Government Unit, including the FDIC, OTS, OCC, the U.S. Department of the Treasury,
Federal Reserve, and SEC, including but not limited to (a) OTS's decision to initiate discussions
about Memorandums of Understanding with WMI and WMB, (b) the Memorandums of
Understanding OTS issued to WMI and WMB on or about September 7,2008, (c) any regulatory
classification of Washington Mutual by the OTS, including without limitation any decision by
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OTS to classify WMB as a "problem institution," and/or (d) U.S. Treasury Secretary Henry
Paulson's "RTC plan" concerning Washington Mutual.
5. All documents concerning Washington Mutual's responses or potential responses
to any regulatory and/or supervisory actions, ratings, or examinations by any Government Unit,
including the FDIC, OTS, OCC, the U.S. Department of the Treasury, Federal Reserve, and the
SEC.
6. All documents concerning Washington Mutual's efforts to raise capital and/or
locate a potential merger partner or acquiror, including without limitation (a) any actual or
possible acquisition or investment by any entity of any stake in Washington Mutual, including
any communications with or among Banco Santander, Bankers Trust, Blackstone, Carlyle,
Cerberus, Citigroup, JPMC, Oak Hill, TPG, TO Bank, and/or Wells Fargo and their affiliates; (b)
any efforts to raise capital through the issuance of debt securities in December 2007 (including
the issuance of approximately $3 billion of debt securities on or about December 17, 2007); (c)
any actual, potential, or contemplated bids for Washington Mutual and/or the bidding process for
Washington Mutual; (d) any efforts to raise capital and/or locate a potential merger partner or
acquiror during the first quarter of2008; (e) TPG's investment of about $7.2 billion into
Washington Mutual on or about April 7,2008; and/or (D any efforts to raise capital and/or locate
a potential merger partner or acquiror in September 2008, including any efforts by Goldman
Sachs and/or Morgan Stanley on Washington Mutual's behalf.
7. All documents concerning any meetings and/or communications between JPMC
and any Government Unit, including the FDIC, OTS, OCC, the U.S. Department of the Treasury,
Federal Reserve, and the SEC, concerning Washington Mutual including (a) any meetings on or
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about March 28, 2008, (b) any meetings between JPMC and the U.S. Department of the Treasury
in April 2008, and/or (c) any meetings on or about July 18,2008.
8. All documents concerning JPMC's trading activity in Washington Mutual stock,
including any actual, potential, or contemplated decision by JPMC to short Washington Mutual
stock in the three months prior to the OTS seizure of WMB.
9. All documents concerning JPMC's disclosure of any Washington Mutual
information, or disclosure of any information about Washington Mutual, to any Governmental
Unit, the media, ratings agencies, investors, and/or any other third parties.
10. All documents concerning any agreement between JPMC and Washington Mutual
concerning access to and/or disclosure of non-public, confidential or proprietary information in
connection with a potential transaction in which JPMC would acquire, merge with, or invest in
Washington Mutual.
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Zitatende
MfG.L:)
Alles nur meine pers. Meinung, kein Kauf- oder Verkaufs-Empfehlung!