EFTA01197726Set 9
2014-06-1612p1,634w
discussed with counsel \
(24, ‘./
If LB comes into possession of material non-public information ("MNPI") during an open t
trading window, he would be prevented from selling unless the MNPI ... established during an open trading window while LB is not
in possession of MNPI
Once established, resales can continue even when the trading window is closed
(whether ... then in possession of MNPI)
Resales under a lob5-1 Plan will generally be made pursuant to Rule 144
iob5-1 Plans generally do not accommodate resales
https://www.justice.gov/epstein/files/DataSet%209/EFTA01197726.pdf
scrutiny (including into whether certain participants made illegal use of
material non-public information ("MNPI")), which can disrupt the progress, delay the
timing and/or preclude the consummation of, any given ... course of doing so, may come — whether purposely or inadvertently — into possession
of MNPI. If so, until such time as such information is no longer "material" or has
become public
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01384564.pdf