EFTA00809690.txt

"In or around 1987, Hoffenberg and TFC hired Epstein as an associate and expert consultant"

"From 1975 through April 1993, Hoffenberg served as Chief Executive Officer of TFC"

"Hoffenberg and Epstein joined forces in the mid-1980s"

"TFC acquired a controlling interest in United Diversified Corporation ("UDC")"

"TFC also owned and operated subsidiaries including Towers Credit Corporation"

"TFC also owned and operated subsidiaries including... Towers Collection Services, Inc."

"TFC also owned and operated subsidiaries including... Towers Healthcare Receivables Funding Corporations I, II, Ill, IV and V"

"Defendant Epstein's involvement... Case 1:18-cv-07580-JPO"

"Steven J. Hoffenberg v. Jeftey E, Epstein, et. al., Case No. 16-03989"

"Hoffenberg's Affidavit, dated August 17, 2018"

"Epstein... transferred the funds to himself and/or to the Defendant Entities"

"his co-conspirator Hoffenberg is court ordered to pay restitution"

"TFC reasonably relied upon the Ponzi scheme, which was created and executed by Epstein"

"Plaintiffs and the Class reasonably relied upon the fraudulent Ponzi scheme"

"In February 1993... the Securities and Exchange Commission ("SEC") filed suit against Hoffenberg, TFC, and other TFC officials"

"the Securities and Exchange Commission ("SEC") filed suit against Hoffenberg, TFC, and other TFC officials"

"The lawsuit was brought against Epstein and his corporations"

"Until April 1993, Hoffenberg was the chief executive officer, president and chairman of the board of Towers Financial Corporation"

"In 1987, Towers acquired a controlling interest in United Diversified Corporation ("UDC")"

"I served as Chief Executive Officer of Towers Financial Corporation ("TFC") from 1975 through April 1993."

"Professional Business Brokers, a corporation Hoffenberg owned"

"As part of his attempt to obstruct the SEC investigation, Hoffenberg gave false testimony to the SEC in New York City on several occasions between Nov"

"in 1987, TFC acquired a controlling interest in United Diversified Corporation ("UDC)"

"Epstein and I used the insurance companies' bonds as collateral in securities brokerage accounts"

"Epstein created or caused to have created TFC subsidiaries -- the THFRC Bond Funds"

"Non-Party Affiant Steven Hoffenberg ("Hoffenberg") was the Chief Executive Officer of TFC from 1975 through April 1993"

"Defendant The Financial Trust Company"

"Defendant Epstein and the Defendant Entities fraudulently obtained investor funds by playing key roles in the fraudulent schemes described herein"

"The Ponzi scheme perpetrated by Hoffenberg and Epstein through Tit was an intricate fraud"

"Plaintiff Marvin Gerber ("Gerber") is a resident of Wantagh, New York. Plaintiff Gerber was an investor and/or noteholder in TFC"

"Plaintiff Kalma Koenig ("Koenig") is a resident of San Mateo, California. Plaintiff Koenig was an investor and/or noteholder in TFC"

"Defendant Epstein and Hoffenberg deliberately misrepresented how investor funds would be used and subsequently misused the proceeds"

"Epstein used the funds as investment capital for corporations he controlled, including The Financial Trust Company"

"Hoffenberg controlled !?owers' daily operations"

"over $3 million of the funds and assets of United Fire and Associated were misappropriated through trading losses... and Hoffenberg's unauthorized use"

"over $3 million of the funds and assets of United Fire and Associated were misappropriated"

"the Insurance Director and the defendants agreed to settle the RICO Action, with Towers paying $3.5 million"

"Towers also owned and controlled Towers Healthcare Receivables Funding Corporations I, II, III, IV and V"

"charging Hoffenberg and others with using the insurance companies as an instrumentality of Towers... in violation of the Racketeer Influenced and Corr"

"Epstein misappropriated the proceeds for not only his personal use. but also to start his own company, Defendant TFTC"

"Defendant Epstein's full involvement in the TFC Ponzi Scheme"

"Defendant Epstein continues to control the Defendant Entities... including, but not limited to, Defendant TFTC"

"conviction of Defendants' co-conspirator... Hoffenberg's Affidavit... sets forth for the first time... Defendant Epstein's full involvement"

"Epstein as a "consultant" to TFC, caused the transfer of securities, cash and assets from TFC to himself"

"Marvin Gerber and Kalma Koenig... by their attorneys, Hach Rose Schirripa & Cheverie, LLP"

"Marvin Gerber and Kalma Koenig... by their attorneys, Hach Rose Schirripa & Cheverie, LLP"

"TFC — Hoffenberg's company"

"Defendant Epstein, directly and indirectly, created, or caused to have created, TFC subsidiaries, the THRFC Bond Funds"

"In May 2016, Hoffenberg through his attorneys, filed a Complaint in this District, docket number 1:16-cv-03989, alleging similar causes of action agai"

"Epstein's involvement in my crimes and the related frauds"