EFTA00811809.txt

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

"Epstein actively participated in devising the TFC Ponzi Scheme"

"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"

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

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

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

"Hoffenberg later became chairman of the boardi of UDC"

"Hoffenberg later became chairman of the boardi of UDC, Associated"

"Hoffenberg later became chairman of the boardi of UDC, Associated and United Fire"

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

"Professional Business Brokers, a corporation Hoffenberg owned"

"Hoffenberg and his co-conspirators had agreed from the outset of the SEC's investigation to take whatever steps they deemed necessary to obstruct that"

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

"Epstein and the corporations he formed were my co-conspirators"

"I was the sole Defendant in the criminal case"

"In February 1993, following a lengthy investigation, the SEC filed suit against me, TFC, and other TFC officials for securities fraud"

"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"

"Hoffenberg was indicted in the Southern District of New York on numerous charges... including mail fraud, securities fraud... unlawful conspiracy and "

"Hoffenberg was sentenced to twenty years' in prison... a one million dollar ($1,000,000) fine, approximately four hundred seventy-five million dollars"

"Hoffenberg controlled Towers' daily operations"

"In an agreement dated May 4, 1992, the Insurance Director and the defendants agreed to settle the RICO Action, with Towers paying $3.5 million"

"Towers had two subsidiaries: Towers Credit corporation"

"Towers had two subsidiaries... Towers Collection Services, Inc."

"Towers also owned and controlled Towers Healthcare Receivables Funding Corporations I, II, III, IV and V (the "THRFC Bond Funds")"

"Defendant Epstein's involvement in the TFC Ponzi Scheme... Case 1:18-cv-07580-JPO"

"Steven J Hoffenberg v. Jay E, Epstein, et al., Case No. 16-03989 (RJS)"

"victims of the TFC Ponzi Scheme include over 200,000 individuals... Pursuant to Hoffenberg"

"MARVIN GERBER AND KALMA KOENIG... Pia intiff(s) V. ... JEFFREY E. EPSTEIN"

"MARVIN GERBER AND KALMA KOENIG... Pia intiff(s) V. ... JEFFREY E. EPSTEIN"

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

"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"

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

"In May 2016... my attorneys filed a civil lawsuit on my behalf. The lawsuit was brought against Epstein"

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

"Defendant Epstein and Hoffenberg deliberately misrepresented how investor funds would be used"

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

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

"the Ponzi schemes, which were created and executed by Epstein, and that such schemes were in the best interests of TFC"

"Respectfully submitted, HACH ROSE SCHIRRIPA & CHEVERIE LLP By:/s/ Frank R. Schirripa"

"Between 1987 and 1991, Hoffenberg evaded personal income taxes by causing his personal expenses to be paid by Professional Business Brokers"

"Epstein used the monies he misappropriated and earned from his illegal trading activities and used them as start-up capital for his corporations, incl"

"Epstein conceived many ways we could cover up our dubious activities... routing all securities trades confirmations from brokerage firms to TFC, rathe"

"his actions were taken on behalf of TFC — Hoffenberg's company for which Epstein only "consulted""

"TFC — Hoffenberg's company"

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

"Epstein has been permitted to use the ill-gotten gains and misappropriated investor funds from his role in the TFC Ponzi Scheme to start and grow Defe"