EFTA00796015.txt

"the Ponzi scheme, which was created and executed by Epstein"

"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"

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

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

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

"the victims of the TFC Ponzi Scheme include over 200,000 individuals, who are directly or indirectly the Noteholders and Bondholders of TFC, and are e"

"Hoffenberg's Affidavit, dated August 17, 2018, sets forth for the first time, under the penalty of perjury, Defendant Epstein's full involvement"

"Defendant Epstein and the Defendant Entities were Hoffenberg's co-conspirators"

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

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

"On April 19, 1994... Hoffenberg was indicted in the Northern District of Illinois on various fraud charges"

"On March 7, 1997, for his role in the TFC Ponzi Scheme, Hoffenberg was sentenced to twenty years' in prison... a one million dollar ($1,000,000) fine,"

"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"

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

"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"

"On March 4, 1997, Hoffenberg was convicted by Judge Sweet of the Southern District of New York for his role in a massive fraud conducted through TFC"

"On March 4, 1997, Hoffenberg was convicted by Judge Sweet of the Southern District of New York"

"Epstein, as a "consultant" to TFC from approximately 1987 through 1993"

"Defendant Epstein's involvement in the TFC Ponzi Scheme and related frauds, which harmed Plaintiffs and the Class"

"caused the transfer of securities, cash and assets from TFC to himself and/or to the Defendant Entities"

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

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

"Frank R. Schirripa... Attorneys for Plaintiffs and the Proposed Class"

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

"HACH ROSE SCHIRRIPA & CHEVERIE LLP... Daniel B. Rehns"

"HACH ROSE SCHIRRIPA & CHEVERIE LLP... Hillary M. Nappi"

"Of Counsel: Gary H. Baise, Esq."

"Plaintiffs and the Class only knew that Hoffenberg had 'co-conspirators' who remained unnamed... Defendant Epstein's full involvement in the TFC Ponzi"

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

"monies misappropriated by Epstein and transferred as capital to the Defendant Entities including, but not limited to, Defendant TFTC"

"TFC — Hoffenberg's company for which Epstein only "consulted""

"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"

"Epstein, by and through the Defendant Entities, purposefully interfered with the rights of TFC"

"Plaintiffs and the Class determined that Hoffenberg had co-conspirators... but for Non-Party Hoffenberg's recent affidavit, Plaintiffs and Class membe"

"Epstein assisting Hoffenberg full-time in all matters of business operations and management of TFC"