Epstein Secrets

PRIVILEGED AND CONFIDENTIAL; ATTORNEY WORK PRODUCT UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X MARVIN GERBER AND KALMA KOENIG, : on behalf of themselves and all others similarly : situated, Plaintiffs,

inated in 1997 when Judge Sweet sentenced Hoffenberg to a 20-year prison sentence and ordered him to pay $475,157,340 in restitution to investors in Towers Financial Corporation ("Towers").1 Plaintiffs' claims here, which allege fraud against Defendants because of their alleged role in Hoffenberg's decades-old scheme, are un

nt 7-1 Filed 08/21/18 Page 6 of 16 Finally, in a further attempt to conceal their activities, Hoffenberg and his co-conspirators filed a lawsuit the United States District Court for the Northern District in of Illinois against individual State of Illinois insurance regulation employees, alleging that these employees insti

on to recover damages on behalf of Plaintiffs and members of the proposed class, defined below (the "Class"), who are Noteholders and Bondholders of Towers Financial Corporation ("TFC") for harm suffered as a result of Defendants' conspiring and participation in a massive Ponzi scheme perpetrated by Defendant Jeffrey Epstein

7-1 Filed 08/21/18 Page 6 of 16 Finally, in a further attempt to conceal their activities, Hoffenberg and his co-conspirators filed a lawsuit in the United States District Court for the Northern District of Illinois against individual State of Illinois insurance regulation employees, alleging that these employees instituted

per count, is mandatory. The Offense Conduct Until April 1993, Hoffenberg was the chief executive officer, president and chairman of the board of Towers Financial Corporation ("Towers"). In 1987, Towers acquired a controlling interest in United Diversified Corporation ("UDC"), which conducted business through its subsid

S Reese - TP v Epstein and Maxwell (2017) - Mesci-)eet- te-STR.Qc-Ti i`4 Cr CAREER P KG 6 P6c---TS cCfr? pLy In 2017, filed a suit, in the United States District Court for the Southern District of New York, againit Epstein and Maxwell, alleging that Maxwell hired her to give massages to a_ Epstein and laterffireat

t!Steven Hoffenberg. They had been introduced through Douglas Leese, a defense contractor, and John Mitchell, the former U.S. Attorney General.(321 Towers Financial Corporation Epstein in 1980 Steven Hoffenberg hired Epstein in 1987, as a consultant for Towers Financial Corporation (unaffiliated with the company of the same name f