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,

jury in Illinois that Epstein came up with the idea of financing these bids through Towers' acquisition of two ailing Illinois insurance companies, Associated Life and United Fire. `He was hired by us to work on the securities side of the insurance companies and Towers Financial, supposedly to make a profit f

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

olation of the Racketeer Influenced and CorruPt Organizations Act (the "RICO Action"). The RICO Action alleged that the defendants had caused UDC, Associated Life and United !ire to suffer damagen in excess of $4 million, become insolvent, and be placed in consarvation and/or liquidation. In an agreement dat

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

olation of the Racketeer Influenced and Corrupt Organizations Act (the "RICO Action"). The RICO Action alleged that the defendants had caused UDC, Associated Life and United !ire to suffer damages in excess of sae $4 million, become insolvent, and be placed in consarvation and/or liquidation. In an agreemen