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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
orporation ("UDC"), which conducted business through its subsidiaries, Associated Life Insurance Co. ("Associated") and United Fire Insurance Co. ("United Fire"). Hoffenberg later became chairman of the boardi of UDC, Associated and United Fire. Hoffenberg obtained the Illinois Department of Insuran
e stocks were purchased with funds borrowed by using insurance company bonds as collateral. Hoffenberg concealed his activities from Associated and United Fire by: routing all securities trade confirmations, periodic account statements and other communications from brokerage firms to Towers, rather than t
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
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 for us and for the
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
e stocks were purchased with fupds borrowed by using insurance company bonds as collateral. Hoffenberg concealed his activities from Associated and United Fire by: routing all securities trade confirmations, periodic account statements and other communications from brokerage firms to Towers, rather than t
aim For Breach Of Contract Against Towers Financial 136. In October 1987, the Companies entered into an oral contract with Towers Financial whereby the Towers Financial would -37- PP) WV Cr:II :)ii :in7_t7_112v EFTA00612554 use space in the premises usually occupied by the Companies in Des Plaines, Illinois as
mpanies funds. 32. Hoffenberg caused Associated and United Fire to issue or deliver insurance policies at a time when he knew that Associated and United Fire were insolvent or impaired in violation of Section 144.1 of the Illinois Insurance Code. (I11. Rev. Stat. Ch. 73 I 756.1 (1987). -8- Ron 'd NY I
Microsoft Word - Exhibit K.docx
the largest Ponzi schemes in American history. When Epstein met Hoffenberg in London in the 1980s, the latter was the charismatic, audacious head of the Towers Financial Corporation, a collection agency that was supposed to buy debts that people owed to hospitals, banks, and phone companies. But Hoffenberg began using company fun
Page: HOUSE_OVERSIGHT_017777 →argets. Meanwhile, in order to throw the insurance regulators off, the $1.8 million was reported as being safely invested in a money-market account. United Fire’s former chief financial officer Daniel Payton confirms part of Hoffenberg’s account. He says he recalls making one or two telephone calls to Epstein (
Page: HOUSE_OVERSIGHT_017781 →Entities connected to both Towers Financial and United Fire

Jeffrey Epstein
PERSON
Steven Hoffenberg
PERSON
Emery
ORGANIZATION
Vicky Ward
PERSON
Prince Andrew
PERSON
Pan Am
ORGANIZATIONAssociated Life
ORGANIZATION
New York
LOCATION
George Mitchell
PERSON
Les Wexner
PERSON
Bill Clinton
PERSONEmery Air Freight Corp.
ORGANIZATION
George W. Bush
PERSON
Kevin Spacey
PERSONSt. Joe Minerals
ORGANIZATION
Jimmy Cayne
PERSONTheram
PERSON
St. Joe
ORGANIZATION
Richard Allen
PERSON
Bear Stearns
ORGANIZATION