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and ABC, Inc., as follows: PARTIES 1. Mr. Marques and Mr. are residents of and , respectively, and were investors and/or noteholders in Towers Financial Corporation, ("TFC") a dissolved Nevada corporation which had its principal place of business in New York, NY at all relevant times during which Steven Hoffenbe
ict. The Parties either do or did business in this District and many of the unlawful practices described herein occurred in this District. Venue in the Southern District of New York is, therefore, proper pursuant to 28 U.S.C. § 1391(a). 14. In or around 1994, a multi-district order was issued by Honorable Judge Whi
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
riginated in and arose out of this District. Furthermore, Defendants reside and/or maintain a principal place of business in this District. Venue in the Southern District of New York is therefore proper pursuant to 28 U.S.C. §139I(a). PARTIES 9. Plaintiff Marvin Gerber ("Gerber") is a resident of Wantagh, New York.
dealings in the Ward House at 457 Madison Avenue.1231 Steven Hoffenbe originally set up the offices for Epstein in 1987 when he was consulting for Tower Financial. ni Epstein used these offices until at least 2003. Around this time, Michael Wolff saw the financier in his office, which in the past were the offi
when the case comes to court513§1 On February 21, 2019, in the case of Two Jane Does v. United States, Senior Judge of the U.S. District Court for the Southern District of Florida Kenneth Marra said federal prosecutors violated the law by faffing to notify victims before they allowed him to plead guilty to only the
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
when the case comes to court 3-§] On February 21, 2019, in the case of Two Jane Does v. United States, Senior Judge of the U.S. District Court for the Southern District of Florida Kenneth Marra said federal prosecutors violated the law by falling to notify victims before they allowed him to plead guilty to only the
ealings in the Ward House at 457 Madison Avenue.l9~1 Steven Hoffenberg originally set up the offices for Epstein in 1987 when he was consulting for Tower Financial. IA Epstein used these offices until at least 2003. Around this time, Michael Wolff saw the financier in his office, which in the past were the offi
e when the case comes to courtly. On February 21, 2019, in the case of Two Jane Does v. United States, Senior Judge of the U.S. District Court for the Southern District of Florida Kenneth Marra said federal prosecutors violated the law by failing to notify victims before they allowed him to plead guilty to only the
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
inal charges were resolved by a guilty plea to a single Florida state law charge and a non-prosecution agreement (a “NPA”) with the U.S. Attorney for the Southern District of Florida. Unknown to the public and the victims at the time, Epstein’s lawyers, including Dershowitz, were pressuring the Government to commit to t
and that he was the "CEO" of "New York Post Publishing Inc." (Ex. A.) While he was incarcerated, Mr. Hoffenberg filed numerous lawsuits related to Towers Financial, and his prosecution, legal representation and sentence in connection with the same. He even unsuccessfully sought to recuse Judge Sweet, himself. T
NYP Holdings, Inc., the publisher of the New York Post, in a Complaint for Injunctive Relief and Damages filed in United States District Court for the Southern District In New York, Mr. Hoffenberg and his company, New York Post Publishing, Inc., had been engaging in trademark infringement, trademark dilution, false
argest Ponzi schemes in American history. When Epstein met Hoffenberg in Lon- don in the 1980s, the latter was the char- ismatic, audacious head of the Towers Financial Corporation. a collection agency that was supposed to buy debts that peo- ple owed to hospitals. banks, and phone companies. But Hoffenberg began using compan
D.C., for plaintiff-appellant. Leonard Alan Sands, Coconut Grove, Fla., for defendant-appellee. Appeal from the United States District Court for the Southern District of Florida. Before RONEY, Chief Judge, TJOFLAT, HILL, FAY, VANCE, KRAVITCH, JOHNSON, HATCHETT, ANDERSON, CLARK, EDMONDSON, and COX, Circuit Judg
Entities connected to both Towers Financial and the Southern District

Jeffrey Epstein
PERSON
United States
LOCATION
Department of Justice
ORGANIZATION
Ghislaine Maxwell
PERSON
Prince Andrew
PERSON
Alexander Acosta
PERSONJane Doe
PERSON
Bradley Edwards
PERSON
Kenneth Marra
PERSON
George W. Bush
PERSON
New York
LOCATION
the United States District Court
ORGANIZATION
Alan Dershowitz
PERSONLeon Black
PERSON
Geoffrey S. Berman
PERSONJack Goldberger
PERSON
Southern District of New York
ORGANIZATION
Virginia Giuffre
PERSON
Scarlett Johansson
PERSON
Paul Cassell
PERSON