Epstein Secrets

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

Filed 08/21/18 Page 1 of 16 Exhibit A EFTA00809717 Case 1:18-cv-07580-JPO Document 7-1 Filed 08/21/18 Page 2 of 16 at 5 STATES DISTRICT COURT RN DISTRICT OF NEW YORK STATES Or AMERICA, - against - £T£VEN EOFFENSERG Defendant. Sweet, D. J. HEItardEalig QPDilial 9 Cra,--213--Mar21 23--CX-9-321-D1WHI_ Defendan

indicted in the Northern District of Illinois on various fraud charges. s See In re Towers Financial Corpora►ion, et at. Case No. 93-841558 (PBA) (S.D.NY. Dec. 8, 1994). II EFTA00809701 Case 1:18•cv-07580-JPO Document 7 Filed 08/21/18 Page 12 of 26 52. The very next day, on April 20, 1994, Hoffen

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

allegedly defrauded back in the 1980's. See Chubb & Son, Inc. v. Kelleher, 92 CV 4484 (CBA), 95 CV 951 (CBA), 1998 U.S. Dist. LEXIS 22542, at *22 (E.D.N.Y. Feb. 26, 1998) (granting motion to dismiss based on statute of limitations in part because "plaintiffs [did] not allege[] any facts suggesting that

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

nt 7-1 Filed 08/21/18 Page 1 of 16 Exhibit A EFTA00795983 Case 1:18-cv-07580-JPO Document 7-1 Filed 08/21/18 Page 2 of 16 STATES DISTRICT COURT RN DISTRICT OF NEW YORK STATES OF AMERICA, - against - STEVEN HOFFENSERG Defendant. sweet, D. J. araistnianallnlanti 2A-CL.-2131B2B1. Sal-Sx-.-32.1-111Wal Defendant Stev