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

ith the Bankruptcy Court to support their loss claims? 51. On April 19, 1994, and as a result of the SEC investigation, Hoffenberg was 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 EFTA008

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

remaining Counts pursuant to 28 U.S.C. S 1332(a). 12. Plaintiff resides in this District. In addition, the claims arose in this District. Venue in the Northern District of Illinois is, therefore, proper under 28 U.S.C. $ 1391(a). Factual Background 13. This is an action for money damages against several former me

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

lly, 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 "sham conservation proce