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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
KALMA KOENIG, : on behalf of themselves and all others similarly : situated, Plaintiffs, -against- THE FINANCIAL TRUST COMPANY, XYZ CORPORATION, ABC, INC., and JEFFREY E. EPSTEIN, Defendants. X Index No. 1:18-cv-07580-JPO DEFENDANTS' MEMORANDUM OF LAW IN SUPPORT OF THEIR MOTION TO DISMISS PLAINTIFF
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
IN GERBER AND KALMA KOENIG, on behalf of themselves and all others similarly situated, Plaines) v. fNE FINANCIAL TRUST COMPANY, XYZ CORPORATION, ABC, INC., and JEFFREY E. EPSTEIN Defendant(s) Civil Action No. 18.7580 SUMMONS IN A CIVIL ACTION To: (Defendant's name and address) The Financial Trust Co
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
ERBER AND KALMA KOENIG, on behalf of themselves and all others similarly situated, Plaintiffs, v. THE FINANCIAL TRUST COMPANY, XYZ CORPORATION, ABC, INC., and JEFFREY E. EPSTEIN, Defendants. Case No. INITIAL COMPLAINT ECF CASE Marvin Gerber and Kalma Koenig (collectively "Plaintiffs"), on behalf
Entities connected to both Towers Financial and ABC, INC.

Jeffrey Epstein
PERSON
Steven Hoffenberg
PERSON
New York
LOCATION
Financial Trust Company
ORGANIZATIONAssociated Life
ORGANIZATIONthe Southern District
LOCATIONMARVIN GERBER
PERSON
Hillary Clinton
PERSONUnited Fire
ORGANIZATION
the United States District Court
ORGANIZATION
Southern District of New York
ORGANIZATIONXYZ Corp.
ORGANIZATIONRobert Sweet
PERSONKalma Koenig
PERSON