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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
1988 through TFC's acquisition of a controlling interest in United Diversified Corporation ("UDC") and, as a result, UDC's two ailing subsidiaries, Associated Life Insurance Co. and United Fire Insurance Co., (the "Subsidiaries"). Hoffenberg, 1997 U.S. Dist. LEXIS 2394, at *2. 22. Epstein's Insurance Ponzi Fraud scheme inc
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
red a controlling interest in United Diversified Corporation ("UDC"), which conducted business through two Illinois insurance company subsidiaries, Associated Life Insurance Co. ("Associated") and United Fired Insurance Co. ("United Fire"). 26. Epstein was the architect of the plan to secure the approval from Illinois stat
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
s"). In 1987, Towers acquired a controlling interest in United Diversified Corporation ("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.
Entities connected to both Towers Financial and Associated Life Insurance Co.

Steven Hoffenberg
PERSON
Jeffrey Epstein
PERSON
Emery
ORGANIZATION
Pan Am
ORGANIZATIONAssociated Life
ORGANIZATION
George W. Bush
PERSONUnited Fire's
ORGANIZATIONthe Southern District
LOCATIONUnited Fire
ORGANIZATION
Financial Trust Company
ORGANIZATIONUnited Air Fleet
ORGANIZATION
Michael Cohen
PERSON
the United States District Court
ORGANIZATIONthe Northern District
LOCATIONPan American Airways, Inc.
ORGANIZATIONAssociated
ORGANIZATIONDinsmore v. Towers Financial
ORGANIZATIONTowers Diversified
ORGANIZATION
Southern District of New York
ORGANIZATIOND. J.
PERSON