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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
estment capital to keep up with their lavish lifestyles. 29. Notably, between November 1987 and July 1988, checks were issued by TFC from UDC and United Fire's accounts for a number of improper expenditures, including the payment of investment consultant fees for TFC consultants, including Epstein. 30. Be
he 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 f
gets. Meanwhile, in order to throw the insurance regulators off, the $1.8 million was reported as being safely invested in a money-market account. United Fire's former chief financial officer Daniel Payton confirms part of Hoffenberg's account. He says he recalls making one or two telephone calls to Epstein
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 HolTenberg began using compan
s. Mean- while. in order to throw the insurance regula- tors off. the 51.8 million was rerorted as being safely invested in a money-market account. United Fire's former chief financial officer Daniel Payton confirms part of Reifenberg.; account. He says he recalls making one or two telephone calls to Epstei
lamest Ponzi schemes in American history. When Epstein met HotTenberg 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
s. Mean- while. in order to throw the insurance regula- tors off. the 51.8 million was reported as being safely invested in a money-market account. United Fire's former chief financial officer Daniel Payton confirms part of Hollinarg's account. He says he recalls making one or two telephone calls to Epstein
largest Paul schemes in American history, When Epstein met Reifenberg 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- pk owed to hospitals. banks. and phone companies. But HotTenbera began using company
rgets. Mean- while. in order to throw the insurance regula- tors ott the 51.8 million was rammed u being safely invested in a money-market account. United Fire's former chief financial officer Daniel Payton confirms pan of HotTenbag's account. He says he recalls making one or two telephone calls to Epstein
rgest Ponzi schemes in American history. When Epstein met Hotienbcre_ 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
ts. Mean- while. in order to throw the insurance regula- tors off the S1.8 million was reported as being safely invested in a money-market account. United Fire's former chief financial officer Daniel Payton confirms part of Hoffenberg's account. He says he recalls making one or two telephone calls to Epstei
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
gets. Meanwhile, in order to throw the insurance regulators off, the $1.8 million was reported as being safely invested in a money-market account. United Fire's former chief financial officer Daniel Payton confirms part of Hoffenberg's account. He says he recalls making one or two telephone calls to Epstein
amest 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 HotTenbere began using compan
s. Mean- while. in order to throw the insurance regula- tors otT. the S1.8 million was reported as being safely invested in a money-market account. United Fire's former chief financial officer Daniel Payton confirms part of Hoffenberg's account. He says he recalls making one or two telephone calls to Epstei
Entities connected to both Towers Financial and United Fire's

Jeffrey Epstein
PERSON
Steven Hoffenberg
PERSON
Vicky Ward
PERSON
Alan Dershowitz
PERSON
Ghislaine Maxwell
PERSON
Prince Andrew
PERSON
Emery
ORGANIZATION
Bill Clinton
PERSON
Pan Am
ORGANIZATION
Les Wexner
PERSON
George Mitchell
PERSON
Donald Trump
PERSONEva Andersson-Dubin
PERSONAssociated Life
ORGANIZATION
Marc Rich
PERSON
Philadelphia
LOCATION
Douglas Leese
PERSON
Nathan Myhrvold
PERSON
Michael Douglas
PERSON
New York
LOCATION