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

fendant Entities were Hoffenberg's co- conspirators. 59. As per the Sentencing Opinion, Hoffenberg and his co-conspirators (i) used certain of the Associated and United's bonds as collateral in securities brokerage accounts in order to purchase stock of Pan Am and Emery; (ii) created false documents and f

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

nited Diversified acted as a holding company whose principal business activities were conducted through and for its insurance subsidiaries, namely; Associated and United Fire. 3. At all relevant times Associated was a domestic stock legal reserve insurance company organized under the laws of the State o

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

additional $1 million at a later date. In approximately November 1967, Hoffenberg and his co- lt" nn't !Lt 4ein ) conspirator's used certain of the Associated and United Fire bonds as collateral in securities brokerage accounts in order to purchase stock of Pan American Airways, Inc. ("Pan Am"). When thi