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

rs also agreed to sell its interest in lb. Towers Diversified to the:` Insurance Director for $1, and to withdraw objections to the liquidation of Towers Diversified. According to the SEC, Towers never disclosed the liquidation of these companies or the filing of this civil suit to its investors, and continued

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

is a resident of the State of New York, and at all relevant times, was Chairman of the Board of Directors of United Fire, Associated, Diversified, Towers Diversified and Towers Financial. On information and belief, Boffenberg, through an entity known as the "Hoffenberg Family Trust", at all relevant times owned

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

nsurance Director and the defendants agreed to settle the RICO Action, with Towers paying $3.5 million. Towers also agreed to sell its interest in Towers Diversified to tilt:* Insurance Director for $1, and to withdraw objections to the liquidation of Towers Diversified. According to the SEC, Towers never disclo