Epstein Secrets

claimed that the expenditures were for broker's fees on investment advice associated with an investment in the capital stock of Emery Air Freight ("Emery"). Within a period of shortly over six months the Companies lost —13— bin') ew It'll 'VI rin- L7 :l :u EFTA00612530 . . • approximate

the State of New York, contrary to law. Within the -15- amn%; wv 7C:I I IVJ C11)7_4,7...fly EFTA00612532 following five days, 531,300 shares of Emery were acquired in the account at a cost in excess of $4,000,000. Contrary to law, the individual defendants failed to prepare any documentation

f writing health insurance for individuals and groups as well as various lines of property and casualty coverages. 5- Hoffenberg 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 Financia

The funds were then transferred to an account in the name of United Fire Insurance Company with the brokerage firm of Guinan and Company, Inc. in the State of New York, contrary to law. Within the -15- amn%; wv 7C:I I IVJ C11)7_4,7...fly EFTA00612532 following five days, 531,300 shares of Emery were acquired i

Ponzi scheme (the "Insurance Ponzi Fraud") to finance bids to take over Pan American Airways, Inc. ("Pan Am") in 1987 and Emery Air Freight Corp. ("Emery") in 1988 through TFC's acquisition of a controlling interest in United Diversified Corporation ("UDC") and, as a result, UDC's two ailing subsidia

y. Epstein improperly and knowingly removed the 7 EFTA00804512 Subsidiaries' bonds from TFC and UDC to use as collateral in order to purchase the Emery shares. 25. Epstein manipulated the price of Emery stock to minimize the losses which occurred when Hoffenberg's and Epstein's bids failed and the

rom all of the bonds owned by the Subsidiaries, valued in excess of two million five hundred thousand ($2,500,000) dollars, to brokerage accounts in the State of New York. a EFTA00804513 30. In late-1980s, TFC became insolvent and Hoffenberg, Epstein and other individuals at TFC devised another fraudulent Ponzi s

atton Boggs LLP (DC), Martin Francis McMahon, Stephanie Wall Fell, Martin F. McMahon and Associ- ates, Thomas Peter Steindler, McDermott, Will and Emery (DC), James Ernest Gauch, Jennifer Allyson Shumaker, Jona- than Chapman Rose, Melissa Danielle Stear, Michael Peter Gurdak, Michael Rol- lin Shumak

where the complaint stated, without any supporting facts, that the defendant "participates in a 'multina- tional insurance arrangement' present in the State of New York"); In re Ski Train Fire in Kaprun, Austria, 230 F.Supp.2d at 410-413 (granting motion to dismiss and denying jurisdictional discovery where compl