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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
-WK 1 :93-cv-01047-WK 1 :93-cv-01094 -WK 1 :93-cv-01095-WK 1 :93-cv-01155-WK 1 :93-cv-01303-WK 1 :93-cv-01543-WK Foti v. Towers Financial Cor United Air Fleet v. Hoffenberg, et al Gold, et al v. Towers Financial, et al Field v. Twrs Financial Corp., et al Ziegler v. Twrs Financial Corp., et al l72O v. T
of Emery was a dismal failure, resulting in massive trading losses to TFC. 31. In the wake of these losses to TFC, Epstein manipulated the price of Emery stock to minimize the losses when the share price began to fall. In order to do so, Epstein opened and maintained a number of brokerage accounts to
mber of high risk investments, including one 7 EFTA00809697 Case 1:18-cv-07580-JPO Document 7 Filed 08/21/18 Page 8 of 26 in Emery Air Freight ("Emery"). Similar to the situation with Pan Am, TFC's attempted take-over of Emery was a dismal failure, resulting in massive trading losses to TFC. 31.
ev-00992-WK :93-cv-0 1543-WK 13-ev-04449-WK :91-c-v-05231-1.JF -93-a-00961-WIC :93-ev-0 1927-WK Foti v. Towers Financial Corp. filed 03/13/89 United Air Fleet v. lioffenberg, et al filed 12/14/92 Gold, et a! v. Towers Financial, et al filed 02/10/93 Field v. Twrs Financial Corp., al filed 02/11/93 Zie
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
ited Fire and Diversified accounts as follows: COMPANY: Check 4 United Fire Insurance Company Payee. Date Amount 100111 11/06/87 $50,000.00 United Air Fleet 100110 11/13/87 25,000.00 Jeff Epstein 100108 11/20/87 25,000.00 Corporate Risk 100107 11/30/87 8,000.00 Mintz, Fraade & Sieger PC 1000
Entities connected to both Emery and United Air Fleet

Jeffrey Epstein
PERSON
Steven Hoffenberg
PERSON
George W. Bush
PERSON
Pan Am
ORGANIZATIONTowers Financial
ORGANIZATION
Michael Cohen
PERSONthe Southern District
LOCATIONUnited Fire
ORGANIZATIONAssociated
ORGANIZATIONthe Northern District
LOCATIONTowers Diversified
ORGANIZATIONthe State of New York
LOCATIONAssociated Life Insurance Co.
ORGANIZATIONDinsmore v. Towers Financial
ORGANIZATION
Financial Trust Company
ORGANIZATIONHoffenberg, TFC
ORGANIZATIONal v. Twrs Financial Corp.
PERSON