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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.
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
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
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
that company. The attempted acquisition of Emery Air Freight ultimately failed. United Fire and Associated lost over $1 million on the purchase of Emery securities, as those stocks were purchased with funds borrowed by using insurance company bonds as collateral. Hoffenberg concealed his activities
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
rators (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 filed false pleadings in related legal proceedings brought by state insurance regulators, closed out securities po
efendant 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
Entities connected to both Emery and Associated

Jeffrey Epstein
PERSON
Alfredo Rodriguez
PERSON
Ghislaine Maxwell
PERSON
George W. Bush
PERSON
Steven Hoffenberg
PERSON
Prince Andrew
PERSON
Vicky Ward
PERSON
George Mitchell
PERSON
American Express
ORGANIZATION
Donald Trump
PERSON
Bill Clinton
PERSON
New York
LOCATION
Pan Am
ORGANIZATION
Barry Diller
PERSON
Michael Douglas
PERSON
Ralph Lauren
PERSONLeon Black
PERSON
Marc Rich
PERSON
Alan Dershowitz
PERSON
Michael Jackson
PERSON