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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.
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
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
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
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
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
Entities connected to both Emery and Towers Diversified

Jeffrey Epstein
PERSON
Steven Hoffenberg
PERSON
George W. Bush
PERSON
Pan Am
ORGANIZATIONTowers Financial
ORGANIZATIONAssociated Life
ORGANIZATIONUnited Fire
ORGANIZATION
Southern District of New York
ORGANIZATIONAssociated
ORGANIZATIONthe Northern District
LOCATION
the United States District Court
ORGANIZATIONUnited Air Fleet
ORGANIZATIONAssociated Life Insurance Co.
ORGANIZATIONthe Bankruptcy Court
ORGANIZATIOND. J.
PERSONPan American Airways, Inc.
ORGANIZATIONthe THRFC Bond Funds
ORGANIZATION
Medicaid
ORGANIZATIONState of Illinois
ORGANIZATIONthe Illinois Insurance
ORGANIZATION