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it mere legal conclusions that are dressed up as factual allegations that a defendant was in a fiduciary relationship with a plaintiff." Childers v. N.Y. & Presbyterian Hosp., 36 F. Supp. 3d 292, 306 (S.D.N.Y. 2014) (citing Faktor v. Yahoo! Inc., No. 12 Civ. 5220, 2013 WL 1641180, at *3 (S.D.N.Y. 2013)
Epstein came up with the idea of financing these bids through Towers' acquisition of two ailing Illinois insurance companies, Associated Life and United Fire. `He was hired by us to work on the securities side of the insurance companies and Towers Financial, supposedly to make a profit for us and for the
ined forces in the mid-1980s. Prior to that, Epstein had been running International Assets Group Inc., a consulting company, out of his apartment in New York City. 22. In or around 1987, Hoffenberg and TFC hired Epstein as an associate and expert consultant. This "consulting" engagement entailed Epstein assi
e stocks were purchased with fupds borrowed by using insurance company bonds as collateral. Hoffenberg concealed his activities from Associated and United Fire by: routing all securities trade confirmations, periodic account statements and other communications from brokerage firms to Towers, rather than t
Page 12 The Talented Mr. Epstein; Lately, Jeffrey Epstein's high-ying style has been drawing oohs and aahs: the bachelor nancier lives in New York's largest private residence, claims to take only billionaires as clients, and ies celebrities including Bill Clinton and Kevin Spacey on his Boeing 7
Epstein came up with the idea of financing these bids through Towers's acquisition of two ailing Illinois insurance companies, Associated Life and United Fire. "He was hired by us to work on the securities side of the insurance companies and Towers Financial, supposedly to make a profit for us and for the
Microsoft Word - Exhibit K.docx
ng oohs and aahs: the bachelor financier lives in New York’s largest private residence, claims to take only bi
argets. Meanwhile, in order to throw the insurance regulators off, the $1.8 million was reported as being safely invested in a money-market account. United Fire’s former chief financial officer Daniel Payton confirms part of Hoffenberg’s account. He says he recalls making one or two telephone calls to Epstein (
Page: HOUSE_OVERSIGHT_017781 →t they knew they could get ... and that was the fraudulent promissory notes [i.e., the much larger and unrelated part of Hoffenberg’s fraud, based in New York State].... What they couldn’t get, they didn’t bother with.” Another lawyer involved in the criminal prosecution of Hoffenberg says, “In a criminal invest
Page: HOUSE_OVERSIGHT_017782 →Entities connected to both New York and United Fire

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
George W. Bush
PERSON
Bill Clinton
PERSON
George Mitchell
PERSON
Les Wexner
PERSON
Vicky Ward
PERSON
Southern District of New York
ORGANIZATION
the United States District Court
ORGANIZATION
Bear Stearns
ORGANIZATION
Steven Hoffenberg
PERSON
Jimmy Cayne
PERSON
Kevin Spacey
PERSON
Financial Trust Company
ORGANIZATION
Medicaid
ORGANIZATIONthe Northern District
LOCATION
Emery
ORGANIZATIONTowers Financial
ORGANIZATION
Pan Am
ORGANIZATIONAssociated Life
ORGANIZATION