Epstein Secrets

orporation ("UDC"), which conducted business through its subsidiaries, Associated Life Insurance Co. ("Associated") and United Fire Insurance Co. ("United Fire"). Hoffenberg later became chairman of the boardi of UDC, Associated and United Fire. Hoffenberg obtained the Illinois Department of Insuran

e stocks were purchased with funds 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

lly, in a further attempt to conceal their activities, Hoffenberg and his co-conspirators filed a lawsuit in the United States District Court for the Northern District of Illinois against individual State of Illinois insurance regulation employees, alleging that these employees instituted "sham conservation proce

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

ith the Bankruptcy Court to support their loss claims? 51. On April 19, 1994, and as a result of the SEC investigation, Hoffenberg was indicted in the Northern District of Illinois on various fraud charges. s See In re Towers Financial Corpora►ion, et at. Case No. 93-841558 (PBA) (S.D.NY. Dec. 8, 1994). II EFTA008

mpanies funds. 32. Hoffenberg caused Associated and United Fire to issue or deliver insurance policies at a time when he knew that Associated and United Fire were insolvent or impaired in violation of Section 144.1 of the Illinois Insurance Code. (I11. Rev. Stat. Ch. 73 I 756.1 (1987). -8- Ron 'd NY I

remaining Counts pursuant to 28 U.S.C. S 1332(a). 12. Plaintiff resides in this District. In addition, the claims arose in this District. Venue in the Northern District of Illinois is, therefore, proper under 28 U.S.C. $ 1391(a). Factual Background 13. This is an action for money damages against several former me