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Filed 08/21/18 Page 1 of 16 Exhibit A EFTA00809717 Case 1:18-cv-07580-JPO Document 7-1 Filed 08/21/18 Page 2 of 16 at 5 STATES DISTRICT COURT RN DISTRICT OF NEW YORK STATES Or AMERICA, - against - £T£VEN EOFFENSERG Defendant. Sweet, D. J. HEItardEalig QPDilial 9 Cra,--213--Mar21 23--CX-9-321-D1WHI_ Defendan
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 EFTA00809701 Case 1:18•cv-07580-JPO Document 7 Filed 08/21/18 Page 12 of 26 52. The very next day, on April 20, 1994, Hoffen
bonds to investors ("TFC Bonds"). 43. Moreover, Defendant Epstein, directly and indirectly, created, or caused to have created, TFC subsidiaries, the THRFC Bond Funds, which were a series of corporate entities that issued the TFC Bonds. The TFC Bonds were sold pursuant to five (5) separate private placement memor
nt 7-1 Filed 08/21/18 Page 1 of 16 Exhibit A EFTA00795983 Case 1:18-cv-07580-JPO Document 7-1 Filed 08/21/18 Page 2 of 16 STATES DISTRICT COURT RN DISTRICT OF NEW YORK STATES OF AMERICA, - against - STEVEN HOFFENSERG Defendant. sweet, D. J. araistnianallnlanti 2A-CL.-2131B2B1. Sal-Sx-.-32.1-111Wal Defendant Stev
of collection receivables which Towers did not own, but only collected as agent and took a fee, and of certain healthcare receivables purchased by the THRFC Bond Funds. Receivables not actually owned by Towers could not properly collateralize the Notes. 9 EFTA00795992 Case 1:18-cv-07580-JPO Document 7-1 Filed
s indicted in the Northern District of Illinois on various fraud charges. s See In re Towers Financial Corporation, a al. Case No. 93-B41558 (PBA) (S.D.NY. Dec. 8, 1994). II CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0088595 CONFIDENTIAL SDNY GM_00234779 EFTA01386757
rther, Epstein and Hoffenberg created phony receivables, then included those items in reports designed to misrepresent the true financial picture of the THRFC Bond Funds. Despite Defendant Epstein's central role in this now widespread, massive Ponzi scheme, his actions were taken on behalf of TFC — Hoffenberg's comp
Entities connected to both Southern District of New York and the THRFC Bond Funds

Jeffrey Epstein
PERSON
the United States District Court
ORGANIZATIONthe Northern District
LOCATION
Steven Hoffenberg
PERSON
Medicaid
ORGANIZATIONthe Bankruptcy Court
ORGANIZATION
Emery
ORGANIZATIONTowers Financial
ORGANIZATIONAssociated Life
ORGANIZATION
Pan Am
ORGANIZATIONUnited Fire
ORGANIZATIONState Farm Insurance Company
ORGANIZATIONthe Bond Funds
ORGANIZATIONBond Fund
ORGANIZATIOND. J.
PERSONEmery Air Freight
ORGANIZATIONHoffenberg, TFC
ORGANIZATIONAssociated Life Insurance Co.
ORGANIZATIONPan American Airways, Inc.
ORGANIZATIONAssociated
ORGANIZATION