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with over 20 years of accrued interest, now totals approximately one billion ($1,000,000,000) dollars, which represents the losses as determined by the Bankruptcy Court of the victims of his Ponzi scheme. 5 EFTA00809695 Case 1:18-cv-07580-JPO Document 7 Filed 08/21/18 Page 6 of 26 19. From 1975 through April 19
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
At the time of the Towers bankruptcy, Noteholders and Bondholders (as well as victims such as vendors and collections clients) filed petitions with the Bankruptcy Court to support their loss claims. As of April 1996, the Bankruptcy Court has already determined the following Noteholder and Bondholder claims to be va
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
cial condition. 50. In or around March 1993, TFC filed for Chapter 11 bankruptcy protection, and the Noteholders and Bondholders filed claims with the Bankruptcy Court to support their loss claims.5 51. On April 19, 1994, and as a result of the SEC investigation, Hoffenberg was indicted in the Northern District of
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 the Bankruptcy Court and the THRFC Bond Funds

Jeffrey Epstein
PERSON
Southern District of New York
ORGANIZATION
Steven Hoffenberg
PERSONthe Northern District
LOCATIONAssociated
ORGANIZATION
Pan Am
ORGANIZATION
Emery
ORGANIZATIONHoffenberg, TFC
ORGANIZATIONAssociated Life Insurance Co.
ORGANIZATIONPan American Airways, Inc.
ORGANIZATIONState of Illinois
ORGANIZATIONthe Illinois Insurance
ORGANIZATIONTowers Diversified
ORGANIZATIONTowers Healthcare Receivables
ORGANIZATIONBlue Cross/Blue Shield
ORGANIZATIONState Farm Insurance Company
ORGANIZATIONthe Bond Funds
ORGANIZATIONBond Fund
ORGANIZATIOND. J.
PERSON
the United States District Court
ORGANIZATION