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year. 18. Epstein, who was also referred to as "The Talented Mr. Epstein" in the March 2003 issue of the magazine VANITY
K X Ray Marques and , individually, and as representatives of the Noteholders and Bondholders of Towers Financial Corporation, Plaintiff, v. Jeffrey E. Epstein, individually, and as President and Chief Executive Officer of The Financial Trust Company, The Financial Trust Company, XYZ Corp. and ABC, Inc.
ndholders of Towers Financial Corporation, by their attorney, Gary H. Raise, Esq., bring this Complaint against the Defendants, Jeffrey E. Epstein ("Epstein"), individually, and as President and Chief Executive Officer of The Financial Trust Company, XYZ Corp., and ABC, Inc., as follows: PARTIES 1. M
of Towers Financial Corporation, Plaintiff, v. Jeffrey E. Epstein, individually, and as President and Chi
of Towers Financial Corporation, Plaintiff, v. Jeffrey E. Epstein, individually, and as President and Chie
pstein, who was also referred to as "The Talented Mr. Epstein" in the March 2003 issue of the magazine VANITY
shall 2 EFTA00804507 hereinafter be collectively referred to as the "Epstein Ponzi Companies" 6. At all relevant times, as co-conspirator with Hoffenberg, TFC and other agents of TFC, Epstein managed, and continues to control, the Epstein Ponzi Companies, which include a number of financial companies and
tten gains, obtained from his participation in a Defendant Epstein is sued herein in his individual capacity as well
L TRUST COMPANY, XYZ CORPORATION, ABC, INC., and JEFFREY E. EPSTEIN Defendant(s) Civil Action No. 18.7580
L TRUST COMPANY, XYZ CORPORATION, ABC, INC., and JEFFREY E. EPSTEIN Defendant(s) Civil Action No. 18.7580
KOENIG, on behalf of themselves and all others similarly situated, Plaintiffs, v. THE FINANCIAL TRUST COMPANY, XYZ CORPORATION, ABC, INC., and JEFFREY E. EPSTEIN, Defendants. Case No. INITIAL COMPLAINT ECF CASE Marvin Gerber and Kalma Koenig (collectively "Plaintiffs"), on behalf of themselves and all ot
ch Rose Schirripa & Cheverie, LLP ("HRSC"), bring this Complaint against the Defendants, The Financial Trust Company ("TFTC"), Jeffrey E. Epstein ("Epstein"),' XYZ Corp., and ABC, Inc., as follows: INTRODUCTION I. This is an action to recover damages on behalf of Plaintiffs and members of the propose
e financial condition. 49. In February 1993, following a lengthy investigation, the Securities and Exchange Commission ("SEC") filed suit against Hoffenberg, TFC, and other TFC officials for, among other things, securities fraud through the circulation of false and misleading financial statements to investor
Case 1:18-cv-07580 Document 1 Filed 08/20/18 Page 11 of 26 46. Despite the intended and stated purpose in the offering documents, Epstein diverted the funds and funneled a substantial amount of the proceeds of the sale of the TFC Bonds to pay TFC's operating expenses. 47. To cover u
operating expenses. 47. To cover up the fraud, Defendant Epstein directed collateral to be moved from one THRFC B
e financial condition. 49. In February 1993, following a lengthy investigation, the Securities and Exchange Commission ("SEC") filed suit against Hoffenberg, TFC, and other TFC officials for, among other things, securities fraud through the circulation of false and misleading financial statements to investor
Entities connected to both Jeffrey Epstein and Hoffenberg, TFC

George W. Bush
PERSON
Michael Cohen
PERSONthe Southern District
LOCATION
Financial Trust Company
ORGANIZATION
Southern District of New York
ORGANIZATION
Steven Hoffenberg
PERSONthe Northern District
LOCATION
Emery
ORGANIZATIONthe Bankruptcy Court
ORGANIZATIONTowers Financial
ORGANIZATION
Pan Am
ORGANIZATIONthe THRFC Bond Funds
ORGANIZATIONAssociated Life Insurance Co.
ORGANIZATIONUnited Air Fleet
ORGANIZATIONDinsmore v. Towers Financial
ORGANIZATIONal v. Twrs Financial Corp.
PERSON