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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
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
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f 26 personal expenses of the conspirators, and to pay interest on the TFC Promissory Notes which were not properly collateralized. 41. Defendant Epstein, directly and indirectly, represented to investors that the face value of the collateral exceeded the face value of the TFC Promissory Notes. Instea
es which were not properly collateralized. 41. Defendant Epstein, directly and indirectly, represented to investor
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
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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
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
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Mutual Connections (17)
Entities connected to both Jeffrey Epstein and the THRFC Bond Funds
Southern District of New York
ORGANIZATION686 w/ Jeffrey·3 w/ the
the United States District Court
ORGANIZATION526 w/ Jeffrey·2 w/ the
Steven Hoffenberg
PERSON256 w/ Jeffrey·4 w/ the
Medicaid
ORGANIZATION114 w/ Jeffrey·2 w/ the
the Northern District
LOCATION101 w/ Jeffrey·3 w/ the
Emery
ORGANIZATION47 w/ Jeffrey·2 w/ the
the Bankruptcy Court
ORGANIZATION36 w/ Jeffrey·3 w/ the
Pan Am
ORGANIZATION27 w/ Jeffrey·2 w/ the
Towers Financial
ORGANIZATION27 w/ Jeffrey·2 w/ the
Associated Life
ORGANIZATION12 w/ Jeffrey·2 w/ the
Associated
ORGANIZATION9 w/ Jeffrey·2 w/ the
United Fire
ORGANIZATION6 w/ Jeffrey·2 w/ the
Hoffenberg, TFC
ORGANIZATION3 w/ Jeffrey·2 w/ the
Associated Life Insurance Co.
ORGANIZATION3 w/ Jeffrey·2 w/ the
Towers Diversified
ORGANIZATION2 w/ Jeffrey·2 w/ the
Emery Air Freight
ORGANIZATION2 w/ Jeffrey·2 w/ the
Pan American Airways, Inc.
ORGANIZATION2 w/ Jeffrey·2 w/ the