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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
7580-JPO Document 7 Filed 08/21/18 Page 5 of 26 the massive Ponzi scheme described herein. 16. On March 4, 1997, Hoffenberg was convicted by Judge Sweet of the Southern District of New York for his role in a massive fraud conducted through TFC and associated entities and perpetrated by him and his, unt
on to take notes during his meetings with probation officers.° (Petition at 10-15.) The petition asserts that a non- party "multi-billionaire" named Jeffrey Epstein can "easily" provide for restitution through his "over one hundred billion dollar hedge fund" that was formed with Hoffenberg's assistance. (Petiti
at a non- party "multi-billionaire" named Jeffrey Epstein can "easily" provide for restitution through his
serts that a non- party "multi-billionaire" named Jeffrey Epstein can "easily" provide for restitution thro
371, conspiracy to obstruct SEC proceedings, 18 U.S.C. § 371, mail fraud, 18 U.S.C. §§ 1341 & 2, and tax evasion, 21 U.S.C. § 7201. In 1997, Judge Sweet of this Court sentenced Hoffenberg to 240 months of imprisonment, three years of supervised release, restitution in the amount of $475,157,340 and a $1
on to take notes during his meetings with probation officers.4 (Petition at 10-15.) The petition asserts that a non- party "multi-billionaire" named Jeffrey Epstein can "easily" provide for restitution through his "over one hundred billion dollar hedge fiord" that was formed with Hoffenberg's assistance. (Petit
at a non- party "multi-billionaire" named Jeffrey Epstein can "easily" provide for restitution through his
serts that a non- party "multi-billionaire" named Jeffrey Epstein can "easily" provide for restitution thro
371, conspiracy to obstruct SEC proceedings, 18 U.S.C. § 371, mail fraud, 18 U.S.C. §§ 1341 & 2, and tax evasion, 21 U.S.C. § 7201. In 1997, Judge Sweet of this Court sentenced HofTenberg to 240 months of imprisonment, three years of supervised release, restitution in the amount of $475,157,340 and a $1
Entities connected to both Jeffrey Epstein and Sweet of

Alan Dershowitz
PERSON
United States
LOCATION
New York
LOCATION
Philadelphia
LOCATION
the United States Government
ORGANIZATION
Steven Hoffenberg
PERSONSweet
PERSONTowers Financial
ORGANIZATION
Alan P. Fraade
PERSONMarques
PERSONthe U.S. Probation Office
ORGANIZATIONFraade
PERSONNew York City Staff
LOCATIONRey Marques
PERSONthe Mintz & Fraade
ORGANIZATIONCASTEL
LOCATIONthe Probation Office of this District
ORGANIZATIONHewitson
ORGANIZATIONPetition Ex
ORGANIZATION3 & Ex
ORGANIZATION