Epstein Secrets

Case 1:18-cv-07580 Document 1 Filed 08/20/18 Page 15 of 26 62. The full extent of Defendant Epstein's involvement in the TFC Ponzi Scheme and related frauds, which harmed Plaintiffs and the Class, could not have been discovered prior to Hoffenberg

d 08/20/18 Page 15 of 26 62. The full extent of Defendant Epstein's involvement in the TFC Ponzi Scheme and relate

laintiff Hoffenberg. See Steven J. Hoffenberg v. Jeffrey £ Epstein, et. al., Case No. 16-03989 (RJS) (S.D.

o statements sworn under penalties of perjury and was ultimately withdrawn with prejudice by then-Plaintiff Hoffenberg. See Steven J. Hoffenberg v. Jeffrey £ Epstein, et. al., Case No. 16-03989 (RJS) (S.D.N.Y May 27, 2016). 15 CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0088599 CONFIDENTIAL SDNY

his involvement in the TFC Ponzi Scheme and continues to wrongfully possess the funds to which Plaintiffs and the Class are entitled as victims of the TFC Ponzi Scheme. CLASS ACTION ALLEGATIONS 67. This action is brought and may properly be maintained as a class action pursuant to Rules 23(a) and 23(bX3) of the

ts which were committed by Hoffenberg "and his co-conspirators." The Affidavit of Hoffenberg, annexed hereto, makes abundantly clear that Defendant Epstein and the Defendant Entities were Hoffenberg's co- conspirators. 59. As per the Sentencing Opinion, Hoffenberg and his co-conspirators (i)used certai

erg, annexed hereto, makes abundantly clear that Defendant Epstein and the Defendant Entities were Hoffenberg's co-

aims of the TFC Noteholders and Bondholders, in the total amount of $475,157,340, were valid and actionable. 57. On March 7, 1997, for his role in the TFC Ponzi Scheme, Hoffenberg was sentenced to twenty years' in prison, a term of supervised release, as well as a one million dollar ($1,000,000) fine, approximatel

his District offered Hoffenberg a reduced sentence in exchange for information about his co-conspirators in the TFC Ponzi Scheme — namely Defendant Epstein's role. However, Hoffenberg did not disclose any details about Defendant Epstein's involvement, let alone orchestration, of the fraudulent scheme. I

co-conspirators in the TFC Ponzi Scheme — namely Defendant Epstein's role. However, Hoffenberg did not disclose any

ding Defendant Epstein's role, 54. As a result of Hoffenberg's refusal to implicate Defendant Epstein, Epstein was never indicted for his role in the TFC Ponzi Scheme. Epstein was never charged with any crime in connection with the TFC Ponzi Scheme. Rather, Epstein has been permitted to use the ill-gotten gains a

v-07580 Document 1 Filed 08/20/18 Page 23 of 26 TFC to suffer tremendous financial loss. 115. Beginning in or around 1987 and through the present, Epstein, in breach of his obligations, negligently transferred securities and cash from assets or accounts in TFC, properly belonging to Plaintiffs and the

belonging to TFC, Plaintiffs and the Class, and with the intent to injure such entities and individuals, Epstein actively participated in devising the TFC Ponzi Scheme by participating in acquiring assets and funds though TFC for his own personal gain or use, or the gain or use of the Defendant Entities. 119. Und