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n benefit or for expenditures, totalling over $3 million, unrelated to the insurance companies, -including tuition costs and credit ca'd bills for Hoffenberg's stepdaughter; the payment of investment consultant fees for Towers; the purchase of Emery Air Freight stock; the payment of margin interest; the pa
d.e with a series of Indenture Agreements. The Bonds were sold pursuant to five separate, private placement memoranda prepared at the direction of Hoffonberg and his co-conspiratdis. The private placement memoranda got.* each issuance of the Bonds'represented that the proceeds from the sales of the Bond
016 Complaint contained no statements sworn under penalties of perjury and was ultimately withdrawn with prejudice by then-Plaintiff Hoffenberg. See Steven J. Hoffenberg v. Jeftey E, Epstein, et. al., Case No. 16-03989 (RJS) (S.D.N.Y May 27, 2016). 15 EFTA00809705 Case 1:18-cv-07580-JPO Document 7 Filed 08/21/18
d Defendants' deceptive, unlawful and unfair practices. While Plaintiffs and the Class realized the depth and breadth of the Ponzi scheme following Hoffenberg's conviction and the several related civil lawsuits, Defendants' involvement was purposefully concealed and not revealed until Hoffenberg's 2 In Un
0-JPO Document 7-2 Filed 08/21/18 Page 1 of 8 Exhibit B EFTA00809733 Case 1:18-cv-07580-JPO Document 7-2 Filed 08/21/18 Page 2 of 8 AFFIDAVIT OF STEVEN J. HOFFENBERG STATE OF NEW YORK ) ss.: COUNTY OF NEW YORK STEVEN J. HOFFENBERG, being duly sworn, deposes, and says that: 1. I am a not a party in the above caption
nt 7-1 Filed 08/21/18 Page 6 of 16 Finally, in a further attempt to conceal their activities, Hoffenberg and his co-conspirators filed a lawsuit the United States District Court for the Northern District in of Illinois against individual State of Illinois insurance regulation employees, alleging that these employees insti
judge. However, the Offices will in- form the sentencing judge and the Probation De- partment of: (i) this Agreement; (ii) the nature and extent of Steven Hoffenberg's activities with re- spect to this case; and (iii) the full nature and extent of Steven Hoffenberg's cooperation with the Of- fices and the date when
nd the Gov- ernment entered into the Agreement dated Septem- ber 23, 1993. On January 27, 1994, and on February 14, 1994, the Government confronted Hoffcnberg with allega- tions that he had violated his obligations under the Agreement. On February 17 he was advised that the Agreement had been terminated,
Exchange Commission ("SEC"). The SEC filed an action in this District against Hoffenberg and others on February 8, 1993, and on February 17, 1993, Hoffenbcrg and certain other defendants agreed to a preliminary injunction issued by the Honorable Whitman Knapp (the "Consent Order") which, among other thi
ing Stratford. Hoffenberg in- structed Dryfus to tell counsel that Hoffenberg was just a consultant and that Dryfus was in business with members of Hoffenberg's family. Dryfus fol- lowed Hoffenberg's instructions. In January and February 1994, Hoffenberg spoke with Dryfus "every day" about Stratford's busin
d and after it had procured statements from Hughes and Lowy on the subject. When Nardello learned of Lowy's and Hughes' cooperation, he challenged Iloffenberg on January 24, and Hoffen- berg conceded certain of the information relating to his involvement in Stratford and sought to " cure" his conduct. Nar
al. * John M. Fitzgibbons, Asst. U.S. Any., Tampa, Fla., for plaintiff-appellant. Frank Regano, Tampa, Fla., for defendant- appellee. Appeal from the United States District Court for the Middle District of Florida. Before HILL and HENDERSON, Circuit Judges, and TUTTLE, Senior Circuit Judge. PER CURIAM: This is an appeal f
d)). As a matter of law, Plaintiffs were not permitted to sit on their rights merely because, while they knew for decades that they were victims of Hoffenberg's and his "co-conspirator's" scheme, they did not know Defendant Epstein was the alleged "co-conspirator": Once a plaintiff becomes aware [of its inj
MINARY STATEMENT: MULTIPLE SDNY JUDGES WARNED THE PERSON DRIVING THIS ACTION AGAINST SUCH FRIVOLOUS LAWSUITS Judges Sweet, Berman and Castel warned Steven Hoffenberg ("Hoffenberg"), whom Plaintiffs identify as the "Non-Party Affiant" (Compl. 15) and whose affidavit forms the entire basis for their Complaint, ag
ing frivolous and improper litigation like this action. Nevertheless, Hoffenberg remains intent on shifting blame for his own massive Ponzi scheme. Hoffenberg's scheme culminated in 1997 when Judge Sweet sentenced Hoffenberg to a 20-year prison sentence and ordered him to pay $475,157,340 in restitution to
PRIVILEGED AND CONFIDENTIAL; ATTORNEY WORK PRODUCT UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X MARVIN GERBER AND KALMA KOENIG, : on behalf of themselves and all others similarly : situated, Plaintiffs,
n benefit or for expenditures, totalling over $3 million, unrelatud to the insurance companies, :including tuition costs and credit cawd bills for Hoffenberg's stepdaughter; the payment of investment consultant fees for Towers; the purchase of Emery Air Freight stock; the payment of margin interest; the pa
3 Case 1:18-cv-07580-JPO Document 7-1 Filed 08/21/18 Page 2 of 16 STATES DISTRICT COURT RN DISTRICT OF NEW YORK STATES OF AMERICA, - against - STEVEN HOFFENSERG Defendant. sweet, D. J. araistnianallnlanti 2A-CL.-2131B2B1. Sal-Sx-.-32.1-111Wal Defendant Steven Hoffenberg ("Hoffenberg") pled guilty on April 2
d 08/21/18 Page 3 of 16 Tv U.S.C. § 3013, a special assessment of $250.00, $50.00 per count, is mandatory. The Offense Conduct Until April 1993, Hoffenberg was the chief executive officer, president and chairman of the board of Towers Financial Corporation ("Towers"). In 1987, Towers acquired a contro
7-1 Filed 08/21/18 Page 6 of 16 Finally, in a further attempt to conceal their activities, Hoffenberg and his co-conspirators filed a lawsuit in the United States District Court for the Northern District of Illinois against individual State of Illinois insurance regulation employees, alleging that these employees instituted
Judge Sweet ordered a status conference for December 5, 2013. The Petition was directly related to the December 5, 2013 Status Conference Regarding Steven Hoffenberg Case #: 4346 Docket #: 95-cr-00213-001. At this status conference, Judge Sweet questioned why the papers had been sealed. 20. At the time the Petition
ly prohibits a lawyer from simultaneously representing clients with differing interests, in the narrow circumstances of M&F's representation of Mr. Hoffenberg in connection with his supervised release and the Petitioners with respect to the issue of permitting Mr. Hoffenberg to engage in activities which
o decades ago would not impair our professional ability to diligently represent the Petitioners with respect to "the efforts to submit a petition to the United States District Court for the Southern District of New York..." because Towers Financial no longer exists. 16. We believe that what we were seeking in the Petition was i
hrough Douglas Leese, a defense contractor, and John Mitchell, the former U.S. Attorney General.(321 Towers Financial Corporation Epstein in 1980 Steven Hoffenberg hired Epstein in 1987, as a consultant for Towers Financial Corporation (unaffiliated with the company of the same name founded in 1998, and acquire
and Epstein then refashioned themselves as corporate raiders using Towers Financial as their raiding vessel. One of Epstein's first assignments for Hoffenberg was to implement what tuned out to be an unsuccessful bid to take over Pan American World Airways in 1987. A similar unsuccessful bid in 1988 was m
S Reese - TP v Epstein and Maxwell (2017) - Mesci-)eet- te-STR.Qc-Ti i`4 Cr CAREER P KG 6 P6c---TS cCfr? pLy In 2017, filed a suit, in the United States District Court for the Southern District of New York, againit Epstein and Maxwell, alleging that Maxwell hired her to give massages to a_ Epstein and laterffireat
ein SexuAL Aepose R kt Accounts differ on when Maxwell first met American financier Jeffrey Epstein. According to Epstein's former business partner, Steven Hoffenberg, Robert Maxwell introduced his daughter to Epstein in the late 198Os.491 The Times reported that Maxwell met Epstein in the early 199os at a New Yo
ing to Epstein's former business partner, Steven Hoffenberg, Robert Maxwell introduced his daughter to Epstei
blic, in May 2017 the case was settled in favour,1451 with Maxwell paying "millions".1t1 6 v Epstein and Maxwell (2017) In 2017, filed a suit, in the United States District Court for the Southern District of New York, against Epstein and Maxwell, alleging that Maxwell hired her to give massages to Epstein and later threatene
as his money, is a gentleman by the name of Steve Hoffenberg, who went to jail for 20 years for committing th
e Limited. Mr. Wexner is the chief executive of L Brands, which now operates Victoria's Secret and Bath & Body Works. Mr. Epstein also did work for Steven Hoffenberg, a financier who offered to rescue The New York Post in 1994, the year before he was charged with securities fraud. Mr. Epstein's townhouse was onc
xists but He Gives No Details Public Corruption Epstein Who Protected Jeffrey Epstein? New York Times By The Editorial Board 7/8/19 On Monday, the United States District Court for the Southern District of New York unsealed a 14-page indictment against Jeffrey Epstein, charging the wealthy financier with operating and consp
e Limited. Mr. Wexner is the chief executive of L Brands, which now operates Victoria's Secret and Bath & Body Works. Mr. Epstein also did work for Steven Hoffenberg, a financier who offered to rescue The New York Post in 1994, the year before he was charged with securities fraud. 29 EFTA00076685 SDNY News Cl
as his money, is a gentleman by the name of Steve Hoffenberg, who went to jail for 20 years for committing th
Clips, Tuesday, July 9, 2019 Public Corruption Epstein Who Protected Jeffrey Epstein? New York Times By The Editorial Board 7/8/19 On Monday, the United States District Court for the Southern District of New York unsealed a 14-page indictment against Jeffrey Epstein, charging the wealthy financier with operating and consp
with Jeffrey Epstein Accounts differ on when Maxwell first met American financier Jeffrey Epstein. According to Epstein's former business partner, Steven Hoffenbe Robert Maxwell introduced his daughter to Epstein in the late 198Os. The limes reported that Maxwell met Epstein in the early 199O5 at a New York
ublic, in May 2017 the case was settled in favour, 51 with Maxwell paying "millions" LL61 v Epstein and Maxwell (2017) In 2017, filed a suit, in the United States District Court for the Southern District of New York, against Epstein and Maxwell, alleging that Maxwell hired her to give massages to Epstein and later threatene
Entities connected to both Steven Hoffenberg and the United States District Court

Jeffrey Epstein
PERSONthe Southern District
LOCATION
United States
LOCATION
Ghislaine Maxwell
PERSON
Alexander Acosta
PERSON
Prince Andrew
PERSONFBI
ORGANIZATION
Department of Justice
ORGANIZATION
Kenneth Marra
PERSONJane Doe
PERSONLeon Black
PERSON
Bradley Edwards
PERSON
Alan Dershowitz
PERSON
George W. Bush
PERSON
New York
LOCATION
Donald Trump
PERSON
Bill Clinton
PERSONJack Goldberger
PERSONGerald Lefcourt
PERSON
Les Wexner
PERSON