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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
e 101 v. Epstein Page 7 Certificate of Service Jane Doe No. 2 v. Jeffrey Epstein Case No. 08-CV-80119-MARRA/JOHNSON Stuart S. Mermelstein, Esq. Adam D. Horowitz, Esq. Mermelstein & Horowitz, P.A. 18205 Biscayne Boulevard Suite 2218 Miami FL 3 160 Fax: ssmasexabuseattomev.com Counsel for Plaintiffs in Re
financial instruments and other assets. 5. According to the Vanity Fair article, defendant Jeffrey Epstein's real mentor was not Leslie Wexner, but Steven Jude Hoffenberg, who was sent to federal prison for twenty years for bilking investors out of more than $450 million in one of the largest Ponzi schemes in America
ison for twenty years for bilking investors out of more than $450 million in one of the largest Ponzi schemes in American history. Epstein assisted Hoffenberg with (failed) takeover bids of Pan American World Airways and Emery Air Freight. 6. According to the Vanity Fair article, before working with Wexne
lclaw.com Paul G. Cassell [email protected] Richard Horace Willits [email protected] Robert C. Josefsberg rjosefsbe rg@pod h u rst.com Adam D. Horowitz [email protected] Stuart S. Mermelstein [email protected] William J. Berger [email protected] 21 Case 9:08-cv-80119-KA
s is based on inadmissible hearsay newspaper reports, Wikipedia, and the 2005 Vanity Fair Article. Mr. Cassell asserts that Epstein's "real mentor [Steven Hoffenberg] was sent to federal prison for twenty years for bilking investors out of more than $450 million on one of the largest Ponzi schemes in American hi
a Ponzi scheme. The 2005 Vanity Fair Article reports on Epstein's business dealings with Steven Hoffenberg during the 1980's and merely notes that Hoffenberg is "currently ... serving a 20-year sentence" for operating a Ponzi scheme. Importantly, despite all the questionable and speculative suggestions a
of24 Certificate of Service Jane Doe No. 2 v. Jeffrey Epstein Case No. 08-CV-80119-MARRA/JOHNSON Stuart S. Mermelstein, Esq. Brad Edwards, Esq. Adam D. Horowitz, Esq. Rothstein Rosenfeldt Adler Mermelstein & Horowitz, P.A. 401 East Las Olas Boulevard 18205 Biscayne Boulevard Suite 1650 Suite 2218 Fort
s is based on inadmissible hearsay newspaper reports, Wikipedia, and the 2005 Vanity Fair Article. Mr. Cassell asserts that Epstein's "real mentor [Steven Hoffenberg] was sent to federal prison for twenty years for bilking investors out of more than $450 million on one of the largest Ponzi schemes in American hi
a Ponzi scheme. The 2005 Vanity Fair Article reports on Epstein's business dealings with Steven Hoffenberg during the 1980's and merely notes that Hoffenberg is "currently ... serving a 20-year sentence" for operating a Ponzi scheme. Importantly, despite all the questionable and speculative suggestions a
f 24 Certificate of Service Jane Doe No. 2 v. Jeffrey Epstein Case No. 08-CV-80119-MARRA/JOHNSON Stuart S. Mermelstein, Esq. Brad Edwards, Esq. Adam D. Horowitz, Esq. Rothstein Rosenfeldt Adler Mermelstein & Horowitz, P.A. Counsel for Plaintiff in Related Case No. 08-80893 ounse or amttj s In related Ca
Entities connected to both Steven Hoffenberg and Adam D. Horowitz

Jeffrey Epstein
PERSONJack Goldberger
PERSONJane Doe
PERSON
Bradley Edwards
PERSON
Paul Cassell
PERSONMichael J. Pike
PERSONRobert D. Critton
PERSONRichard Horace Willits
PERSONJack Patrick Hill
PERSONIsidro Manuel Garcia
PERSON
Alan Dershowitz
PERSONStuart S. Mermelstein
PERSONKatherine W. Ezell
PERSONRobert C. Josefsberg
PERSON
Kenneth Marra
PERSON
Jeffrey Marc Herman
PERSONSouthern District
LOCATION
Salt Lake City
LOCATIONScott Rothstein
PERSONAtterbury Goldberger & Weiss
ORGANIZATION