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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016 Complaint contained no statements sworn under penalties of perjury and was ultimately withdrawn with prejudice by then-Plaintiff Hoffenberg.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
s Financial, et al filed 03/12/93 Dinsmore v. Towers Financial, et al filed 06/30/93 Superstock, Inc. v. Towers Fin. Corp., et al filed 08/01/91 Murphy, et al v. Tins Financial Corp.. et al filed 02/18/93 Von Stange v. Twrs Financial Corp.. et al filed 03/24/93 closed 01/04/90 closed 11/1693 clo
umen than his connections to two men — Steven J. Hoffenberg, a onetime owner of The New York Post and a noto
ittle evidence that Mr. Epstein is a billionaire. Mr. Epstein's wealth may have depended less on his math acumen than his connections to two men — Steven J. Hoffenberg, a onetime owner of The New York Post and a notorious fraudster later convicted of running a $460 million Ponzi scheme, and Leslie H. Wexner, the
votes of women. Kane and Felicia Sonmez report: "Cheney (Wyo.), chair of the House Republican Conference, was speaking one day after state Rep. Murphy bested pediatrician Joan Perry to win the GOP nomination for a U.S. House seat in North Carolina. Perry had received nearly $1 million in support
umen than his connections to two men — Steven J. Hoffenberg, a onetime owner of The New EFTA00044386 York
ittle evidence that Mr. Epstein is a billionaire. Mr. Epstein's wealth may have depended less on his math acumen than his connections to two men — Steven J. Hoffenberg, a onetime owner of The New EFTA00044386 York Post and a notorious fraudster later convicted of running a $460 million Ponzi scheme, and Leslie H
es of women. M Kane and Felicia Sonmez report: "Cheney (Wyo.), chair of the House Republican Conference, was speaking one day after state Rep. M Murphy bested pediatrician Joan Perry to win the GOP nomination for a U.S. House seat in North Carolina. Perry had received nearly $1 million in support f
t Citibank once sued him for defaulting on a $20 million loan. The article suggested that one of his business mentors and previous employers was Steven Hoffenberg, now serving a prison term after "bilking investors out of more than $450 million in one of the largest Ponzi schemes in American hisio- As he am
siness mentors and previous employers was Steven Hoffenberg, now serving a prison term after "bilking inves
OPHER STERN and 004 JEFFREY Bkornterg Nebo Todd Murphy is fed up with satellite radio, and he isn't even a customer. During morning com- mutes. Murphy says, his National Public Radio sta- tion begins blaring out foul- mouthed talk show host Howard Stern. "I'm sitting at a traffic light and all o
urt of the Southern District of New York against Hoffenberg and TFC in connection with the TFC Ponzi Scheme:
s Financial. et al filed 03/12/93 Dinsmore v. Towers Financial. et al filed 06/30/93 Superstock, Inc. v. Towers Fin. Corp.. et al filal 08/01/91 Murphy, et al v. Tun Financial Corp.. et al filed 02/18/93 Von Stange v. Twrs Financial Corp.. et al filed 03/24/93 I:93-cv-00992-WK I :93-cv-0 1543-WK
Entities connected to both Steven Hoffenberg and Murphy

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
Bill Clinton
PERSON
Donald Trump
PERSONLeon Black
PERSON
Marc Rich
PERSON
Les Wexner
PERSON
New York
LOCATION
Department of Justice
ORGANIZATION
Virginia Giuffre
PERSON
Vicky Ward
PERSON
George W. Bush
PERSON
Julie K. Brown
PERSON
Joe Biden
PERSON
United States
LOCATION
Alan Dershowitz
PERSON
Robert Maxwell
PERSON
Bradley Edwards
PERSON
Stephen Hawking
PERSON