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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016 Complaint contained no statements sworn under penalties of perjury and was ultimately withdrawn with prejudice by then-Plaintiff Hoffenberg.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
Iloffenbcrg. et al filed 03/15/94 Sahlen & Assoc. v. Towers Financial Cor filed 01/04/90 Associated Dry Goods v. Towers Financial filed 12/28/88 Riviera v. Towers Financial. et al filed 02119/93 Siudmak, et al v. Towers Financial, et al filed 03/12/93 Dinsmore v. Towers Financial, et al filed 06/
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
ck to an in-house gar- bage operation. The latter has the least backing from staff members. They estimate it would cost about $8 million to revive Riviera Beach's public garbage collection, al- though some residents support the idea. "Nobody can do it cheaper than you; Herman McCray, the city's sanit
s would have wanted to know if Moore could be impartial in lamb's case given the fact that he is charged with murdering his wife. Moore. 47, of Riviera Beach admitted in court Fri- day that she didn't mention that her daughter. Tanga, Moore. was murdered by her husband. who then killed himself. "
urt of the Southern District of New York against Hoffenberg and TFC in connection with the TFC Ponzi Scheme:
0-cv-00056-LBS Sahlim & Assac. v. Towers Financial Cor filed 01/04/90 I:88-cv-09178-RWS Associated Dry Goods v. Tossers Financial filed 12/28/88 Riviera v. Towers Financial, et al filed 02119/93 Siudinak, et al v. Towers Financial. et al filed 03/12/93 Dinsmore v. Towers Financial. et al filed 06
Entities connected to both Steven Hoffenberg and Riviera

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
Bill Clinton
PERSON
Marc Rich
PERSON
Donald Trump
PERSONLeon Black
PERSON
Vicky Ward
PERSON
Alan Dershowitz
PERSON
New York
LOCATION
Bradley Edwards
PERSON
Department of Justice
ORGANIZATION
Virginia Giuffre
PERSON
United States
LOCATION
George W. Bush
PERSON
New York City
LOCATIONDarren Indyke
PERSON
Alfredo Rodriguez
PERSON
Bradley Cooper
PERSON
Barry Diller
PERSON