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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
a "perfect circumstantial evidence case that [Epstein] ha[s] means, motive, and opportunity" to fraudulently transfer assets. See United States v. Sparks, 265 F.3d 825, 830 (9th Cir. 2001) (finding probable cause for an arrest based solely on a showing of means, motive, and opportunity). The fact tha
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
Epstein is fraudulently transferring assets because he purportedly has the means, the motive and the opportunity to do so, citing United States v. Sparks, 265 F.3d 825, 830 (9th Cir. 2001). See Injunction Motion (DE #165) at 11. Sparks is completely inapposite as it concerned whether probable cause fo
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
al mentor was not Leslie Wexner, but Steven Jude Hoffenberg, who was sent to federal prison for twenty years
a "perfect circumstantial evidence case that [Epstein] ha[s] means, motive, and opportunity" to fraudulently transfer assets. See United States v. Sparks, 265 F.3d 825, 830 (9th Cir. 2001) (finding probable cause for an arrest based solely on a showing of means, motive, and opportunity). The fact tha
Entities connected to both Steven Hoffenberg and Sparks

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
Bill Clinton
PERSON
Les Wexner
PERSON
Donald Trump
PERSON
Marc Rich
PERSONLeon Black
PERSON
Vicky Ward
PERSON
New York
LOCATION
Bradley Edwards
PERSON
Martha Stewart
PERSON
Department of Justice
ORGANIZATION
Bear Stearns
ORGANIZATION
Alfredo Rodriguez
PERSON
George W. Bush
PERSONJane Doe
PERSON
Kenneth Marra
PERSON
United States
LOCATION
U.S. Virgin Islands
LOCATION
Paul Cassell
PERSON