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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016 Complaint contained no statements sworn under penalties of perjury and was ultimately withdrawn with prejudice by then-Plaintiff Hoffenberg.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
used the monies he misappropriated and earned from his illegal trading activities and used them as start-up capital for his corporations, including The Financial Trust Company. 19. Epstein conceived many ways we could cover up our dubious activities. Some of the actions we took included routing all securities trades conf
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
DISTRICT OF NEW YORK X MARVIN GERBER AND KALMA KOENIG, : on behalf of themselves and all others similarly : situated, Plaintiffs, -against- THE FINANCIAL TRUST COMPANY, XYZ CORPORATION, ABC, INC., and JEFFREY E. EPSTEIN, Defendants. X Index No. 1:18-cv-07580-JPO DEFENDANTS' MEMORANDUM OF LAW IN SUPPORT OF THEI
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
. Epstein reportedly made all the investment calls. Since the 1990s, the company has been incorporated in the U.S. Virgin Islands and is now called Financial Trust Co. A person answering the phone at the Saint Thomas-based company hung up after a request for comment was made. The main client was Wexner, the founde
up that he ran out of his apartment, according to Vanity Fair. Later he set up a money management firm called J. Epstein & Co. It eventually became the Financial Trust Company, based in the Virgin Islands. EFTA00076644 But there was an expensive footnote about him and Bear Stearns. When two big Bear Stearns hedge funds
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
. Epstein reportedly made all the investment calls. Since the 1990s, the company has been incorporated in the U.S. Virgin Islands and is now called Financial Trust Co. A person answering the phone at the Saint Thomas-based company hung up after a request for comment was made. The main client was Wexner, the founde
up that he ran out of his apartment, according to Vanity Fair. Later he set up a money management firm called J. Epstein & Co. It eventually became the Financial Trust Company, based in the Virgin Islands. But there was an expensive footnote about him and Bear Stearns. When two big Bear Stearns hedge funds collapsed in 20
al Corporation, ("TFC") a dissolved Nevada corporation which had its principal place of business in New York, NY at all relevant times during which Steven Hoffenberg ("Hoffenberg") was an officer, director and controlled a majority of its stock. 2. Epstein, a co-conspirator in connection with the fraudulent Pon
ntly acquired through fraudulent Ponzi schemes described herein and without disclosure of the Epstein Fraudulent Activities. 7. In or around 1997, Hoffenberg was convicted for a Ponzi scheme in connection with securities frauds committed at TFC (the "TFC Ponzi Fraud"), which resulted in approximately fiv
and Bondholders of Towers Financial Corporation, Plaintiff, v. Jeffrey E. Epstein, individually, and as President and Chief Executive Officer of The Financial Trust Company, The Financial Trust Company, XYZ Corp. and ABC, Inc. Defendant. X Index No. RELATED ACTIONS: Case No. 94 CR 213 (RWS) Case No. 95 CR 213 (RW
°1[49] In the mid- 19805, Epstein traveled multiple times between the United States, Europe, and Southwest Asia.(5°1[50 While in London, Epstein met Steven Hoffenberg. They had been introduced through Douglas Leese, a defense contractor, and John Mitchell, the former U.S. Attorney General.Ll°1 Towers Financial Co
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 turned out to be an unsuccessful bid to take over Pan American World Airways in 1987. A similar unsuccessful bid in 1988,was
s at his New York City home, as well as helping aspiring models get work with the company.r§p1F611 In 1996, Epstein changed the name of his firm to the Financial Trust Company[321 and, for tax advantages, based it on the island of St. Thomas in the U.S. Virgin Islands. By relocating to the U.S. Virgin Islands, Epstein was ab
al Trust Co appears to be a hedge fund that JE ran Lawsuit alleged that :PE and FTC received funds from a Ponzi scheme dating to the 1980s for which Steven Hoffenberg was convicted in 1997 No mention of DB that I can see The lawsuit is a quick read with some interesting history (whether accurate or not) Will lo
Ponzi scheme dating to the 1980s for which Steven Hoffenberg was convicted in 1997 No mention of DB that I c
n: Confidential FW: Epstein - negative media [CI Original lawsuit linked below. Subsequent dismissal (dated within weeks of the lawsuit) attached. Financial Trust Co appears to be a hedge fund that JE ran Lawsuit alleged that :PE and FTC received funds from a Ponzi scheme dating to the 1980s for which Steven Hoff
sult of Defendants' conspiring and participation in a massive Ponzi scheme perpetrated by Defendant Jeffrey Epstein, an uncharged co-conspirator of Steven Hoffenberg ("Hoffenberg"). Epstein used The Financial Trust Company, XYZ Corp., and ABC, Inc. to conceal his ill-gotten gains, obtained from his participation
y Epstein, an uncharged co-conspirator of Steven Hoffenberg ("Hoffenberg"). Epstein used The Financial Trust
COURT SOUTHERN DISTRICT OF NEW YORK MARVIN GERBER AND KALMA KOENIG, on behalf of themselves and all others similarly situated, Plaintiffs, v. THE FINANCIAL TRUST COMPANY, XYZ CORPORATION, ABC, INC., and JEFFREY E. EPSTEIN, Defendants. Case No. INITIAL COMPLAINT ECF CASE Marvin Gerber and Kalma Koenig (collectiv
the "Defendant Entities." 15. Non-Party Affiant Steven Hoffenberg ("Hoffenberg") was the Chief Executive Officer o
fendant Entities." 15. Non-Party Affiant Steven Hoffenberg ("Hoffenberg") was the Chief Executive Officer o
Case 1:18-cv-07580 Document 1 Filed 08/20/18 Page 4 of 26 York, New York 10021. 12. Defendant The Financial Trust Company ("TFTC") is a hedge fund formed under the laws of St. Thomas in the U.S. Virgin Islands in 1996. Defendant TFTC was created, incorporated, owned, a
ial Trust Co appears to be a hedge fund that JE ran Lawsuit alleged that JE and FTC received funds from a Ponzi scheme dating to the 1980s for which Steven Hoffenberg was convicted in 1997 No mention of DB that I can see The lawsuit is a quick read with some interesting history (whether accurate or not) Will lo
Ponzi scheme dating to the 1980s for which Steven Hoffenberg was convicted in 1997 No mention of DB that I c
negative media [C] Classification: Confidential Original lawsuit linked below. Subsequent dismissal (dated within weeks of the lawsuit) attached. Financial Trust Co appears to be a hedge fund that JE ran Lawsuit alleged that JE and FTC received funds from a Ponzi scheme dating to the 1980s for which Steven Hoffe
Entities connected to both Steven Hoffenberg and Financial Trust Company

Jeffrey Epstein
PERSONDarren Indyke
PERSON
JPMorgan Chase
ORGANIZATION
Les Wexner
PERSON
U.S. Virgin Islands
LOCATION
Ghislaine Maxwell
PERSON
Bear Stearns
ORGANIZATION
Richard Kahn
PERSON
John Brennan
PERSON
Prince Andrew
PERSON
Alan Dershowitz
PERSONJ. Epstein & Co.
ORGANIZATIONHarry Beller
PERSONLeon Black
PERSON
Bill Clinton
PERSONSouthern Trust Company
ORGANIZATION
Marc Rich
PERSON
Mort Zuckerman
PERSON
Martha Stewart
PERSON
FedEx
ORGANIZATION