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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016 Complaint contained no statements sworn under penalties of perjury and was ultimately withdrawn with prejudice by then-Plaintiff Hoffenberg.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
Filed 08/21/18 Page 1 of 16 Exhibit A EFTA00809717 Case 1:18-cv-07580-JPO Document 7-1 Filed 08/21/18 Page 2 of 16 at 5 STATES DISTRICT COURT RN DISTRICT OF NEW YORK STATES Or AMERICA, - against - £T£VEN EOFFENSERG Defendant. Sweet, D. J. HEItardEalig QPDilial 9 Cra,--213--Mar21 23--CX-9-321-D1WHI_ Defendan
indicted in the Northern District of Illinois on various fraud charges. s See In re Towers Financial Corpora►ion, et at. Case No. 93-841558 (PBA) (S.D.NY. Dec. 8, 1994). II EFTA00809701 Case 1:18•cv-07580-JPO Document 7 Filed 08/21/18 Page 12 of 26 52. The very next day, on April 20, 1994, Hoffen
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
EFTA00182828 Page 18 of 20 908 F.Supp. 1265 908 F.Supp. 1265 (Cite as: 908 F.Supp. 1265) Memorandum of Decision and Order, October 19, 1995 (E.D.N.Y.). In Brechner, a defendant subjec- ted to a similar truthfulness obligation was asked in a debriefing session whether or not he had received unrepo
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
allegedly defrauded back in the 1980's. See Chubb & Son, Inc. v. Kelleher, 92 CV 4484 (CBA), 95 CV 951 (CBA), 1998 U.S. Dist. LEXIS 22542, at *22 (E.D.N.Y. Feb. 26, 1998) (granting motion to dismiss based on statute of limitations in part because "plaintiffs [did] not allege[] any facts suggesting that
n benefit or for expenditures, totalling over $3 million, unrelatud to the insurance companies, :including tuition costs and credit cawd 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
3 Case 1:18-cv-07580-JPO Document 7-1 Filed 08/21/18 Page 2 of 16 STATES DISTRICT COURT RN DISTRICT OF NEW YORK STATES OF AMERICA, - against - STEVEN HOFFENSERG Defendant. sweet, D. J. araistnianallnlanti 2A-CL.-2131B2B1. Sal-Sx-.-32.1-111Wal Defendant Steven Hoffenberg ("Hoffenberg") pled guilty on April 2
d 08/21/18 Page 3 of 16 Tv U.S.C. § 3013, a special assessment of $250.00, $50.00 per count, is mandatory. The Offense Conduct Until April 1993, Hoffenberg was the chief executive officer, president and chairman of the board of Towers Financial Corporation ("Towers"). In 1987, Towers acquired a contro
nt 7-1 Filed 08/21/18 Page 1 of 16 Exhibit A EFTA00795983 Case 1:18-cv-07580-JPO Document 7-1 Filed 08/21/18 Page 2 of 16 STATES DISTRICT COURT RN DISTRICT OF NEW YORK STATES OF AMERICA, - against - STEVEN HOFFENSERG Defendant. sweet, D. J. araistnianallnlanti 2A-CL.-2131B2B1. Sal-Sx-.-32.1-111Wal Defendant Stev
H, FL 33401 137. Address Currently Unknown 138. Steven Hoffenberg Address Currently Unknown 139. Michael Stroll
3401 137. Address Currently Unknown 138. Steven Hoffenberg Address Currently Unknown 139. Michael Stroll
6. Records Custodian of Palm Beach Police Department 345 South County Road Palm Beach, FL 33480 17. Records Custodian of United States Attorney's Office for the Southern District of Florida 18. Records Custodian of the Federal Bureau of Investigations 19. Spencer Kuvin, Esquire 1800 S. Australian Avenue, #400 West Palm B
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
or girls experienced horrible sexual abuse and rape in Florida. But then Epstein was given a slap-on- the-wrist deal in 2008 from the U.S. Attorney's Office for the Southern District of Florida and some of his co- conspirators were shielded from prosecution. To make matters even worse, that deal seems to have been the product of
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
or girls experienced horrible sexual abuse and rape in Florida. But then Epstein was given a slap-on- the-wrist deal in 2008 from the U.S. Attorney's Office for the Southern District of Florida and some of his co- conspirators were shielded from prosecution. To make matters even worse, that deal seems to have been the product of
-cv -7433 (5 .D.N.Y), ECF No. 496 (Nov. Z 2016); Hoffenberg v. Epstein et al, No. 1:16 -cv-3989 (S.D.N.Y.) D
Request ACTIVE All records regarding, concerning or relating to a deceased individual named Jeffrey Edward Epstein maintained by the US Attorney's Office for the Southern District of New York and/or the US Attorney's Office for the Southern District of Florida. Mr. Epstein was born on January 20, 1953 and died on or about August 10,2019.
death. As Jeffrey Epstein is now deceased, any privacy concerns are extinguished. 1. Any and all records from the from the United States Attorney's Office for the Southern District of New York relating to: a. Jeffrey Epstein (DOB: 01/20/53); b. Ghislaine Maxwell DOB: 12/25/61 ; c. . Mark E stein; Page 8 EFTA00091023 in.
A former business partner of Epstein's, Steven Hoffenberg, even explained how Epstein assisted him in runni
30 219. Media reports also appeared about Epstein's prior SEC violations in his job at Bear Stearns arose. A former business partner of Epstein's, Steven Hoffenberg, even explained how Epstein assisted him in running a massive Ponzi scheme that landed Hoffenberg in prison. JP Morgan was aware of these and other
anently labeled a "Registered Sex Offender," and was jailed in 2008. Epstein also entered into a non-prosecution agreement with the U.S. Attorney's Office for the Southern District of Florida barring his prosecution (and prosecution of his known and unknown co-conspirators) for violations of the TVPA and other sex offenses in
investors and SEC filings. Further, Epstein and Hoffenberg created phony receivables, then included those i
s indicted in the Northern District of Illinois on various fraud charges. s See In re Towers Financial Corporation, a al. Case No. 93-B41558 (PBA) (S.D.NY. Dec. 8, 1994). II CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0088595 CONFIDENTIAL SDNY GM_00234779 EFTA01386757
Entities connected to both Steven Hoffenberg and Southern District of New York

Jeffrey Epstein
PERSON
United States
LOCATIONthe Southern District
LOCATION
Ghislaine Maxwell
PERSON
Department of Justice
ORGANIZATION
Prince Andrew
PERSONFBI
ORGANIZATION
Bradley Edwards
PERSON
Alexander Acosta
PERSON
Kenneth Marra
PERSONLeon Black
PERSONJane Doe
PERSON
New York
LOCATIONJack Goldberger
PERSON
Bill Clinton
PERSON
Alan Dershowitz
PERSON
George W. Bush
PERSON
Donald Trump
PERSONSouthern District
LOCATION
Les Wexner
PERSON