Epstein Secrets

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016 Complaint contained no statements sworn under penalties of perjury and was ultimately withdrawn with prejudice by then-Plaintiff Hoffenberg.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

12 Filed 08/22/18 Page 1 of 1 AO 440 (Rev. 06/12) Sim /mons in a Civil Action UNITED STATES DISTRICT COURT for the Southern District of New York MARVIN GERBER AND KALMA KOENIG, on behalf of themselves and all others similarly situated, Plaines) v. fNE FINANCIAL TRUST COMPANY, XYZ CORPORATION, ABC, INC.

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

PRIVILEGED AND CONFIDENTIAL; ATTORNEY WORK PRODUCT UNITED STATES DISTRICT COURT SOUTHERN 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 CORPORAT

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

Case 1:18-cv-07580 Document 1 Filed 08/20/18 Page 1 of 26 UNITED STATES DISTRICT 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,