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016 Complaint contained no statements sworn under penalties of perjury and was ultimately withdrawn with prejudice by then-Plaintiff Hoffenberg.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

ev-00992-WK :93-cv-0 1543-WK 13-ev-04449-WK :91-c-v-05231-1.JF -93-a-00961-WIC :93-ev-0 1927-WK Foti v. Towers Financial Corp. filed 03/13/89 United Air Fleet v. lioffenberg, et al filed 12/14/92 Gold, et a! v. Towers Financial, et al filed 02/10/93 Field v. Twrs Financial Corp., al filed 02/11/93 Zie

poration, and as Liquidator of Associated Life Insurance Company and United Fire Insurance Company, 'by his attorneys, complains of Defendants, Stephen Hoffenberg ("Hoffenberg"), Mitchell Brater ("Brater"), Charles Chugerman ("Chugerman"), Michael Rosoff ("Rosoff"), Towers Financial Cor- poration ("Towers Fin

was Chairman of the Board of Directors of United Fire, Associated, Diversified, Towers Diversified and Towers Financial. On information and belief, Boffenberg, through an entity known as the "Hoffenberg Family Trust", at all relevant times owned 100% of Professional Business Broker's Inc., a New York cor

ued primarily for the benefit of Hoffenberg or the Controlling Companies and not for the benefit of the Companies. 41. Among the checks benefiting Roffenberg individually are checks payable to American Express for personal expenses and to Wellesley College for, upon information and belief, tuition for a

ited Fire and Diversified accounts as follows: COMPANY: Check 4 United Fire Insurance Company Payee. Date Amount 100111 11/06/87 $50,000.00 United Air Fleet 100110 11/13/87 25,000.00 Jeff Epstein 100108 11/20/87 25,000.00 Corporate Risk 100107 11/30/87 8,000.00 Mintz, Fraade & Sieger PC 1000

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

-WK 1 :93-cv-01047-WK 1 :93-cv-01094 -WK 1 :93-cv-01095-WK 1 :93-cv-01155-WK 1 :93-cv-01303-WK 1 :93-cv-01543-WK Foti v. Towers Financial Cor United Air Fleet v. Hoffenberg, et al Gold, et al v. Towers Financial, et al Field v. Twrs Financial Corp., et al Ziegler v. Twrs Financial Corp., et al l72O v. T

urt of the Southern District of New York against Hoffenberg and TFC in connection with the TFC Ponzi Scheme:

87-WK 1:93-cv-0 1045-WK I:93cv-01047-WK I:93-cv-01094-WK I:93-cv-0 1095-WK I :93-cv-01155-WK I:93-cv-0 1303-WK Foti v. Towers Financial Corp. United Air Fleet v. Hoffenberg. et al Gold. et a! v. Towers Financial. et al Field v. Tuts Financial Corp.. ell Ziegler v. T'.ws Financial Corp., et al lzzo v. To