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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016 Complaint contained no statements sworn under penalties of perjury and was ultimately withdrawn with prejudice by then-Plaintiff Hoffenberg.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
Corp.. et al filed 03/04/93 Siudmak, et al v. Towers Financial, et al filed 03/12/93 Bank Of Capc Verde v. TFC Funding Corp.. ca filed 03/17/93 Dinsmore v. Towers Financial, et al filed 06/30/93 Davis v. Hoffenbers, et al filed 02/01/94 Rothman v. Hoffenberg filed 02/04/94 General Rciircmcnt. et al v. liolTcnbcrg,
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
dmak, et al v. Towers Financial, et al 1:93-cv-01686-WK-KAR Bank Of Cape Verde v. TFC Funding Corp., et al 1:93-cv-04449-WK 1:94-cv-00619-WK-KAR Dinsmore v. Towers Financial, et al Davis v. Hoffenberg, et al 10 filed 03/13/89 closed 01/04/90 filed 12/14/92 filed 02/10/93 filed 02/11/93 filed 02/19/93 filed 02/23/9
urt of the Southern District of New York against Hoffenberg and TFC in connection with the TFC Ponzi Scheme:
v. Tossers Financial filed 12/28/88 Riviera v. Towers Financial, et al filed 02119/93 Siudinak, et al v. Towers Financial. et al filed 03/12/93 Dinsmore v. Towers Financial. et al filed 06/30/93 Superstock, Inc. v. Towers Fin. Corp.. et al filal 08/01/91 Murphy, et al v. Tun Financial Corp.. et al filed 02/18/93 Von
Entities connected to both Steven Hoffenberg and Dinsmore v. Towers Financial

Jeffrey Epstein
PERSON
George W. Bush
PERSONthe Southern District
LOCATIONTowers Financial
ORGANIZATION
Pan Am
ORGANIZATION
Emery
ORGANIZATION
Michael Cohen
PERSON
Financial Trust Company
ORGANIZATIONUnited Air Fleet
ORGANIZATION
Murphy
PERSONAssociated Life Insurance Co.
ORGANIZATIONRiviera
ORGANIZATIONHoffenberg, TFC
ORGANIZATIONVon Stange v.
PERSONal v. Twrs Financial Corp.
PERSONthe District Court of the Southern District
ORGANIZATIONTowers Financial Corp.
ORGANIZATIONSiudmak
ORGANIZATIONShawmut Bank
ORGANIZATIONSuperstock, Inc.
ORGANIZATION