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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016 Complaint contained no statements sworn under penalties of perjury and was ultimately withdrawn with prejudice by then-Plaintiff Hoffenberg.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
fendant Entities were Hoffenberg's co- conspirators. 59. As per the Sentencing Opinion, Hoffenberg and his co-conspirators (i) used certain of the Associated and United's bonds as collateral in securities brokerage accounts in order to purchase stock of Pan Am and Emery; (ii) created false documents and f
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
nited Diversified acted as a holding company whose principal business activities were conducted through and for its insurance subsidiaries, namely; Associated and United Fire. 3. At all relevant times Associated was a domestic stock legal reserve insurance company organized under the laws of the State o
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
additional $1 million at a later date. In approximately November 1967, Hoffenberg and his co- lt" nn't !Lt 4ein ) conspirator's used certain of the Associated and United Fire bonds as collateral in securities brokerage accounts in order to purchase stock of Pan American Airways, Inc. ("Pan Am"). When thi
t Citibank once sued him for defaulting on a $20 million loan. The article suggested that one of his business mentors and previous employers was Steven Hoffenberg, now serving a prison term after "bilking investors out of more than $450 million in one of the largest Ponzi schemes in American histo- ry?" •
ment URL: EFTA00188389 HOTSHOT EPSTEIN NOT SO HOT: VF PAUL THARP. New York Post. New York, N.Y.: Feb 4, 2003. pg. 036 People: Epstein, Jeffrey, Hoffenberg, Steve Section: Business Text Word Count 249 Document URL: r. 41)stract 02pp:taw; turupary) "...SP4-4trw [Jeffrey Epstein], a 50-year-old Ral
THE PALM BEACH POST • THURSDAY, OCTOBER 18, 2007 Milian sues billionaire investor, /says they had sex when she was 16 The Associated hers NEW YORK — A billionaire investor, already facing jail in Palm Beach County on charges of soliciting under- age prostitutes, is being sued
ch 7, 1997, for his role in the TFC Ponzi Scheme, Hoffenberg was sentenced to twenty years' in prison, a term
efendant Entities were Hoffenberg's co- conspirators. 59. As per the Sentencing Opinion, Hoffenberg and his co-conspirators (i)used certain of the Associated and United's bonds as collateral in securities brokerage accounts in order to purchase stock of Pan Am and Emery; (ii) created false documents and f
Entities connected to both Steven Hoffenberg and Associated

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
Bill Clinton
PERSON
Marc Rich
PERSON
Donald Trump
PERSONLeon Black
PERSON
Vicky Ward
PERSON
Alan Dershowitz
PERSON
New York
LOCATION
Bradley Edwards
PERSON
Martha Stewart
PERSON
Department of Justice
ORGANIZATION
Bear Stearns
ORGANIZATION
New York City
LOCATION
George W. Bush
PERSON
Alfredo Rodriguez
PERSON
United States
LOCATION
Barry Diller
PERSONJane Doe
PERSON