Epstein Secrets

erly be maintained as a class action pursuant to Rules 23(a) and 23(bX3) of the Federal Rules of Civil Procedure. This action is brought pursuant ' Hoffenberg's 2016 Complaint contained no statements sworn under penalties of perjury and was ultimately withdrawn with prejudice by then-Plaintiff Hoffenberg.

016 Complaint contained no statements sworn under penalties of perjury and was ultimately withdrawn with prejudice by then-Plaintiff Hoffenberg.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. Jeffrey £ Epstein, et. al., Case No. 16-03989 (RJS) (S.D.N.Y May 27, 2016). 15 CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-008859

his involvement in the TFC Ponzi Scheme and continues to wrongfully possess the funds to which Plaintiffs and the Class are entitled as victims of the TFC Ponzi Scheme. CLASS ACTION ALLEGATIONS 67. This action is brought and may properly be maintained as a class action pursuant to Rules 23(a) and 23(bX3) of the

ch 7, 1997, for his role in the TFC Ponzi Scheme, Hoffenberg was sentenced to twenty years' in prison, a term

aims of the TFC Noteholders and Bondholders, in the total amount of $475,157,340, were valid and actionable. 57. On March 7, 1997, for his role in the TFC Ponzi Scheme, Hoffenberg was sentenced to twenty years' in prison, a term of supervised release, as well as a one million dollar ($1,000,000) fine, approximatel

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

ited to, the cases listed below, were filed in the District Court of the Southern District of New York against Hoffenberg and TFC in connection with the TFC Ponzi Scheme: 1:89-ev-0 1689-12O I :92-cv-08998-SS 1:93-cv-00810-WK-AJP 1:93-cv-00855-WK-KAR 1: 93-cv-00987-WK 1:93-cv-0 1045-WK I:93cv-01047-WK I:93-cv-0

only in May 2016 that Hoffenberg provided the first insight to the public and authorities regarding Defendant Epstein's role, 54. As a result of Hoffenberg's refusal to implicate Defendant Epstein, Epstein was never indicted for his role in the TFC Ponzi Scheme. Epstein was never charged with any crime

ding Defendant Epstein's role, 54. As a result of Hoffenberg's refusal to implicate Defendant Epstein, Epstein was never indicted for his role in the TFC Ponzi Scheme. Epstein was never charged with any crime in connection with the TFC Ponzi Scheme. Rather, Epstein has been permitted to use the ill-gotten gains a