25-WK General Retirement. el al v. Hoffenberg. et al I:94-cv-00814-WK Incl. et al v. Hoffenberg. et al 1:94-ev-02727-WK Amer. Intl Lines, dal v. Tow= Financial, is al filed 04/14/94 1:94-cv-09344-WK-AN Sheridan. et al v. Hoffenberg. et al filed 12/29/94 I:96-cv-04656-MGC Cohen, et al v. Hoffenberg, et al

Tenberg. el al filed 03/15/94 I:90-cv-00056-LBS Sahlim & Assac. v. Towers Financial Cor filed 01/04/90 I:88-cv-09178-RWS Associated Dry Goods 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 Fi

PLC Merck & Co Inc. Monsanto Co. Morgan Stanley NBCUniversal Inc. NFL Enterprises LLC National Basketball Association Nestle Oakland Raiders Ocwen Financial Corporation PHH Corporation Panasonic Corporation PepsiCo Inc. Petrobras Pfizer Inc. PhRMA Platinum Partners LP Prime Inc. Robert Half International Inc

ntle Barks and Nato' al Bondi Check cashing businete .• O kkin-bank Fintrod Intiptons (Clurrenci Ent-Wipe. Foreign Exchange 0 Operating acocunts tor Financial are Non-Bank Maim re CO not and Canes) ware the approrar 0? Fattiants BSA Coma:war DePasenent. In to •• Nee0 a Meet Vann to .stmt on colt Pany let

William W. Wiles, Secretary of the Board Dear Mr. Mannion: This is in reference to the Board's Order of July 24, 1990, approving the application of Avantor Financial Corporation, Norfolk, Virginia ("Applicant") to become a bank holding company by acquiring The Citizens and Southern Corporation, Atlanta, Georgia ("C&S"), and

lamest Ponzi schemes in American history. When Epstein met HotTenberg in Lon- don in the 1980s. the latter was the char- ismatic, audacious head of the Towers Financial Corporation. a collection agency that was supposed to buy debts that peo- ple owed to hospitals. banks. and phone companies. But Hoffenberg began using compan

he largest Ponzi schemes in American history. When Epstein met Hoffenberg in London in the 1980s, the latter was the charismatic, audacious head of the Towers Financial Corporation, a collection agency that was supposed to buy debts that people owed to hospitals, banks, and phone companies. But Hoffenberg began using company f

argest Ponzi schemes in American history. When Epstein met Hoffenberg in Lon- don in the 1980s. the latter was the char- ismatic. audacious head of the Towers Financial Corporation. a collection agency that was supposed to buy debts that peo- ple owed to hospitals. banks. and phone companies. But HolTenberg began using compan

dealings in the Ward House at 457 Madison Avenue.1231 Steven Hoffenbe originally set up the offices for Epstein in 1987 when he was consulting for Tower Financial. ni Epstein used these offices until at least 2003. Around this time, Michael Wolff saw the financier in his office, which in the past were the offi

t!Steven Hoffenberg. They had been introduced through Douglas Leese, a defense contractor, and John Mitchell, the former U.S. Attorney General.(321 Towers Financial Corporation Epstein in 1980 Steven Hoffenberg hired Epstein in 1987, as a consultant for Towers Financial Corporation (unaffiliated with the company of the same name f

ealings in the Ward House at 457 Madison Avenue.l9~1 Steven Hoffenberg originally set up the offices for Epstein in 1987 when he was consulting for Tower Financial. IA Epstein used these offices until at least 2003. Around this time, Michael Wolff saw the financier in his office, which in the past were the offi

TION VICTIMS IN PENSION FUNDS, MUTUAL FUNDS, THE COUNTRY OF CAPE VERDE, CORPORATE EMPLOYEE PENSION UNIONS, CHURCHES, AND INDIVIDUAL INVESTORS IN TOWERS FINANCIAL CORP. WHO ARE THE BENEFICIARIES OF STEVEN HOFFENBERG'S JUDGE SWEET ORDERED $475 MILLION RESTITUTION THAT IS NOW UNDER TWO BILLION DOLLARS PLUS ACCRUED

, we believe that it is necessary to evaluate the long history between Mr. Jeffrey E. Epstein and Mr. Steven J. HofTenberg and their involvement in Towers Financial Corporations' ("TFC") Ponzi fraud, which includes many fraudulent securities offerings of promissory notes and bonds by TFC, (the Page 1 of 3 EFTA00592314 Cas

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 controlling interest in United Diversified Corporation ("UDC"), which conducted business through its subsid

inated in 1997 when Judge Sweet sentenced Hoffenberg to a 20-year prison sentence and ordered him to pay $475,157,340 in restitution to investors in Towers Financial Corporation ("Towers").1 Plaintiffs' claims here, which allege fraud against Defendants because of their alleged role in Hoffenberg's decades-old scheme, are un

and ABC, Inc., as follows: PARTIES 1. Mr. Marques and Mr. are residents of and , respectively, and were investors and/or noteholders in Towers Financial Corporation, ("TFC") a dissolved Nevada corporation which had its principal place of business in New York, NY at all relevant times during which Steven Hoffenbe

on to recover damages on behalf of Plaintiffs and members of the proposed class, defined below (the "Class"), who are Noteholders and Bondholders of Towers Financial Corporation ("TFC") for harm suffered as a result of Defendants' conspiring and participation in a massive Ponzi scheme perpetrated by Defendant Jeffrey Epstein

TION VICTIMS IN PENSION FUNDS, MUTUAL FUNDS, THE COUNTRY OF CAPE VERDE, CORPORATE EMPLOYEE PENSION UNIONS, CHURCHES, AND INDIVIDUAL INVESTORS IN TOWERS FINANCIAL CORP. WHO ARE THE BENEFICIARIES OF STEVEN HOFFENBERG'S JUDGE SWEET ORDERED $475 MILLION RESTITUTION THAT IS NOW UNDER TWO BILLION DOLLARS PLUS ACCRUED

aim For Breach Of Contract Against Towers Financial 136. In October 1987, the Companies entered into an oral contract with Towers Financial whereby the Towers Financial would -37- PP) WV Cr:II :)ii :in7_t7_112v EFTA00612554 use space in the premises usually occupied by the Companies in Des Plaines, Illinois as

TION VICTIMS IN PENSION FUNDS, MUTUAL FUNDS, THE COUNTRY OF CAPE VERDE, CORPORATE EMPLOYEE PENSION UNIONS, CHURCHES, AND INDIVIDUAL INVESTORS IN TOWERS FINANCIAL CORP. WHO ARE THE BENEFICIARIES OF STEVEN HOPFENBERG'S JUDGE SWEET ORDERED $475 MILLION RESTITUTION THAT IS NOW UNDER TWO BILLION DOLLARS PLUS ACCRUED

and that he was the "CEO" of "New York Post Publishing Inc." (Ex. A.) While he was incarcerated, Mr. Hoffenberg filed numerous lawsuits related to Towers Financial, and his prosecution, legal representation and sentence in connection with the same. He even unsuccessfully sought to recuse Judge Sweet, himself. T