stors (Le., Plaintiffs in this action).? • 2016: Hoffenberg, represented by the same counsel who faced sanctions from Judge Castel, as well as by Gary H. Raise, who represents Plaintiffs in this latest baseless matter, filed a duplicative action in which Hoffenberg claimed money damages on behalf of victim

and as the Plaintiffs, individually, and as representatives of the Noteholders and Bondholders of Towers Financial Corporation, by their attorney, Gary H. Raise, Esq., bring this Complaint against the Defendants, Jeffrey E. Epstein ("Epstein"), individually, and as President and Chief Executive Officer of T