EFTA00612518Set 9
39p8,650w
Plaintiff,
vs. )
91r4024
STEPHEN HOFFENBERG,
MITCHELL BRATER, CHARLES H. )
)
CHUGERMAN, MICHAEL ROSOFF, )
TOWERS FINANCIAL CORPORATION,
and TOWERS DIVERSIFIED )
)
COMPANY,
MAeISTRATE JUDGEL4113KOYIURY DEMANDED
Defendants. )
COMPLAINT
Plaintiff, JAMES W. SCHACHT, Acti ... Defendants, Stephen Hoffenberg
("Hoffenberg"), Mitchell Brater ("Br
ater"), Charles Chugerman
("Chugerman"), Michael Rosoff ("Rosoff
"), Towers Financial Cor-
poration ("Towers Financial") and
Towers Diversified Company
("Towers Diversified"), as foll ... 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
https://www.justice.gov/epstein/files/DataSet%209/EFTA00612518.pdf
EFTA00809690Set 9
2018-08-2251p13,224w
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 ... Northern District of Illinois on various fraud charges.
s See In re Towers Financial Corpora►ion, et at. Case No. 93-841558 (PBA) (S.D.NY. Dec. 8,
1994).
II
EFTA00809701
Case ... connection with the TFC Ponzi Scheme:
:89-cv-0 1689-R0 Foti v. Towers Financial Corp. filed 03/13/89 closed 01/04/90
92-a-08998-SS United Air Fleet v. lioffenberg
https://www.justice.gov/epstein/files/DataSet%209/EFTA00809690.pdf
EFTA00811809Set 9
2018-08-2251p13,267w
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 ... Northern District of Illinois on various fraud charges.
s See In re Towers Financial Corporation, et. al. Case No. 93-B41558 (PBA) (S.D.NY. Dec. 8,
1994).
11
EFTA00811820
Case ... connection with the TFC Pont Scheme:
1:89-cv-0 1689-R0 Foti v. Towers Financial Corp. filed 03/13/89 closed 01/04/90
I :92-cv-08998-SS United Air Fleet
https://www.justice.gov/epstein/files/DataSet%209/EFTA00811809.pdf
EFTA01433867Set 10
2018-08-2029p7,744w
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 ... indicted
in the Northern District of Illinois on various fraud charges.
See In re Towers Financial Corporation, et. al. Case No. 93-641558 (PBA)
(S.D.NY ... connection with the TFC Ponzi Scheme:
1:89-cv-0 1689-R0
Foti v. Towers Financial Corp
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01433867.pdf
EFTA00804506Set 9
1997-03-0420p4,984w
Marques and , individually, and as Index No.
representatives of the Noteholders and
Bondholders of Towers Financial Corporation, RELATED ACTIONS:
Case No. 94 CR 213 (RWS)
Plaintiff, Case ... 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 ... 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
https://www.justice.gov/epstein/files/DataSet%209/EFTA00804506.pdf
EFTA00796015Set 9
2018-08-2126p7,735w
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 ... indicted
in the Northern District of Illinois on various fraud charges.
See In re Towers Financial Corporation, et. at. Case No. 93-B4I558 (PBA) (S.D.NY. Dec. 8,
1994).
11
EFTA00796025 ... connection with the TFC Ponzi Scheme:
I:89-cv-0 1689-R0 Foil v. Towers Financial Corp. filed 03/13/89 closed 01/04/90
I :92-cv-08998-SS United Air Fleet
https://www.justice.gov/epstein/files/DataSet%209/EFTA00796015.pdf
EFTA01120694Set 9
1995-04-2011p8,362w
financial statements accurately reflected *5 Between July 1990 and May 1992, Towers sold
Towers' financial condition. approximately $210 million in bonds through the five
THRFC funds. The offering documents touted ... request for accounting records supporting
each of the Bond Funds were properly collateralized by Towers' financial statements, in or about May 1992,
accounts receivable. Since Hoffenberg was using monies Hoffenberg
https://www.justice.gov/epstein/files/DataSet%209/EFTA01120694.pdf
EFTA01120705Set 9
1995-04-2011p8,362w
financial statements accurately reflected *5 Between July 1990 and May 1992, Towers sold
Towers' financial condition. approximately $210 million in bonds through the five
THRFC funds. The offering documents touted ... request for accounting records supporting
each of the Bond Funds were properly collateralized by Towers' financial statements, in or about May 1992,
accounts receivable. Since Hoffenberg was using monies Hoffenberg
https://www.justice.gov/epstein/files/DataSet%209/EFTA01120705.pdf
EFTA00795983Set 9
2018-08-2116p3,378w
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 ... have a certified public accountant falsely certify that the
financial statements accurately ;reflected Towers' financial
condition.
Only a small fraction of the proceeds from the sale of
the Notes were ... soundness of Towers; the Bond
sales were promoted by the figures in the fraudulent Towers
financial statements. The offering documents described Towers and
its subsidiaries as having:engaged in either
https://www.justice.gov/epstein/files/DataSet%209/EFTA00795983.pdf
EFTA00263107Set 9
2019-08-1024p12,915w
Jeffrey Epstein - Wikipedia
Teaching Ghislaine Maxwell
Banking (late 1980s and
Financial consulting 1990s)
Towers Financial Corporation Details
Financial management firm 36111
Victims
Media activities
Date July 6, 2019
Liquid Funding ... Douglas Leese, a defense contractor, and John Mitchell, the former U.S. Attorney General.Ll°1
Towers Financial Corporation
Steven Hoffenberg hired Epstein in 19872 as a consultant for Towers Financial Corporation ... 2o21).E3LA
Hoffenberg and Epstein then refashioned themselves as corporate raiders using Towers Financial
as their raiding vessel. One of Epstein's first assignments for Hoffenberg was to implement what
https://www.justice.gov/epstein/files/DataSet%209/EFTA00263107.pdf
EFTA00618271Set 9
2013-12-1812p3,493w
COUNTRY OF CAPE VERDE,
BANKS, CORPORATE EMPLOYEE PENSIONS
UNIONS, CHURCHES, AND INDIVIDUAL
INVESTORS IN TOWERS FINANCIAL CORP. Affidavit
WHO ARE THE BENEFICIARIES OF STEVEN
HOFFENBERG'S JUDGE SWEET ORDERED ... fact that our firm has been
engaged by the perpetrator of the Towers Financial fraud, Mr. Hoffenberg, following his release
from incarceration on October 11, 2013 and (B) the retention ... firm by Mr. Rey Marques,
one of the victims of the Towers Financial fraud.
5. We, respectfully, would like to offer more facts to explain why we do not believe
https://www.justice.gov/epstein/files/DataSet%209/EFTA00618271.pdf
EFTA00802452Set 9
1997-03-0425p6,896w
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 ... hired by us to work on the securities side of the
insurance companies and Towers Financial, supposedly to make a profit
for us and for the companies,' Hoffenberg reportedly told ... beyond stating, in merely conclusory terms, that Defendant Epstein made
fraudulent statements and concealed Towers' financial status. The absence of such allegations
falls short not only of the heightened pleading
https://www.justice.gov/epstein/files/DataSet%209/EFTA00802452.pdf
EFTA00263640Set 9
2019-08-1012p6,047w
Douglas Leese, a defense contractor, and John Mitchell, the former U.S. Attorney General.(321
Towers Financial Corporation
Steven Hoffenberg hired Epstein in 1987, as a consultant for Towers Financial Corporation ... Hoffenberg and Epstein then refashioned themselves as corporate raiders using Towers Financial
as their raiding vessel. One of Epstein's first assignments for Hoffenberg was to implement what
tuned ... Epstein worked closely together and traveled everywhere on Hoffenberg's private
jetig•
In 1993, Towers Financial Corporation imploded when it was revealed as being one of the biggest
Ponzi schemes
https://www.justice.gov/epstein/files/DataSet%209/EFTA00263640.pdf
EFTA00261828Set 9
2022-06-1570p22,085w
Douglas Leese, a defense contractor, and John Mitchell, the former U.S. Attorney Genera1.13°1
Towers Financial Corporation
Steven Hoffenberg hired Epstein in 1987z. as a consultant for Towers Financial Corporation ... equivalen
2021)53°1
Hoffenberg and Epstein then refashioned themselves as corporate raiders using Towers Financial
as their raiding vessel. One of Epstein's first assignments for Hoffenberg ... worked closely together and traveled everywhere on Hoffenberg's
jet Lao)
biggest
In 1993, Towers Financial Corporation imploded when it was revealed as being one of the
US$45o million
https://www.justice.gov/epstein/files/DataSet%209/EFTA00261828.pdf
EFTA00583735Set 9
2014-08-253p1,120w
familiar to you, he was convicted in the
1990s for perpetrating the Towers Financial Ponzi scheme. Mr. Hoffenberg was sentenced to 20
years in prison, and ordered to pay almost ... 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 ... enjoining vexatious and frivolous litigation, enjoined Mr. Hoffenberg from further litigation
pertaining to the Towers Financial case without leave of the court. Hoffenberg v. Hoffman &
Pollok, 288 F. Supp
https://www.justice.gov/epstein/files/DataSet%209/EFTA00583735.pdf
EFTA00592320Set 9
2013-12-0536p9,111w
With regard to the employment, what counsel apparently
24 is referring to is Towers Financial.
25 THE COURT: Is what?
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
EFTA00592344
Case ... Document 150 Filed 01/08/14 Page 26 of 36 26
Dc5Whofl
MR. RAISE: Towers Financial. There is no such thing
as Towers Financial now. I mean, Mr. Hoffenberg is devoting
https://www.justice.gov/epstein/files/DataSet%209/EFTA00592320.pdf
EFTA00593790Set 9
2016-05-274p1,144w
STEVEN JUDE HOFFENBERG, INDIVIDUALLY, AND AS CONSTRUCTIVE
TRUSTEE OF THE NOTEHOLDERS AND BONDHOLDERS OF TOWERS
FINANCIAL CORPORATION, PLAINTIFFS, AGAINST JEFFREY E. EPSTEIN,
INDIVIDUALLY, AND AS PRESIDENT AND CHIEF EXECUTIVE OFFICER ... Jude Hoffenberg
("Hoffenberg"), individually, and as Constructive Trustee of the Noteholders and Bondholders
of Towers Financial Corporation (collectively, "Plaintiffs"), on the one hand, against Jeffrey E.
Epstein ("Epstein"), individually ... Defendants' alleged role in a "Ponzi" scheme in which the bondholders
and noteholders of Towers Financial Corporation ("Towers") were defrauded.
As a matter of background, until April 1993, Hoffenberg
https://www.justice.gov/epstein/files/DataSet%209/EFTA00593790.pdf
EFTA01405372Set 10
2013-08-1448p11,551w
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 ... hired by us to
work on the
securities side of the insurance companies and Towers Financial, supposedly
to make a
profit for us and for the companies," Hoffenberg reportedly told ... said he can't remember the details
and has
disputed the accuracy of the Towers financial reports.)
Around the same time, Nederlander and Toboroff let Epstein come in with them
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01405372.pdf
EFTA00612557Set 9
2013-12-0536p8,854w
With regard to the employment, what counsel apparently
24 is referring to is Towers Financial.
25 THE COURT: Is what?
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
EFTA00612581
26
Dc5Whof1 ... BAISE: Towers Financial. There is no such thing
2 as Towers Financial now. I mean, Mr. Hoffenberg is devoting
3 his time and effort, as I understand it from
https://www.justice.gov/epstein/files/DataSet%209/EFTA00612557.pdf