EFTA00811809Set 9
2018-08-2251p13,267w
massive Ponzi scheme perpetrated by Defendant Jeffrey Epstein, an uncharged
co-conspirator of Steven Hoffenberg ("Hoffenberg"). Epstein used The Financial Trust Company,
XYZ Corp., and ABC, Inc. to conceal ... shall
hereinafter be collectively referred to as the "Defendant Entities."
15. Non-Party Affiant Steven Hoffenberg ("Hoffenberg") was the Chief Executive
Officer of TFC from 1975 through April ... Document 7-2
Filed 08/21/18 Page 2 of 8
AFFIDAVIT OF STEVEN J. HOFFENBE
RG
STATE OF NEW YORK
) ss.:
COUNTY OF NEW YORK
STEVEN J. HOFFENBERG, being duly sworn
https://www.justice.gov/epstein/files/DataSet%209/EFTA00811809.pdf
EFTA00809690Set 9
2018-08-2251p13,224w
massive Ponzi scheme perpetrated by Defendant Jeffrey Epstein, an uncharged
co-conspirator of Steven Hoffenberg ("Hoffenberg"). Epstein used The Financial Trust Company,
XYZ Corp., and ABC, Inc. to conceal ... shall
hereinafter be collectively referred to as the "Defendant Entities."
15. Non-Party Affiant Steven Hoffenberg ("Hoffenberg") was the Chief Executive
Officer of TFC from 1975 through April ... 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
https://www.justice.gov/epstein/files/DataSet%209/EFTA00809690.pdf
EFTA00796015Set 9
2018-08-2126p7,735w
massive Ponzi scheme perpetrated by Defendant Jeffrey Epstein, an uncharged
co-conspirator of Steven Hoffenberg ("Hoffenberg"). Epstein used The Financial Trust Company,
XYZ Corp., and ABC, Inc. to conceal ... shall
hereinafter be collectively referred to as the "Defendant Entities."
15. Non-Party Affiant Steven Hoffenberg ("Hoffenberg") was the Chief Executive
Officer of TFC from 1975 through April ... United States of America v. Steven Hoffenberg, 94 Cr. 213 (RWS), 95 Cr. 321 (RWS), 1997
U.S. Dist. LEXIS 2394 (S.D.N.Y. Mar. 4, 1997). Hoffenberg was convicted of conspiracy
https://www.justice.gov/epstein/files/DataSet%209/EFTA00796015.pdf
EFTA01433867Set 10
2018-08-2029p7,744w
massive Ponzi scheme perpetrated by Defendant Jeffrey
Epstein, an uncharged
co-conspirator of Steven Hoffenberg ("Hoffenberg"). Epstein used The
Financial Trust Company,
XYZ Corp., and ABC, Inc. to conceal ... shall
hereinafter be collectively referred to as the "Defendant Entities."
15.
Non-Party Affiant Steven Hoffenberg ("Hoffenberg") was the Chief Executive
Officer of TFC from 1975 through April ... United States of America v. Steven Hoffenberg, 94 Cr. 213 (RWS), 95 Cr.
321 (RWS), 1997
U.S. Dist. LEXIS 2394 (S.D.N.Y. Mar. 4, 1997). Hoffenberg was convicted of
conspiracy
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01433867.pdf
EFTA00804506Set 9
1997-03-0420p4,984w
place of business in
New York, NY at all relevant times during which Steven Hoffenberg ("Hoffenberg") was an
officer, director and controlled a majority of its stock.
2. Epstein ... Dist. LEXIS 2394
Mar. 4, 1997), in which the District Court convicted Steven Hoffenberg (hereinafter "Hoffenberg")
of conspiracy to violate securities laws by fraudulently selling securities in violation ... against Hoffenberg in Hoffenberg was
against "Hoffenberg and his co-conspirators" (emphasis added) as written throughout the
Sentencing Opinion. Hoffenberg's co-conspirators included Epstein.
20. TFC, Hoffenberg, Epstein
https://www.justice.gov/epstein/files/DataSet%209/EFTA00804506.pdf
EFTA01120694Set 9
1995-04-2011p8,362w
credit card bills for
Hoffenberg's stepdaughter; the payment of investment
*1 Defendant Steven Hoffenberg ("Hoffenberg") pled consultant fees for Towers; the purchase of Emery Air
guilty on April ... Government Works. 6
EFTA01120699
U.S. v. Hoffenberg, Not Reported In F.Supp. (1997)
probation and restitution. Hoffenberg's conviction arose
As to Hoffenberg's alleged physical impairment ... Steven Hoffenberg Associates, Consultants and During March and April of 1995, Hoffenberg was taking
Manufacturers Representatives. Between 1969 and 1971, homeopathic and herbal medication for his depression, as
Hoffenberg operated
https://www.justice.gov/epstein/files/DataSet%209/EFTA01120694.pdf
EFTA01120705Set 9
1995-04-2011p8,362w
credit card bills for
Hoffenberg's stepdaughter; the payment of investment
*1 Defendant Steven Hoffenberg ("Hoffenberg") pled consultant fees for Towers; the purchase of Emery Air
guilty on April ... Government Works. 6
EFTA01120710
U.S. v. Hoffenberg, Not Reported In F.Supp. (1997)
probation and restitution. Hoffenberg's conviction arose
As to Hoffenberg's alleged physical impairment ... Steven Hoffenberg Associates, Consultants and During March and April of 1995, Hoffenberg was taking
Manufacturers Representatives. Between 1969 and 1971, homeopathic and herbal medication for his depression, as
Hoffenberg operated
https://www.justice.gov/epstein/files/DataSet%209/EFTA01120705.pdf
EFTA00802452Set 9
1997-03-0425p6,896w
DRIVING THIS ACTION AGAINST SUCH FRIVOLOUS LAWSUITS
Judges Sweet, Berman and Castel warned Steven Hoffenberg ("Hoffenberg"), whom
Plaintiffs identify as the "Non-Party Affiant" (Compl. 15) and whose affidavit forms ... this action.
Nevertheless, Hoffenberg remains intent on shifting blame for his own massive Ponzi scheme.
Hoffenberg's scheme culminated in 1997 when Judge Sweet sentenced Hoffenberg to a 20-year ... resulted in Hoffenberg's conviction and which was imputed to Hoffenberg's co-
conspirators." (See Compl. 2, at fn. 2).
Plaintiffs' central, legally-erroneous argument is that Hoffenberg's affidavit
https://www.justice.gov/epstein/files/DataSet%209/EFTA00802452.pdf
EFTA00610321Set 9
2013-12-115p1,501w
COURT ELECTRONICALLY FILED
SOUTHERN DISTRICT OF NEW YORK
DOC #:
200,000 TOWERS INVESTORS DATE FILED: M - /1 - /3
RESTITUTION VICTIMS IN PENSION
FUNDS, MUTUAL FUNDS, THE COUNTRY
OF CAPE VERDE ... 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 ... annexes a
November 8, 2013 memo from Hewitson to the "Steven Hoffenberg File" with the boldface label "Attorney Work
Product," in which Hewitson recounts her efforts to attend
https://www.justice.gov/epstein/files/DataSet%209/EFTA00610321.pdf
EFTA00800143Set 9
2003-03-013p489w
Hoffenberg, No. 94-
cr-213-RWS [Doc. 150], is attached hereto as Exhibit E.
7. A copy of a Memorandum and Order filed on December ... Verified Petition to Perpetrate Testimony dated June 11, 2015 and filed
in U.S. v. Steven J. Hoffenberg, 94-CR-213-RWS, is attached hereto as Exhibit I.
II. A copy ... Complaint filed on May 27, 2016 in Steven Jude Hoffenberg v. Jeffrey
E. Epstein, et aL, No. 1:16-cv-03989, is attached hereto as Exhibit J.
36343433v1
EFTA00800144
DRAFT
https://www.justice.gov/epstein/files/DataSet%209/EFTA00800143.pdf
EFTA00618266Set 9
2013-12-115p1,540w
CRIME
VICTIMS ACT,
Respondent.
--x
CASTEL, District Judge:
Two hundred thousand victims of Steven Hoffenberg's criminal fraud scheme
relating to Towers Financial Corporation, purportedly represented by Alan P. Fraade ... Hoffenberg," and acting
as "Hoffenberg's 'house counsel' at Towers." United States v. Hoffenberg, 908 F. Supp. 1265,
1273 (S.D.N.Y. 1995). Indeed, the petition describes Mintz & Fraade as "Mr. Hoffenberg ... annexes a
November 8, 2013 memo from Hewitson to the "Steven Hoffenberg File" with the boldface label "Attorney Work
Product," in which Hewitson recounts her efforts to attend
https://www.justice.gov/epstein/files/DataSet%209/EFTA00618266.pdf
EFTA00795983Set 9
2018-08-2116p3,378w
STEVEN HOFFENSERG
Defendant.
sweet, D. J.
pled guilty on
Defendant Steven Hoffenberg ("Hoffenberg")
violate the
April 20, 1995, to five counts: (i) conspiracy to
securities laws by fraudulently selling securities ... followed by three
years of supervised release.
-1Por the reasons set forth below, Hoffenberg Will be
sentenced to serve a term of imprisonment of 240
months, followed
by three ... Pursuant to 18
3.
EFTA00795984
Case 1:18-cv-07580-JPO Document 7-1 Filed 08/21/18 Page 3 of 16
Tv
U.S.C. § 3013, a special assessment
https://www.justice.gov/epstein/files/DataSet%209/EFTA00795983.pdf
EFTA00593790Set 9
2016-05-274p1,144w
memorialize your document
preservation obligations in connection with a lawsuit commenced by Steven Jude Hoffenberg
("Hoffenberg"), individually, and as Constructive Trustee of the Noteholders and Bondholders
of Towers Financial Corporation ... until April 1993, Hoffenberg was the CEO, President and Chairman
of the Board of Towers. In 1997, U.S. District Court Judge Robert W. Sweet sentenced
Hoffenberg ... term of twenty years imprisonment and ordered that Hoffenberg pay
$475,157,340.00 in restitution following Hoffenberg's conviction for defrauding the bondholders
and noteholders of Towers through an extensive
https://www.justice.gov/epstein/files/DataSet%209/EFTA00593790.pdf
EFTA00270328Set 9
2019-01-102p577w
OBSTRUCTION OF JUSTICE Synopsis: EC requesting
Trenton RA to conduct interview of federal inmate, STEVEN HOFFENBERG,
regarding captioned investigation. Details: In October 2009, Miami
Division opened an obstruction of justice ... contacted STEVEN HOFFENBERG as a potential plaintiff's witness against
EPSTEIN. HOFFENBERG is a federal inmate at Fort Dix Federal
Correctional Institution (FCI), inmate number 35601-054. HOFFENBERG
(Overall Document ... review of ACS does not reflect HOFFENBERG offered
this information as a proffer during the 196C matter. It should be
noted that HOFFENBERG appears to have a history of mental
https://www.justice.gov/epstein/files/DataSet%209/EFTA00270328.pdf
EFTA00796003Set 9
2018-08-218p1,878w
Case 1:18-cv-07580-JPO Document 7-2 Filed 08/21/18 Page 2 of 8
AFFIDAVIT OF STEVEN 1 HOFFENBERG
STATE OF NEW YORK
) ss.:
COUNTY OF NEW YORK
STEVEN ... Illinois insurance company
EFTA00796004
Case 1:18-cv-07580-JPO Document 7-2 Filed 08/21/18 Page 3 of 8
subsidiaries, Associated Life Insurance Co. ("Associated") and United Fired Insurance ... lengthy investigation, the SEC filed suit against
me, TFC, and other TFC officials for securities fraud.
35. In or around March 1993, TFC filed for Chapter 11 bankruptcy protection
https://www.justice.gov/epstein/files/DataSet%209/EFTA00796003.pdf
EFTA00594948Set 9
2016-06-293p508w
Courthouse
40 Foley Square, Room 2104
New York, New York 10007
(SullivanNYSDChambers@nysd.uscourts.gov)
Re: Steven Jude Hoffenberg v. Jeffrey E.
Epstein, et al. (Index No. 1:16-cv-03989)
Dear Judge ... necessary to evaluate the long history between Mr. Jeffrey E. Epstein and Mr. Steven J.
Hoffenberg and their involvement in Towers Financial Corporations' ("TFC") Ponzi fraud,
which includes many fraudulent ... Firm, PC
13
Alan P. Fraade
APF/Ilk
Cc: Gary H. Baise, Esq.
Mr. Steven Hoffenberg
Bennet J. Moskowitz, Esq.
Page 3 of 3
EFTA00594950
https://www.justice.gov/epstein/files/DataSet%209/EFTA00594948.pdf
EFTA00263107Set 9
2019-08-1024p12,915w
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
(unaffiliated with ... take over Emery Air Freight Corp. During this period,
Hoffenberg and Epstein worked closely together and traveled everywhere on Hoffenberg's private
jet.1321
In 1993, Towers Financial Corporation imploded when ... rented offices for his business dealings in the Villard House at 457 Madison Avenue.19-31
Steven Hoffenberg originally set up the offices for Epstein in 1987 when he was consulting
https://www.justice.gov/epstein/files/DataSet%209/EFTA00263107.pdf
EFTA00592320Set 9
2013-12-0536p9,111w
Filed 01/08/14 Page 1 of 36
Dc5Whofl
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
x
UNITED STATES OF AMERICA,
4 v. 94 CR 213 (RWS)
5 STEVEN HOFFENBERG ... REPORTERS, P.C.
(212) 805-0300
EFTA00592320
Case 1:94-cr-00213-RWS Document 150 Filed 01/08/14 Page 2 of 36
Dc5Whofl
(Case called)
THE COURT: Please be seated.
MR. COOPER ... Honor, Gary Baise, Olsson Frank,
8 Washington, D.C., for Mr. Steven Hoffenberg. I'm accompanied
9 by Mr. Hoffenberg and counsel for Towers Investors and one of
10 the investors
https://www.justice.gov/epstein/files/DataSet%209/EFTA00592320.pdf