Confidential Attorney-Client Privileged Communication and Work Product. Please do not forward except as set forth below. CONTINUED LITIGATION HOLD / PRESERVATION NOTICE FROM: ATTORNEYS DARREN K. INDYICE AND BENNET J. MOSKOWITZ TO: MATTER: 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 OF THE FINANCIAL TRUST COMPANY, THE FINANCIAL TRUST COMPANY, XYZ CORP., AND ABC, INC., DEFENDANTS, INDEX NO. 1:16- cv-03989-RJS (S.D.N.Y.) **NOTE: YOU MUST COMPLETE THE WRITTEN ACKNOWLEDGEMENT ATTACHED TO THIS NOTICE Confidential Attorney-Client Privileged Communication and Work Product. Please do not forward except as set forth below. This Continued Litigation Hold/Preservation Notice is issued to 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 (collectively, "Plaintiffs"), on the one hand, against Jeffrey E. Epstein ("Epstein"), individually, and as President and Chief Executive Officer of The Financial Trust Company ("FTC"), FTC, XYZ Corp., and ABC, Inc. (collectively, "Defendants"), on the other hand, concerning 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 was the CEO, President and Chairman of the Board of Towers. In 1997, U.S. District Court Judge Robert W. Sweet sentenced Hoffenberg to a 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 Ponzi scheme. On May 27, 2016,