UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X Ray Marques and , individually, and as representatives of the Noteholders and Bondholders of Towers Financial Corporation, Plaintiff, v. 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. Defendant. X Index No. RELATED ACTIONS: Case No. 94 CR 213 (RWS) Case No. 95 CR 213 (RWS) JUDGE ROBERT W. SWEET COMPLAINT Ray Marques 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 The Financial Trust Company, XYZ Corp., 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 Hoffenberg ("Hoffenberg") was an officer, director and controlled a majority of its stock. 2. Epstein, a co-conspirator in connection with the fraudulent Ponzi schemes described herein, is an individual with a residence at 9 East 71st Street, New York, New York EFTA00804506