Epstein Data Wiki

Towers Financial Corporation

Properties2
tagsentity, new-york, nevada, illinois, fraud, ponzi-scheme, receivables, sdny, northern-district-of-illinois
aliasesTowers Financial, Towers Financial Corp., Towers, TFC (Towers Financial Corporation), Towers Diversified Company

41 min read

CompanyTowers Financial Corporation, described in the 1991 Illinois pleading as “a publicly held Nevada corporation with its principal place of business in New York, New York”1
BusinessPurchasing and collecting outstanding receivables, through subsidiaries including Towers Credit Corporation, Towers Collection Services Inc. and Towers HealthCare Receivables Funding Corporations I to V2
Chief executiveSteven J. Hoffenberg, by his own sworn account “from 1975 through April 1993”2; the 1997 sentencing opinion says he became chief executive, president and chairman in 19743
Illinois insurance armA controlling interest in United Diversified Corporation, acquired 1987, which held Associated Life Insurance Co. and United Fire Insurance Co.4
First institutional action recorded hereJuly 29, 1988, the Circuit Court of Cook County enters a Conservation Order over the three Illinois companies; Liquidation Orders follow on March 3, 19895
The 1991 suitSchacht v. Hoffenberg, Brater, Chugerman, Rosoff, Towers Financial Corporation and Towers Diversified Company, N.D. Ill. Eastern Division, No. 91 C 4024, complaint dated June 27, 1991 and stamped DOCKETED JUN 28 199167
Where Epstein appears in itAs a payee. Nine rows of the improper-disbursement table name “Jeff Epstein” or “Jeffrey Epstein”; the complaint pleads checks to “Jeff Epstein or Jeff Epstein & Co. totaling $215,000”8910
CollapseSEC action February 8, 199311; Chapter 11 in or around March 1993, sworn to by Hoffenberg12
SentenceMarch 7, 1997: 240 months, three years supervised release, a $1,000,000 fine and restitution of $475,157,340413
Later civil actions against EpsteinHoffenberg v. Epstein, No. 1:16-cv-03989 (S.D.N.Y.), filed May 27, 2016, withdrawn with prejudice July 1, 201614; Gerber and Koenig v. The Financial Trust Company, No. 1:18-cv-07580-JPO, filed August 20, 2018, voluntarily dismissed without prejudice October 5, 20181516
Status of every allegation belowPleaded, sworn or alleged. Nothing here is a finding against Jeffrey Epstein, who was never charged in connection with any of it17

Towers Financial Corporation was a New York receivables-collection business whose collapse produced a restitution order of $475,157,340 against its chief executive.4 Of the documents cited on this page, its 1991 paper trail is the earliest at which Jeffrey Epstein’s name appears beside a named institution’s account of financial wrongdoing. The record here has two very different halves. The first is a 1991 regulator’s pleading and a 1997 federal sentencing opinion, in which Epstein is not a party, is not charged, and in the sentencing opinion is not named at all. The second is a run of pleadings, letters and an affidavit filed between 2013 and 2018 by or on behalf of Steven Hoffenberg, in which Epstein is named as the architect of the fraud. The two halves are separated by more than twenty years, and they carry very different evidentiary weight.

This page treats the corporation as the subject and Hoffenberg as the person acting inside it, because the institutions that decided things about Towers were the Illinois Department of Insurance, the Circuit Court of Cook County, the United States District Courts for the Northern District of Illinois and the Southern District of New York, the Securities and Exchange Commission and the Bankruptcy Court. Hoffenberg appears here as the person acting inside the corporation. What this release holds about the man himself is chiefly a few lines of the 1997 sentencing opinion, which is not enough to carry a person page.3

What the 1991 Illinois complaint actually says

On June 27, 1991 James W. Schacht, Acting Director of Insurance of the State of Illinois, acting as Conservator of United Diversified Corporation and as Liquidator of Associated Life Insurance Company and United Fire Insurance Company, filed a complaint in the Northern District of Illinois against Stephen Hoffenberg, Mitchell Brater, Charles H. Chugerman, Michael Rosoff, Towers Financial Corporation and Towers Diversified Company.6 The caption spells the first defendant Stephen; the body of the same sheet does too.6 That spelling is rare in this release: a full-text search returns 2 pages for “Stephen Hoffenberg” against 303 for “Steven Hoffenberg”, and 874 for the surname alone.

The complaint recites the regulatory history. Orders of conservation and liquidation were entered by the Circuit Court of Cook County on July 29, 1988 and March 3, 1989.5 It pleads that Hoffenberg was at all relevant times chairman of the board of all five companies, and that through the “Hoffenberg Family Trust” he owned all of a New York corporation which owned 82.5 per cent of Towers Financial.1

Its central factual section is headed Improper Disbursements. Paragraph 38 pleads that, in violation of an Illinois regulation requiring “at least two” authorised signatures on cheques over $5,000, “Hoffenberg issued a series of checks, for which he was the only signator and provided no supporting documentation,” drawn on United Fire and United Diversified accounts.8 Two four-column tables follow, headed Check # · Date · Amount · Payee, one for each company, covering November 1987 to July 1988.

Nine rows of those tables name Epstein. Four appear on the United Fire table, each for $25,000, dated 11/13/87, 12/01/87, 01/05/88 and 02/01/88, all payable to “Jeff Epstein”.8 Five appear on the United Diversified table: 03/01/88 for $25,000, 03/02/88 for $20,000, 03/04/88 for $25,000, 04/06/88 for $20,000 and 05/03/88 for $25,000. Four of those five are payable to “Jeff Epstein”; the fifth, dated 03/04/88, is payable to “Jeffrey Epstein”.9 The nine rows total $215,000.

The complaint states that total itself. Paragraph 43 reads:

Other disbursements included a series of checks payable to Jeff Epstein or Jeff Epstein & Co. totaling $215,000. At different times Hoffenberg claimed that the expenditures were for broker’s fees on investment advice associated with an investment in the capital stock of Emery Air Freight (“Emery”). Within a period of shortly over six months the Companies lost approximately $2 million on the Emery investment.10

Two things about that paragraph are worth holding separately. The first is that it is the only place in this release where the string “Jeff Epstein & Co” occurs at all: a search of the full-text index for the phrase returned one page, this one.10 Whether the payee named there is the New York corporation covered at J. Epstein & Company, Inc., which a Dun & Bradstreet record gives as incorporated in New York on October 18, 1982 and a corporate-records extract gives as dissolved on a filing date of April 4, 2001,18 is not stated by any document cited here, and the two names are not the same string. The second is that paragraph 43 is a pleading. It is the Illinois Director’s allegation about what the cheques were for and what Hoffenberg said about them. It is not a finding, and the action it opened was settled: a later draft pleading states that the Insurance Lawsuit “was settled pursuant to a settlement agreement dated May 4, 1992,” and adds that “Epstein was not named as a defendant in the Insurance Lawsuit.”19

The complaint’s own conclusion asks for compensatory damages against Hoffenberg, Brater, Chugerman and the two Towers companies, and for $190,729.96 from Towers Financial on an oral contract for the use of the Illinois companies’ premises.7 The signature page is executed: a manuscript signature in ink runs across the “By:” rule above the printed words “One of His Attorneys”, over the block of counsel Barry B. Gross of Shefsky & Froelich Ltd., Chicago.7

Reading the tables at all requires the page image

The machine-read text of these two sheets cannot be used. On the United Fire sheet the column headings emit in the order “Payee. Date Amount” while the rows arrive check number, date, amount, payee, so field association is destroyed. On the United Diversified sheet the extraction breaks the table into four separate blocks and renders almost every zero as the letter O, so that a $6,009.00 row reads “6,OO9.OO” and a check number reads “7O62”. Neither fault is visible without opening the sheet. Every figure, date and payee given above was read from the page images at 400 dpi; the arithmetic closure of the nine rows on the $215,000 in paragraph 43 is corroboration, not proof, and it was checked after the rows were read and not instead of reading them.

The same two sheets carry a name the extraction gets wrong in two different ways, and the document itself is inconsistent about it. A payee row on the United Fire sheet reads, at the image, “Mintz, Fraade & Zieger PC”; the machine-read text gives “Sieger”. A payee row on the United Diversified sheet reads, at the image, “Mintz, Fraade & Zeiger”, without the “PC” and with the vowels in the other order.89 The name reappears twenty-two years later, in the order set out below; whether the 1987 payee and the later firm of Mintz & Fraade are the same entity is not stated by any document cited here.

The federal case, and what the sentencing court found

Judge Robert W. Sweet’s sentencing opinion, which every later pleading on this page cites as of March 4, 1997, is in the release as a WestlawNext reprint bearing a 2013 Thomson Reuters footer, which is why its extraction interleaves the two printed columns.4 Its account of the Illinois transaction matches the Director’s: Towers acquired the controlling interest in United Diversified in 1987, and “Hoffenberg obtained the Illinois Department of Insurance’s approval for this acquisition by representing that Towers would contribute $3 million to the surplus of United Fire.”4

The opinion sets out the loss arithmetic. As of April 1996 the Bankruptcy Court had allowed bondholder claims of $196,948,864, noteholder claims of $258,244,618 and a second class of noteholder claims of $19,963,858, “The total of those claims equals a loss of $475,157,340.” The opinion adds that this figure covers the Towers fraud only and not the Illinois insurance fraud, “which totalled between $3 million and $4 million”, so that “The total losses attributable to Hoffenberg’s conduct are $478,157,340.”11

It also sets out what happened to Hoffenberg’s cooperation. He initiated proffer sessions in March 1993; on September 24, 1993 he and the Government entered into a plea agreement dated September 23, 1993. “On January 27, 1994, and on February 14, 1994, the Government confronted Hoffenberg with allegations that he had violated his obligations under the Agreement. On February 17, Hoffenberg was advised that the Agreement had been terminated, and he was arrested.”11 He moved for specific performance of the agreement, and “On December 18, 1995, this Court issued an opinion denying Hoffenberg’s motion and finding that Hoffenberg had breached the Agreement.”20 The opinion elsewhere records that he “provided significant assistance to the Government during the period of March 1993 to February 1994, by explaining the circumstances and participants involved in the Towers case”, and treats that as a ground for downward departure.21

The opinion does not name Jeffrey Epstein. It refers throughout to “Hoffenberg and his co-conspirators”, and that phrase is what every later pleading on this page is built on.

December 2013: the conflict Judge Castel identified

Hoffenberg was released from federal custody on October 11, 2013. On December 5, 2013 Judge Sweet convened a hearing in the criminal case on his conditions of supervised release. The transcript records the appearances: Assistant U.S. Attorney Richard Cooper with two probation officers for the Government, and “Gary Baise, Olsson Frank, Washington, D.C., for Mr. Steven Hoffenberg. I’m accompanied by Mr. Hoffenberg and counsel for Towers Investors and one of the investors, Mr. Ed Kramer, from Mintz & Fraade.”22 Sweet modified the terms of supervised release by order of December 11, 2013; Castel’s account of that order is that it imposed, “among other restrictions, a prohibition from engaging in direct contact with his victims.”13

A week after that order, on December 18, 2013, Judge P. Kevin Castel issued a memorandum and order in a separate civil proceeding captioned for “200,000 Towers Investors Restitution Victims”, 13 Civ. 8563 (PKC).13 The petition, brought under the Crime Victims’ Rights Act, asked the court to direct the Probation Office to stop obstructing Hoffenberg’s efforts to collect and pay his restitution, and specifically to allow him “to renounce his U.S. citizenship and move to China to set up a business.”23

Castel’s opinion is unsparing about the conflict:

Why would the victims of Hoffenberg’s frauds be so eager to have him placed beyond the reach of U.S. authorities? A possible answer is found in the body of the petition and its annexations, which reveal that the law firm of Mintz & Fraade, P.C., in addition to representing the victims of Hoffenberg’s fraud, also represents Hoffenberg.23

He noted that Judge Sweet had described Alan Fraade as having “a longstanding relationship with Hoffenberg,” and acting as “Hoffenberg’s ‘house counsel’ at Towers.”23 He recorded that the petition identified only one actual petitioner, “an individual named Rey Marques, whose ‘Emergency Retainer Agreement’ with Mintz & Fraade is annexed to the petition,” and that the retainer agreement told Marques “We hereby advise you that we are not aware of any conflicts with respect to our representation of you pursuant to this Retainer Agreement.”2425 He directed the petitioners and Fraade to show cause why the action should not be dismissed and sanctions imposed under Rule 11(b).25

The same order records what the petition said about Epstein: that “a non-party ‘multi-billionaire’ named Jeffrey Epstein can ‘easily’ provide for restitution through his ‘over one hundred billion dollar hedge fund’ that was formed with Hoffenberg’s assistance.”24 That is Castel quoting the petition, and the petition itself is not among the documents cited here. December 2013 is nonetheless the earliest dated point among the documents cited here at which Hoffenberg’s side put Epstein’s fortune forward as the source of the Towers restitution.

Two copies of this order sit in the release under different identifiers, one carrying the court’s electronic filing header and one carrying a docket-aggregator footer instead. On the sheet whose machine-read text renders the caption name “HOPFENBERG”, the page image prints “HOFFENBERG”; the defect is in the extraction, not in the order.13

2016: the suit Hoffenberg brought himself

On May 27, 2016 the Mintz Fraade Law Firm filed Steven Jude Hoffenberg v. Jeffrey E. Epstein, et al., No. 1:16-cv-03989 (S.D.N.Y.), as a related action to the criminal case.26 On June 7, 2016 Alan Fraade wrote to Judge Richard J. Sullivan asking that the matter be transferred to Judge Sweet, “who is still overseeing restitution issues, as they arise.”26

On July 1, 2016 the same firm withdrew it. The one-page letter states the reason:

After consulting with the Plaintiff with respect to the issues raised in the Defendants’ Letter dated June 28, 2016, the Plaintiff, in order to avoid needless litigation, believes that the individuals and entities which are victims of Tower Financial Corporation’s “Ponzi” schemes set forth in the Complaint may be in a better position to pursue and assert their own claims against the Defendants, Mr. Jeffrey E. Epstein and The Financial Trust Company.14

The letter is signed in ink by Alan P. Fraade and copied to Gary H. Baise, to Hoffenberg himself, and to Bennet J. Moskowitz, whose name is on the motion to dismiss filed two years later.1427 The letter says the victims may be better placed to sue the same two defendants; a victims’ class action against those two defendants was filed on August 20, 2018. Whether the second followed from the first is not stated by any document cited here.

March 2018: an unexecuted draft

The release holds a twenty-sheet complaint captioned Ray Marques and ______ v. Jeffrey E. Epstein, naming Epstein “individually, and as President and Chief Executive Officer of The Financial Trust Company”, and carrying at its foot a typed counsel block naming Gary H. Baise, with “Attorney for Plaintiffs” on the line beneath.2829

This copy is unexecuted. At the image the blanks in the caption and in paragraph 1 are typed underscore rules on the baseline, not redaction bars: this is a template with fields the drafter had not filled in, and the second plaintiff’s name and both plaintiffs’ places of residence are left blank. The “Index No.” field is blank. The date line reads “March __, 2018” with the day left open. The signature rule above the typed name is empty: no ink and no bar.2829 Neither of the two sheets read at the image carries a court filing header, and none appears in the machine-read text of the other eighteen. The two 2018 complaints that were filed are not like that: an electronic filing header appears in the machine-read text of 26 of the 29 sheets of the one and 50 of the 51 sheets of the other.29

Its caption also misstates the criminal cases it claims to relate to, giving “Case No. 94 CR 213 (RWS)” and “Case No. 95 CR 213 (RWS)”.28 The second number is wrong: the Illinois indictment 94 CR 272 was transferred to the Southern District of New York on April 11, 1995 and became 95 CR 321 (RWS), which is the number the draft’s own body text uses four sheets later.1130

The draft asserts, on information and belief, that The Financial Trust Company was “formed by Epstein, or on his behalf, under the laws of St. Thomas in the U.S. Virgin Islands, sometime between 1995 and 1997” and “raised in excess of fifty billion ($50,000,000,000) dollars from investors”.31 Those are the pleading’s assertions and this page does not adopt them; the corporate filing history is set out at Financial Trust Company, Inc., where the articles of incorporation are dated November 6, 1998. The corporate title the draft attaches to Epstein is likewise the pleading’s, and appears in no corporate instrument cited on that page.

Whether the “Ray Marques” of this draft is the “Rey Marques” whom Judge Castel identified as the sole named petitioner in 2013 is not established by any document cited here. The two spellings differ by one letter, both men are described as Towers investors, and both are represented by counsel connected to Hoffenberg.

August 2018: the affidavit and the class action

On a date the jurat gives in manuscript as the seventeenth day of August 2018, Steven J. Hoffenberg swore a seven-page affidavit before a notary in New York County; it was filed as an eight-sheet exhibit behind a cover sheet.32 The pleadings that rest on it were filed on August 20 and August 21.

The affidavit’s account is that Hoffenberg met Epstein “in or around the mid-1980s”, when “Epstein was running his own consulting company, International Assets Group Inc. out of his New York City apartment”, and that “In or around 1987, I hired Epstein as an associate and expert to consult with TFC and me.”2 From there it inverts the roles the 1997 opinion assigned: “Through TFC, Epstein orchestrated and planned an intricate fraud”; “Epstein was the architect of the plan to secure the approval from the regulators”; “Epstein devised yet another scheme to raise capital for TFC by selling Promissory Notes.”23334 It closes:

Epstein and the corporations he formed were my co-conspirators. Epstein has remained free and has used and benefitted from the ill-gotten gains he amassed as a result of his criminal and fraudulent activities.32

The execution page is complete and was read at 400 dpi. The declaration under 28 U.S.C. § 1746 is printed type; the signature above the typed name “Steven J. Hoffenberg” is manuscript ink, running over the rule; the jurat’s day and month are filled in by hand; and the notary’s signature is ink over its own rule. A notary commission-expiry date and registration number are handwritten below it and are not reproduced here. The machine-read text drops the signature entirely, as it drops every manuscript signature, and renders the four handwritten lines as unusable fragments.32

Two internal problems limit what the affidavit can carry. Paragraph 39 says “During the course of my criminal trial, Prosecutors offered me a reduced sentence in exchange for information about Epstein’s role. However, I did not disclose any details about Epstein’s involvement, let alone orchestration, of the fraudulent scheme”; paragraph 40, on the same sheet, records that he pleaded guilty, and there was no trial.12 And the sworn statement that he withheld information about Epstein from prosecutors in the 1990s is what the 2018 pleadings must rely on to explain why the claims are not stale.

Marvin Gerber and Kalma Koenig, on behalf of themselves and all others similarly situated, v. The Financial Trust Company, XYZ Corporation, ABC, Inc., and Jeffrey E. Epstein was filed in the Southern District of New York on August 20, 2018 as Document 1, and refiled the next day as Document 7 under the caption 1:18-cv-07580-JPO; the summons issued on August 22.153536 The plaintiffs are noteholders and bondholders of Towers. Their first paragraph pleads harm from “a massive Ponzi scheme perpetrated by Defendant Jeffrey Epstein, an uncharged co-conspirator of Steven Hoffenberg”. A footnote on the same sheet says “Defendant Epstein is sued herein in his individual capacity as well as in his capacity as President and Chief Executive Officer of The Financial Trust Company.” That corporate title is the pleading’s assertion and is not adopted here.35 Paragraph 4 pleads, on information and belief, that the practices “date back to the mid-1980s”.37 Exhibit A to the complaint is Judge Sweet’s sentencing opinion; Exhibit B is the Hoffenberg affidavit.37

The Document 1 copy in the release is not a photograph of a filed page. It is a re-rendering of a machine-read text stream in a monospaced face, over which redaction bars have been applied. Five labelled contact-line fields across its two counsel blocks are barred, and two further lines beneath the first block are barred as well; none of those values is reproduced here. The extraction of that sheet closes every one of the gaps, so the barred fields read as though they were simply blank.38

The answer, the cost, and the end

Epstein and The Financial Trust Company answered through Troutman Sanders LLP. Their memorandum of law in support of a motion to dismiss, dated September 14, 2018, opens under the heading “PRELIMINARY STATEMENT: MULTIPLE SDNY JUDGES WARNED THE PERSON 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 the entire basis for their Complaint, against pursuing frivolous and improper litigation like this action. Nevertheless, Hoffenberg remains intent on shifting blame for his own massive Ponzi scheme.39

The memorandum’s substantive argument is limitation: that the plaintiffs “admit they knew, since at least 1997, about Hoffenberg and Defendant Epstein’s alleged misconduct”, and that the affidavit cannot restart a clock that ran out fifteen years earlier.3940 It sets out four earlier Hoffenberg actions, in 2001, 2003, 2013 and 2015, that courts dismissed or that he withdrew, and it characterises the 2016 withdrawal as Hoffenberg “implying he may recruit class members he claimed to represent, to bring the same frivolous, withdrawn claims in his place.”4041 The motion asked for dismissal with prejudice.27

Three weeks later the plaintiffs ended the case themselves. Document 19, filed October 5, 2018, is a notice of voluntary dismissal under Rule 41(a), “without prejudice”, signed for Hach Rose Schirripa & Cheverie by Hillary M. Nappi.16 No ruling on the motion to dismiss appears in the documents cited here.

What the defence cost is documented. A Troutman Sanders invoice dated October 17, 2018, addressed to Jeffrey Epstein care of Darren K. Indyke, PLLC and submitted by B J Moskowitz, bills the matter “Gerber vs. The Financial Trust Co.” at $40,017.00 in fees through September 30 and $8,943.59 in costs, for $48,960.59.42 Its earliest time entry is dated August 27, 2018, and the entries run continuously from there to the filing of the motion on September 14; several record conferring with Indyke and incorporating his comments into the memorandum of law.43 An identity-number-class value printed on the invoice sheet is not reproduced here.

What this page does not establish

Everything on this page about Epstein’s role in Towers Financial comes from one of three places: a 1991 regulator’s pleading in which he is named only as a payee and is not a defendant; a 2018 affidavit by a man convicted of the fraud he is describing, whose cooperation agreement with the Government was terminated in February 1994 and judicially found breached in December 1995; and pleadings built on that affidavit which plead the central allegation flatly and plead key elements of it on information and belief. No finding that Epstein participated in the Towers fraud appears in any document cited here, and the 1997 sentencing opinion that is the source for “Hoffenberg and his co-conspirators” does not name him.

Searches run, and what they returned. On the surname alone, “Hoffenberg” returns 874 pages across 481 documents in this release; the full name “Steven Hoffenberg” returns 303 pages, and “Stephen Hoffenberg”, the caption spelling of the 1991 complaint, returns 2. “Towers Financial” returns 218 pages across 127 documents and “Towers Diversified” 21 pages across 6. “Jeff Epstein & Co” returns one page. A search for a ruling on the 2018 motion to dismiss, and for any opinion in the 2016 action, returned only the parties’ own filings and the voluntary dismissals. The Rule 11 show-cause response Judge Castel ordered for January 17, 2014 is not among the documents cited here, nor is the petition it concerned, nor the May 2016 complaint itself, nor the “Defendants’ Letter dated June 28, 2016” that the withdrawal letter answers.

Footnotes

  1. Same complaint, EFTA00612518 p.3, paragraphs 5 to 9. Read at the image at 250 dpi; the sheet is printed type and carries no redaction. Paragraph 5 names the five boards Hoffenberg chaired and gives the ownership chain, and paragraph 9 carries the description of Towers Financial quoted above. The machine-read text of this sheet gives the surname as “Boffenberg” and the percentage as “82.5E”; the page prints “Hoffenberg” and “82.5%”. ↩ ↩2

  2. Affidavit of Steven J. Hoffenberg, sworn in New York County, filed as Document 7-2 in No. 1:18-cv-07580-JPO on August 21, 2018. EFTA00811809 p.45, paragraphs 1 to 8. Read at the image at 250 dpi; the sheet is printed type and carries no redaction. This is the second sheet of an eight-sheet exhibit inside a 51-sheet run; the first sheet is an “Exhibit B” cover and the affidavit itself runs to seven pages. ↩ ↩2 ↩3 ↩4

  3. Same opinion, EFTA01120705 p.7, the section headed “Hoffenberg’s History”. UNVERIFIED, from a search hit: this sheet was not rendered, and its extraction gives the company name as “Tower” at the point where the 1974 date appears. ↩ ↩2

  4. United States v. Steven Hoffenberg, Nos. 94 Cr. 213 (RWS), 95 Cr. 321 (RWS), Sentencing Opinion of Sweet, D.J., 1997 WL 96563, reproduced as a WestlawNext printout. EFTA01120705 p.1. Read at the image at 400 dpi; the sheet is printed type and carries no redaction. The Westlaw header prints the two case numbers followed by the date March 5, 1997, while the pleadings citing the opinion give March 4, 1997; this page does not settle which is right. The sheet carries the offence-conduct passage quoted above, the 240 months, the $475,157,340 restitution, the $1,000,000 fine and the March 7, 1997 hearing date. The printout is a two-column page and its extraction interleaves the columns, so the running order of sentences in the machine-read text is not the running order on the page. The reprint carries a 2013 Thomson Reuters footer, so it is a commercial reprint rather than a copy of the court’s own document. The run is 11 sheets. ↩ ↩2 ↩3 ↩4 ↩5

  5. Same complaint, EFTA00612518 p.2, paragraph 1. Read at the image at 250 dpi; the sheet is printed type and carries no redaction. It gives the Conservation Order of July 29, 1988 and the Liquidation Orders of March 3, 1989, both entered by the Circuit Court of Cook County, Illinois. ↩ ↩2

  6. James W. Schacht, Acting Director of Insurance of the State of Illinois … v. Stephen Hoffenberg, Mitchell Brater, Charles H. Chugerman, Michael Rosoff, Towers Financial Corporation, and Towers Diversified Company, Complaint, United States District Court, Northern District of Illinois, Eastern Division, No. 91 C 4024. EFTA00612518 p.1. Read at the image at 300 dpi: the caption, the “COMPLAINT” heading and the opening paragraph are printed type, and the sheet carries no redaction bar. The clerk’s filed stamp is overprinted on the court line and shows a day and “PM 3:48” with the month obscured; a separate stamp reads “DOCKETED JUN 28 1991”; the case number is stamped “91C4024”; two assignment stamps are overprinted on the caption and are only partly legible. A mirrored fax transmission line dated April 24, 2015 shows through from the reverse of the sheet, which is the source of the unreadable strings at the foot of every page of the machine-read text. The run is 39 sheets, Bates EFTA00612518 to EFTA00612556. ↩ ↩2 ↩3

  7. Same complaint, EFTA00612518 p.39. Read at the image at 300 dpi. “DATED: June 27, 1991” is printed type. The “By:” rule carries a manuscript signature in ink, of varying stroke width, running across the rule and over the printed words “One of His Attorneys”; the counsel block beneath gives Barry B. Gross, Shefsky & Froelich Ltd., Chicago. Paragraph 140 and the prayer on pp.38 and 39 give the figure $190,729.96. ↩ ↩2 ↩3

  8. Same complaint, EFTA00612518 p.11, paragraph 38 and the United Fire Insurance Company table. Read at the image at 400 dpi, and re-read at 500 dpi on 2026-09-10. The sheet carries no redaction. The top of the sheet carries subparagraph (c) of the preceding paragraph, which pleads that “Ill. Admin. Code tit. 50, § 904.30 (1987) requires at least two authorized signatures on checks in excess of $5,000”; the words “at least” are on the sheet. The four columns are headed “Check # · Date · Amount · Payee”; the machine-read text emits the headings as “Payee. Date Amount” and the rows in a different order, so no figure or payee from this table may be taken from the extraction. ↩ ↩2 ↩3 ↩4

  9. Same complaint, EFTA00612518 p.12, the United Diversified Corporation table. Read at the image at 400 dpi. The sheet carries no redaction. The machine-read text of this sheet breaks the table into four column blocks and renders most zeros as the capital letter O. ↩ ↩2 ↩3

  10. Same complaint, EFTA00612518 pp.13 and 14, paragraphs 40 to 44. Read at the image at 600 dpi (p.13) and 400 dpi (p.14); neither sheet carries a redaction and the quoted paragraph is printed type. Paragraph 43 runs over the page break: p.13 ends “Within a period of shortly over six months the Companies lost” and p.14 opens “approximately $2 million on the Emery investment.” The machine-read text renders the defendant’s surname as “Roffenberg” at paragraph 41 on p.13 and again at paragraph 44 on p.14, once on each sheet; both sheets print “Hoffenberg” at the image, and p.13 prints it correctly five further times, so the fault is confined to those two paragraphs. The count of one page for the phrase “Jeff Epstein & Co” is a full-text index search of the release run 2026-09-10, and a corpus count is a count of what survived extraction. ↩ ↩2 ↩3

  11. Same opinion, EFTA01120705 p.5. Read at the image at 250 dpi; both columns are printed type and the sheet carries no redaction. This sheet carries the loss arithmetic, the September 1993 agreement, the February 17, 1994 termination and arrest, and the transfer of the Illinois indictment 94 CR 272 to become 95 CR 321 (RWS) on April 11, 1995. ↩ ↩2 ↩3 ↩4

  12. Same affidavit, EFTA00811809 p.50, paragraphs 33 to 40. Read at the image at 250 dpi, and re-read at 400 dpi on 2026-09-10; the sheet is printed type and carries no redaction. Paragraph 35 is the source of the Chapter 11 date: “In or around March 1993, TFC filed for Chapter 11 bankruptcy protection, and the TFC’s Noteholders and Bondholders filed claims with the Bankruptcy Court to support their loss claims.” Paragraph 34 gives the SEC suit only as “In February 1993”, with no day; the February 8, 1993 date in the infobox is Sweet’s, at [^sweet5]. Paragraphs 39 and 40, both quoted or described above, are on this sheet. ↩ ↩2

  13. 200,000 Towers Investors Restitution Victims v. United States of America by the U.S. Probation Office New York City Staff, No. 13 Civ. 8563 (PKC), Memorandum and Order of Castel, D.J., December 18, 2013, Document 2. EFTA00618266 p.1. Read at the image at 400 dpi: the caption is printed type and the sheet carries no redaction. The machine-read text of this sheet renders the caption name “HOPFENBERG”; the page prints “HOFFENBERG”. Footnote 1 on the same sheet carries the sentence, the restitution figure and the December 11, 2013 modification of supervised release, which it describes as imposing “among other restrictions, a prohibition from engaging in direct contact with his victims”, citing 94 Cr. 213, Docket # 145. That is Castel’s account of Sweet’s order; the order itself is not among the documents cited here. A second copy of the same order sits in the release at EFTA00610321, five sheets, carrying a docket-aggregator footer instead of the court’s filing header. ↩ ↩2 ↩3 ↩4

  14. The Mintz Fraade Law Firm, P.C. to Hon. Richard J. Sullivan, D.J., July 1, 2016, filed as Document 22 in No. 1:16-cv-03989-RJS. EFTA00594947 p.1. Read at the image at 250 dpi. The single sheet carries the court’s electronic filing header, is printed type, and carries no redaction. The “By:” rule carries a manuscript signature in blue ink above the typed name “Alan P. Fraade”. The Cc block names Gary H. Baise, Esq., Mr. Steven Hoffenberg and Bennet J. Moskowitz, Esq. ↩ ↩2 ↩3

  15. Marvin Gerber and Kalma Koenig v. The Financial Trust Company, XYZ Corporation, ABC, Inc., and Jeffrey E. Epstein, Complaint, Document 1, filed August 20, 2018, No. 1:18-cv-07580 (S.D.N.Y.). EFTA01433867 p.1. UNVERIFIED, from a search hit for the header line on this sheet. The run is 29 sheets for a 26-page document, because the re-rendering places some footnotes on sheets of their own; sheet numbers here are sheets, not document pages. The same Document 1 sits in the release under a third Bates number as well, EFTA01386752, which is the copy cited for paragraph 12 at Financial Trust Company, Inc.. The two copies this page cites are redacted to different extents; the third has not been opened here, and a statement about what is or is not barred holds only for the sheet it is made about. ↩ ↩2

  16. Notice of Voluntary Dismissal Pursuant to Fed. R. Civ. P. 41(a), Document 19, filed October 5, 2018, No. 1:18-cv-07580-JPO. EFTA00802936 p.1. Read at the image at 250 dpi. The sheet carries the court’s electronic filing header and is printed type. The three labelled contact-line fields in its counsel block are barred, and the bar continues over the lines beneath them; none of those values is reproduced here. The signature is the electronic “/s/” form. ↩ ↩2

  17. Same affidavit, EFTA00811809 p.50, paragraph 38: “Epstein was never charged with any crime for his involvement in the fraudulent schemes described herein.” Read at the image at 250 dpi. ↩

  18. Two commercial extracts for the New York corporation, both produced by JPMorgan Chase under a request for confidential treatment and both cited on J. Epstein & Company, Inc.. Dun & Bradstreet, Dun’s Market Identifiers for “J Epstein & Co Inc”, 457 Madison Ave, New York, dated December 9, 2002. EFTA01582866 p.1, read at the image at 300 dpi on 2026-09-10: the sheet is printed type, prints “YEAR STARTED: 1982” and “INCORPORATION: October 18, 1982 - New York”, and one labelled contact-line field on it is barred, whose value is not reproduced here. LexisNexis corporate-records extract for “J. EPSTEIN & COMPANY, INC.”, drawn from New York Department of State data. EFTA01582873 p.1, read at the image at 300 dpi on 2026-09-10: the sheet is printed type, carries no redaction, and prints “Status: INACTIVE”, “Status Comment: DISSOLUTION” and “Filing Date: 4/4/2001”. The two extracts do not agree on the incorporation date. The same LexisNexis sheet gives “Date of Incorporation/Qualification: 11/18/1988” and records a prior corporate name with a 1997 file date, and its own heading states that the data is not an official record of the Department of State or of the State of New York. This page does not settle which date is right; neither extract is a filed corporate instrument, and nothing here turns on either date. ↩

  19. Ray Marques and ______ v. Jeffrey E. Epstein, Complaint, undated draft. EFTA00804506 p.8, paragraphs 26 to 28. UNVERIFIED, from a search hit: this sheet was not rendered. It is cited for what the draft asserts about the 1992 settlement and about Epstein not being a defendant in the Illinois action, and both are the draft’s assertions, not findings. ↩

  20. Same opinion, EFTA01120705 p.6. Read at the image at 250 dpi. The machine-read text gives the date as “December IS, 1995”; the page prints December 18, 1995. ↩

  21. Same opinion, EFTA01120705 p.9. Read at the image at 400 dpi; both columns are printed type and the sheet carries no redaction. The passage sits in the left column and reads in full: “Other grounds are also present that provide the basis for downward departure. Hoffenberg has provided substantial assistance to private parties in their civil suits to recover losses against Towers. He also provided significant assistance to the Government during the period of March 1993 to February 1994, by explaining the circumstances and participants involved in the Towers case.” The sheet also carries yellow highlighting over a different passage; who applied it is not stated on the sheet. ↩

  22. United States of America v. Steven Hoffenberg, No. 94 CR 213 (RWS), transcript of proceedings before Sweet, D.J., December 5, 2013. EFTA00612557 pp.1 and 2. Read at the image at 400 dpi; both sheets are reporter’s transcript pages, printed type, and neither carries a redaction. P.1 carries the case number “94 CR 213 (RWS)”, the place-and-date block “New York, N.Y. / December 5, 2013 / 2:05 p.m.” — the time is printed under the court’s own place line, so it is New York court time — and the APPEARANCES block, which prints “RICHARD COOPER” above “Assistant United States Attorney” and “GARY H. BAISE” above “Attorney for Defendant”. The title Assistant U.S. Attorney is taken from that block: on p.2 Cooper gives himself only as “for the government”. P.2 carries the quoted appearance at lines 7 to 10, the two probation officers named by Cooper at lines 4 to 6, and at lines 14 and 15 Sweet’s statement that Hoffenberg “was released from federal custody on October 11, this year”, the year being the transcript’s own. One conflict on the face of the document is not settled here: the caption gives the sitting time as 2:05 p.m. and counsel’s first words on p.2 are “Good morning, your Honor.” The run is 36 sheets. ↩

  23. Same order, EFTA00618266 pp.2 and 3. Read at the image at 400 dpi; both sheets are printed type and neither carries a redaction. The block quotation above sits whole on p.2, as do the two descriptions of Alan Fraade and the request that the Probation Office allow Hoffenberg “to renounce his U.S. citizenship and move to China to set up a business”; p.3 carries the statement that the petition is brought under the CVRA. ↩ ↩2 ↩3

  24. Same order, EFTA00618266 p.4. Read at the image at 400 dpi; the sheet is printed type and carries no redaction. On this sheet Castel writes that counsel “purports to directly represent approximately 200,000 individuals who invested in Towers Financial”, and that “The petition identifies only one petitioner, however: an individual named Rey Marques”; Marques is described there only as the sole petitioner and as one who “claims to have ‘been a witness to the obstruction by the United States Government which is alleged herein … .’” Nothing on the sheet calls him a noteholder. The 2018 draft, by contrast, pleads at its own paragraph 1 that its plaintiffs were investors and/or noteholders in Towers Financial Corporation, on the sheet at [^marques1], read at the image at 400 dpi. Investor is the descriptor the two documents share. ↩ ↩2

  25. Same order, EFTA00618266 p.5. Read at the image at 400 dpi; the sheet is printed type and carries no redaction, and Castel signed it in ink over the rule above his printed name. The retainer-agreement quotation above runs over the page break, p.4 ending mid-sentence after the words We hereby advise, which is why both sheets are cited for it. The conclusion directs petitioners and Alan Fraade to show cause by January 17, 2014, “with petitioners’ counsel disqualified from representing petitioners”. The same conclusion appears in the second copy at EFTA00610321 p.5. ↩ ↩2

  26. The Mintz Fraade Law Firm, P.C. to Hon. Richard J. Sullivan, D.J., June 7, 2016, filed as Document 9 in No. 1:16-cv-03989-RJS. EFTA00601555 pp.1 and 2. UNVERIFIED, from a search hit: this two-sheet letter was not rendered. It states that the complaint was filed on May 27, 2016 as a related action to the criminal case. ↩ ↩2

  27. Same memorandum, EFTA00802452 pp.24 and 25, the conclusion and the signature block for Bennet J. Moskowitz. UNVERIFIED, from a search hit: these sheets were not rendered, so whether the signature is manuscript or the electronic “/s/” form the extraction shows has not been settled at the image. ↩ ↩2

  28. Ray Marques and ______, individually, and as representatives of the Noteholders and Bondholders of Towers Financial Corporation 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., Complaint. EFTA00804506 p.1. Read at the image at 400 dpi. The blanks in the caption and in paragraph 1 are typed underscore rules with white space above them, not redaction bars, and the sheet carries no redaction of any kind. The “Index No.” field is blank. The caption gives the related actions as “Case No. 94 CR 213 (RWS)” and “Case No. 95 CR 213 (RWS)”. The machine-read text gives the attorney’s surname as “Raise”; the page prints “Baise”. The sheet’s opening paragraph names counsel in body prose as “by their attorney, Gary H. Baise, Esq., bring this Complaint” — the only place in the run where the honorific is printed. Paragraph 1 pleads that the plaintiffs “were investors and/or noteholders in Towers Financial Corporation”. The run is 20 sheets. ↩ ↩2 ↩3

  29. Same draft, EFTA00804506 p.20. Read at the image at 600 dpi. The date line reads “March __, 2018” with the day left blank. The rule above the typed counsel block is an empty rule: a uniform printed line, no ink and no bar. The block prints “Gary H. Baise (DC Bar #194878)” and, on the line beneath and in italic, “Attorney for Plaintiffs”. The honorific Esq. is not printed on this sheet at all; where it occurs in this run is p.1, in body prose, recorded at [^marques1]. A text-layer sweep of all twenty sheets of the run, made 2026-09-10, finds Esq on sheet 1 alone and finds the phrase Attorney for Plaintiffs on no sheet at all. The two strings sit on different sheets and occur together on neither. The sheet carries no redaction and no court filing header. A second sweep, made the same day, looked for an electronic filing header of the form Case 1:..-cv- in the machine-read text: it finds one on none of the twenty sheets of this run, on 26 of the 29 sheets of EFTA01433867 and on 50 of the 51 sheets of EFTA00811809. Those three figures are counts of the text layer, and a text-layer count is a count of what survived extraction; the 0 of 20 is corroborated at the image on the two sheets of this run that were rendered. ↩ ↩2 ↩3

  30. Same draft, EFTA00804506 p.4, paragraph 9, which gives the second criminal case number as 95 Cr. 321 (RWS). UNVERIFIED, from a search hit: this sheet was not rendered. ↩

  31. Same draft, EFTA00804506 p.2, paragraph 3. UNVERIFIED, from a search hit: this sheet was not rendered. ↩

  32. Same affidavit, EFTA00811809 p.51, paragraphs 41 to 45 and the execution block. Read at the image at 400 dpi. The 28 U.S.C. § 1746 declaration is printed type and no part of this sheet is barred. Above the printed name “Steven J. Hoffenberg” is a manuscript signature in ink of varying stroke width, crossing the rule. The jurat’s day and month are completed in manuscript, the day reading as 17 and the month written out. The notary’s signature is manuscript ink over its own rule beneath the printed words “Notary Public”. Two further handwritten lines beneath carry values not reproduced here. The machine-read text of this sheet drops the two ink signatures entirely and reduces the manuscript lines to fragments; it also gives “benefated” and “smacepd” where the page prints “benefitted” and “amassed”, and the quotation above is as the page prints it. ↩ ↩2 ↩3

  33. Same affidavit, EFTA00811809 p.46, paragraph 9. UNVERIFIED, from a search hit: this sheet was not rendered. ↩

  34. Same affidavit, EFTA00811809 p.48, paragraphs 20 to 25. Read at the image at 300 dpi on 2026-09-10; the sheet is printed type and carries no redaction. Paragraph 20 prints “Epstein devised yet another scheme to raise capital for TFC by selling Promissory Notes.”; the machine-read text of the sheet renders “another” as “mother”, and the quotation above is now as the page prints it rather than as the extraction has it. Nothing on this sheet carries the Chapter 11 filing, which is at paragraph 35 on p.50. ↩

  35. Same case, Complaint, Document 7, filed August 21, 2018. EFTA00811809 p.2, being document page 1 of 26, carrying the caption, paragraph 1 and footnote 1. Read at the image at 300 dpi; the sheet is printed type and carries no redaction. The “Case No.” field in the caption block is blank. ↩ ↩2

  36. Summons in a civil action, Document 11, issued August 22, 2018, addressed to Jeffrey E. Epstein. EFTA00811809 p.1. UNVERIFIED, from a search hit: this sheet was not rendered. ↩

  37. Same complaint, EFTA00811809 p.3, being document page 2 of 26, carrying paragraphs 2 to 5 and footnotes 2 and 3, which identify Exhibit A as the sentencing opinion and Exhibit B as the affidavit. Read at the image at 400 dpi; the sheet is printed type and carries no redaction. Paragraph 4 opens “On information and belief, Defendants’ deceptive practices date back to the mid-1980s”, and it is paragraph 4, not paragraph 1, that carries the qualifier. The sheet prints “Ponzi” correctly wherever it appears; the machine-read text of it renders that word “Pont”. ↩ ↩2

  38. Same complaint, EFTA01433867 p.29, the last sheet, being document page 26 of 26. Read at the image at 300 dpi. This sheet is not a photograph of a filed page: it is a re-rendering of a machine-read text stream in a monospaced face with no original layout, over which solid redaction bars have been applied. Five labelled contact-line fields across the two counsel blocks are barred, and two further unlabelled lines beneath the first block are barred as well; none of those values is reproduced here. The signature line carries the electronic “/s/” form. ↩

  39. Defendants’ Memorandum of Law in Support of Their Motion to Dismiss Plaintiffs’ Complaint, No. 1:18-cv-07580-JPO, dated September 14, 2018. EFTA00802452 p.4, being the memorandum’s first text page. Read at the image at 250 dpi; the sheet is printed type and carries no redaction. The machine-read text renders the defined term for The Financial Trust Company as “F=”; the page prints “FTC”. The run is 25 sheets and its first sheet is marked “PRIVILEGED AND CONFIDENTIAL; ATTORNEY WORK PRODUCT”. ↩ ↩2

  40. Same memorandum, EFTA00802452 p.5, listing the 2001, 2003, 2013 and 2015 actions. UNVERIFIED, from a search hit: this sheet was not rendered. ↩ ↩2

  41. Same memorandum, EFTA00802452 p.6. UNVERIFIED, from a search hit: this sheet was not rendered. ↩

  42. Troutman Sanders LLP invoice number 2040188, invoice date October 17, 2018, addressed to Jeffrey Epstein care of Darren K. Indyke, PLLC, re “Gerber vs. The Financial Trust Co.” EFTA00804463 p.1. Read at the image at 250 dpi. One field on the sheet is barred. An identity-number-class value printed on this sheet is not reproduced here. The run is 7 sheets. ↩

  43. Same invoice, EFTA00804463 pp.2 and 3, the time entries from August 27, 2018 onward. UNVERIFIED, from a search hit: these sheets were not rendered. ↩

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