EFTA01106124.pdf

MINTZ & FItAADE, P. Q. COUNSELORS AT LAW TELEPHONE OF COUNSEL. EDWARD C. ICRAMER AFernum L. Poinm. JR. THIRCOPIER Jon. M. PROILSTION Sin-moum Thirrionxwr I. FREDERICK EMOTION JOSEPH J. TOMASEK October 23. 2013 BY HAND DELIVERY Mr. Jeffrey Epstein 9 East 7151 Street New York, New York 10021 Re: Steven Hoffenberg Dear Mr. Epstein: I am attaching a memorandum prepared and signed by Steven Hoffenberg dated October 3, 2013 with respect to the Towers Investors claim against you. Mr. Hoffenberg was released from incarceration recently and has returned to New York. If you or your attorneys have any questions with respect to the attached memorandum, I suggest you contact the undersigned. Very truly yours, Mintz & Fraade, Alan P. Fraade CC: Mr. Steven Hoffenberg APF/ek End. N:Clientsgloffenbug, Steeentorrespondencateleffrey.Epsteini 0.22.13.63c EFTA01106124 10/09/2013 09:06 2154565953 EINSTEIN TRANSPLANT PAGE 02/10 STEVEN JUDE FOFFSNBERG OWNER NEW YORK POST PUBLISHING CORP. CHAIRMAN TOWERS FINANCIAL CORPORATION SEE: NEW YORK POST NEWSPAPER SEE TOWERS INVESTORS Working Draft Memo in the Continuing Multi Billionaire Jeff Epstein Massive aedge Fund Crimes in the New York City Venue That have'No Civil Restitu- tion Collection Suitatatute of Limitations Causing Epstein Guilty Plea 01) The multi-billonaire Jeff Epstein, was under th extreme finan- ical disability, when Towers Investors Dot-Com, employed Epstein, that is evidenced in, the vanity Fair March 2003, nine page story, named, "The Talented'Mr. Epstein;' showing the intro- duction in, the Epstein and Hoffenberg Crimes history, in the partnership Towers on;going agreements. 02) The multi-billionaire Jeff Epstein, had no financial assets when the Towers Investors Dot-Com, 2C0,000 restitution victims, corpor- ations, crimes paid for the Epstein hedge fund, set forth in the above story points of fact, naming persons who did witness, the Towers Investors, payment crimes. 03) The actual dates, and assets, money amounts in the crimes herein, will be provided. The freeze of the multi-billionaire Epstein assets are in the constructive. trust unjust enriChment7.1aw. -01- ' EFTA01106125 10/09/2013 89:06 2154565953 EINSTEIN TRANSPLANT PAGE 03/10 04) The multi-billionaire, Jeff Epstein, was employed by the Towers Investors, as the Hoffenbera assistant, in the Hoffenberg Towers crimes, that are recorded in continuing federal court orders. Epstein had the fiduciary relationship with Towers. 05) Epstein acted full-time with Hoffenberg, in the Ponzi scheme pre- sumption, crimes, fraudulent asset transfers in Towers investors that converted money; assets, securities. by the Epstein fraud, unjust enrichment, concealment, fraudulent convevance act viol- ations, mail and wire fraud, converting Towers assets failing to perform duties under the Towers Investors Epstein contracts, with Hoffenberq, and the Leese Family corporations, including, overseas crimes, with investor funds, raised in the United States. in the Towers Investors Epstein, Leese. Hoffenberg continuing contract crimes up to 2013, ongo%ng. 06) The Vanity Fair nine Paae story names persons. and federal court litigations, that Epstein acted :al at the partnership, in the Epstein hedge fund operations, in New York City, with the Towers Investors Dot-Com, crimes ongoing contracts, that included Hoffen- berg. 07) The purpose of this memo, is the introduction in the continuing Epstein criminal acts, that are now subject to the Towers Investors Pot-Com, 200,000.restitution Hoffenberg court ordered victims, and Government, civil collection restitution suits, that will motivate, the multi-biflionaire Jeff Epstein criminal -02- EFTA01106126 18/09/2013 09:06 2154565953 EINSTEIN TRANSPLANT PAGE 04/18 case guilty plea, and Epstein government cooperation, freeze of Epstein assets, by constructive trust law. 08) Hoffenberg will meet with his partner, and former best friend Epstein, in order to discern this memo, asset freeze with the Epstein hedge fund One Hundred Billion Dollars in bank currency major margin overseas bank loan currency accounts, that will be called in, by the banks defaulting Epstein, in the massive Epstein bank hedge fund margin loan accounts fraud crimes. See Constructive Trust, unjust enrichment law. 09) The Bernie Hadoff crimes, are somewhat on point, in the huge Epstein hedge fund continuing crimes. The Epstein hedge fund crimes, are much higher in oam0Ont4 compared with the Bernie Medoff hedge fund crimes. The freeze of Epstein assets, will be ordered herein. 10) The Epetein hedge fund currency bank margin loan account, crimes, provides over one hundred dollars. in margin bank loans, against one dollar, in the currency margin loan trading investment, one hundred to one, bank margin loan accounts, in trading of currency contracts. The largest loans on Wall Street world wide. 11) United States V. Summerlin, 84 L.ed.; 1283 (19404, discerns the well settled law, whereby the government, is not bound by the statute of limitations, in civil restitution collection suits, herein against Epstein and others. EFTA01106127 10/09/2013 09:06 2154565953 EINSTEIN TRANSPLANT PAGE 05/10 11A) Soffehberg has over 35-years in collection law training. 12) United States et al, V. Walter A. Forbs et al, 740 F. Supp 2d 334, District of Connecticut, September'/O, 2010, order shows the joint government, and restitution creditoreecedent Corp. 'federal debt collection procedure act, recovery, that may be • used against, the multi-biilionaLre Epstein crimes herein. The government has over 400•Billion :.n judgments in other cases that apply herein. 13) The constructive trust well sett:.ed law; may be used to freeze, the multi-billion Epstein assets and money. 14) Epstein understands, that the effort in this memo, will cause the huge Epstein hedge fund currency margin, bank trading loan accounts to be called in, and defaulted by the Epstein banks, for the Epstein bank fraud loan application crimes in seeking the bank margin loan accounts. . 15) Epstein understands his bank loan margin accounts fraud crimes, used by Epstein tb open each bank loan margin account, in the Epstein hedge fund criminal enterprise, are at risk, in the operations herein. 16) Hoffenberg will turn over evidence in'the Towers Invektor s bot- Com, bankruptcy:cases. showing how Epstein did act by criminal. and civil fraud. in the bankruptcy cases in the. massive 'Epstein hedge tund. triminal enterprise, by defrauding all of the Towers Investors Dot Com. -04- EFTA01106128 10/09/2013 09:06 2154565953 EINSTEIN TRANSPLANT PAGE 06/10 17) Epstein understands that, the operations herein, will cause the major Epstein hudge fund investors, to demand the repayment,of each investment, in the Epstein hedge fund. Therein ending the Epstein hedge fund criminal enterprise. 18) Attached hereto are the Jeff Epatein investor hedge fund audit crimes project, (33) thirty-three points of fact. Said points of fact, crimes will be further discerned by Hoffenberg, and experts, showing the government, the inside operations, crimes, in the massive multi-Mllionaire Jeff Epstein hedge fund criminal enterprise. 19) The Leese Family Towers Investors Hoffenberg overseas contracts, are vital in, the Epstein massive hedge fund criminal enter- prise. Said contracts are ongoing today. 20) The Leese Family members, will cooperate with the Government, in the Epstein criminal case. Hcffenberg not Epsterin, has the key relationship, with the Leese Family members. Hoffenberg did the Leese, Towers Investors, Epstein contracts. 21) Epstein defrauded the Leese Family members, in their continuing Epstein hedge fund, -crimes overseas bank relationships. that are controlled by the Leese Family. The Leese Family operate over- seas, not in the United States. The Leese Family don't under- stand, the massive Epstein crimes. 22) The Leese Family members, pay cut the illegal overseas Epstein EFTA01106129 10/09/2013 09:06 2154565953 EINSTEIN TRANSPLANT PAGE 07/10 hedge fund criminal enterprise, funds, that violates the United States criminal law, with Epstein. 23) The government will be provided with further evidence, from the Towers Investors , restitution civil collections, from the multi-billionaire Jeff Epstein hedge fund criminal enter- prise, investigation. 24) The government will be paid billions of dollars, from the multi- billionaire Epstein criminal enterprise. Hoffenberg, the Epstein hedge fund partner, will meet with, the Epstein hedge fund banks, now. Government agents will be at the bank meetings. 25) The Epstein hedge fund banks, did violate the United States criminal law, whereby the banks will consider the need to reach the hedge fund bank loans settlement reduction with Hoffenberg, in the banks margin and the other Epstein bank hedge fund loans. Government agents, will be at the bank. 26) Epstein understands that the hedge fund bank loans reduction settlement, provide(s) the billions of dollars, to pay the Govern- ment, with ail the Epstein hedge fund investors, and Towers Investors Dot-Com, 200,000 restitution victims. 27) Epstein must pay out some (50) f:Lfty million dollars to the Towers Investors Dot-Com, in order to fund the operations herein, now. 28) Epstein understands his major risk in the civil and criminal -06- EFTA01106130 10/09/2013 09:06 2154565953 EINSTEIN TRANSPLANT PAGE 08/10 issues, that will cause the Epstin over (150) One Hundred Fifty year prison sentence. 29) Epstein understands that his Government continuing cooperation, in the Epstein guilty plea agreement, are now mandated, for the most serious Epstein considerations. 30) The Government must consider the terms in the Epstein guilty plea agreement, set forth below. 31) The court will order and bind the terms in the Epstein guilty plea agreement. 32) Epstein's Government continuing cooperation, will provide Epstein with home detention up to the tine of the Epstein criminal case sentence. 33) The Epstein sentence will be served at the Government.baser not prison, the same kind of detention terms, provided to'Sammy the Bull, in the John Gotti, case. The Epstein financial details will be settled with the Government in the Epstein court ordered guilty plea agreement. (Loa el.g2/'—‘ LAkal> to-3- 401.3 By: even JuJ .Hoffenberg -07- EFTA01106131 10/09/2013 09:06 2154565953 EINSTEIN TRANSPLANT PAGE 09/10 JEFF EPSTEIN INVESTOR AUDIT PROJECT 1. The currency future contracts copy, are notprevided to each investor, by Epstein: 2. Currency is a commodity, ilipfined under, the Commodity Exch7 tugs Act, hereinafter OEA. 3. Each currency transaction, for the inveltor(s), are placed in needed valid counterparty, in the bank. 4. The bank counterparty, trade(s) they investor currency account(s). 5. Each investor currency account, must.be listed by the bank, in the name of each investor. 0. Epstein conceal(s), the, investor required name, from the 'bank.: currency trading account(s). 7. Epstein is sot the valid investor dOuntarpatry-, that must trade, for each investor account. 8. The .investor account, will not take the physical delivery . Pf the trading currency. 9. Commodity Futures Trading CoMmiaaitin.'mai open the .inveetigatiun in currency investor trading.violation(s),. by. Epstein. 10. Commodity Futures Trading Commission vs International Foreign Currency. Inc Etal 334 F.Supp 2d 305 (EDNY.2064), show(s) the inve- stor currenerbasic trading. • 11. The investor fund(s), are deposited in, the Epstein account(s), not the investor currency account(s), operated by the bank curren- cy trader. 12. Epstein, not the bank, has authority, in the investor funds. -1- EFTA01106132 10/09/2013 09:06 2154565953 EINSTEIN TRANSPLANT PAGE 10/10 13. VioIation(s) in .the investor 'currency account,, may' show up at, the bank currency trading accounts. 14. Epstein operate(s) aIode,..the bank currency trading accounts, concealing that evidentq9 .from. the toasters.. . . .- 15..Each investor audit, 1.1% the banki\currency evading accounts, will show, the violation(s))*by Epeteth;. - < .. . . 16. The inmestoc.ctiatrect(A)- with Epstein, vi11 show the road map, in the Epstein eloUtion(s) of Federa.4.1ai. 17. The Eoffenberg Collection assistance, with the investors, will . . produce, the Epstein violatien(s),.iilederal law.' 18. The Commodity Futures.tradimg ComMigfaion, will'act,' in the Ep- stein turnover of account evidence, for each investor, if needed.. 19. Hoffenberg will assist, in the candeted Collection Audit, in each investor account. 20. The Collection Investor Audit, will be performed by expert(s), in. this inmestment: 21. Hoffenberg can.assist in picking the investor.tollection audit experts, In addition teithe audit work prOceis. 22. Epstein stated in the media:that Epstein alone, operate(s), the Investor Currency Trading stratogieer like Medoff. 23. Epstein alone structura(s), the• investor currency trading acc- ount, profit and.loss, like Tfadof£.• .24.. The Epstein investor solicitation friend, will show how, the in- vestor Epstein contract, proie(s)the Epstein investor'fraud, scheme. 25. Epstein violate(s) the CEA anti fraud provision(s),, with each ' • EFTA01106133 10/02/2012 02Lg9 2154565953 EINSTEIN TRANSPLANT PAGE 01/01 trading the in credit from the bank investor account, Epsnin marg currency, in the Epstein scheme. scheme, converts) bad faith, extreme fraud 26. The Epstein investor profit, that it account, in the Epstein the massive bank margin cred r ..... defraud(s) each investor account. acconetp provide(s) Epstein with 27. The bank major margin credit the s), Prod each investor, into the fund(s), that Epstein convert( presEit(s)-. Epstein account currency trading each inv- h scheme, remove(s) from 28. The Epstein investor bit fait it bank major margin trading cred estor currency trading account, the investors. with no material disclosure, to the Epstein is paid a flat fee, 29. Epstein stated in the Media, that from each investor account. each investor account cha- 30. The flat fee Epstein statement, from h, by converting the inves- rge, show(s) the Epstein fraud, bad fait Epstein account trading tor bank margin credit sccount, into the use. , the investor looted 31, The Epstein trading profit(s), come(a) from stor, that Ep- defrauded bank,,margin trading crudit,:for each inve rom each investor account stein loot(s) in his trading accoumtts,.f profit. eals) and defraud(s), 32. The Epstein investor contract(s), conc credit. each investor in the bank margin trading it, that Epstein loots, 33. The Epstein extraordinary bank margin cred ein profit, in viola- from each investor account, provide(s) the Epst Fraud Scheme. tion of Federal law. Invest/or Epstein Contract EFTA01106134