EFTA Document EFTA01386768

Case 1:18-cv-07580 Document 1 Filed 08/20/18 Page 23 of 26 TFC to suffer tremendous financial loss. 115. Beginning in or around 1987 and through the present, Epstein, in breach of his obligations, negligently transferred securities and cash from assets or accounts in TFC, properly belonging to Plaintiffs and the Class who invested in TFC Bonds and TFC Promissory Notes, into the Defendant Entities. 116. As a direct and proximate consequence of Epstein's negligence, individually, and by a