EFTA Document EFTA01386769

Case 1:18-cv-07580 Document 1 Filed 08/20/18 Page 24 of 26 or use of Epstein and/or the Defendant Entities. 123. TFC, Plaintiffs and the Class reasonably relied upon the Ponzi schemes, which were created and executed by Epstein, and that such schemes were in the best interests of TFC, Plaintiffs and the Class. 124. Plaintiffs and the Class became aware of the fraud and Ponzi scheme and the subsequent conviction of Hoffenberg and made all reasonable efforts to recover their lost monies,