Case 1:16-cv-03989-RJS Document 21 Filed 06/30/16 Page 1 of 3

Case 1:16-cv-03989-RJS Document 21 Filed 06/30/16 Page 1 of 3 Case 1:16-cv-03989-RJS Document 20 Filed 06/29/16 Page 1 of 3 THE MINTZ FRAADE LAW FIRM, P.C. COUNSELORS AT LAW 271 MADISON AVENUE, 121° FLOOR NEW YORK, NEW YORK 10016 TF.LEPHONE. (212)486.2500 TELECOPIER U12)1864701 Via E-mail Hon. Richard J. Sullivan, D.J. United States District Court Southern District of New York Thurgood Marshall United States Courthouse 40 Foley Square, Room 2104 New York, New York 10007 (SullivanNYSDChambers(n?nysd.uscourts.aov) Dear Judge Sullivan: OF COUNSEL EOWARDC. KRAMER JON M. PROBSTEIN SEYMOUR REITKNECHT JOSEPH 1. TOMASEJ( June 29, 2016 .3DN DOCUMENT ELECTRONICALLY FILED DOC 4;: DATE FILED: 6. so _ Re: Steven Jude Hoffenbera v. Jeffrey E. Epstein, et al. (Index No. I :16-cv-039891 Reference is made to the Defendants' letter to the Court (the "Defendants' Letter") which was filed yesterday, June 28, 2016, via the Electronic Case Filing system for the Southern District of New York. We totally disagree with the facts and conclusions which were raised in the Defendants' Letter. To properly resolve the issues raised in the Defendants' Letter, we believe that it is necessary to evaluate the long history between Mr. Jeffrey E. Epstein and Mr. Steven J. Hoffcnberg and their involvement in Towers Financial Corporations' ("TFC") Ponzi fraud, which includes many fraudulent securities offerings of promissory notes and bonds by TFC, (the Page 1 of 3 EFTA01190079 Case 1:16-cv-03989-RJS Document 21 Filed 06/30/16 Page 2 of 3 Case 1:16-cv-03989-RJS Document 20 Filed 06/29/16 Page 2 of 3 "TFC Ponzi Fraud"). It is Mr. Hoffenberg's position that Mr. Epstein's fraudulent actions and engagement in the TFC Ponzi Fraud with Mr. Hoffenberg and TFC resulted in over 200,000 victims and damages of over one billion ($1,000,000,000) dollars directly or indirectly from the purchase of fraudulent securities consisting of promissory notes and bonds from TFC, (the "TFC Victims") and from Mr. Epstein's original and subsequent actions. Moreover, the Defendants' Letter raises several issues which demand joining the TFC Victims in this litigation as co-plaintiffs with Mr. I loffenberg. Councilman George Cushingberry, Jr., Esq., for the City of Detroit, who was the Chairman of the Appropriations Committee for the City of Detroit until 2010, originally introduced Mr. Hoffenberg to the Retirement System City of Detroit, which is now one of the TFC Victims. Mr. Hoffenberg has been in constant communications with Councilman Cushingberry, Jr., Esq.'s Legislative Aide, and friend of Mr. Hoffenberg, Mr David Cavanagh, who recently advised Mr. Hoffenberg that the Retirement System City of Detroit may join this pending lawsuit before this Court to recover over one hundred twenty-five million ($125,000,000) dollars in damages from Mr. Epstein for his fraudulent actions pursuant to the TFC Ponzi Fraud set forth in the Complaint. Page 2 of 3 EFTA01190080 Case 1:16-cv-03989-RJS Document 21 Filed 06/30/16 Page 3 of 3 Case 1:16-cv-03989-RJS Document 20 Filed 06/29/16 Page 3 of 3 In view of the upcoming Fourth of July holiday weekend, we respectfully request additional time until July 12, 2016, to respond to the Defendants' Letter in further detail with respect to this matter in order to ensure that the interests of the TEC Victims are protected. Respectfully submitted, The Mintz Prude Law Firm, PC Alan P. Fraade Plaintiff's request is denied. As required under Rule 2.A. of the Court's Individual Practices, IT IS HEREBY ORDERED THAT Plaintiff shall submit a response to Defendants' pre-motion letter by July 1, 2016. IT IS FURTHER ORDERED THAT the initial conference scheduled for July 15, 2016 at 10 a.m. shall also serve as a pre-motion conference on Defendants' contemplated motion to dismiss. APE/Ilk Cc: Gary H. Baise, Esq. Mr. Steven Hoffenberg Bennet J. Moskowitz, Esq. SO ORDERED smatC Mot J. SULLIVAN 45/30 6 Page 3 of 3 EFTA01190081