AU.S. Appeals Court has provided renewed hope for the Trustee
tasked with recovering billions of dollars for victims of Bernie
Madoff’s massive Ponzi Scheme, ruling that a district court
applied an incorrect (and more difficult) standard in preventing
the Trustee from recovering subsequent recipients of transfers from
the now-defunct investment company. In Picard v. Citibank
 20-01333, Second U.S. Circuit Court of Appeals
(Manhattan), published on August 30, 2021, the Second Circuit
revived two lawsuits filed by Trustee Irving
Picard1 against various recipients of allegedly
fraudulent transfers from Madoff’s firm after concluding that
the district court erred in applying a stricter pleading standard.
The decision promises to have sweeping ramifications going forward
and further increases the possibility that Madoff’s victims
could recover 100% of their losses through the Trustee’s

Following Madoff’s arrest, the…

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