On June 20, 2013, the United States Court of Appeals for the Second Circuit issued an opinion in Picard v. JP Morgan Chase & Co., et al. that addressed the ability of a trustee (a “SIPA Trustee”) appointed pursuant to the Securities Investor
Protection Act (“SIPA”) to assert common law claims against financial institutions in connection with the Ponzi scheme perpetrated by Bernard L. Madoff and Bernard L. Madoff Investment Securities LLC (collectively, “Madoff”).
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