Irving H. Picard v. Saul B. Katz et al
Filing
150
SECOND MOTION in Limine To Exclude All Evidence And Arguments Relating To The Inaction And/Or Failures Of The United States Securities And Exchange Commission. Document filed by Irving H. Picard. Return Date set for 3/19/2012 at 09:00 AM.(Sheehan, David)
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
In re:
Adv. Pro. No. 08-01789 (BRL)
BERNARD L. MADOFF INVESTMENT
SECURITIES LLC,
Debtor,
SIPA LIQUIDATION
(Substantively Consolidated)
IRVING H. PICARD, Trustee for the Liquidation of Adv. Pro. No. 10-5287 (BRL)
Bernard L. Madoff Investment Securities LLC,
Plaintiff,
v.
11-cv-03605-JSR
SAUL B. KATZ, et al.,
Defendants.
NOTICE OF TRUSTEE’S MOTION NO. 2 TO EXCLUDE ALL EVIDENCE AND
ARGUMENTS RELATING TO THE INACTION AND/OR FAILURES OF THE
UNITED STATES SECURITIES AND EXCHANGE COMMISSION
PLEASE TAKE NOTICE that Plaintiff Irving H. Picard (“Trustee”), as Trustee for the
liquidation of the business of Bernard L. Madoff Investment Securities LLC (“BLMIS”) under
the Securities Investor Protection Act (“SIPA”), 15 U.S.C. §§ 78aaa et seq., and the substantively
consolidated estate of Bernard L. Madoff (“Madoff”) individually, by and through the Trustee’s
counsel, Baker & Hostetler LLP, will hereby move this Court, before the Honorable Jed. S.
Rakoff, United States District Judge, at the Daniel Patrick Moynihan United States Courthouse,
500 Pearl Street, New York, NY, at 9:00 a.m. on March 19, 2012 for an Order excluding all
evidence and arguments relating to the inactions and/or failures of the United States Securities
and Exchange Commission in the above-captioned matter, pursuant to Rules 401, 402 and 403 of
the Federal Rules of Evidence.
PLEASE TAKE FURTHER NOTICE that pursuant to the Court’s individual rules of
practice, the Trustee’s moving papers were served on March 5, 2012, and shall be filed on March
12, 2012 and answering papers shall be served and filed on March 12, 2012. The first day of trial
is currently scheduled for March 19, 2012 at 9:00 a.m. as directed by the Court.
Date: March 12, 2012
New York, New York
By: /s/ David J. Sheehan
BAKER & HOSTETLER LLP
45 Rockefeller Plaza
New York, New York 10111
Telephone: (212) 589-4200
Facsimile: (212) 589-4201
David J. Sheehan
dsheehan@bakerlaw.com
Fernando A. Bohorquez, Jr.
fbohorquez@bakerlaw.com
Regina L. Griffin
rgriffin@bakerlaw.com
Attorneys for Irving H. Picard, Trustee for the
Substantively Consolidated SIPA Liquidation of
Bernard L. Madoff Investment Securities LLC
and Bernard L. Madoff
2
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