Irving H. Picard v. Saul B. Katz et al

Filing 158

FOURTH MOTION in Limine To Exclude All Evidence and Arguments Relating to the BLMIS-Merrill Lynch Technology Partnership. 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 IN LIMINE NO. 4 TO EXCLUDE ALL EVIDENCE
AND ARGUMENTS RELATING TO THE BLMIS-MERRILL LYNCH TECHNOLOGY
PARTNERSHIP
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 BLMIS-Merrill Lynch Technology Partnership 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: [phone]
Facsimile: [phone]
David J. Sheehan
[e-mail]
Fernando A. Bohorquez, Jr.
[e-mail]
Regina L. Griffin
[e-mail]
Attorneys for Irving H. Picard, Trustee for the
Substantively Consolidated SIPA Liquidation
of Bernard L. Madoff Investment Securities
LLC and Bernard L. Madoff

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