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

Filing 81

MOTION for Partial Summary Judgment. Document filed by Irving H. Picard. Responses due by 2/9/2012 Return Date set for 2/23/2012 at 04:00 PM.(Sheehan, David)

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
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. 10-05287 (BRL)
Bernard L. Madoff Investment Securities LLC,
Plaintiff,
v.

11-cv-03605-JSR

SAUL B. KATZ, et al.,
Defendants.

NOTICE OF MOTION FOR PARTIAL SUMMARY JUDGMENT

PLEASE TAKE NOTICE that Irving H. Picard (“Trustee”), as trustee for the
substantively consolidated 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 estate of Bernard L. Madoff (“Madoff”), by and through his undersigned
counsel, 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 4:00pm on February 23, 2012 for an Order granting partial summary judgment
(“Motion”) pursuant to Rule 56 of the Federal Rules of Civil Procedure on Count One of the
Trustee’s March 18, 2011 Amended Complaint.
PLEASE TAKE FURTHER NOTICE that consistent with the Court’s Case Management
Plan entered on September 28, 2011, the Trustee’s moving papers shall be served and filed on or
before January 26, 2012, answering papers shall be served and filed on or before February 9,
2012, and reply papers shall be served and filed on or before February 16, 2012. Oral Argument
on the Motion is currently scheduled for February 23, 2012 at 4:00 p.m. as directed by the Court.
Date: January 20, 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

300194823