Irving H. Picard v. Saul B. Katz et al
Filing
82
MOTION to Strike the Expert Report and Testimony of John Maine. 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: (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
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 TO STRIKE THE EXPERT REPORT AND TESTIMONY OF
JOHN MAINE
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 pursuant to Rule 702 of the Federal Rules of
Evidence, striking the report and testimony of John Maine, who has been offered by Defendants
as an expert in the above-captioned matter.
PLEASE TAKE FURTHER NOTICE that pursuant to the Court’s direction, 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: (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
300194823
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