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

Filing 85

DECLARATION of Lisa M. Collura in Support re: 81 MOTION for Partial Summary Judgment.. Document filed by Irving H. Picard. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7 Exhibit 7, # 8 Exhibit 8, # 9 Exhibit 9, # 10 Exhibit 10)(Bohorquez, Fernando)

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 Civ. 03605 (JSR) (HBP)

SAUL B. KATZ, et al.,
Defendants.

DECLARATION OF
LISA M. COLLURA

I, Lisa M. Collura, declare under penalty of perjury:
1.

I am Lisa M. Collura, a Managing Director in the Forensic and Litigation

Consulting practice of FTI Consulting, Inc. (“FTI”) and a retained expert in the above captioned
matter. I submit this Declaration in support of the motion for partial summary judgment brought
by Irving H. Picard (“Trustee”), 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”).
2.

Attached as Exhibit 1 is a true and correct copy of my Expert Report dated

November 22, 2011, and submitted to Defendants on or about November 22, 2011 (the “Expert
Report”). I hereby incorporate by reference the contents of the Expert Report as my sworn
testimony as if fully rewritten herein.
3.

I described my retention in this matter in my Expert Report at ¶¶ 4-8.

4.

A true and correct description of my background and qualifications are set forth in

the Expert Report, ¶¶ 1-3.
5.

The findings, statements, conclusions and opinions rendered in the Expert Report

and the bases thereof are detailed in various sections of my Expert Report, including but not
limited to ¶¶ 9-63, which identify the (a) the methodology that I employed and/or supervised in
connection with the analyses performed, and (b) the sources of information and data that form
the basis of my findings, conclusions and opinions.
6.

The information sources and data reviewed by myself and those under my

direction at FTI include voluminous documents concerning the Defendants’ BLMIS accounts
including BLMIS’ books and records, BLMIS customer files, and various bank records and