June 10, 2009 Complaint against Irving Picard
Complaint of Diane and Roger Peskin and Maureen Ebel for declaratory judgment on “net equity,” for declaratory judgment that Picard cannot recover preferences; and for damages for Picard’s breach of fiduciary duty
August 17, 2009 Memorandum of Law
Memorandum of Law of Phillips Nizer LLP in opposition to Picard’s motion to dismiss the complaint
Declaration of Helen Davis Chaitman in oposition to Picard’s motion to dismiss the complaint
September 1, 2009 Peskin Amended Complaint
Amended complaint of Diane and Roger Peskin and Maureen Ebel seeking declaration that the Peskins are each entitled to $500,000 in SIPC insurance, etc. August 3, 2009 Objection
Phillips Nizer objection to the first fee application of Picard and Baker & Hostetler LLP on grounds that they have a conflict of interest
August 3, 2009 Exh. A to Objection
March 10, 2009 Information filed by the United States of America against Bernard L. Madoff
August 3, 2009 Exh. B to Objection
Testimony of SEC Commissioner Mary Schapiro before the House Subcommittee on Capital Markets, Insurance and Government Sponsored Enterprises on July 14, 2009
August 3, 2009 Exh. C to Objection
Picard’s Hardship Program as reflected on madofftrustee.com
August 3, 2009 Exh. D to Objection
Report from the Committee on Banking and Currency, 91st Cong. 2d Sess. September 21, 1970
August 3, 2009 Exh. E to Objection
July 28, 2000 transcript of proceedings in New Times Securities Services, Inc. before Judge Bernstein
August 3, 2009 Exh. F to Objection
1973 Third Annual Report of SIPC
August 3, 2009 Exh. G to Objection
August 3, 2009 Declaration of Rodger Peskin in support of objection to first fee application of Picard and Baker & Hostetler LLP
August 3, 2009 Exh. H to Objection
The Peskins’ SIPC claim
August 3, 2009 Exh. I to Objection
August 3, 2009 declaration of Diane Peskin in support of objection to first fee application of Picard and Baker & Hostetler LLP
August 3, 2009 Exh. J to Objection
June 26, 2009 letter from David Sheehan to Helen Davis Chaitman agreeing to preserve Ebel’s claim for $102,000 to be withheld by Picard
August 3, 2009 Exh. K to Objection
July 16, 2009 determination letter from Picard to the Peskins
August 3, 2009 Exh. L to Objection
July 21, 2009 letter from Helen Davis Chaitman to Picard requesting revision of Peskin partial assignment and release to preserve Peskins’ claim for an additional $500,000
August 3, 2009 Exh. M to Objection
August 3, 2009 declaration of Maureen Ebel in support of the objection to Picard’s first fee application
August 3, 2009 Exh. N to Objection
May 20, 2009 determination letter from Picard to Ebel
August 30, 2009 Exh. O to Objection
June 9, 2009 determination letter from Picard to Ebel
August 3, 2009 Exh. P to Objection
June 16, 2009 letter from Helen Davis Chaitman to Irving Picard accepting Picard’s offer to pay Ebel $398,000 with her reserving her right to the remaining $102,000.
August 3, 2009 Exh. Q to Objection
June 23, 2009 letter from David Sheehan to Helen Davis Chaitman acknowledging that Picard will apply any adverse ruling on net equity to all customers, even those whose claims have already been determined.
August 3, 2009 Exh. R to Objection
June 23, 2009 letter from Helen Davis Chaitman to David Sheehan demanding that the Peskins and Ebel be paid the undisputed portion of their SIPC insurance
August 3, 2009 Exh. S to Objection
June 26, 2009 letter from David Sheehan to Helen Davis Chaitman regarding the determination of the claims of the Peskinsand Ebel
August 3, 2009 Exhibit T to Objection
June 29, 2009 letter from Helen Davis Chaitman to David Sheehan re determinations of the claims of the Peskins and Ebel
August 14, 2009 Memorandum of Law
Phillips Nizer brief in support of objection to the first fee application of Picard and Baker & Hostetler LLP
Transcript of oral argument before Judge Lifland on the first fee application of Irving Picard and Baker & Hostetler LLP
