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Table Of Contents

INTRODUCTION
JURISDICTION AND VENUE
A.PLAINTIFF
B.DEFENDANTS
1.Tremont Entity Defendants
2.Oppenheimer and Massachusetts Mutual Life Insurance
3.Tremont Individual Defendants
4.KPMG Defendants
5.Individual BMIS Defendants
6.Financial Institution Defendants
7.Nominal Defendant
8.Doe Defendants
C.AGENCY/JOINT VENTURE
D.AIDING AND ABETTING
E.CONSPIRACY
FACTUAL BACKGROUND
A.DEVELOPMENT OF THE MADOFF SCHEME
3.BMIS: Early Years
To Feeder Funds and Tighten His Operation
8.BMIS’ London Affiliate
1.The Ponzi Scheme Ends
2.Feeder Funds Failed To Protect Their Investors
Individual BMIS Defendants
Money Through BMIS’ London Affiliate
1.MSIL Was Used to Hide the Ponzi Scheme
3.MSIL Was Used by Madoff to Launder Money
G.THE ROLE AND KNOWLEDGE OF OPPENHEIMER
H.THE ROLE AND KNOWLEDGE OF MASS MUTUAL
INTERNATIONAL
1.KPMG International Annual Review 2008
2.Hedge Funds
1.Frank DiPascali
2.Andrew Madoff
3.Mark Madoff
4.Peter Madoff
5.Annette Bongiorno
6.Paul Konigsberg
Linked Structured Notes to Investors
PLAINTIFF’S INVESTMENT IN THE SCHEME
NEARING THE END
A.The Collapse of BMIS and Exposure of the Fraud
C.Other Professionals Recognized Indications of Fraud
FRAUD AGAINST TREMONT (DERIVATIVE)
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Madoff Complaint

Madoff Complaint

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Published by: BwayJoe on Jun 05, 2011
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08/16/2012

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