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Squadron Madoff

Squadron Madoff

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Published by adamlisberg
Court filing by Madoff trustee against Squadron family.
Court filing by Madoff trustee against Squadron family.

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Published by: adamlisberg on Jan 15, 2012
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04/13/2014

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EXHIBIT A
Case 1:11-cv-08900-JSR Document 1-1 Filed 12/06/11 Page 1 of 31
 
WINDELS MARX LANE & MITTENDORF,LLP
156 West 56th Street New York, NY 10019212-237-1000Howard L. SimonRegina GriffinStaceyA. Bell
Special Counsel to Irving H. Picard,Trustee for theSubstantively Consolidated SIPA Liquidation of  Bernard L. Madoff Investment Securities LLC and Bernard L. Madoff 
UNITED STATES BANKRUPTCY COURTSOUTHERN DISTRICT OF NEW YORK 
SECURITIES INVESTOR PROTECTIONCORPORATION,Plaintiff-Applicant,v.BERNARD L. MADOFF INVESTMENTSECURITIES LLC,Defendant.Adv. Pro. No. 08-01789 (BRL)SIPA LIQUIDATION(Substantively Consolidated)In re:BERNARD L. MADOFF,Debtor.IRVING H. PICARD, Trustee for the Liquidation of Bernard L. Madoff InvestmentSecurities LLC,Plaintiff,v. NTC & Co. LLP, as former custodian of anIndividualRetirement Account for the benefit of ANNE SQUADRON, ANNE STRICKLANDSQUADRON, SETH SQUADRON,ELIZABETHSQUADRON, DANIEL SQUADRON, WILLIAMSQUADRON,DEBRA LAGAPA, RICHARDSQUADRON,THEODOSIA PRICE, DIANESQUADRON,THOMAS SHEA, PETER GOLD,CAROL GOLD, SARAH D. GOLD, SWINGHARRE,DAVID HARRE, VANESSA N. GANG,ANNA ROTHWELL, ROBERT VASDIASandMARGARET BUTCHER,Defendants.Adv. Pro. No. 10-__________ (BRL)
Case 1:11-cv-08900-JSR Document 1-1 Filed 12/06/11 Page 2 of 31
 
-2 -
COMPLAINT
Irving H. Picard (the “Trustee”), as trustee for the liquidation of the business oBernardL. Madoff InvestmentSecurities LLC (“BLMIS”) under the Securities Investor Protection Act, 15 U.S.C. §§78aaa,
et seq
. (“SIPA”),
1
and the substantively consolidated estateofBernard L. Madoff individually (“Madoff”), by and through his undersigned counsel, for hiscomplaint (the “Complaint”), states as follows:
NATURE OF PROCEEDING
1.This adversary proceeding arises from the massive Ponzi scheme perpetrated byMadoff. Over the course of the scheme, there were more than 8,000 client accounts at BLMIS.In early December 2008, BLMIS generated client account statements for its approximately 4,900open client accounts. When added together, these statements purport that clients of BLMIS hadapproximately$65 billion invested with BLMIS. In reality, BLMIS had assets on hand worth asmall fraction of that amount. On March 12, 2009, Madoff admitted to the fraudulent schemeand pled guilty to 11 felony counts, and was sentenced on June 29, 2009 to 150 years in prison.The within defendant Anne Strickland Squadron (“Defendant”) was a beneficiary of this schemewho received avoidable transfers directly from BLMIS and indirectly through NTC & Co. LLP(“NTC”) and the estate of her late husband, Howard M. Squadron (the “Estate of Howard M.Squadron”).2.Upon information and belief, Defendant and her late husband, Howard M.Squadron, maintained close personal relationships with Madoff. They were among Madoff’searliest investors holding a BLMIS account (AccountNo. 1S0135) since the mid 1980s. For nearly three decades, Defendant, her family members, and entities controlled by them, held at
1
For convenience, future reference to SIPA will not include “15 U.S.C.”
Case 1:11-cv-08900-JSR Document 1-1 Filed 12/06/11 Page 3 of 31

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