Picard v. Estate of Mendelow (In re Bernard L. Madoff Investment Securities LLC)
This memorandum decision addresses a motion by Irving H. Picard, the Trustee for the liquidation of Bernard L. Madoff Investment Securities LLC (BLMIS), seeking leave to amend a complaint against Steven B. Mendelow and other defendants to recover fraudulent transfers. The Trustee's original complaint, filed in 2010, alleged that Mendelow knew or should have known about Madoff's Ponzi scheme. The court outlines the history of the BLMIS Ponzi scheme, Mendelow's role as a sophisticated investor and operator of feeder funds like Telfran, and how he allegedly received guaranteed returns and fictitious profits (Extra P&L) from BLMIS. The decision discusses the impact of evolving pleading standards and the applicability of the Section 546(e) safe harbor on the Trustee's claims. Despite objections from the defendants regarding undue delay and prejudice due to the deaths of key witnesses (Frank DiPascali and Steven B. Mendelow), the court grants the motion to amend, finding that the Trustee's proposed amendment plausibly alleges Mendelow's actual knowledge of the fraud and that this knowledge can be imputed to the other defendants through agency relationships. However, the motion is denied to the extent it seeks to recover transfers predating January 1, 2001, when BLMIS was formed as a limited liability company. Claims against subsequent transferees are dismissed without prejudice.