On behalf of UniCredit S.p.A., Skadden secured the dismissal of claims by Irving Picard, the trustee for the Securities Investor Protection Act liquidation of Bernard L. Madoff Investment Securities LLC, seeking to recover funds transferred from Madoff Securities to certain foreign customers and in turn transferred to the defendants. On July 6, Judge Jed Rakoff of the U.S. District Court for the Southern District of New York agreed with the defendants' argument that Section 550(a)(2) of the Bankruptcy Code, the provision allowing for such recovery, does not apply extraterritorially.

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