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EFTA00826051
in pari delicto, the debtor's misconduct is imputed to the trustee because, "innocent as he may be, he acts as the debtor's representative." In re Bernard L. Madoff Securities, LLC, 721 F.3d 54 (2d Cir. 2013). Picard unsuccessfully argued that the "adverse interest" exception prevented BLMIS's wrongdoing from being impute
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