FILE - In this Monday, March 19, 2012, photo, David Sheehan, representing the trustee for Bernard Madoff's fraud victims, leaves federal court in New York. Irving Picard, the trustee appointed to recover funds for Madoff victims, and a battalion of lawyers headed by Sheehan have spent long days untangling Madoff's fraud. On the fourth anniversary of Madoff's Dec. 11, 2008, arrest, it's an international effort that shows no signs of slowing. (AP Photo/Seth Wenig)
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