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TENTH CAUSE OF ACTIONDISALLOWANCE OF MRS. MADOFF’S CLAIMS - 11 U.S.C. § 502(b) and (d)99. The Trustee incorporates by reference the allegations contained in the previousparagraphs of this Complaint as if fully rewritten herein.100. By Proof Of Claim, dated June 30, 2009 and received July 2, 2009, Mrs. Madofffiled a claim in this proceeding (the “Claim”). Mrs. Madoff’s claim was filed as “a contingentand unliquidated claim” in connection with four pending actions “seeking contribution,indemnification and/or reimbursement” for any damages awarded against her in those actions.101. Mrs. Madoff’s Claim is not supported by the books and records of BLMIS nor theclaim materials submitted by Mrs. Madoff, and, therefore, should be disallowed pursuant tosection 502(b) of the Bankruptcy Code.102. The Claim also should not be allowed as a customer claim or as a generalunsecured claim. Mrs. Madoff is the recipient of transfers of BLMIS’ property which arerecoverable under sections 544, 548, and 550 of the Bankruptcy Code and 15 U.S.C. § 78fff-2(c)(3), and Mrs. Madoff has not returned the Transfers to the Trustee. As a result, pursuant tosection 502(d) of the Bankruptcy Code, the Claim must be disallowed unless and until Mrs.Madoff return the Transfers to the Trustee.Claim.103. As a result of the foregoing, the Trustee is entitled to an order disallowing the-25-