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10-04285-brl Doc 127 Filed 08/17/12 Entered 08/17/12 14:29:55 Main Document
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Irving H. Picard, as trustee (“Trustee”) for the substantively consolidated liquidation of
the business of Bernard L. Madoff Investment Securities LLC (“BLMIS”) and the estate of
Bernard L. Madoff (“Madoff”), under the Securities Investor Protection Act (“SIPA”), 15 U.S.C.
§§ 78aaa et seq., by his undersigned counsel, hereby submits this consolidated opposition to the
April 27, 2012 motions to dismiss the Amended Complaint for lack of personal jurisdiction filed
by the following defendants (collectively, the “Moving Defendants”):
� Luxalpha: Luxalpha Sicav, as represented by its Liquidators Maitre Alain
Rukavina and Mr. Paul Laplume, and Maitre Alain Rukavina and Mr. Paul Laplume, in their
capacities as liquidators and representatives of Luxalpha Sicav (collectively, “Luxalpha”);
� The Moving UBS Defendants: UBS (Luxembourg) S.A. (“UBS SA”), UBS
Fund Services (Luxembourg) S.A. (“UBSFSL”), and UBS Third Party Management
Company S.A. (“UBSTPM”) (collectively, the “Moving UBS Defendants”);
� The Moving Luxalpha Director Defendants: Alain Hondequin, Hermann
Kranz, Rene Egger, and Ralf Schroeter (collectively, the “Moving Luxalpha Director
Defendants”);
� The Moving Access Defendants: Access International Advisors Europe Limited
(“AIA Europe”), Access International Advisors Ltd. (“AIA Ltd.”), Access Management
Luxembourg SA (f/k/a Access International Advisors (Luxembourg) SA) (“AML” or “AIA
(Lux)”), Access Partners SA (“AP (Lux)”), and Access Partners (Suisse) SA (“AP (Suisse)”)
(collectively, the “Moving Access Defendants”); and
� Pierre Delandmeter (“Delandmeter”).
This consolidated opposition also opposes Luxalpha’s motion to dismiss for forum non
conveniens, which is not joined by any other Defendant.