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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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37:11–12; 98 at 7.) Access’s coordinated activity was directed by Littaye and Villehuchet out of
the New York office. Marketing materials prepared by Access’s New York office refer to
Access as a single company that was “[b]ased in New York City, with additional European
offices in Paris, London and Luxembourg.” (Pergament Decl. Ex. 99 at 3.) Nearly all Access
personnel, including Littaye and Villehuchet, attended Quarterly Strategic Meetings in New
York, where they discussed changes relating to the structure and management of Access.
(Pergament Decl. Exs. 89 at 41:23–43:12; 100-102.) These meetings, which were often attended
by potential or current Access clients and investors, featured substantive discussions and
presentations regarding Access’s business, including discussions of Access’s involvement with
BLMIS-related funds and the duties of the various Access affiliates with regard to these funds.
(Id.) The Quarterly Strategic Meetings also included a special “executive session,” during which
Littaye, Villehuchet, and other Access managers discussed Access’s operational policies,
including budgets for the upcoming year, salaries, and hiring decisions. (Pergament Decl. Ex. 89
at 110:20–111:13.) Access’s New York office purported to perform all of the due diligence,
monitoring, strategy formation, and risk assessment duties for the Madoff-related investments.
(Pergament Decl. Exs. 89 at 30:3–31:25, 39:16–21, 47:4–49:8, 57:9–58:16, 74:20–76:10, 81:21–
82:6; 88 at 22:23–23:10.)
2. Access Ignored Corporate Formalities with Regard to Its
International Affiliates and Treated Its Business as One Entity
Littaye, Villehuchet, and other Access personnel ignored the corporate separateness of
the various Access entities and, in internal and external documents, held themselves out as one
New York-based entity with multiple offices, variously referred to as Access Group, Access
International Advisor Group, Access International Advisors, or simply Access. For example,
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