Participants in the Madoff investment scandal Stanley Chais, a philanthropist who invested heavily with Mr. Madoff, and Carl J. Shapiro, one of the money manager's oldest friends, are among at least eight Madoff investors and associates being scrutinized by the U.S. attorney's office in Manhattan. Prosecutors are continuing to probe Madoff family members and employees. Others include: Frank Avellino, a Florida accountant who ran an investment fund that invested client money; Noel Levine, a real-estate investor who works out of a two-room office on the 17th floor, next door to Madoff's fraudulent investment operation, and Palm Beach investor Robert Jaffe, a son-in-law of Mr. Shapiro who
Fraudulent trading order for fraudulent trading to subrogated to any claim that the company might have with respect to a fraudulent conveyance. In practice, applications for orders in respect of fraudulent trading are rare because of the high burden of proof associated with fraud. Usually, even where fraudulent trading is suspected, an application is made with respect to an allegation of "wrongful trading" (or "insolvent trading") where the burden of proof is lower. Where applications are brought for fraudulent trading, it is usually because when the trading occurred, the company was not insolvent at that time (insolvency at the time of the