smb Doc Filed 01/22/19 Entered 01/22/19 19:23:29 Main Document Pg 1 of 3

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1 Pg 1 of 3 UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK SECURITIES INVESTOR PROTECTION CORPORATION, Plaintiff-Applicant, v. BERNARD L. MADOFF INVESTMENT SECURITIES LLC, Adv. Pro. No (SMB) SIPA Liquidation (Substantively Consolidated) In re: Defendant. BERNARD L. MADOFF, Debtor. DECLARATION OF VINEET SEHGAL IN SUPPORT OF THE TRUSTEE S TWENTY-SIXTH OMNIBUS MOTION TO DISALLOW CLAIMS AND OVERRULE OBJECTIONS OF CLAIMANTS WHO HAVE NO NET EQUITY I, Vineet Sehgal, pursuant to 28 U.S.C. 1746, declare as follows: 1. I am a Managing Director at AlixPartners LLP ( AlixPartners ), a consultant to, and claims agent for, Irving H. Picard as trustee (the Trustee ) for the substantively consolidated liquidation of the business of Bernard L. Madoff Investment Securities ( BLMIS ) and Bernard L. Madoff. 2. In December, 2008, AlixPartners was retained by the Trustee as the Trustee s claims agent. As the claims agent, AlixPartners was responsible for both mailing the notice of the liquidation and claim forms to potential claimants and causing the notice of the liquidation to be published. AlixPartners has also been responsible for processing all claims submitted to the Trustee and assisting the Trustee in reviewing each customer claim filed to determine whether the asserted claim amount agrees with the net equity for that account. In addition, as the accountants for the BLMIS estate, AlixPartners has assisted and continues to assist the Trustee in

2 Pg 2 of 3 accounting for the assets of the BLMIS estate, including the cash and cash equivalents available to the Trustee. 3. I have been actively involved in the liquidation of BLMIS and the claims process since December 2008 and have personal knowledge of the matters set forth herein. 4. I submit this Declaration based upon the information and knowledge acquired during the course of my retention and in support of the Trustee s Twenty-Sixth Omnibus Motion to Disallow Claims and Overrule Objections of Claimants Who Have No Net Equity (the Motion ) At the Trustee s direction, my colleagues at AlixPartners and I have reviewed the books and records of BLMIS. During the course of my involvement in this matter, I have personally reviewed thousands of documents, as well as schedules prepared and information collected by my colleagues, relating to the books and records of BLMIS, third party records, bank records and other documentation relevant to BLMIS and its customer accounts and information systems. I have reviewed the books and records of BLMIS and the customer claims filed, analyzing the cash deposit activity, cash withdrawal activity, and transfers between accounts. 6. I make this Declaration to verify to the Court that, as consultant to the Trustee and claims agent in the above-captioned case, after conducting a diligent review of BLMIS books and records, we have identified eight (8) Objections, which dispute the Trustee s Net Investment Method, the Inter-Account Method, and/or request a Time-Based Damages Adjustment or Tax- Based Adjustment. The Objections are in alphabetical order on Exhibit A as well as in BLMIS account number order on Exhibit B. 1 Capitalized terms used herein and not otherwise defined shall have the meanings ascribed to them in the Motion

3 Pg 3 of 3 and correct. Pursuant to 28 U.S.C. 1746, I declare under penalty of perjury that the foregoing is true Executed on January 22, 2019 New York, New York Vineet Sehgal Managing Director AlixPartners, LLP 909 Third Avenue New York, New York

4 smb Doc Filed 01/22/19 Entered 01/22/19 19:23:29 Exhibit A Pg 1 of 1 IN RE: BLMIS. CASE NO: (SMB) TWENTY-SIXTH OMNIBUS MOTION: EXHIBIT A CLAIMS AND OBJECTIONS Objection Party Aspen Fine Arts Co. Defined Contribution Plan Barbara Schlossberg Lynn Ott / Robert Rosenberg (Deceased) Claim Number Objection To Determination Docket Number Counsel Account Name Account Number 708 Milberg LLP 1EM Milberg LLP 1EM Milberg LLP 1EM Milberg LLP Barbara Schlossberg 1ZG Kohrman Jackson & Krantz PLL Millennium Trust Company, LLC FBO Robert Rosenberg (36885) Lynn Ott / Robert Rosenberg (Deceased) 2833 Kohrman Jackson & Krantz PLL Millennium Trust Company, LLC FBO Robert Rosenberg (36885) Phyllis A. Poland McLaughlin & Stern, LLP Phyllis A Poland 1P0038 The Adina Michaeli Revocable Trust Milberg LLP NTC & Co. FBO Ursula Michaeli (Dec'D) 1ZR305

5 smb Doc Filed 01/22/19 Entered 01/22/19 19:23:29 Exhibit B Pg 1 of 1 IN RE: BLMIS. CASE NO: (SMB) TWENTY-SIXTH OMNIBUS MOTION: EXHIBIT B CLAIMS AND OBJECTIONS Claim Number Objection To Determination Docket Number 1788 Objection Party Account Name Account Number Counsel Date of Objection Lynn Ott / Robert Rosenberg (Deceased) Millennium Trust Company, LLC FBO Robert Rosenberg (36885) Kohrman Jackson & Krantz PLL 1/20/ Lynn Ott / Robert Rosenberg (Deceased) Millennium Trust Company, LLC FBO Robert Rosenberg (36885) Kohrman Jackson & Krantz PLL 7/30/ EM320 Milberg LLP 11/11/ EM320 Milberg LLP 11/18/ Aspen Fine Arts Co. Defined 1EM320 Milberg LLP 3/11/ Phyllis A. Poland Phyllis A Poland 1P0038 McLaughlin & Stern, LLP 4/8/ Barbara Schlossberg Barbara Schlossberg 1ZG022 Milberg LLP 11/11/ The Adina Michaeli Revocable Trust NTC & Co. FBO Ursula Michaeli (Dec'D) 1ZR305 Milberg LLP 4/16/2010