On August 25th, the Southern District Court for New York severed and dismissed a foreign investors lawsuit against a foreign investment fund that invested fund assets in Bernard Madoff's Ponzi scheme. Plaintiffs named Madoff CFO Frank DiPascali and various foreign investment advisers and banks as defendants. The foreign defendants moved to sever the claims against them from those filed against DiPascali and to dismiss for forum non conveniens. Granting severance, the Court held that DiPascali was a defendant in name only. Granting dismissal for forum non conveniens, the Court held that the documents and witnesses are mostly located in Switzerland, which has an interest in the case and whose courts can adequately address the issues. Erausquin v. Notz, Stucki Management (Bermuda) Ltd.