(Be warned, link will direct you to picture of Kohn and we cannot be held responsible for loss of eyesight or motor skills that may result from it being viewed. Yes that is a woman, we think.)
Irving H Picard, the court-appointed trustee seeking to recover money for Mr Madoff's investors, alleges that Sonja Kohn, the former president of Bank Medici, masterminded the funnelling of billions of dollars to the New York-based investment company.
Ms Kohn is alleged to have begun the deception soon after she met Mr Madoff in 1985.
"More than $9bn of the Ponzi scheme's stolen capital is directly attributable to Kohn and the Medici enterprise," claimed Timothy Pfeifer, of Baker & Hostetler, the law firm representing Mr Picard. In return, Ms Kohn and her family allegedly received more than $62m from Mr Madoff.
The lawsuit is the latest in a flurry from Mr Picard, who is trying to retrieve more than $15bn from those he claims helped perpetuate the biggest Ponzi scheme in history.