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Walter Noel's messy legal situation just got messier. Irving Picard, the court-appointed trustee responsible for liquidating Bernie Madoff's investment firm and recouping funds for Madoff's victims, just filed a $3.2 billion lawsuit against Noel's firm, Fairfield Greenwich Group. So while Noel may get a chance to play golf in the Hamptons this summer, he's clearly going to have to learn how to swing a club and talk to his lawyer on his cellphone at the same time. [NYT]