Madoff victims may share in $2.35B federal fund

``Courts have ruled that indirect Madoff investors are not allowed to seek recovery from the trustee... Approximately $2.2 billion of the new victim fund announced by prosecutors came via a Dec. 2010 civil forfeiture recovery from the estate of deceased Madoff investor Jeffry Picower, said Bharara. The remaining funds were collected via civil forfeiture actions against investor Carol Shapiro and separate actions against Madoff, his brother, Peter and accused co-conspirators.''