Such an attack is easily sustained if, as the Ehrlichs do, the technique is to sum up a complex view in a sentence and then attack it as parody.

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In July, 2009 Madoff began serving a 150-year prison sentence at the Butner Federal Correctional complex in North Carolina.

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"It deals with complex subject matter, but in a single sentence the law authorized the courts to go off" and create a body of interpretations, says Mr. McConnell.

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Madoff is imprisoned in Butner Federal Correctional Complex in North Carolina for a 150-year sentence for the largest investment fraud in U.S. history.

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But the defence team said the case was so complex the only person able to pass a realistic sentence was the judge who had listened to all three months of the trial.

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