Alfonso, a 46-year-old chef from Malaga, arrived in Cardiff last autumn after his online business began to lose money and offers of work in local hotels dried up.

BBC: Rise in Spaniards moving to Wales in search of work

And Rakoff said courts for good reason do not allow lawsuits based on indirect damages, such as the losses of investors who were only able to lose money with Madoff because he was still in business due to earlier investments by others.

FORBES: Rakoff Dismisses More Claims By Madoff Trustee