Irving Picard of Baker & Hostetler, the liquidation trustee for fraudster Bernie Madoff’s former firm, suffered a new setback late Tuesday in his bankruptcy court fight with J. Ezra Merkin and the Madoff investment vehicles he managed.

In a 66-page ruling, U.S. Bankruptcy Judge Stuart Bernstein in Manhattan dismissed nine out of 13 claims in a long-running lawsuit in which Picard sought to claw back millions from Merkin and the so-called feeder funds he managed. Bernstein found that Merkin, who profited handsomely from directing more than $2 billion in investor money to Madoff, lacked actual knowledge of Madoff’s fraud.