A complaint by a Florida-based foundation seeking $30 million in damages from Merrill Lynch claims the Wall Street financial advisory firm was taken in by Bernard Madoff at a face-to-face meeting months before his investment empire collapsed in fraud.

The MorseLife Foundation alleges Merrill Lynch was negligent and breached its fiduciary duty by failing to advise the foundation to pull its money from what ended up being the largest Ponzi scheme in U.S. history.