The database “will disprove what he’s represented throughout the case,” Chaitman said of Picard. “Why wouldn’t he just give us access -- there’s no cost to him.”

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Madoff in his 2009 guilty plea traced his Ponzi scheme to 1992, while prosecutors at a 2014 trial of five Madoff aides said there was never actual trading. Matthew L. Schwartz, one of the prosecutors in the sprawling case, was dismissive of Chaitman’s argument. Madoff didn’t have securities on-hand to sell, forcing his employees to carefully track the balance of the single "slush fund" account at JPMorgan Chase & Co. where all customer money was deposited and withdrawn, he said.

“Bernard Madoff’s fraud was a Ponzi scheme if ever there was one," Schwartz, now a white-collar defense lawyer at Boies Schiller & Flexner, said in an email. "The evidence at trial proved beyond a reasonable doubt that Madoff did not buy and sell securities for his investment advisory clients."

Heather Wlodek, a spokeswoman for Picard, declined to comment. Picard has previously said that Madoff did buy billions of dollars in securities over the life of his firm, including some with cash from the investment advisory business. But the securities weren’t for customers’ benefit, and statements listing such purchases were falsified for years, he’s said.

U.S. Bankruptcy Court Judge Stuart Bernstein recommended at the July 25 hearing that Picard grant Chaitman access to the larger database and put the dispute to rest. It may take one or more trials to decide the issue.

"This has been he-said-she-said for two years," the judge said.

Picard says he’s given Chaitman more than 260,000 documents and 4.7 million pages -- including documents stored on 206 microfilm reels. He says he’s also provided "an itemized accounting of the hard-copy and electronic" data, according to an April filing.

Chaitman counters that Picard’s team falsely claimed a smaller database dubbed E-Data Room 1 was the repository of all relevant trading records. She said she found out only last year about Madoff’s master database, and wants to use the records in her planned depositions of former Madoff traders.

The theory, she said, "will be proven by the trading records -- if I ever get them.”