Case Explained: In re ELEONORA L. ZETTELER, LLM, In her capacity as insolvency practitioner in the insolvency

Court: United States Court of Appeals for the Fourth Circuit Filed: 2026-06-15 The Fourth Circuit denied the petitioners’ request for a writ of mandamus under the Crime Victims’ Rights Act (CVRA), 18 U.S.C. § 3771, affirming the district court’s exclusion of the Dutch insurance company Conservatrix from the restitution order in the criminal case against Greg E. Lindberg. The court held that to qualify as a “victim” entitled to restitution under the CVRA, an entity must demonstrate harm that is “directly and proximately” caused by the federal offense, requiring the injury to be “closely related to the conduct inherent to the offense, rather than merely tangentially linked.” Applying this standard of review for abuse of discretion, the court found that the petitioners failed to sufficiently connect Conservatrix’s financial losses to Lindberg’s specific criminal conduct. The court noted that while Lindberg failed to meet capital replenishment and solvency ratio agreements, the petitioners did not identify facts tying these breaches directly to the fraud, conspiracy, or money laundering activities charged in the indictment; rather, the Special Master determined the harm stemmed from Lindberg’s self-serving investment activities which were not the crux of the criminal offenses. Consequently, the district court did not abuse its discretion in denying restitution to Conservatrix. The practical consequence is that the petition for mandamus is denied without prejudice to further proceedings, and the district court’s preliminary restitution order excluding Conservatrix remains in effect. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.