What is the current state of the law on "similar to" a similar to a similar-to-any agreement?

MultiRegion, United States of America

The following excerpt is from Picard v. Ida Fishman Revocable Trust (In re Bernard L. Madoff Inv. Sec. LLC), 773 F.3d 411 (2nd Cir. 2014):

or adopted the broad similar to catch-all in subsection (vii) or the any ... arrangement ... related to any agreement ... language in subsection (xi). See Penn. Dep't of Pub. Welfare v. Davenport, 495 U.S. 552, 562, 110 S.Ct. 2126, 109 L.Ed.2d 588 (1990).

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