A New York state judge has ruled that Citadel can subpoena two senior Marshall Wace executives, Anthony Clake and Alan Hofmeyr, as part of a sprawling legal fight over the hedge fund's recruitment of former Citadel portfolio manager Daniel Shatz. The judge also ordered Marshall Wace to broaden its search for documents tied to Shatz's hiring, deepening the dispute.
As reported by Bloomberg, the ruling found that Clake and Hofmeyr are covered by Citadel's subpoena, and Justice Andrea Masley ordered Marshall Wace to widen its document search related to Shatz's hiring. Shatz, who was hired as Marshall Wace's global credit head, joined the firm in 2024 after completing a 15-month garden-leave period away from Citadel, according to a court filing.
Citadel had asked the court to order Marshall Wace to turn over communications about Shatz's hire involving Clake and Hofmeyr, both described as senior Marshall Wace executives, according to Business Insider. Citadel alleges that the pair were heavily involved in recruiting Shatz and that they met with him in London during his noncompete period, the outlet reported, though that allegation carries only medium confidence in the underlying evidence.
A Dispute Rooted in Allegations of Stolen Secrets
The underlying arbitration, identified in court papers as Shatz v. Citadel Americas Services LLC before the American Arbitration Association, centers on dueling accusations. Citadel maintains that Shatz breached his employment agreement by taking confidential information before leaving the firm, per the same court filing cited by Hedgeweek. Shatz, for his part, alleges that Citadel withheld an eight-figure deferred compensation award after his departure in retaliation for concerns he raised about potential securities violations, according to the same account.
Those allegations remain attributed claims rather than adjudicated findings in the record reviewed so far. The broader competition for credit talent has also drawn in other firms, with Point72, Millennium, and Jain Global named among hedge funds vying for similar expertise, per a separate Hedgeweek report.
Escalating Subpoena Fight
The subpoena dispute has involved a series of legal steps. On January 27, 2026, the arbitration panel issued hearing subpoenas to Marshall Wace, quant trading head Nicholas Nielsen, and Joshua Lercher, according to a Bloomberg Law court document. Marshall Wace, Nielsen, and Lercher responded by filing a New York Supreme Court petition on February 5, 2026, seeking to quash three Citadel subpoenas or obtain a protective order.
Citadel moved to compel enforcement of its subpoenas on February 10, 2026, the filing states.
Marshall Wace Calls Demands Overbroad; Citadel Alleges Stonewalling
Marshall Wace has pushed back hard on the scope of what Citadel is asking for. The firm has characterized the discovery demands as involving overbroad and burdensome searches, according to Bloomberg's reporting on the matter. Citadel, in turn, has accused Marshall Wace of failing to comply with an earlier court order, per Business Insider's account.
A New York Supreme Court filing concerning subpoena enforcement addressed documents and testimony. The ruling that Clake and Hofmeyr must now participate marks a win for Citadel in its effort to widen the discovery net beyond the firm itself and its lower-level employees.
What the final outcome of the underlying arbitration will be remains unresolved, and the evidence reviewed does not establish how many documents will ultimately be produced under the broadened search Justice Masley ordered.
