Loper was also recused as judge in Bibbs's trial. The Interim U.S. Attorney, Geoffrey Berman, was recused. However, the case dragged because six judges recused. The city councilperson who is a member of Bethel recused herself from voting. Sessions denied this, saying that he recused himself from the case. Bush recused himself from any official role in the recount. Shortly thereafter, she recused herself from the investigation. On May 12, 2008, the California Supreme Court ruled that Zonen need not be recused. He then recused himself from the investigation. Later, Mishra recused himself from the case. In June 2009, in response to a motion filed by Arpaio's lawyers, she recused herself. Marshall instead recused himself, citing a conflict of interest. In April 2009, Richards recused herself from the Madoff investigation. On October 29, 2013, she recused herself from the investigation without explanation. On June 15, 2008, it was reported that Kozinski had recused himself from the case.