“A memo by U.S. District Judge Jed Rakoff lambasting a secret settlement involving New York’s Museum of Modern Art and the Solomon R. Guggenheim Museum has become the talk of the Holocaust restitution community. The museums announced a confidential pact with a German historian named Julius H. Schoeps and his relatives on Feb. 2…. Seven weeks later, in a six-page written judicial opinion tinged with sarcasm, Rakoff questioned the motives of both sides.”