Declaration Of Helen J. Hodges In Support Of Lead Counsel's ...

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Deponent Entity Date[s] Location Nom. By Lead Counsel Attorney Sargent, Patrick A&K 03/07/06-03/08/06 Dallas Defs J. Lowther Bailey, David 30(b)(6) Deutsche Bank 03/08/06-03/09/06 NYC Plfs M. Siben Sullivan, Daniel A&K 03/21/06-03/22/06 Dallas Defs J. Lowther McFarling, Muriel Cheri A&K 03/28/06 Dallas Defs S. Hays Popplewell, Thomas A&K 04/04/06 Dallas Defs J. Lowther Barbour, David A&K 04/11/06-04/12/06 Dallas Defs J. Lowther Odom, Michael Andersen 07/05/06-07/07/06 Houston Defs J. Jaconette LaForest, Pierre RBC 07/11/06-07/12/06 Toronto n/a S. Hays Giles, Debra RBC 07/18/06-07/19/06 NYC n/a A. Box Aitken, John RBC 07/20/06 Calgary n/a S. Hays Bass, Carl Andersen 07/17/06-07/21/06 Houston Defs J. Jaconette McArthur, Ian RBC 07/25/06 NYC n/a A. Box Hall, Bob RBC 07/26/06 Toronto n/a S. Hays Stevenson, Jennifer Andersen 07/24/06-07/26/06 Houston Defs J. Jaconette LaBarge, Suzanne RBC 07/27/06 Toronto n/a S. Hays Piazza, Frank RBC 08/03/06-08/04/06 Toronto n/a S. Hays Watkins, Sherron Enron 08/02/06-08/04/06 Houston Defs P. Howes Fleming, Blair RBC 08/09/06 NYC n/a A. Box S. Burkholz Roberts, John RBC 08/10/06 Houston n/a K. Splan Tilney, Schuyler Merrill Lynch 08/17/06-08/18/06 Houston Defs B. Henssler S. Hays Bauer, Thomas Andersen 08/21/06-08/25/06 Houston Defs J. Jaconette Stephens, Linda RBC 08/30/06-08/31/06 NYC n/a A. Box S. Burkholz Hepworth, Graeme RBC 09/06/06 NYC n/a J. Hail Pulsifer, Natheniel Class Rep-Goldman 09/13/06 Boston n/a DNA Bayly, Daniel Merrill Lynch 09/29/06 NYC Plfs/Defs DNA Goza, Joshua Goldman 10/04/06 NTC n/a B. Henssler Easterbrook, Mark RBC 10/12/06 NYC n/a K. Splan Berney, Jeffrey Goldman 10/20/06 NYC n/a DNA Hintze, Martin 30(b)(6) Goldman 10/24/06 London n/a B. Henssler Textor, Donald Goldman 10/26/06 NYC n/a X. Bernay Begley, William 30(b)(6) PWC 11/02/06 Houston B. Henssler Ryan, Michael Goldman 11/10/06 NYC n/a S. Burkholz Brundage, Peter Goldman 11/15/06 Dallas n/a X. Bernay Sweeney, Robert Goldman 11/17/06 NYC n/a B. Henssler Hughes, Mark RBC 11/29/06-11/30/06 NYC n/a S. Burkholz A. Box Duncan, David Enron 01/30/07 Houston Defs DNA Daniel, Steven Goldman 01/09/07 Houston n/a X. Bernay Rice, Kenneth Enron 02/26/07 Houston Plfs DNA Hannon, Kevin Enron 03/16/07 Houston Defs DNA For each of these depositions where we participated, the Houston staff culled pertinent documents from the millions of pages in our discovery database and compiled voluminous witness binders – some witnesses had nine or ten volumes each, nine inches thick – which were used by our lawyers for their examinations. 17. Lead Plaintiff’s Responses to Discovery 170. Concurrent with Lead Counsel’s pursuit of defendants’ evidence, Lead Counsel responded to myriad discovery propounded by defendants. Lead Plaintiff and Lead Counsel - 100 -
promptly responded to all discovery. Where appropriate, Lead Counsel sought to curtail abusive requests. Lead Plaintiff and Class representatives gathered, and Lead Counsel reviewed and produced, tens of thousands of responsive documents. Lead Counsel responded to thousands of document, interrogatory, admission, and similar discovery requests. And Lead Counsel defended dozens of depositions noticed by defendants who sought to undermine plaintiffs’ claims at every stage of the litigation. Responding to the numerous discovery requests and vigorously defending Lead Plaintiff and class representatives were important steps in reaching agreement on the settled claims. a. Lead Counsel, Lead Plaintiff, Institutional Plaintiffs and Individuals Responded to Initial Class Certification Discovery 171. From the beginning, Enron’s directors, officers, lawyers and accountants, and its financial institutions requested extensive information via multiple document production requests, interrogatories, depositions and RFAs. Lead Counsel responded to each demand, and either provided a timely and accurate response, or objected when necessary, to protect the rights of plaintiffs and class representatives. 172. Defendants’ discovery demands began in mid-2002, before the motions to dismiss were decided in December 2002. The financial institutions, along with Enron executives, including Kenneth Lay, Jeffrey Skilling, Lou Pai, and others, sought information from Lead Plaintiff, institutional plaintiffs and individual class representatives. 173. The discovery demands included scores of document production requests concerning Enron-related investments and transactions, investment advice received or relied upon, decision to serve as a plaintiff or Class representative, social contacts between representatives and Lead Counsel, documents concerning the complaints’ allegations, damages suffered from Enron’s collapse, insider trading data, expert testimony to be offered, and many other topics. These requests - 101 -
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UNITED STATES DISTRICT COURT SOUTHE
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2. The Parties Establish a Document
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I, HELEN J. HODGES, declare as foll
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• Reviewed over 70 million pages
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6. The above recoveries were based
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gathered and which the banks and En
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14. In this endeavor, Coughlin Stoi
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17. Lead Counsel prosecuted the lit
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[T]his representation has been unde
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and the necessary involvement with
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case. The Court hereby awards attor
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published an article, “Enron Jolt
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statements. We compiled profiles on
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34. We had no way of knowing whethe
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which witnesses to pursue, but cont
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the market in October 2001. The ana
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said it was unable to determine whe
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depositions because discovery was p
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65. After the motion was filed, The
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institutional plaintiffs, their rep
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drawing on the expertise of our in-
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83. On May 3, 2002, the Preferred P
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finance certain of the partnerships
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and participated in a scheme to def
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(j) Arthur Andersen LLP (Docket No.
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Lead Plaintiff had adequately alleg
Page 53 and 54: (a) The Court ruled that Lead Plain
Page 55 and 56: director of New Power, and issuance
Page 57 and 58: 94. On September 26, 2002, Lead Pla
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Page 61 and 62: 106. On May 6, 2003, defendant Citi
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Page 67 and 68: Merrill Lynch and Deutsche Bank Ent
Page 69 and 70: 4. Motions to Intervene Additional
Page 71 and 72: Gramm, Jaedicke, LeMaistre, Meyer,
Page 73 and 74: professionals and experts, and atte
Page 75 and 76: 121. On May 7, 2003, the Outside Di
Page 77 and 78: of Enron’s prominence and magnitu
Page 79 and 80: 131. As part of discovery, Lead Cou
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Page 89 and 90: 146. In addition to JPMorgan’s in
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Page 93 and 94: Protocol Order provided for the ord
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Page 97 and 98: Deponent Entity Date[s] Location No
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Page 111 and 112: 187. Lead Counsel made further supp
Page 113 and 114: April 16, 2004, Lead Counsel filed
Page 115 and 116: 195. On April 13, 2004, defendants
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Page 121 and 122: 208. A two-day hearing was held reg
Page 123 and 124: Expert Entity Area of Opinion Dorri
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Page 131 and 132: primarily involving Deutsche Bank,
Page 133 and 134: We filed a notice of request for se
Page 135 and 136: 236. Bankruptcy Examiner Batson him
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Page 139 and 140: proceeds for our settlement. Thus,
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Page 143 and 144: team; for example, we reviewed info
Page 145 and 146: Court ruled that Lead Plaintiff fai
Page 147 and 148: Opposition to Deutsche Bank’s Mot
Page 149 and 150: Sec. Litig., 443 F.3d 987 (8th Cir.
Page 151 and 152: Plaintiff’s Opposition to Motion
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the Pleadings (Docket No. 5019). On
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joint-and-several liability for kno
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pricing or trade volume data, estim
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y the court and cited in In re Cend
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296. Attached hereto as Ex. 2 is a
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ADDITIONAL SERVICE LIST Stuart Yoes
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ENRON COUGHLIN STOIA GELLER RUDMAN
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Name Title Hours Rate Lodestar Meye
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ENRON - SUMMARY OF PLAINTIFFS' FIRM
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EXHIBIT 4
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TOP SECURITIES SETTLEMENTS Case Nam
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Exhibit Listings and Notes regardin
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Declaration Of Helen J. Hodges In Support Of Lead Counsel's ...

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