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

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
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