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

were followed by RFAs and interrogatories. Defendants sought detailed information from Lead
Plaintiff The Regents, including information about its investment procedures and guidelines,
relationship with Enron, Enron-related energy contracts, and similar documents.
174. Lead Counsel responded to all of the discovery propounded by defendants. For
example, in July and August 2002 Lead Counsel filed 15 separate document production request
responses. Lead Counsel served its document production request responses to the bank defendants
on August 2, 2002, and therein agreed to produce a significant amount of information, including
Lead Plaintiff’s trades in Enron-related securities, the institution’s tax returns, statements of net
worth, assets and liabilities, and similar financial information. Lead Plaintiff further agreed to
produce various documents concerning the allegations contained in the complaint, and nearly all
nonprivileged Enron-related documents held by Lead Plaintiff. Similarly detailed responses were
filed on behalf of the financial institution plaintiffs and individual Class representatives. Every
document gathered and produced was reviewed in detail by Lead Counsel to ensure no privileged
documents were inadvertently produced.
b. Lead Counsel, Lead Plaintiff and Class Representatives
Respond to Interrogatories
175. Defendants such as Jeffrey Skilling, Lou Pai, and the financial institutions served
voluminous interrogatories on Lead Plaintiff, other institutional plaintiffs and Class representatives.
Among the information requested by defendants’ interrogatories was total losses suffered due to
Enron’s collapse, the Class each prospective plaintiff sought to represent, detailed insider trading and
disgorgement data for alleged violations of §20A of the Exchange Act, material nonpublic
information the defendants purportedly failed to disclose to the Class, facts demonstrating the
litigation was suitable for Rule 23 class action treatment, legal theories concerning plaintiffs’ causes
of action, questions concerning expert witnesses, whether “inducements” resulted in the purchase of
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