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

Deponent
Depo
Date
Location of
Depo
Entity
Defending
Attorney
Ben Schuette 8/13/03 Corpus Christi, Individual
Paul Howes
TX
Mervin H. Schwartz, Jr. 9/19/03 Hershey, PA Individual Paul Howes
Stephen M. Smith 8/11/03 Houston, TX Individual Paul Howes
Joseph C. Speck 8/19/03 Sarasota, FL Individual Paul Howes
John Zegarski 8/29/03 San Diego, CA Individual James Jaconette/
John Lowther
f. Lead Plaintiff, Institutional Plaintiffs and Class
Representatives Produce Tens of Thousands of Pages of
Documents to Defendants
184. Beginning on May 9, 2003 Lead Plaintiff, institutional plaintiffs and individual Class
representatives began to produce responsive documents to the Enron document depository. A team
of experienced lawyers and staff was tasked with reviewing all of the gathered documents. Tens of
thousands of pages of documents were gathered, reviewed and produced in response to defendants’
discovery.
185. Production began on July 9, 2003, when thousands of pages of documents were
produced by The Regents, Amalgamated Bank, Staro Asset Management, Hawaii Laborers Pension
Plan, San Francisco City and County Employee’s Retirement System, and individual plaintiffs.
Lead Plaintiff and others produced Enron security trading confirmations, market reports, SEC filings
in their possession, news articles, emails, correspondence, notes and asset allocations, all of which
were responsive to defendants’ lengthy document production requests.
186. More documents were produced in September 2003. The original document
productions were supplemented with additional trading confirms, investment guideline documents,
meeting minutes, analyst reports and similar documents. And additional productions occurred in
March and November 2004, at which time Washington State Investment Board produced responsive
documents, and correspondence and transactional data from plaintiffs was produced. Each of these
document productions was in addition to the interrogatory and RFA answers Lead Plaintiff and Lead
Counsel provided during the discovery phase.
- 106 -