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

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ADDITIONAL SERVICE LIST Stuart Yoes THE YOES LAW FIRM, LLP 3535 Calder Avenue, Suite 235 Beaumont, TX 77726-7584 409/833-2352 409/838-5577 (fax) Edward W. Cochran 20030 Marchmont Rd. Shaker Heights, OH 44122 216/751-5546 216/751-6630 (fax) Paul S. Rothstein 626 N.E. First Street Gainesville, FL 32601 352/376-7650 352/374-7133 (fax) Lawrence W. Schonbrun LAW OFFICES OF LAWRENCE W. SCHONBRUN 86 Eucalyptus Road Berkeley, CA 94705 510/547-8070 Frank H. Tomlinson PRITCHARD, McCALL; & JONES, LLC 505 N. 20th Street, Suite 800 Birmingham, AL 35203 205/328-9190 205/458-0035 (fax) N. Albert Bacharach Jr. 115 N.E. Sixth Avenue Gainesville, FL 32601-6592 352/378-9859 352/338-1858 (fax) Maureen McGuirl FENSTERSTOCK & PARTNERS LLP 30 Wall Street, 9th Floor New York, NY 10005 212/785-4100 212/785-4040 (fax) Richard C. Bauerle 30 Greenbriar Ottumwa, IA 52501 SERVICE VIA UPS OVERNIGHT Arnold Gregg 4445 Forest Glen Road Anaheim Hills, CA 92807 Mr. Stanley Majors 22868 Beaverhead Drive Diamond Bar, CA 91765 909/860-8150 Steven F. Helfand HELFAND LAW OFFICES 582 Market Street, Suite 1400A San Francisco, CA 94104 415/397-0007 415/397-0009 (fax) Stephen Neuwirth QUINN EMANUEL URQUHART OLIVER & HEDGES, LLP 51 Madison Avenue, 22nd Floor New York, NY 10010
EXHIBIT 1
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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
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(a) The Court ruled that Lead Plain
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director of New Power, and issuance
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94. On September 26, 2002, Lead Pla
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mandamus review, and that the Court
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106. On May 6, 2003, defendant Citi
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scheme, and certain specific allega
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pled with the requisite particulari
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Merrill Lynch and Deutsche Bank Ent
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4. Motions to Intervene Additional
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Gramm, Jaedicke, LeMaistre, Meyer,
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professionals and experts, and atte
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121. On May 7, 2003, the Outside Di
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of Enron’s prominence and magnitu
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131. As part of discovery, Lead Cou
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Third Parties and Defendants Date S
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Third Parties and Defendants Date S
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133. Document requests and subpoena
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139. In responding to the document
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146. In addition to JPMorgan’s in
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10. Requests for Admission 152. In
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Protocol Order provided for the ord
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privilege. And the defendants agree
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Deponent Entity Date[s] Location No
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promptly responded to all discovery
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Enron securities, and questions con
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securities, understanding of a repr
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187. Lead Counsel made further supp
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April 16, 2004, Lead Counsel filed
Page 115 and 116: 195. On April 13, 2004, defendants
Page 117 and 118: Plaintiffs’ Investors Partner Lif
Page 119 and 120: • Outside Directors’ Memorandum
Page 121 and 122: 208. A two-day hearing was held reg
Page 123 and 124: Expert Entity Area of Opinion Dorri
Page 125 and 126: and is the basis for a presumption
Page 127 and 128: nature of Enron’s financial condi
Page 129 and 130: economically valid method and frame
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
Page 137 and 138: egarding the §11 claims, which wer
Page 139 and 140: proceeds for our settlement. Thus,
Page 141 and 142: egarding the policies and he moved
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
Page 153 and 154: dated June 5, 2006 as It Pertains t
Page 155 and 156: the Pleadings (Docket No. 5019). On
Page 157 and 158: joint-and-several liability for kno
Page 159 and 160: pricing or trade volume data, estim
Page 161 and 162: y the court and cited in In re Cend
Page 163: 296. Attached hereto as Ex. 2 is a
Page 168 and 169: ENRON COUGHLIN STOIA GELLER RUDMAN
Page 170 and 171: Name Title Hours Rate Lodestar Meye
Page 172 and 173: ENRON - SUMMARY OF PLAINTIFFS' FIRM
Page 178: EXHIBIT 4
Page 182 and 183: TOP SECURITIES SETTLEMENTS Case Nam
Page 184 and 185: Exhibit Listings and Notes regardin
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