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

information to either support or defend against the allegations contained in the numerous complaints
and answers filed in the Enron litigation.
2. The Parties Establish a Document Depository for the Exchange
of Information
118. Lead Counsel spearheaded efforts to establish a “document depository” to allow for
the uniform production of documents and electronic evidence used in all Enron-related proceedings.
The document depository minimized duplication of production efforts, significantly reduced the
aggregate costs of producing and maintaining documents, and permitted a centralized, uniform
method for identifying documents used during the litigation, including fact witness depositions,
expert depositions and summary judgment.
119. The document depository order was signed by the Court on October 30, 2002, and
also was signed by the parties to the litigation (Docket No. 1116). In addition to governing the
orderly flow of documentary and electronic information to the depository, the order also allocated
costs among the parties, contained provisions for production and access by third parties, provided for
the creation of privilege logs, and established production and retention dates to be followed by all
parties.
3. Lead Counsel Compels Enron Executives to Produce
Particularized Discovery Concerning Financial Conflicts
120. During the discovery phase Lead Counsel pursued evidence from Enron’s Board and
high-level executives. The evidence included personal financial information showing financial
conflicts of interest, profiteering and personal communications outside the office. Lead Plaintiff
demanded the production of particularized information concerning the executives’ and Board
members’ personnel files, along with evidence concerning insider trading, business and financial
conflicts, and similar information showing the Board’s objectivity was compromised.
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