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

131. As part of discovery, Lead Counsel issued scores of subpoenas to third parties, which
involved the requisite meet-and-confer sessions, letters to memorialize those sessions, and
considerable follow-up to insure receipt of the requested documents. We sought documents from the
sureties, that is the insurance companies, in the Liberty Mutual case where JPMorgan Chase was
trying to collect on insurance policies purchased to cover default on the commodities trades, which
were really loans, underlying the prepay transactions. We subpoenaed documents from rating
agencies, such as Moody’s, to learn about the information they relied on to rate Enron’s debt and
how they determined the ratings issued. We subpoenaed stock analysts, such as David Fleischer,
and short-sellers to gather evidence relating to loss causation. We sought documents from
Innovision, which recorded Enron’s analyst and employee conferences. We sought trade data from
investment banks in order to support our allegation that debt prices reacted when there was a default
risk.
Third Parties and Defendants
Date Subpoena
Issued
Thomas H. Bauer 01/29/02
David B. Duncan 01/29/02
Michael C. Odom 01/29/02
Nancy Temple 01/29/02
Lehman Brothers Holdings Inc. 03/05/02
Citigroup Inc., Robertson Stephens & Co. Inc., JPMorgan Chase, Salomon Smith Barney, Inc., Credit 03/05/02
Suisse First Boston, Banc of America Securities, CIBC World Markets, Morgan Stanley Dean Witter
& Co., Prudential Securities, Deutsche Bank Securities Inc., Merrill Lynch & Co., Inc.
St. Paul Fire & Marine Insurance Co. 01/02/03
01/17/03
02/27/03
The Travelers Indemnity Co. 01/02/03
01/17/03
02/27/03
The Travelers Casualty & Surety Co. 01/02/03
01/17/03
02/27/03
Hartford Fire Insurance Co. 01/02/03
01/17/03
02/27/03
Safeco Insurance Co. of America 01/02/03
01/17/03
02/27/03
Lumbermens Mutual Casualty Co. 01/02/03
01/21/03
02/27/03
Fireman’s Fund Insurance Co. 01/02/03
01/17/03
02/27/03
National Fire Insurance Co. of Hartford 01/02/03
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