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

133. Document requests and subpoenas to defendants and third parties, and interviews of
former Enron employees and others resulted in Lead Counsel receiving, coding and processing, and
analyzing terabytes of data – tens of millions of pages of documents (in hard-copy and electronic
format). The gargantuan volume of documents, millions produced on an ever-rolling basis, required
a massive and sustained effort led by the staff and lawyers in Houston, utilizing two shifts of coding
teams and analysts in the trial office. The document-review effort included work by forensic
experts, paralegals, consultants, and lawyers to literally sort, identify, cull, de-duplicate, extract data
from and then analyze, pertinent documents from electronic databases from all defendants and third
parties for more in-depth review and use in depositions and pre-trial preparation. The effort required
an organized approach to staff the coding and analytic teams, prepare for and receive the documents,
create the database and shepherd the coding process, and build hundreds of transaction and witness
binders – nine-inch volumes – for all potential deponents and trial witnesses. Our abilities, patience,
and perseverance were tested by unique, at first, and later, routine electronic complexities presented
by the colossal volume of documents we received, organized, reviewed, analyzed and utilized.
6. Lead Counsel’s Interrogatories and Motions to Compel
Responses
134. Lead Counsel vigorously pursued interrogatory discovery. The first of several sets of
interrogatory discovery was served in May 2003. The interrogatories requested detailed information
from the financial institutions and others concerning the nature of their business relationship with
Enron, the names and positions of employees who participated in Enron-related transactions, and
fees earned from the transactions. The interrogatories also probed the affirmative defenses,
including reliance on advice of counsel and the assigning of liability to third parties.
135. Lead Counsel also held numerous meet and confer sessions with the financial
institutions to compel further responses, especially where defendants either delayed in responding to
questions pending the completion of discovery, or simply refused to answer the interrogatories.
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