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one another and to cause one another to participate in transactions with Enron. As demonstrated inthis Complaint, Citigroup employees analyzed and approved all transactions with Enron but oftenassigned subsidiaries to take part in their financing and/or implementation. For example, Citigroupcaused its subsidiary Citibank to participate in eleven prepay transactions with Enron and thusdisguise billions of dollars of loans as commodity trades. Citigroup also caused its SPE, DeltaEnergy Corporation, to serve as the pass-through entity in six of the prepay transactions. Similarly,Citigroup caused its affiliate CXC to make loans of $485 million to capitalize the minority intereststructures Nighthawk and Nahanni. Citigroup also caused its subsidiary Salomon Holding topurportedly contribute $28.5 million to the Sundance Industrial transaction.275. The Enron Examiner observed, “Citigroup appears to structure its operations aroundbusiness units rather than legal entities. Units such as Global Capital Structuring and Derivativesdesign the products, sell them, and use various legal entities within Citigroup to participate in andbook the transactions.” Exam III, App. D at 9. Indeed, the Enron Examiner noted that “[f]ew of theCitigroup employees who gave testimony . . . were certain of the legal entity that employed them,and some had signing authority for multiple legal entities.” Id. In addition to those direct andindirect subsidiaries of Citigroup named in this Complaint, there may be other subsidiaries oraffiliates which Citigroup caused to participate in one or more of the transactions with Enron thatserve as the basis for this Complaint. It is Enron’s intention to hold Citigroup and each of thesesubsidiaries and affiliates responsible for their participation in the challenged transactions, andEnron notifies Citigroup of its intention to include the subsidiaries and affiliates as defendants upondiscovery of their identities.276. Throughout the relevant period, Citigroup maintained an office in Houston, Texas.Citigroup executives and other personnel in the Houston office were involved in the SPEtransactions with Enron. James Reilly, head of Citigroup’s Global Energy & Mining Group in604041v1/007457-83-