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(c)Three million Four Hundred Fifty-Nine Thousand Eight Hundred Forty-FourDollars ($3,459,844) was applied to Enron’s alleged obligation as guarantor of the Richmond PowerEnterprise, L.P., a Delaware limited partnership;(d)Two Hundred Twenty-Two Thousand Fifteen Dollars ($222,015) was appliedto alleged and unspecified obligations of Enron Credit Limited; and(e)Three Hundred Fifteen Thousand Three Hundred Thirty-Seven Dollars($315,337) was applied to alleged and unspecified obligations of Enron.441. As with the September Transaction, the October Transaction provided ENA withfinancing from Barclays, which the parties attempted to secure by the Emission Credits purportedlysold to Colonnade and the rights under the call and put agreements.442. In accordance with the 1994 ISDA Credit Support Annex dated January 13, 1994between ENA and Barclays, ENA deposited cash on or about September 28, 2001, in an ENAaccount at Barclays (“Deposited Funds”). The balance of the account as of December 1, 2001 was$27,132,999.00, and the interest accrued thereon by December 31, 2001 was $32,494.442A. On or about December 3, 2001 – the day following the Petition Date – Barclaysnotified ENA that Barclays was: (a) terminating all transactions governed by the ISDA MasterAgreement because ENA had filed a chapter 11 petition, and (b) designating December 4, 2001 asthe Early Termination Date for the outstanding transactions under the ISDA Master Agreement.443. On or about December 31, 2001, Barclays sent a letter entitled “Statement ofPayment on Early Termination.” The letter stated that Barclays had calculated the amount ENAowed Barclays, with respect to certain transactions governed by the 1992 ISDA Master Agreementand the 1994 ISDA Credit Support Annex, to be $72,617,084 plus $150,704 in interest for a totalof $72,767,788. The letter also stated that, after Barclays had applied the Deposited Funds plusaccumulated interest, ENA owed Barclays $45,602,295.604041v1/007457-145-

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