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REORGANIZED DEBTORS’ FOURTH AMENDED COMPLAINTFOR THE AVOIDANCE AND RETURN OF PREFERENTIALPAYMENTS AND FRAUDULENT TRANSFERS, EQUITABLESUBORDINATION, AND DAMAGES, TOGETHER WITH OBJECTIONSAND COUNTERCLAIMS TO CREDITOR DEFENDANTS’ CLAIMSEnron Corp., Enron North America Corp., Enron Natural Gas Marketing Corp., EnronBroadband Services, Inc., Enron Energy Services, Inc., EES Service Holdings, Inc., EnronInternational, Inc., Enron Energy Services Operations, Inc., ECT Merchant Investments Corp.,Enron Power Marketing, Inc., and Atlantic Commercial Finance, Inc., as reorganized debtors,together with affiliated reorganized debtors for purposes of Counts 73, 73A and 73B as specifiedbelow, allege for their Complaint as follows:I.NATURE OF THIS ACTION1. Reorganized debtors Enron Corp. (“Enron”), Enron North America Corp. (“ENA”),Enron Natural Gas Marketing Corp. (“ENGM”), Enron Broadband Services, Inc. (“EnronBroadband”), Enron Energy Services, Inc. (“Enron Energy Services”), EES Service Holdings, Inc.(“EES Service Holdings”), Enron International, Inc. (“Enron International”), Enron Energy ServicesOperations, Inc. (“EESO”), ECT Merchant Investments Corp. (“ECTMI”), Enron Power Marketing,Inc. (“EPMI”), and Atlantic Commercial Finance, Inc. (“ACFI”), together with affiliatedreorganized debtors as specified below, bring this adversary proceeding against the banks andinvestment banks that bear substantial responsibility for the stunning downfall of what was once theseventh largest corporation in the United States. These banks and investment banks (together withcertain subsidiaries and affiliates, the “Bank Defendants”) participated with a small group of seniorofficers and managers of Enron (the “Insiders”) in a multi-year scheme to manipulate Enron’sfinancial statements and misstate its financial condition. The central purposes of this scheme wereto mask a growing disparity between the company’s reported revenues, which were increasingly604041v1/007457