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703. As a direct and proximate result of the Bank Defendants’ participation in the Insiders’scheme, the Insiders were able to obtain tens of millions of dollars in improper personal benefitswhich came at the company’s expense. More significantly, as a direct and proximate result of theBank Defendants’ participation in the Insiders’ scheme, Enron’s debt was wrongfully expanded outof all proportion to its ability to repay. As a result, at least as early as 1999, Enron was insolvent.Thereafter, while its true financial condition was concealed by the acts and omissions of the Insidersand the Bank Defendants, the company’s debt load increased substantially and its insolvency wasaggravated and deepened. When the scheme of the Insiders and the Bank Defendants was exposed,Enron was forced to file for bankruptcy and incurred and continues to incur substantial legal andadministrative costs and the costs of numerous governmental investigations, its relationships withits customers, suppliers, and employees were undermined, and its assets were dissipated. By thetime of its bankruptcy in December 2001, Enron was insolvent by tens of billions of dollars.A. COUNTS 1 - 5(Against Citigroup Defendants)by reference.V.CLAIMS FOR RELIEFCOUNT 1(Avoidance of the Citi Preferential Transfers)704. The allegations in paragraphs 1 through 703 of this Complaint are incorporated herein705. Within ninety (90) days prior to the Petition Date, or within one year for insiders,Enron and/or ENA, directly or through a conduit, made the transfers identified in the followingtable, or caused them to be made, to or for the benefit of the transferees on or about the datesspecified below:604041v1/007457-244-