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717. The transfers identified in the foregoing table, together with any interest, fees, andother payments to or for the benefit of the transferees related to the foregoing transfers, are referredto herein as the “Citi 548 Transfers.”718. To the extent Klondike, Marengo, Nahanni, Sundance Industrial, Caymus Trust, LongLane, Yosemite I Trust, Yosemite Securities, Delta or ECLN II Trust are found to be mere conduitsof the transfers for which the entities in the third column of the foregoing table are marked with anasterisk, then Salomon Holding, CXC or Citibank was the initial transferee of those transfers andthe other defendants identified in the fourth column of the table were either conduits or subsequenttransferees of those transfers.719. Although some of the Citi 548 Transfers were related to agreements designated as“swap” agreements, these transfers were actually payments on disguised loans and the agreementswere not genuine “swaps.”720. To the extent that any of the Citi 548 Transfers are also included in Count 1 asavoidable preferential transfers, those transfers are pled alternatively as fraudulent transfers.721. Enron and/or ENA received less than a reasonably equivalent value from thetransferees in exchange for the Citi 548 Transfers.722. The Citi 548 Transfers constitute transfers of interests in property of Enron and/orENA.723. Each of the Citi 548 Transfers was made to or for the benefit of the entities listed inthe third column of the foregoing table as initial transferees or beneficiaries.724. The Citi 548 Transfers were made on or within one year before the Petition Date.725. Upon information and belief, when the Citi 548 Transfers were made, Enron and/orENA were insolvent, or became insolvent as a result of the transfers; were engaged in business ora transaction, or were about to engage in business or a transaction, for which their remaining604041v1/007457-249-