Footnote 8

829. Each of the Chase Preferential Purported Margin Transfers was made to or for thebenefit of Mahonia or Stoneville as initial transferee or beneficiary.830. Each of the Chase Preferential Purported Margin Transfers was made to or for thebenefit of a creditor for or on account of an antecedent debt owed by Enron, ENA and/or ENGMbefore the transfer was made.831. Upon information and belief, at the time each of the Chase Preferential PurportedMargin Transfers was made, Enron, ENA and/or ENGM were insolvent for purposes of section547(b) of the Bankruptcy Code.832. Each of the Chase Preferential Purported Margin Transfers enabled the transferee toreceive more than it would have received if the case were a case under chapter 7 of the BankruptcyCode, the transfer had not been made, and the transferee received payment of its debts to the extentprovided by the Bankruptcy Code.833. The Chase Preferential Purported Margin Transfers are avoidable as preferentialtransfers under section 547(b) of the Bankruptcy Code.COUNT 13(Avoidance of the Chase 548 Purported Margin Transfers as Fraudulent Transfers)by reference.834. The allegations in paragraphs 1 through 833 of this Complaint are incorporated herein835. On or within one year of the Petition Date, Enron, ENA and/or ENGM, directly orthrough a conduit, made the transfers identified in the following table, or caused them to be made,to or for the benefit of the transferees on or about the dates specified below:604041v1/007457-302-