Footnote 8

840. The Chase 548 Purported Margin Transfers constitute transfers of interests inproperty of Enron, ENA and/or ENGM.841. Each of the Chase 548 Purported Margin Transfers was made to or for the benefit ofMahonia or Stoneville as initial transferee or beneficiary.842. The Chase 548 Purported Margin Transfers were made on or within one year beforethe Petition Date.843. Upon information and belief, when the Chase 548 Purported Margin Transfers weremade, Enron, ENA and/or ENGM were insolvent, or became insolvent as a result of the transfers;were engaged in business or a transaction, or were about to engage in business or a transaction, forwhich their remaining property was unreasonably small capital; and/or intended to incur, or believedthat they would incur, debts that would be beyond their ability to pay as such debts matured.844. The Chase 548 Purported Margin Transfers are avoidable as fraudulent transfersunder section 548(a)(1)(B) of the Bankruptcy Code.by reference.COUNT 14(Avoidance of the Chase 544 Purported Margin TransfersUnder Section 544 of the Bankruptcy Code and ApplicableState Fraudulent Conveyance or Fraudulent Transfer Law)845. The allegations in paragraphs 1 through 844 of this Complaint are incorporated herein846. Pursuant to Bankruptcy Code section 544(b), Plaintiff has the rights of an existingunsecured creditor of Plaintiff. Section 544(b) permits Plaintiff to assert claims and causes of actionthat such a creditor could assert under applicable state law.847. Enron, ENA and/or ENGM, directly or through a conduit, made the transfersidentified in the following table, or caused them to be made, to or for the benefit of the transfereeson or about the dates specified below:604041v1/007457-313-