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851. Enron, ENA and/or ENGM received less than a reasonably equivalent value from thetransferees in exchange for the Chase 544 Purported Margin Transfers.852. The Chase 544 Purported Margin Transfers constitute transfers of interests inproperty of Enron, ENA and/or ENGM.853. Each of the Chase 544 Purported Margin Transfers was made to or for the benefit ofMahonia or Stoneville as initial transferee or beneficiary.854. Upon information and belief, when the Chase 544 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.855. The Chase 544 Purported Margin Transfers are avoidable as fraudulent conveyancesor fraudulent transfers under section 544 of the Bankruptcy Code and applicable state law.by reference.COUNT 14A(Violation of Automatic Stay)855A. The allegations in paragraphs 1 through 855 of this Complaint are incorporated herein855B. For purposes of Counts 14A through 14C, Mahonia, Stoneville and/or JPMC will bereferred to individually and collectively as “Mahonia/JPMC.”855C. Subsequent to the Petition Date, Mahonia/JPMC exercised control over funds thatENGM, ENA or Enron delivered to Mahonia/JPMC, purportedly as “margin” or collateral inconnection with the Mahonia transactions, together with interest earned on those funds (collectively,the “Prepay Collateral”), and/or acted to apply the Prepay Collateral as a purported offset toobligations that Mahonia/JPMC asserted ENGM or ENA owed it in connection with the Mahonia604041v1/007457-326-