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Margin Transfers, the Chase 544 Purported Margin Transfers, the Mahonia/JPMC PostpetitionTransfers, the Chase Preferential Transfer, the Chase 548 Transfers and/or the Chase 544 Transfersare avoided under Bankruptcy Code sections 547, 548, 549, or 544, then, pursuant to section 550of the Bankruptcy Code, Plaintiff may recover from the initial transferee or beneficiary, or from anyimmediate or mediate transferee, the property transferred, or the value of such property, for thebenefit of Plaintiff’s estate.by reference.COUNT 19(Disallowance of Claims Under Bankruptcy Code Section 502(d))890. The allegations in paragraphs 1 through 889 of this Complaint are incorporated herein891. By reason of the foregoing facts and pursuant to Bankruptcy Code section 502(d),the claims of Chase, the initial transferees or beneficiaries identified in paragraphs 744, 756, 769,781, 793, 807, 824, 835, 847, 855L, 857, 867, and 879, and any immediate or mediate transferees,must be disallowed unless and until they have turned over to Plaintiff the property transferred, orpaid Plaintiff the value of such property, for which they are liable under Bankruptcy Code section550.C. COUNTS 20 - 29(Against Barclays Defendants)by reference.COUNT 20(Avoidance of the Barclays Preferential Transfers)892. The allegations in paragraphs 1 through 891 of this Complaint are incorporated herein893. On or within ninety (90) days before the Petition Date, Enron and/or ENA, directlyor through 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:604041v1/007457-334-

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