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Footnote 8

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H. COUNTS 50 - 54(Against Toronto Dominion Defendants)COUNT 50(Avoidance of the Toronto Dominion Preferential Transfers)1102. The allegations in paragraphs 1 through 1101 of this Complaint are incorporatedherein by reference.1103. 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:Transferor ObligorInitialTransferee orBeneficiaryEnron or ENA ENA and Enron TorontoDominion Texasand/or TorontoDominion BankEnron Enron TorontoDominion TexasEnron or ENA ENA and Enron TorontoDominion Texasand/or TorontoDominion BankEnron or ENA Enron or ENA TorontoDominion Texasand/or TorontoDominion BankInitialTransferDate TransactionTransferAmount9/19/01 London Prepay $2,556,901.259/19/01 London Prepay $139,810.009/28/01 London Prepay $2,268.6010/19/01 Coal Corp.Letter of Credit$22,750.001104. 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 “Toronto Dominion Preferential Transfers.”1105. Not Used.1106. Although some of the Toronto Dominion Preferential Transfers were related toagreements designated as “swap” agreements, these transfers were actually payments on disguisedloans and the agreements were not genuine “swaps.”604041v1/007457-385-

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