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1107. The Toronto Dominion Preferential Transfers constitute transfers of interests inproperty of Enron and/or ENA.1108. Each of the Toronto Dominion Preferential Transfers was made to or for the benefitof the entities listed in the third column of the foregoing table as the initial transferees orbeneficiaries.1109. Each of the Toronto Dominion Preferential Transfers was made to or for the benefitof a creditor for or on account of an antecedent debt owed by Enron and/or ENA before the transferwas made.1110. Upon information and belief, at the time each of the Toronto Dominion PreferentialTransfers was made, Enron and/or ENA were insolvent for purposes of section 547(b) of theBankruptcy Code.1111. Each of the Toronto Dominion Preferential Transfers enabled the transferees toreceive more than they would have received if the case were a case under chapter 7 of theBankruptcy Code, the transfers had not been made, and the transferees received payment of theirdebts to the extent provided by the Bankruptcy Code.1112. The Toronto Dominion Preferential Transfers are avoidable as preferential transfersunder section 547(b) of the Bankruptcy Code.COUNT 51(Avoidance of the Toronto Dominion 548 Transfersas Fraudulent Transfers)1113. The allegations in paragraphs 1 through 1112 of this Complaint are incorporatedherein by reference.1114. On or within one year before the Petition Date, Enron and/or ENA, 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:604041v1/007457-386-