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1221A. The Challenged Transaction Obligations include, but are not limited to, Enron’sagreements to obtain the JPMC L/C and/or the West LB Mahonia L/C, the JPMC ReimbursementAgreement, the West LB Mahonia Reimbursement Agreement, and the following guarantees:Guarantor Named Beneficiaries Transaction Date TransactionEnron Mahonia 10/09/01 Chase XIIEnron Besson Trust 9/28/01 NikitaEnron Sphinx Trust 9/28/01 NileEnron Sideriver Investments Limited 6/20/01 ETOL IIIEnronState Street Bank and Trust Co.,State Street Bank and Trust Co.of Connecticut, N.A. andCitibank, N.A.12/07/00(2nd Amended andRestated ParentGuarantee)JT Holdings, Inc.1222. Any modifications or amendments of Challenged Transaction Obligations are alsoreferred to herein as “Challenged Transaction Obligations.”1223. Enron received less than a reasonably equivalent value from the beneficiaries inexchange for the Challenged Transaction Obligations.1224. The Challenged Transaction Obligations constitute obligations incurred by Enron.1225. The Challenged Transaction Obligations were incurred on or within one year beforethe Petition Date.1226. Upon information and belief, when the Challenged Transaction Obligations wereincurred, Enron was insolvent, or became insolvent as a result of the Challenged TransactionObligations; was engaged in business or a transaction, or was about to engage in business or atransaction, for which its remaining property was an unreasonably small capital; and/or intended toincur, or believed that it would incur, debts that would be beyond its ability to pay as such debtsmatured.604041v1/007457-402-

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