Footnote 8

1250. The Intentional Fraudulent Conveyances include obligations that Enron incurred inthe form of guarantees, and/or obligations to obtain or reimburse draws on letters of credit, inconnection with the transactions marked with an asterisk in the foregoing table and the table inparagraph 1241.1251. Each transfer of an interest of the Plaintiff in property and each obligation incurredin connection with the transactions identified in the foregoing table and in the preceding Count ofthis Complaint, including each fee, principal, interest and other payment or transfer of funds orobligation incurred whether directly or as a guarantor, was an Intentional Fraudulent Conveyance.The Intentional Fraudulent Conveyances include without limitation each transfer of an interest ofPlaintiff in property that Plaintiff has sought to avoid and recover in any of the preceding Countsof this Complaint.1252. Each Intentional Fraudulent Conveyance was caused by the Insiders in breach of theirfiduciary duties with actual intent to hinder, delay or defraud one or more entities to which Plaintiffwas or became, on or after the date that such transfers were made or such obligations were incurred,indebted. These transfers were made to assist the Insiders in presenting misleading or incompletefinancial information about Enron and diminished Plaintiff’s estate.1253. The Intentional Fraudulent Conveyances are avoidable as fraudulent conveyancesor fraudulent transfers under section 544 of the Bankruptcy Code or applicable state law.COUNT 71(Recovery of Avoided Intentional Fraudulent Transfers and Conveyances UnderSection 550 of the Bankruptcy Code; Against All Defendants)1254. The allegations in paragraphs 1 through 1253 of this Complaint are incorporatedherein by reference.1255. To the extent that any Intentional Fraudulent Transfer or Conveyance is avoidedunder Bankruptcy Code sections 544 or 548(a)(1)(A), then, pursuant to Bankruptcy Code section604041v1/007457-411-