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550, Plaintiff may recover from the initial transferee or beneficiary, or from any immediate ormediate transferees, the property transferred, or the value of such property, for the benefit ofPlaintiff’s estate.COUNT 72(Disallowance of Claims Under Bankruptcy Code Section 502(d);Against All Defendants)1256. The allegations in paragraphs 1 through 1255 of this Complaint are incorporatedherein by reference.1257. By reason of the foregoing facts and pursuant to Bankruptcy Code section 502(d),the claims of each Defendant must be disallowed unless and until the Defendant has turned over toPlaintiff the property transferred, or paid Plaintiff the value of such property, for which theDefendant is liable under Bankruptcy Code section 550.COUNT 73(Equitable Subordination Under Sections 510(c)(1)-(2) and 105(a) of theBankruptcy Code; Against Subordination Defendants)1258. The allegations in paragraphs 1 through 1257 of this Complaint are incorporatedherein by reference.1259. This Count is brought on behalf of Enron, ENA, and all of their affiliated debtorentities in the chapter 11 cases jointly administered under case number 01-16034 [AJG](collectively, the “Subordination Plaintiff”), a list of which is annexed as Schedule A.1260. Except as otherwise indicated below, Subordination Plaintiff alleges this claimagainst all Defendants (except the RBC Defendants and certain other defendants with respect toparticular obligations as specified below) that have asserted or may assert claims againstSubordination Plaintiff in any capacity (collectively, the “Subordination Defendants”).1261. The Subordination Defendants engaged in and benefitted from inequitable conduct,including the conduct described in this Complaint, that has resulted in injury to Subordination604041v1/007457-412-