Footnote 8

(3) employing transactions with the company for the purpose or with the effect of manipulating andmisstating Enron’s financial statements. The Insiders made each misrepresentation or omitted todisclose each material fact, even those made in the first instance to Andersen, for the purpose andwith the intention that Enron and/or its Board of Directors would rely upon it.1532. By virtue of the acts and omissions described in this Complaint, the Bank Defendantsknowingly gave substantial assistance to the Insiders in committing fraud against Enron. In eachof the structured finance transactions described in this Complaint, one or more of the BankDefendants participated with actual knowledge that the purpose of the transaction was to manipulateand misstate Enron’s financial statements and that the transaction would be reported by Enron in amaterially misleading manner. In each of the structured finance transactions described in thisComplaint, one or more of the Bank Defendants gave substantial assistance to the Insiders bydesigning, implementing, financing, purporting to invest in, and/or closing the transaction and/orby causing their subsidiaries or affiliates to do the same. In each of the transactions described in thisComplaint in which an Insider and/or a member of his family improperly derived a personal benefitfrom a transaction with Enron, one or more of the Bank Defendants participated with actualknowledge that the transaction was designed to or would benefit the Insider at Enron’s expense. Ineach of these transactions, one or more of the Bank Defendants and/or their officers gave substantialassistance to the Insiders by investing, or by obtaining others to invest, in the transaction or theentity formed by the Insiders to participate in the transaction.1533. Specifically, by way of examples and not an exhaustive list, the Bank Defendantsgave substantial assistance to the Insiders as follows:Citigroup1534. In connection with the Roosevelt transaction, Citigroup knowingly gave substantialassistance to the Insiders.604041v1/007457-469-