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126A. Each of FleetBoston Financial, Fleet National Bank, and Long Lane acted as thecontrol person, successor, agent, co-conspirator, co-venture partner and/or alter ego of the others asto matters discussed herein, and they are collectively referred to as “Fleet.”127. A number of the Additional Defendants have filed one or more proofs of claimagainst the Subordination Plaintiff in the Chapter 11 cases being jointly administered in this Courtunder consolidated case number 01-16034.D. Claim Transferee Defendants127A. Defendant Deutsche Bank Trust Company Americas is a Claim Transferee Defendantas that term is defined in paragraph 1266E. Between the Petition Date and on or about May 28,2002, Deutsche Bank Trust Company Americas received transfers of claims against Enron or itsaffiliates that were held as of the Petition Date by defendants Citibank, Deutsche Bank AG, andCIBC Inc.127B. Defendant Chase is a Claim Transferee Defendant as that term is defined inparagraph 1266E. Between the Petition Date and on or about January 10, 2002, Chase receivedtransfers of claims against Enron or its affiliates that were held as of the Petition Date by defendantsMerrill Lynch, CSFB, and Bank Boston, NA, Fleet’s predecessor-in-interest.III.JURISDICTION AND VENUE128. On December 2, 2001 (the “Petition Date”), Enron, ENA, Enron Broadband, EnronEnergy Services, EESO, and EPMI filed voluntary petitions for relief under Chapter 11 of theBankruptcy Code in this Court. ENGM, EES Service Holdings, ECTMI, Enron International, andACFI filed their voluntary petitions for relief on January 11, 2002, April 18, 2002, May 16, 2003,and June 27, 2003, respectively.604041v1/007457-29-