Footnote 8

1570. In connection with the Pilgrim transaction, there were two separate but relatedtransactions, Pilgrim/Trakya and Pilgrim/Sarlux. While the transactions commenced on the sameday and closed at approximately the same time, a unique asset supported each transaction. Inconnection with these transactions, CIBC and CIBC, Inc. knowingly gave substantial assistance tothe Insiders.(a)On or about October 27, 1998, Ian Schottlaender, Mark Wolf, and BillyBauch sent a Memorandum to Richard Hassard, William Phoenix, and Ray Smith regardingstructuring and underwriting a transaction to provide Enron with an accounting gain on two powerplants in which Enron has an equity interest.(b)On or about December 4, 1998, Colette DeLaney sent an e-mail to Bob Abraand Lorne Robbins authorizing Pilgrim and asking questions regarding Pilgrim and Riverside.(c)On or about December 4, 1998, Bob Abra sent a Credit Communication toExecutive Director, Credit Management Houston with a copy to CEO, Large Corporate Market andExecutive Director, ACSC authorizing Pilgrim with the understanding that Enron will be askedquestions about earnings on Riverside and Pilgrim.(d)On or about October 21, 1998, Billy Bauch sent a Memorandum to JohnHunkin, Gerald Beasley, Ron Ormand, Ian Schottlaender, and Mark Wolf regarding a meeting withEnron to discuss Enron’s financing needs and the transactions Enron intends to complete by yearend.(e)On or about December 1, 1998, Mark Wolf and Lucia Martinez sent anApplication for Corporate Credit to VP Risk Management, the CIBC Credit Committee, ColetteDelaney, and Katheryn McGovern.1571. In connection with the Riverside V transaction, CIBC and CIBC World Markets plc.knowingly gave substantial assistance to the Insiders.604041v1/007457-488-