Footnote 8

eports. In these reports and their appendices, the Enron Examiner dissects “substantially all of1Enron’s material SPE transactions identified to date.” Exam. II at 3. He explains precisely howSPEs were improperly used at Enron in conjunction with specific accounting techniques “to impactdramatically its financial statements” in violation of Generally Accepted Accounting Principles(“GAAP”). Exam. III at 2. He identifies a number of Enron’s senior officers responsible formanipulating Enron’s financial statements, discusses specific claims Enron has against thoseofficers, discusses the role Bank Defendants other than RBC played in that manipulation, anddiscusses specific claims Enron has against these Bank Defendants for their wrongdoing.134. For his part, the ENA Examiner has issued one report which totals 917 pages of textand includes 24 annexes. Among the topics in his report is the role RBC played in the Insiders’manipulation of Enron’s financial statements and the specific claims Enron has against RBC as aresult.135. It is not surprising that the Enron and ENA Examiners required, collectively, over5,100 pages of text to explain the fraud that caused Enron to collapse into bankruptcy. The scopeand complexity of the transactions in which certain Enron officers entangled Enron, with the helpof the Bank Defendants, during the late 1990s and early 2000s is breathtaking.136. Basically, Enron was bled to death during the late 1990s and early 2000s by a relativefew, key Insiders. From at least 1997, the Insiders engaged in a sophisticated – and startlinglyeffective – fraud using SPEs that ultimately destroyed Enron. Based on his review of “substantiallyall” of Enron’s material SPE transactions, the Enron Examiner concluded in his second report that:1The Enron Examiner’s four reports are cited as Exam. I, Exam. II, Exam. III, and Exam. IV orExam. Final Report. If the cite is to the report as opposed to its appendices, the volume is followed by a pagenumber. An example is “Exam. II at 6.” If the cite is to one of the appendices, the volume is followed bythe appendix title, which is followed by a page number. An example is “Exam. II, App. B at 3.”604041v1/007457-31-