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eing used to reduce Enron’s reported year-end net debt position and noted issues relating to theabsolute level of manipulation undertaken by Enron in its financial statements.(c)On or about February 1, 2000, McAlister sent an e-mail to Derek Weirregarding RBS’ knowledge that Enron was going to boost cash flows from operating activities fromNixon.RBC1594. In connection with the Alberta transaction, RBC knowingly gave substantialassistance to the Insiders:(a)On August 24, 2000, Ian McArthur e-mailed Bob Hall, Frank Piazza, andBlair Fleming, regarding RBC’s participation in the Alberta financing.(b)On August 30, 2000, Ian McArthur and Mike Ellison submitted to RBC a firsttransaction approval request for Alberta that acknowledged that the structure would receiveoff-balance sheet treatment.(c)On September 27, 2000, RBC employees prepared a Final AlbertaTransaction request, detailing the structure of the Alberta Transaction.(d)On September 26, 2000, Blair Fleming e-mailed Ian McArthur, GraemeHepworth and others explaining that a linkage in the Alberta structure could not be documented foraccounting reasons.1595. As a direct and proximate result of the Bank Defendants’ actions and omissions,Enron was injured and damaged in at least the following ways: (1) its debt was wrongfully expandedout of all proportion to its ability to repay and it became insolvent and thereafter deeply insolvent;(2) it was forced to file bankruptcy and incurred and continues to incur substantial legal andadministrative costs, as well as the costs of governmental investigations; (3) its relationships withits customers, suppliers and employees were undermined; and (4) its assets were dissipated.604041v1/007457-504-