Enron Corp. - University of California | Office of The President

learned as a director of Enron and a member of its Finance Committee. Alliance controlled and
directed Savage in his activities as a director of Enron. A key to keeping Enron's stock high was
Enron maintaining its investment grade credit rating and its apparently strong financial condition –
which required Enron to constantly raise new capital – an activity which was under the Enron
Board's Finance Committee's control. Savage is sued under §11 of the 1933 Act for the above-
referenced securities offering. Alliance is sued as a controlling person of Savage and is liable under
§§11 and 15 of the 1933 Act.
(ff) The individuals named as defendants in 83(a)-(d), (f)-(n), (p)-(ee) are
referred to herein as the "Enron Defendants." Because of their positions with the Company, each
Enron Defendant had access to the adverse non-public information about the Company's business,
finances, products, markets and present and future business prospects via access to internal corporate
documents (including the Company's product sales, operating plan, budget and forecast and product
sales reports of actual operations compared thereto), conversations and connections with other
corporate officers and employees, attendance at management and Board of Directors meetings and
committees thereof and via reports and other information provided to them in connection therewith.
(gg) Defendants Lay, Mark-Jusbasche and Skilling served as officers and/or
directors of Azurix, a company related to Enron and which was involved in the alleged wrongdoing.
These defendants, in committing the wrongs alleged herein, were acting not only in their capacity
as officers and/or directors of Enron, but also in their capacities as officers or directors of Azurix.
(hh) Defendants Lay, Pai and Causey served as officers and/or directors of New
Power, a company related to Enron and which was involved in the alleged wrongdoing. These
defendants, in committing the wrongs alleged herein, were acting not only in their capacity as
officers and/or directors of Enron, but also in their capacities as officers or directors of New Power.
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