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

(u) Deleted.
(v) Deleted.
(w) Deleted.
94. Each defendant listed in 93(a)-(d), (g)-(o) and (q) was a partner and/or employee
of Andersen. They were involved in the audits and consultations of Enron and had knowledge of
the adverse facts as pleaded at 897-982.
95. Deleted.
96. Defendant Berardino, is named herein as a control person of Andersen pursuant to
§20(a) of the 1934 Act and §15 of the 1933 Act.
97. A more detailed description of Andersen's involvement and its failure to comply with
Generally Accepted Auditing Standards ("GAAS") is found in 897-982.
(3) The Law Firm
98. Defendant Vinson & Elkins L.L.P. ("Vinson & Elkins") was Enron's outside general
counsel during the Class Period. Enron was Vinson & Elkins's largest client. Vinson & Elkins
participated in structuring Enron's illicit partnerships (Chewco/JEDI and the LJMs) and the bogus
SPEs (Raptors/Condor, etc.) knowing these were manipulative devices being used to falsify Enron's
reported financial results and financial condition. Vinson & Elkins repeatedly issued false opinions
on these transactions – that they were "true sales" or otherwise legitimate business transactions –
when they were, in fact, manipulative contrivances designed to artificially boost Enron's reported
profits and hide billions of dollars of debt that belonged on Enron's balance sheet.
99. Deleted.
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