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

fraudulent scheme by repeatedly issuing throughout the Class Period false and misleading statements
in its analyst research reports.
(d) Deutsche Bank Trust Company Americas – a wholly owned subsidiary of
Deutsche Bank AG through multiple subsidiaries – is the successor of Bankers Trust Company,
which was acquired by Deutsche Bank AG on 6/4/99 in the Deutsche Bank acquisition of BT Alex.
Brown. Bankers Trust and Deutsche Bank Trust Company Americas (collectively referred to herein
as "Bankers Trust") – acted (as is detailed further in the section of this Complaint entitled
"Involvement of Deutsche Bank") to further the defendants' fraudulent scheme by creating and
implementing fraudulent tax schemes designed to artificially inflate Enron's reported financial
results. Deutsche Bank Trust Company Americas, through BT Alex. Brown, Inc., also underwrote
Enron's 2/11/99 common stock offering. At all times after its acquisition, Bankers Trust was
controlled by Deutsche Bank AG.
108. (a) Defendant Lehman Brothers Holding, Inc. is a large integrated financial
services institution that through known and unknown subsidiaries, divisions, and/or affiliates acting
as the agent of and under the control of Lehman Brothers, Inc., such as Lehman Brothers, Inc. and
LBI Group Inc. (collectively, "Lehman Brothers"), provides commercial and investment banking
services, commercial loans to corporate entities, and advisory services regarding the structuring of
financial transactions, including engaging in or helping to structure derivatives and hedging financial
transactions, acting as underwriter in the sale of corporate securities to the public and providing
investment analysis and opinions on public companies, including its clients, via reports issued by
securities analysts. Lehman Brothers engaged and participated in the scheme to defraud purchasers
of Enron securities and Enron's course of business which operated as a fraud and deceit on
purchasers of Enron's securities by rendering all of the above services to Enron as described in
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