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

anging falsification of its financial statements over the several prior years. Thus, Dynegy refused
to acquire Enron and Enron went bankrupt.
672. An example of the lengths to which JP Morgan was prepared to go to continue the
Enron fraud was the Unicredito Italiano v. JPM Chase and Citigroup case. In the Unicredito case,
CitiGroup and JP Morgan misrepresented to Unicredito (an Italian bank) that there has been no
changes in Enron's financial condition as of 10/25/01, causing Unicredito to fund a $22 million credit
facility for Enron.
673. Thus, JP Morgan is directly liable to the Class for making false and misleading
statements in Registration Statements and Prospectuses utilized by Enron and JP Morgan to raise
billions of dollars of new capital for Enron, for false and misleading statements in analysts' reports
written and issued by JP Morgan, which helped to artificially inflate the trading price of Enron's
publicly traded securities, as well as for its knowing participation in a fraudulent scheme, course of
conduct and course of business of Enron, which operated to defraud purchasers of Enron's publicly
traded securities during the Class Period.
C. Involvement of CitiGroup
674. CitiGroup is a financial services enterprise that provided both commercial banking
and investment banking services to Enron, helped to structure and finance one or more of Enron's
illicit partnerships or SPEs and helped it conceal billions of dollars of debt from Enron's balance
sheet, while its securities analysts were issuing extremely positive – but false and misleading –
reports on Enron extolling its business success, the strength of its financial condition and its
prospects for strong future earnings and revenue growth. In addition to the huge underwriting,
advisory and transactional fees, and interest and commitment charges CitiGroup was receiving from
Enron and related entities, in return for and as a reward for CitiGroup's participation in the scheme,
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