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

knew would be highly embarrassing and could expose them to liability to third parties and
subordination of their creditor claims against Enron. Their scheme could not succeed unless they
kept Enron's investment grade credit rating in place until the sale to Dynegy could be completed.
So, on or about 11/8/01, Rubin, the Vice Chairman of CitiGroup, and Harrison, the Chairman of JP
Morgan, called Moody's – a key rating agency – and pressured Moody's to keep Enron's investment
grade credit rating in place until JP Morgan and CitiGroup could complete the sale of Enron to
Dynegy.
691. As noted above, in the Unicredito case CitiGroup and JP Morgan misrepresented to
Unicredito that there had been no changes in Enron's financial condition as of 10/25/01, causing
Unicredito to fund a $22 million credit facility for Enron. This was right after Enron had announced
$1 billion in charges and written down equity by $1 billion and was just as Enron was in the process
of restating transactions, including LJM which CitiGroup was involved in.
692. Thus, CitiGroup is directly liable to the Class for making false and misleading
statements in Registration Statements and Prospectuses utilized by Enron and CitiGroup to raise
billions of dollars of new capital for Enron, for false and misleading statements in analysts' reports
written and issued by CitiGroup, 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 of Enron and manipulative devices and a fraudulent course of business of Enron, which
operated to defraud purchasers of Enron's publicly traded securities during the Class Period.
D. Involvement of CS First Boston
693. CS First Boston is a financial services enterprise that had an extensive and extremely
close relationship with Enron. During the Class Period, CS First Boston provided both commercial
banking and investment banking services to Enron, helped structure and/or finance several of Enron's
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