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

length transactions with to generate huge profits and to move billions of dollars of debt off its
balance sheet.
759. Barclays's financing and participation in Chewco was an essential and integral part
of Enron's scheme of concealing its true debt levels by moving billions of dollars of debt off its
books and onto the books of SPEs it secretly controlled, while improperly recognizing millions of
dollars of profits on transactions with those entities. The importance of the Chewco transactions can
not be overstated. Later on, when the Enron scheme collapsed and Enron was forced to restate its
prior financial results, the impact of its illicit transactions with Chewco were enormous.
760. Barclays knew that Enron was falsifying its publicly reported financial results and that
its true financial condition was much more precarious than was publicly known. It obtained this
knowledge due to its unlimited access to Enron's internal business and financial information as one
of Enron's lead lending bank, as well as its intimate interaction with Enron's top officials which
occurred virtually on a daily basis.
761. Thus, Barclays is directly liable to the Class for statements in Registration Statements
and Prospectuses utilized by Enron and Barclays to raise billions of dollars of new capital for Enron,
for false and misleading statements in analysts' reports written and issued by Barclays, which helped
to artificially inflate the trading price of Enron's publicly traded securities, as well as for its knowing
participation in manipulative devices, a fraudulent scheme, course of conduct and fraudulent course
of business of Enron, which operated to defraud purchasers of Enron's publicly traded securities
during the Class Period.
H. Involvement of Lehman Brothers
762. Lehman Brothers is a banking enterprise which had an extensive and extremely close
relationship with Enron. During the Class Period, Lehman Brothers provided commercial banking
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