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

1000. This Claim is brought by the plaintiffs and against the defendants detailed in Ex. A
of the Exhibit Appendix. Each of the plaintiffs detailed in Ex. A of the Exhibit Appendix purchased
Enron stock contemporaneously with sales of Enron stock by defendants named in this Claim.
1001. By virtue of their positions as senior insiders of Enron, defendants named in this
Claim were in possession of material, non-public information about Enron at the time of their
collective sales of more than $1 billion of their own Enron stock to plaintiffs and members of the
Class at artificially inflated prices.
1002. By virtue of their participation in the scheme to defraud investors described herein,
and/or their sales of stock while in possession of material, non-public information about the adverse
information detailed herein, these defendants violated the 1934 Act and applicable rules and
regulations thereunder.
1003. Plaintiffs and all other members of the Class who purchased shares of Enron stock
contemporaneously with the sales of Enron stock by the defendants named in this Claim: (1) have
suffered substantial damages in that they paid artificially inflated prices for Enron stock as a result
of the violations of §§10(b) and 20(a) and Rule 10b-5 herein described; and (2) would not have
purchased Enron stock at the prices they paid, or at all, if they had been aware that the market prices
had been artificially inflated by defendants' false and misleading statements.
1004. The Enron Defendants are required to account for all such stock sales and to disgorge
their profits or ill-gotten gains.
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