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

JP Morgan and Lehman Brothers had a clear financial interest in consummating the offerings, as they
received approximately $4 million in underwriting fees for each and stood to obtain millions of
dollars for completing the offerings and/or stood to benefit from the resulting capital infusion to
Enron, as JP Morgan and Lehman Brothers collectively had billions of dollars of outstanding loan
exposure to Enron.
of the Notes:
1016.19 The defendants named herein did the following acts in furtherance of the sale
(a) They actively and jointly drafted, revised and approved the Selling Documents
by which the sale of the 6.40% Notes and 6.95% Notes was made to the investing public. The
Registration Statement and Prospectus were "selling documents," calculated by these defendants to
create interest in the 6.40% Notes and 6.95% Notes, were filed with the SEC and were widely
distributed by defendants for that purpose.
(b) The defendants named herein finalized the Selling Documents, caused them
to become effective and caused them to be provided to the Washington Board and the Note Subclass.
But for the defendants having drafted, filed, and/or signed the Selling Documents, the offering of the
6.40% Notes and 6.95% Notes could not have been made.
1016.20 The Washington Board and the members of the Note Subclass have been
damaged in that they paid artificially inflated prices for the 6.40% Notes and 6.95% Notes. The
Washington Board and the Note Subclass would not have purchased the 6.40% Notes or the 6.95%
Notes at the prices they paid, or at all, if they had been aware that the prices had been artificially
inflated by defendants' misleading statements.
1016.21 Each of the defendants named herein issued, caused to be issued and/or
participated in the issuance of materially false and misleading statements and/or misrepresented or
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