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

PRAYER FOR RELIEF
WHEREFORE, plaintiffs pray for relief and judgment, including preliminary and permanent
injunctive relief, as follows:
A. Determining that this action is a proper class action, and certifying plaintiffs as class
representatives under Rule 23 of the Federal Rules of Civil Procedure;
B. Awarding preliminary and permanent injunctive relief in favor of plaintiffs and the
Class against defendants and their counsel, agents and all persons acting under, in concert with, or
for them, including an accounting of and the imposition of a constructive trust and/or an asset freeze
on defendants' insider trading proceeds;
C. Ordering an accounting of defendants' insider-trading proceeds;
D. Disgorgement of defendants' insider-trading proceeds;
E. Restitution of investors' monies of which they were defrauded;
F. Awarding compensatory damages in favor of plaintiffs and the other Class members
against all defendants, jointly and severally, for all damages sustained as a result of defendants'
wrongdoing, in an amount to be proven at trial, including interest thereon;
G. As to the §§11, 12(a)(2) and/or §15 claims, awarding rescission or a recessionary
measure of damages;
H. Awarding plaintiffs and the Class their reasonable costs and expenses incurred in this
action, including counsel fees and expert fees; and
I. Such other and further relief as the Court may deem just and proper.
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