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

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(g) Plaintiff Amalgamated Bank, as Trustee for the LongView Collective<br />

Investment Fund, LongView Core Bond Index Fund and Certain Other Trust Accounts<br />

("Amalgamated"), purchased over 115,000 shares <strong>of</strong> <strong>Enron</strong> stock and millions <strong>of</strong> dollars <strong>of</strong> <strong>Enron</strong><br />

debt securities at artificially inflated prices during the Class Period, as detailed in its Amended<br />

Certification, and has suffered damage as a result there<strong>of</strong>. Amalgamated is America's oldest union<br />

owned and operated labor bank.<br />

(h) Deleted.<br />

(i) Plaintiff Robert V. Flint ("Flint") is an 87 year old retiree who purchased<br />

<strong>Enron</strong> equity securities at artificially inflated prices during the Class Period, as detailed in his<br />

Certification previously filed with the Court, and has suffered substantial damage as a result there<strong>of</strong>.<br />

Notwithstanding his substantial pr<strong>of</strong>essional and investment experience, including 57 years investing<br />

in the securities markets and 40+ years working as a metallurgical engineer, Flint was fraudulently<br />

induced to purchase <strong>Enron</strong> equity securities as detailed in his Certification and has been damaged<br />

thereby.<br />

(j) Plaintiff John Zegarski ("Zegarski") is a former <strong>Enron</strong> employee who<br />

purchased equity securities <strong>of</strong> <strong>Enron</strong> in his 401(k) account at $84.50 per share, as detailed in his<br />

Certification previously filed with the Court, and has suffered substantial damage as a result there<strong>of</strong>.<br />

Zegarski's ability to fund his retirement plan has been substantially impaired by the fraud alleged<br />

herein.<br />

(k) Each <strong>of</strong> the plaintiffs detailed in Ex. A attached to the Exhibit Appendix<br />

purchased <strong>Enron</strong> common stock contemporaneously with the sale <strong>of</strong> <strong>Enron</strong> stock by one or more <strong>of</strong><br />

the defendants named in 999-1000 below in violation <strong>of</strong> §20A <strong>of</strong> the 1934 Act, as detailed in their<br />

Certifications, and suffered substantial damage as a result there<strong>of</strong>.<br />

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