Message-ID: <1866828.1075840385972.JavaMail.evans@thyme> Date: Mon, 17 Dec 2001 06:39:35 -0800 (PST) From: richardson@copn.com To: rick.buy@enron.com Subject: RE: Amended Complaint in Amalgamated Bank v. Lay, et al. Mime-Version: 1.0 Content-Type: text/plain; charset=us-ascii Content-Transfer-Encoding: 7bit X-From: Richardson, Terri X-To: Buy, Rick X-cc: X-bcc: X-Folder: \rbuy\Inbox X-Origin: BUY-R X-FileName: richard buy 1-30-02..pst Yes, it is. -----Original Message----- From: Buy, Rick [mailto:Rick.Buy@ENRON.com] Sent: Monday, December 17, 2001 7:53 AM To: Richardson, Terri Subject: RE: Amended Complaint in Amalgamated Bank v. Lay, et al. Is this case consolidated as well as the others? Rick -----Original Message----- From: Richardson, Terri [mailto:richardson@copn.com] Sent: Wednesday, December 12, 2001 6:12 PM To: Baxter, Cliff; Buy, Rick; Causey, Richard; Frevert, Mark; Hirko, Joe; Horton, Stanley; Kean, Steven J.; Koenig, Mark; McConnell, Mike; McMahon, Jeffrey; Metts, Mark; Olson, Cindy; Pai, Lou; Rice, Ken; Sutton, Joe; Williams, Robert C. Cc: Williams, Robert C. Subject: Amended Complaint in Amalgamated Bank v. Lay, et al. Good evening, everyone. Mike Peterson, who many of you have met and who is working with J.C. on your case, asked me to send the following e-mail to you: The lawyers for Amalgamated Bank filed an amended class action complaint yesterday. Based on our initial comparison of the amended complaint versus the original one (our comparison was "line by line" but not "word for word"), it appears that the only change was to add four specific requests for relief at the very end of the complaint - namely, "to order an accounting of insider-trading proceeds," "disgorgement of insider-trading proceeds," "restitution of investors' monies of which they were defrauded," and "as to the section 11 claims, awarding rescission or a rescissionary measure of damages." These additions are technical in nature and probably were designed principally to preempt any copycat suits by other plaintiffs' attorneys. The amended complaint does not appear to contain any revision of the factual allegations or asserted causes of action. If you nonetheless would like your own copy of the amended complaint (all 78 pages), just let me know and I will send it to you. This e-mail and any attached files may be confidential and subject to attorney/client privilege. If you received it in error, please immediately notify the sender by return e-mail or by calling (713)654-7600. ********************************************************************** This e-mail is the property of Enron Corp. and/or its relevant affiliate and may contain confidential and privileged material for the sole use of the intended recipient (s). Any review, use, distribution or disclosure by others is strictly prohibited. If you are not the intended recipient (or authorized to receive for the recipient), please contact the sender or reply to Enron Corp. at enron.messaging.administration@enron.com and delete all copies of the message. This e-mail (and any attachments hereto) are not intended to be an offer (or an acceptance) and do not create or evidence a binding and enforceable contract between Enron Corp. (or any of its affiliates) and the intended recipient or any other party, and may not be relied on by anyone as the basis of a contract by estoppel or otherwise. Thank you. ********************************************************************** This e-mail and any attached files may be confidential and subject to attorney/client privilege. If you received it in error, please immediately notify the sender by return e-mail or by calling (713)654-7600.