ECRC recently filed oppositions to Citigroup's various motions for summary judgment. In these documents, ECRC provides evidence highlighting Citigroup's significant involvement in Enron's collapse.

Below, please copies of some of the internal emails and memos circulated by Citigroup employees at the time of the fraud, which reflect their knowledge and involvement. The text of former CEO Chuck Prince's testimony is also included.

For more information about the Citigroup case, please click here.

Testimony

• Chuck Prince's Senate testimony regarding Enron

Depositions

• P. Deards deposition (relevant parts)
• A. Kulick deposition (relevant parts)
  "We specifically designed the prepaids and tweaked the prepaids according to feedback from Enron to achieve whatever accounting it wanted to."

Citigroup E-mails about Enron

• E-mail between P. Deards and R. Caplan
  "... we put together deals for [E]nron which we knew confused the ratings agencies."
• E-mail between T. Dickens and A. Rifkin
  "Wagman knows where all the bodies are buried..."
• E-mail between R. Caplan and S. Wagman
  "Sounds like we made a lot of exceptions to our standards policies ... let's remember to collect this iou when it really counts."
• E-mail between T. Randolph and C. Lyons
  "just highlight all of the fraudulent deals you've done"; reply: "You mean like Nahanni!"
• E-mail between P. Deards and A. Tomlinson
  "When [E]nron blows up will it be worse than long term capital?"
• E-mail between S. Elliot and W. Fox
  "Based on the 1999 numbers would appear that Enron significantly dresses up its balance sheet for year end; suspect we can expect the same this year."
• E-mail from M. Lo Bosco
  "Make no mistake, this is economically a loan, but it was set up via pre-paid commodity forwards ..."
• E-mail from M. Zimmerman
  ". . . to visit Enron, one of the biggest train wrecks in corporate America."
• E-mail from P. Ryan
  "Dave [Bushnell] is always interested in Enron-related business because he thinks Enron is a bit of a shell game that could blow up someday."
• E-mail between W. Fox and J. Reilly
  "Trust me, Enron, deal"
• E-mail between J. Reilly and D. Mitchell
  "Quarter-end support has been an important part of the foundation of our relationship..."
• E-mail from J. Reilly
  "Enron states that the objective of the transactions is to reduce debt levels at YE ... For Enron this transaction is 'mission critical' (their label not mine) for YE and a 'must' for us."
• E-mail exchange between J. Reilly and M. Nepveux
  "... it is, essentially, an insurance policy for YE 'balancing'."
• E-mail from J. Reilly
  "Bacchus is part of a program designed to ensure that Enron will meet its YE debt/cap targets..."
• E-mail exchange between S. Bernstein and F. Battline
  "I am not suggesting that we are responsible for their accounting, but I am afraid that if we ever had to defend this we would either (a) embarrass the client or (b) lose the accounting argument."
• E-mail exchange between R. Beadon and T. Stott
  "After watching two of our best derivative customers go down in flames ... I wonder whether any of the same dynamics are driving the derivative business with Enron."
• E-mail exchange between J. Miller and N. Kirk
  "Also, please note that FFOs are 'manipulatable.' Enron does quite a bit of it - including prepaid transactions that "create" funds flow. So, if you see a client that uses mark-to-market accounting, then be on the look-out for the tricks."
• E-mail exchange between L. Feintech and R. Caplan
  "[P]erwein wanted to say that this is a funky deal (accounting-wise). He is amazed that they can get it off balance sheet."
• E-mail exchange between P. Deards and C. Fehon
  ". . . does not involve management of commodity exposures at all, but is simply manipulating cash flows ..."
• E-mail from J. Reilly
  "The paperwork cannot reflect their agreement to repay the $190MM as it would unfavorably alter the accounting ..."

Citigroup memos regarding Enron

• D. Bushnell Memo
  "[T]his is a complex structured transaction, which I have refused to sign-off on ... The GAAP accounting is aggressive and a franchise risk to us if there is publicity (a la Xerox) ... Lastly, our internal processes on this left a lot to be desired. ... The mismanagement of the process raises real questions about the discipline and adherence to policies..."
• Yosemite Transaction Memo
  "Enron puts a high degree of value on the innovative transaction brought to them by Enron top tier banks. These transactions have historically provided Enron with various forms of off balance sheet financing, tax efficient financing or cost effective equity-like financing."
• Citigroup Exposure Memo
  "Enron has used Nahanni only for year-end window dressing in the past."