Case Documents

Notice of Hearing Regarding ECRC's Motion Seeking Court Approval of Settlement Agreement

  • This notice provides the date on which the hearing will be held and provides the process by which interested parties can file responses to the motion.

ECRC’s Motion Seeking Court Approval of Settlement Agreement

  • This motion outlines ECRC’s request for approval of the settlement and also includes all relevant exhibits.

Executed Global Settlement Agreement

  • This document provides the agreement between ECRC and Citigroup, along with other relevant parties, to settle litigation and provides the terms of settlement.
  • Please click here to view the Notice of Filing of Exhibit J.
  • A fully executed copy of Exhibit K, the CLN Distribution Agreement, is available here.

Decision Denying Citigroup's Motion to Withdraw

  • This decision denied Citigroup's request to move its case from bankruptcy court to district court, paving the way for the trial to proceed.

ECRC Brief in Opposition of Citigroup’s Motion to Stay

  • This brief sets forth ECRC’s arguments as to why the bankruptcy trial should commence on April 28, 2008 as scheduled.  

ECRC Filing Opposing Citigroup’s Motion for Summary Judgment on the Pleadings

  • This filing outlines the factual details of Citigroup's substantial involvement in the Enron fraud, and includes Citigroup employee email exchanges.

ECRC's Filing Opposing Citigroup's Motion for Summary Judgment on Certain Avoidance Claims

  • This memorandum outlines Citigroup's role in creating the fraudulent transactions and why therefore Enron should recover certain transfers from Citigroup

ECRC's Filing Opposing Yosemite/CLN Trusts and The Bank of New York’s Motion for Summary Judgment

  • This motion outlines why the issues of equitable subordination, avoidable transfer and preference claims merit trial.

ECRC's Filing Opposing Citigroup's Motion for Summary Judgment Dismissing Certain Common Law Claims

  • This memorandum outlines why the claims in question belong to ECRC and why, even if they belong to the creditors, the trustee still has standing to assert them.

Enron Creditors Recovery Corp.’s 4th Amended Complaint

  • This document sets forth Enron Creditors Recovery Corp.’s ("ECRC") arguments regarding the MegaClaims litigation to which Citigroup is a party.

1st Examiners Report

  • This is the first interim report of Neal Batson, the court-appointed examiner.  This report focuses on select special purpose entity (SPE) transactions.  

2nd Examiners Report

  • The second interim report of Batson continues to discuss SPEs, and also provides findings regarding various transactions between Enron and the banks involved.  

3rd Examiners Report

  • Batson filed his third interim report on June 30, 2003, and this report includes findings regarding the specific role of the financial institutions, including their roles in the SPE transactions and the theories of liability.  

Appendix D of 3rd Examiners Report – Findings regarding Citigroup

  • This Appendix to the third interim report examines the role of Citigroup in specific detail and outlines Batson’s findings with respect to Citigroup’s liability.  

ECRC's Motion in Opposition to Citigroup Defendants' Request to Withdraw Reference

  • This memorandum of law outlines ECRC's opposition to Citigroup's  request to remove its case from the bankruptcy court 49 months after the start  of the proceedings.

ECRC’s Motion for Protective Order to Allow Interviews and Testimony of Former Citi Employees

  • Motion filed by ECRC seeking a court order to allow former Citi employees to testify without fear of retribution by Citi 

You may click here to access all of the filings related to ECRC’s efforts.