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Case 2:03-cv-01500-K0B-TMP Document 1391 Filed 05/27/2008 Page 1 of 41 FILED

2008 May-27 PM 06:43

U.S. DISTRICT COURT

N.D. OF ALABAMA





UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ALABAMA

SOUTHERN DIVISION



In re HEALTHSOUTH CORPORATION )

SECURITIES LITIGATION ) MASTER FILE NO.

) CV-03-BE-1500-C

This Document Relates To: All Actions

)

)

In re HEALTHSOUTH CORPORATION ) CONSOLIDATED CASE NO.

STOCKHOLDER LITIGATION ) CV-03-BE-1501-S

This Document Relates To: All Actions )

)

)

In re HEALTHSOUTH CORPORATION ) CONSOLIDATED CASE NO.

BONDHOLDER LITIGATION ) CV-03-BE-1502-S

This Document Relates To: All Actions )

)









UBS DEFENDANTS' MEMORANDUM IN SUPPORT OF

THEIR RULE 12(C) MOTION FOR JUDGMENT ON

THE PLEADINGS DISMISSING PLAINTIFFS'

SECTION 10(B) "SCHEME TO DEFRAUD" CLAIMS

Case 2:03-cv-01500-KOB-TMP Document 1391 Filed 05/27/2008 Page 2 of 41







Robert J. Giuffra, Jr. W. Michael Atchison (ASB-4005-T75W)

Brian T. Frawley Jay M. Ezelle (AZB-4744-Z72J)

Julia M. Jordan Robin H. Jones (ASB-0769-R51J)

Erin R. Chlopak STARNES & ATCHISON LLP

SULLIVAN & CROMWELL LLP 100 Brookwood Place, Seventh Floor

125 Broad Street Birmingham, Alabama 35209

New York, New York 10004 (205) 868-6000

(212) 558-4000

Counsel for UBS AG, UBS Securities LLC,

Counsel for UBS AG, UBS Securities Howard Cape/c, Benjamin D. Lorello and

LLC, Howard Cape/c, Benjamin D. William C. McGahan

Lorello and William C. McGahan



Helen Gredd

Thomas Fitzpatrick Daniel Gitner

LAW OFFICES OF THOMAS LANKLER SIFFERT WOHL LLP

FITZPATRICK 500 Fifth Avenue

500 Fifth Avenue, 33rd Floor New York, New York 10110

New York, New York 10110 (212) 921-8399

(212) 930-1290

Counsel for William C. McGahan

Counsel for Howard Capek



Robert J. Anello

Richard F. Albert

MORVILLO, ABRAMOWITZ, GRAND,

IASON, ANELLO BOHRER, P.C.

656 Fifth Avenue

New York, New York 10017

(212) 856-6000



Counsel for Benjamin D. Lorello



May 27, 2008

Case 2:03-cv-01500-K0B-TMP Document 1391 Filed 05/27/2008 Page 3 of 41









TABLE OF CONTENTS

Page



PRELIMINARY STATEMENT 1



BACKGROUND 4



A. Plaintiffs' Flawed "Scheme" Theory of Section 10(b)

Liability 4



B. The Misrepresentation Claims 5



C. Regents 6



D. The Supreme Court's Stoneridge Decision 6



STANDARD ON THIS MOTION 9



ARGUMENT 9



I. UNDER STONERIDGE AND REGENTS, JUDGMENT MUST

BE ENTERED FOR UBS ON PLAINTIFFS' "SCHEME"

CLAIMS. 9



A. Stoneridge Rejected, as a Matter of Law, Plaintiffs'

"Scheme" Theory Here. 9



1. Following Stoneridge, There is No "Scheme"

Liability. 9



2. Plaintiffs Cannot Establish Reliance on Any DES

Conduct. 11



3. Plaintiffs' "Scheme" Claims Allege Only Legally

Non-Existent Aider and Abettor Liability. 14



4. Plaintiffs' "Scheme" Claims Against DES Lack

Any Viable Theory of Loss Causation. 15



5. Stoneridge Rejected "Scheme" Liability Based on

the Narrow Scope of the Section 10(b) Private

Right of Action, Not the Particular Services

Provided by a Defendant 17

Case 2:03-cv-01500-K0B-TMP Document 1391 Filed 05/27/2008 Page 4o1 41









B. The "Extremely Persuasive" Regents Decision Remains

Good Law, and Requires Judgment for DES 21



1. Regents Remains a Correct Statement of the Law 21



2. Regents Cannot be Distinguished From the Facts

Alleged Here and Requires Judgment for DES. 23



IL ONCE PLAINTIFFS' "SCHEME" CLAIMS ARE

ELIMINATED, THEIR REMAINING SECTION 10(B) CLAIMS

ALSO ARE DEFICIENT. 27



CONCLUSION 29









-11-

Case 2:03-cv-01500-K0B-TMP Document 1391 Filed 05/27/2008 Page 5 of 41









TABLE OF AUTHORITIES



Page (s)

FEDERAL CASES



Avis Budget Group, Inc. v. Cal. State Teachers' Ret. Sys.,

128 S. Ct. 1119 (2008) 21



Central Bank of Denver, N.A. v. First Interstate Bank of Denver, N.A.,

511 U.S. 164 (1994) passim



In re Coca-Cola Enters. Inc. Sec. Litig.,

No. 1:06-CV-0275-TWT, 2007 WL 2904160 (N.D. Ga. Oct. 3, 2007) 16



Cordova v. Lehman Bros.,

526 F. Supp. 2d 1305 (S.D. Fla. 2007) 16



Davies Warehouse Co. v. Bowles,

321 U.S. 144 (1944) 20



Davis v. Coca-Cola Bottling Co. Consol.,

516 F.3d 955 (11th Cir. 2008) 9



Dura Pharms., Inc. v. Broudo,

544 U.S. 336 (2005) 17,29



In re Dura Pharms. Inc. Sec. Litig.,

No. 99CV0151, JLS (WMc),

2008 WL 483613 (S.D. Cal. Feb. 20, 2008). 10



Hawthorne v. Mac Adjustment, Inc.,

140 F.3d 1367 (11th Cir. 1998) 9



JHW Greentree Capital, L.P. v. Whittier Trust Co.,

No. 05 Civ. 2985 (HB),

2005 WL 3008452 (S.D.N.Y. Nov. 10, 2005) 27



Katz v. Image Innovations Holdings, Inc.,

No. 06 Civ. 3707 (JGK), 2008 WL 762105 (S.D.N.Y. Mar. 24, 2008) 10



Lentell v. Merrill Lynch & Co.,

396 F.3d 161 (2d Cir.), cert. denied, 546 U.S. 935 (2005) 27

Case 2:03-cv-01500-K0B-TMP Document 1391 Filed 05/27/2008 Page 6 of 41









Page(s)



In re Marsh & McLennan Cos. Sec. Litig.,

501 F. Supp. 2d 452 (S.D.N.Y. 2006) 27



Matsushita Elec. Indus. Co. v. Epstein,

516 U.S. 367 (1996) 20



In re National Century Fin. Enters., Inc., Inv. Litig.,

No. 2:03-md-1565, 2006 WL 469468 (S.D. Ohio Feb. 27, 2006) 27



In re National Century Fin. Enters., Inc., Inv. Litig.,

No. 2:03-md-1565, 2008 WL 918708 (S.D. Ohio Apr. 2, 2008) 13



In re Parmalat Sec. Litig.,

376 F. Supp. 2d 472 (S.D.N.Y. 2005) 27



Presnell v. Zant,

959 F.2d 1524 (11th Cir. 1992) 22



Provident Mut Life Ins. Co. of Philadelphia v. City of Atlanta,

864 F. Supp. 1274 (N.D. Ga. 1994) 9



Pugh v. Tribune Co.,

No. 06-3898, 2008 WL 867739 (7th Cir. Apr. 2, 2008) 10, 13, 14



In re Recoton Corp. Sec. Litig.,

358F. Supp. 2d1130 (M.D. Fla. 2005) 27



Regents of the University of California v. Merrill Lynch, Pierce,

Fenner & Smith, Inc.,

128 S. Ct. 1120 (2008) 21



Regents of the University of California v. Credit Suisse

First Boston (USA), Inc.,

482 F.3d 372 (5th Cir. 2007) passim



Robbins v. Koger Props., Inc.,

116 F.3d 1441 (11th Cir. 1997) 17,29



Rowinski v. Salomon Smith Barney Inc.,

398 F.3d 294 (3d Cir. 2005) 20







-iv-

Case 2:03-cv-01500-K0B-TMP Document 1391 Filed 05/27/2008 Page 7 of 41









Page (s)



SEC v. Zandford,

535 U.S. 813 (2002) 19



Simpson v. AOL Time Warner Inc.,

452 F.3d 1040 (9th Cir. 2006) 4



Stoneridge Investment Partners, L r v. Scientific-Atlanta, Inc.,

128 S. Ct. 761 (2008) passim



TCS Capital Mgmt., LLC v. Apax Partners, L.P.,

No. 06-CV-13477(CM),

2008 WL 650385 (S.D.N.Y. Mar. 7, 2008) 18



United States v. Savin,

349 F.3d 27 (2d Cir. 2003) 21



Wells v. Meyer 's Bakery,

561 F.2d 1268 (8th Cir. 1977) 22



STATUTES, RULES AND REGULATIONS



17 C.F.R. § 240.10b-5 8









-v-

Case 2:03-cv-01500-K0B-TMP Document 1391 Filed 05/27/2008 Page 8 of 41









PRELIMINARY STATEMENT



In these cases, Stockholder and Bondholder Plaintiffs have asserted



two theories of liability against UBS 1 under Section 10(b) of the Securities



Exchange Act of 1934 (the "Exchange Act"): (1) their so-called "scheme to



defraud" theory under Rule 10b-5(a) and (c); and (2) their more traditional



"misrepresentation" theory under Rule 10b-5(b).



Under their "scheme" theory, Plaintiffs seek to hold DES liable for all



of their losses from HealthSouth's massive, multi-year accounting and financial



reporting fraud, even though there is no dispute that: (a) HealthSouth employees



carried out this fraud by making billions of dollars worth of false entries in



HealthSouth's accounting systems and financial records, (b) the vehicle for



deceiving investors was HealthSouth's publicly issued, fraudulent financial



statements; and (c) DES had no role at all in preparing HealthSouth's accounting



records or financial statements.



The time has come for this Court finally to put to rest Plaintiffs'



legally flawed "scheme" claims against DES. As the Supreme Court has now



made clear in its highly anticipated decision in Stoneridge Investment Partners,



LLC v. Scientific-Atlanta, Inc., 128 S. Ct. 761 (2008), Plaintiffs' "scheme" claims



against DES fail as a matter of law. As numerous courts, including the Seventh



The DES Defendants are DES AG, DES Securities LLC, Benjamin D.

Lorello, William C. McGahan and Howard Capek. For ease of reference, "DES"

is used here to refer to all or some of the DES Defendants.

Case 2:03-cv-01500-K0B-TMP Document 1391 Filed 05/27/2008 Page 9 of 41









Circuit, have confirmed, Stoneridge put to rest any notion of so-called "scheme"



liability. Plaintiffs' "scheme" claims have exaggerated the stakes and



unnecessarily complicated discovery and pretrial proceedings in this already



complex litigation. Dismissing Plaintiffs' legally deficient "scheme" claims now



will substantially narrow and simplify the issues in this case, including those that



bear upon the pending motion for class certification, and streamline expert



discovery, other pretrial proceedings and summary judgment motions.



Even before Stoneridge, this Court had expressed grave reservations



about the viability of Plaintiffs' "scheme" claims against DES. In its September 6,



2007 Opinion ("September 6 Opinion"), this Court observed that the Fifth Circuit's



rejection of indistinguishable "scheme" claims against the Enron investment banks



in Regents of the University of California v. Credit Suisse First Boston (USA), Inc.,



482 F.3d 372 (5th Cir. 2007), "casts serious doubt" on Plaintiffs' "scheme claims"



against DES here. (September 6 Opinion at 5, 10.) Yet, because the then-pending



Stoneridge petition "present[ed] the same question as Regents," this Court



concluded that "prudence require[d] awaiting further developments [from the



Supreme Court] before altering its prior ruling." (Id. at 5, 10.)



The "scheme" claims failed in Stoneridge, as they must in this case,



because this theory cannot satisfy the reliance element of Section 10(b). The



Supreme Court held that reliance upon each defendant's supposed deception is



essential to any claim under Section 10(b) because "[t]he conduct of a secondary

-2-

Case 2:03-cv-01500-K0B-TMP Document 1391 Filed 05/27/2008 Page 10 of 41









actor must satisfr each of the elements or preconditions for liability." Stoneridge,



128 S. Ct. at 769 (emphasis added). Yet, as the Supreme Court held, the reliance



requirement cannot be met with respect to a third party that engaged in even



"[u]nconventional" transactions with an issuer when it was the issuer that later



misreported or otherwise misrepresented the transactions. Id. at 774. The



Stoneridge decision expressly rejected the notion — upon which all of Plaintiffs'



"scheme" claims against DES here rest — "that in an efficient market investors rely



not only upon the public statements relating to a security but also upon the



transactions those statements reflect." Id. at 770.



The Supreme Court also emphasized that a Section 10(b) claim based



on a third party's supposed participation in a public company's "scheme to



defraud" its investors raised a claim only for aiding and abetting barred by its



earlier decision in Central Bank of Denver, N.A. v. First Interstate Bank of Denver,



N.A., 511 U.S. 164 (1994). Stoneridge, 128 S. Ct. at 771. As the Court made



clear, imposing Section 10(b) liability on the theory that a third party, such as an



investment bank, violates Section 10(b) by allegedly committing a "deceptive act



in the process of facilitating the fraud" of a public company would impermissibly



"revive in substance the implied cause of action against all aiders and abettors."



Id. at 771. Here, as well, Plaintiffs' "scheme" claims against the DES Defendants



allege nothing more than aiding and abetting theories barred by Central Bank.







-3-

Case 2:03-cv-01500-K0B-TMP Document 1391 Filed 05/27/2008 Page 11 of 41









Moreover, once Plaintiffs' legally flawed "scheme" claims are



dismissed, other fatal legal defects in Plaintiffs' remaining Section 10(b) claims



become readily apparent. Under settled law, these claims — alleging that DES



made some misrepresentations in research reports or offering documents — fail as a



matter of law to plead any viable theory of reliance or loss causation.



BACKGROUND



A. Plaintiffs' Flawed "Scheme" Theory of Section 10(b) Liability



In their Complaint, Plaintiffs rely on the theory that DES participated



in "a scheme that deceived the investing public regarding HealthSouth's true



financial condition." (Joint Third Amended Consolidated Complaint, dated April



30, 2007 (hereinafter "Complaint") 432.) In pressing their theory, Plaintiffs



parrot the same "principal purpose and effect" formulation — now expressly



rejected by the Supreme Court — from the Ninth Circuit's "Homestore" decision,



Simpson v. AOL Time Warner Inc., 452 F.3d 1040 (9th Cir. 2006), vacated and



remanded, 128 S. Ct. 1119 (2008): "The principal purpose and effect of the UBS



Defendants' activities was to create the false appearance of HealthSouth's financial



vitality and deceive HealthSouth's investors into believing that the Company was a



growing, thriving business." (Complaint 432.)



Plaintiffs do not allege that DES prepared or participated in preparing



any HealthSouth financial statements. Indeed, unlike the allegations in Regents



and Stoneridge, the accounting misstatements here are not even premised on the



-4-

Case 2:03-cv-01500-K0B-TMP Document 1391 Filed 05/27/2008 Page 12 of 41









misrecording of transactions involving DES, but the outright fabrication by



HealthSouth insiders of HealthSouth's revenues and other accounting entries.



Plaintiffs allege merely that DES participated in HealthSouth's "scheme" by



providing various forms of financial advice and services to HealthSouth, including:



(i) advisory services on time-barred transactions that occurred years

before the start of the Class Period (and which, for the most part, did

not involve DES) (see Complaint 433(a), 434-42) and two

unconsummated transactions (id. 443);



(ii) DES's participation, along with dozens of other banks, in

HealthSouth credit facilities (id. 433(e), 459-62);



(iii) sewing as an initial purchaser, with other banks, in Rule

144A/Exxon Capital debt transactions (id. 433(b), 444-450);



(iv) engaging in financing transactions with several HealthSouth

affiliates (id. 433(f), 463-465); and



(vi) advising on (mostly time-barred) stock repurchases undertaken by

HealthSouth (id. 32, 433(d); see September 6 Opinion at 7-8).



B. The Misrepresentation Claims



In addition to their "scheme" claims, Plaintiffs separately allege



misrepresentation claims contending that DES is liable under Section 10(b) for



supposed misrepresentations in (i) four Confidential Private Placement



Memoranda issued in connection with HealthSouth's Rule 144A debt transactions,



and (ii) various HealthSouth equity research reports authored by DES analyst



Howard Capek. (See Complaint, Appendix 6.) These claims rest entirely — and

-5-

Case 2:03-cv-01500-K0B-TMP Document 1391 Filed 05/27/2008 Page 13 of 41









impermissibly — on the legally deficient scheme claims to establish reliance and



loss causation. (Stockholder Plaintiffs' Opposition to the DES Defendants'



Motion to Dismiss Plaintiffs' Amended "Scheme" and Securities Act Theories, at



57 (Sept. 12, 2006) (hereinafter "Stockholders' 2006 Opp'n").)



C. Regents



As this Court held in its September 6 Opinion, the Fifth Circuit's



holding in Regents, if applied here, would require dismissal of Plaintiffs' "scheme"



claims against DES. The defendants in Enron were alleged to have a far broader



participation in "a far-reaching fraudulent scheme designed to take liabilities off



Enron's books temporarily to create the appearance that Enron was generating



revenue when it was actually incurring debt," all of which the Fifth Circuit held



insufficient as a matter of law to state a claim. (September 6 Opinion at 8 (citing



Regents, 482 F.3d at 377).) As this Court observed, the Regents court found that



"the investment banks' allegedly deceptive conduct 'at most aided and abetted



Enron's deceit by making its misrepresentations more plausible. The banks'



participation in the transactions, regardless of the purpose or effect of those



transactions, did not give rise to primary liability under §10(b)." (Id. at 9



(quoting Regents, 482 F.3d at 390) (emphasis added).)



D. The Supreme Court's Stoneridge Decision



Stoneridge was a putative class action on behalf of shareholders of



Charter Communications, Inc. ("Charter"), a cable television provider, against,



-6-

Case 2:03-cv-01500-K0B-TMP Document 1391 Filed 05/27/2008 Page 14 of 41









among others, Respondents Scientific-Atlanta, Inc. and Motorola, Inc.



("Respondents"), two suppliers of cable set top boxes to Charter. Stoneridge, 128



S. Ct. at 766. Respondents allegedly engaged in a variety of transactions designed



for the express purpose of inflating Charter's revenues, including (i) producing



fictional revenues by overpaying for cable boxes in one year with the agreement



that the overpayment would be repaid later through the "purchase" of worthless



advertising, (ii) preparing false documents to make the deals appear substantive,



and (iii) back-dating agreements to create the appearance that these arrangements



were unrelated, which was necessary to dupe Charter's accountants. Id. at 766-67.



The Stoneridge plaintiffs alleged that Respondents violated Section



10(b) by arranging these round-trip sham transactions that "had no economic



substance," but instead had "the purpose and effect of creating a false appearance



of material fact to further a scheme to misrepresent Charter's revenue." Id. at 766,



770. The Supreme Court accepted as true plaintiffs' assertion that Respondents



knew that Charter "inten[ded] to use the transactions to inflate its revenues and



knew the resulting financial statements issued by Charter would be relied upon by



research analysts and investors." Id. at 767. According to Plaintiffs, Charter's



false financial statements were "a natural and expected consequence of



respondents' deceptive acts," establishing a sufficient "causal link to apply



Basic's presumption of reliance to respondents' acts." Id. at 770 (citing Basic Inc.



v. Levinson, 485 U.S. 224 (1988)).

-7-

Case 2:03-cv-01500-K0B-TMP Document 1391 Filed 05/27/2008 Page 15 of 41









The Supreme Court disagreed, holding that the attenuated notions of



reliance and loss causation underlying plaintiff's "scheme liability" theory could



not state a viable claim under Section 10(b). Id. at 770. At the outset, the Court



bluntly rejected any notion that so-called "scheme" liability might exist simply



because such a claim invoked words contained in SEC Rule 10b-5, 17 C.F.R.



§ 240.10b-5. "Rule 10b-5 encompasses only conduct already prohibited by §



10(b)." Id. at 768. Thus, the scope of liability is governed solely by the words of



the statute, and the "narrow dimensions" of the judicially created private right of



action under Section 10(b). Id. at 774.



The Supreme Court rejected Plaintiffs' "scheme" theory for at least



three reasons. First, the "scheme" theory could not provide the requisite reliance to



establish liability under Section 10(b), because the theory did not purport to



establish direct reliance on any action of the scheme participants, which runs afoul



of the rule that the "conduct of a secondary actor must satisfy each of the elements



or preconditions for liability." Id. at 769. Second, the theory would "revive in



substance the implied cause of action against aiders and abettors" that was



previously rejected in Central Bank. Id. at 771. Third, as a judicially created right



of action that Congress has declined to expand in the Private Securities Litigation



Reform Act ("PSLRA"), "the § 10(b) private right should not be extended beyond



its present boundaries" by judicial fiat. Id. at 773.







-8-

Case 2:03-cv-01500-K0B-TMP Document 1391 Filed 05/27/2008 Page 16 of 41









Shortly after Stoneridge, the Supreme Court denied the certiorari



petition filed by plaintiffs in the Regents case.



STANDARD ON THIS MOTION



"Judgment on the pleadings is appropriate when there are no material



facts in dispute, and judgment may be rendered by considering the substance of the



pleadings and any judicially noticed facts." Hawthorne v. Mac Adjustment, Inc.,



140 F.3d 1367, 1370 (11th Cir. 1998). "A motion for judgment on the pleadings is



subject to the same standard as is a Rule 12(b)(6) motion to dismiss." Provident



Mitt Life Ins. Co. of Philadelphia v. City of Atlanta, 864 F. Supp. 1274, 1278



(N.D. Ga. 1994). To state a claim, the allegations must "plausibly suggest' and



not be "merely consistent with' a violation of the law. Davis v. Coca-Cola



Bottling Co. Consol., 516 F.3d 955, 974 n.43 (11th Cir. 2008) (quoting Bell Atl.



Corp. v. Twombly, 127 S. Ct. 1955, 1966 (2007)).



ARGUMENT



I. UNDER STONERIDGE AND REGENTS, JUDGMENT MUST BE

ENTERED FOR UBS ON PLAINTIFFS' "SCHEME" CLAIMS.



A. Stoneridge Rejected, as a Matter of Law, Plaintiffs' "Scheme"

Theory Here.



I. Following Stoneridge, There is No "Scheme" Liability.

Plaintiffs' "scheme" claims against DES cannot possibly state a



Section 10(b) claim here, because the Supreme Court in Stoneridge flatly rejected



the viability of any so-called "scheme to defraud" liability theory. Stoneridge, 128





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S. Ct. at 770-773. Indeed, applying Stoneridge, lower courts have consistently



held that "Plaintiffs' allegations of scheme liability fail on the basis of Supreme



Court precedent." In re Dura Pharms. Inc. Sec. Litig., No. 99CV0151, JLS (WMc),



2008 WL 483613, at *11 (S.D. Cal. Feb. 20, 2008). "[A]fter Stoneridge, a theory



of scheme liability cannot be coupled with the efficient market theory to provide



grounds for asserting claims against secondary actors whose alleged deceptive



conduct was not relied upon by investors." TCS Capital Mgmt., LLC v. Apax



Partners, L.P., No. 06-CV-13447(CM), 2008 WL 650385, at *25 (S.D.N.Y. Mar.



7, 2008). In short, after Stoneridge, the "scheme" theory of liability is dead letter.



Pugh v. Tribune Co., 521 F.3d 686, 696 (7th Cir. 2008) ("allegations of so-called



'scheme liability' are insufficient under the Supreme Court's recent decision in



Stoneridge"); Katz v. Image Innovations Holdings, Inc., No. 06Civ.3707(JGK),



2008 WL 762105, at *2 (S.D.N.Y. Mar. 24, 2008) (claim that defendants 'are



liable as participants in a fraudulent scheme' to defraud purchasers of Image stock"



fails under Stoneridge) (citations and internal quotations omitted).



Thus, labeling some act or event a "scheme to defraud" has no



relevance under the securities laws. While the Supreme Court recognized that



"conduct" might establish one of the elements of a Section 10(b) claim — the



existence of a materially misleading act or omission — that "conduct" must be



"communicated to the public" to be actionable. Stoneridge, 128 S. Ct. at 769. In



other words, after Stoneridge, the only relevant question is whether each

-10-

Case 2:03-cy-01500-KOB-TMP Document 1391 Filed 05/27/2008 Page 18 of 41









defendant's conduct separately "satisflies] each of the elements or preconditions



for liability" Stoneridge, 128 S. Ct. at 769; accord Central Bank, 511 U.S. at 191.



Here, none of Plaintiffs' scheme claims do so.



In their recent submissions, Plaintiffs wrongly claimed that Stoneridge



"does not rule out liability" for "transactions structured and designed solely to



impact the price of the issuer's securities" or to "allow a company to fraudulently



make its quarterly and year-end numbers." (Stockholder Plaintiffs' Response to



DES's Submission of Recent Legal Authority Relevant to this Court's September



6, 2007 Opinion at 2, 6 (filed Jan. 23, 2008) (hereinafter "Stockholders' Stoneridge



Brief').) But those are precisely the sort of allegations that the Supreme Court



held deficient in Stoneridge: allegations that sham transactions were developed



and papered with false, back-dated documents to transform what was, in essence, a



year-end loan into revenues and to allow Charter to prepare financials "showing it



met projected revenue and operating cash flow numbers." 128 S. Ct. at 766-67. In



other words, the Supreme Court in Stoneridge rejected far stronger allegations than



what Plaintiffs say survived.



2. Plaintiffs Cannot Establish Reliance on Any UBS Conduct



"Reliance by the plaintiff upon the defendant's deceptive acts is an



essential element of the § 10(b) private cause of action. It ensures that, for liability



to arise, the 'requisite causal connection between a defendant's misrepresentation



and a plaintiffs injury' exists as a predicate for liability." Stoneridge, 128 S. Ct. at



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769 (quoting Basic, 485 U.S. at 243). The Supreme Court confirmed that the



reliance that must be proven under Section 10(b) is not merely reliance upon some



"scheme" or part of it, but Plaintiffs must allege and prove direct reliance on



DES's "own deceptive conduct." Stoneridge, 128 S. Ct. at 770 (emphasis added).



Thus, it is not enough that UBS supposedly knew that HealthSouth intended "to



use the transactions to inflate its revenues," or that "the resulting financial



statements issued by" HealthSouth in fact were relied upon by investors. Id. at



767.



In Stoneridge, the Supreme Court rejected the notion that reliance



could be established because the fraud required the third party's complicity, and



the issuer's false financial statements were "a natural and expected consequence of



respondents' deceptive acts." Id. at 770. In doing so, the Court made clear that



"there is no authority for th[e] rule" — urged by Plaintiffs here — "that in an



efficient market investors rely not only upon the public statements relating to a



security but also upon the transactions those statements reflect." Id.



Following Stoneridge, investors must show direct reliance on each



defendant's own supposed deceptive act, because Section 10(b) "does not reach all



commercial transactions that are fraudulent and affect the price of a security in



some attenuated way." Id. at 771. As the Seventh Circuit held:



[The defendant] may have foreseen (or even intended) that the . . .

scheme would result in improper revenue . . . , which would

eventually be reflected in [the issuer's] revenues and finally published

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Case 2:03-cv-01500-K0B-TMP Document 1391 Filed 05/27/2008 Page 20 of 41









in its financial statements. But Stoneridge indicates that an indirect

chain to the contents of false public statements is too remote to

establish primary liability.



Pugh, 521 F.3d at 697; see also In re National Century Fin. Enters., Inc. Fin. Invs.



Litig., No. 2:03-md-1565, 2008 WL 918708, at *6-*7 (S.D. Ohio Apr. 2, 2008) (no



Section 10(b) liability for engaging in "legitimate transactions" where "Plaintiffs



allege that they were deceived concerning the [transactions] . . . from the way



another defendant described them").



Here, as in Stoneridge, the "deceptive acts" supposedly engaged in by



DES "were not disclosed to the investing public [and are thus] too remote to



satisfy the requirement of reliance." Stoneridge, 128 S. Ct. at 770. As Stoneridge



held, "Lilt was Charter, not [its service providers], that misled its auditor and filed



fraudulent financial statements [and] nothing [the service providers] did made it



necessary or inevitable for Charter to record the transactions as it did." Id. at 770.



"[T]he implied right of action does not reach" third parties that engage in



transactions that "allowed the investors' company to mislead its auditor and issue a



misleading financial statement affecting the stock price . . . because the investors



did not rely upon their statements or representations." Id. at 766.



Therefore, it is no answer to claim, as Stockholders attempt to do, that



"DES designed and then executed transactions so that they would have to be









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Case 2:03-cy-01500-K0B-TMP Document 1391 Filed 05/27/2008 Page 21 of 41









accounted for in a way that disguised HealthSouth's true financial situation."2



(Stockholders' Stoneridge Brief at 10.) The same argument was presented — and



rejected — in Stoneridge, even though the defendants in Stoneridge, unlike here,



actually prepared the false documentation and false back-dated contracts that



enabled Charter to falsify its financials and to justify the false financials to its



auditor. Id. at 767; see Pugh, 521 F.3d at 696-97 (Stoneridge forecloses claim



against the "mastermind" of a "scheme" that was "intended" to "result in improper



revenue").



3. Plaintiffs' "Scheme" Claims Allege Only Legally Non-

Existent Aider and Abettor Liability.



In Stoneridge, the Supreme Court also rejected the "scheme" theory



under Section 10(b), because a claim alleging that a third party committed



deceptive acts in furtherance of an issuer's fraud would allow a claim for aiding



and abetting in violation of Central Bank. The Court ruled that plaintiffs may not



end-run the ban on aider and abettor liability by alleging that the secondary actor



"committed a deceptive act in the process of providing assistance." Id. The Court

2

Of course, this contrived argument (nowhere presented in the Complaint) is

demonstrably false. The transactions at issue did not "have to be accounted for" in

any particular way or in any way that misrepresented HealthSouth's financials.

HealthSouth later restated its financial statements, which Plaintiffs presumably

agree accurately reflect HealthSouth's financial condition since they cite those

restated financials at length to justify their attempt to claim that HealthSouth

committed some multi-billion dollar fraud. Moreover, the "fraud" that is the focus

of this case has nothing at all to do with HealthSouth's accounting for any services

or transactions involving UBS, but rather a claim that HealthSouth simply recorded

fictional assets and revenues in its core business for over a decade or more.

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found that this construction of Section 10(b) "would revive in substance the



implied cause of action against all aiders and abettors except those who committed



no deceptive act in the process of facilitating the fraud; and we would undermine



Congress's determination that this class of defendants should be pursued by the



SEC and not by private litigants." Id.



Here, too, Plaintiffs allege nothing more than aider and abettor claims



barred by Central Bank. Like the sham transactions supported by false



documentation allegedly designed to deceive Charter's auditors and investors at



issue in Stoneridge, the DES conduct Plaintiffs allege was designed to facilitate the



HealthSouth fraud or to deceive investors or "credit agencies" (Stockholders'



Stoneridge Brief at 6-8), at most aided and abetted HealthSouth's fraud, which



relates to the misrecording of assets, liabilities and revenues, whatever the



supposed bona fides of the underlying transactions with HealthSouth. TCS



Capital, 2008 WL 650385, at *25 (after Stoneridge, "even if this conduct did help



the Buyers to carry out their scheme . . . plaintiff has no claim under the federal



securities laws").



4. Plaintiffs' "Scheme" Claims Against UBS Lack Any Viable

Theory of Loss Causation.



The Stoneridge Court rejected scheme liability, because this theory



failed, as it must, to satisfy each element of a Section 10(b) claim for each



defendant, but instead sought to impute the issuer's misstatements to the third party





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Case 2:03-cv-01500-K0B-TMP Document 1391 Filed 05/27/2008 Page 23 of 41









for purposes of establishing reliance and loss causation. 128 S. Ct. at 769-71.



Under Section 10(b), however, Plaintiffs must prove a violation with respect to



each defendant's "own deceptive conduct." Id. at 770. Here, even if some



"scheme" theory remained viable — and it does not — Plaintiffs have never even



offered any theory of loss causation confined to some deceptive conduct by any



DES Defendant.



Instead, Plaintiffs have alleged merely that the HealthSouth fraud



itself — rather than any actionable DES conduct — caused their losses.



(Stockholders' 2006 Opp'n at 57). Yet, under Stoneridge, Plaintiffs may not rely



on HealthSouth's accounting fraud to establish loss causation as to any claims



against a DES Defendant. 128 S. Ct. at 770. Loss causation may not be shown by



reference to losses caused by other individuals or events. Cordova v. Lehman



Bros., 526 F. Supp. 2d 1305, 1320 (S.D. Fla. 2007) (dismissing complaint because



"the direct cause of the decline in value of the investments was the



misappropriation of investor funds by PFA and its insiders, not any



misrepresentation or omission of Defendants"); see also In re Coca-Cola Enters.



Inc. Sec. Litig., No. 1:06-CV-0275-TWT, 2007 WL 2904160, at *3 (N.D. Ga. Oct.



3, 2007) (rejecting loss causation allegations because price declined in response to



events not at issue in the case).



More recently, Plaintiffs seem to have reversed field and argued that



various financings or other services provided by DES inflated HealthSouth's

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securities prices and led to Plaintiffs' losses. (Stockholders' Stoneridge Brief, at



10-12). However, a "showing of price inflation . . . does not satisfy the loss



causation requirement." Robbins v. Koger Props., Inc., 116 F.3d 1441, 1448 (11th



Cir. 1997); Dura Pharms., Inc. v. Broudo, 544 U.S. 336, 346 (2005).



Plaintiffs offer no argument or allegation that the decline in



HealthSouth's securities prices — i.e., the loss for which causation must be proven



— was in any direct, proximate way related to some UBS deception. The Eleventh



Circuit "explicitly require[s] proof of a causal connection between the



misrepresentation and the investment's subsequent decline in value." Robbins, 116



F.3d at 1448.



5. Stoneridge Rejected "Scheme" Liability Based on the Narrow

Scope of the Section 10(b) Private Right of Action, Not the

Particular Services Provided by a Defendant.



Recognizing that Stoneridge completely rejects their scheme theory,



Plaintiffs attempt to confine the decision to certain commercial transactions, but



not to those in the "investment sphere." (Stockholders' Stoneridge Brief at 2-12;



Bondholder Plaintiffs' Response to DES Defendants' Submission of Recent Legal



Authority Relevant to this Court's September 6 Opinion at 3-4 (filed Jan. 22, 2008)



(hereinafter "Bondholders' Stoneridge Brief'). The Supreme Court plainly did not



limit its holding to a narrow group of defendants, illogically suggest that a federal



statute should be interpreted differently for different defendants or different







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Case 2:03-cv-01500-K0B-TMP Document 1391 Filed 05/27/2008 Page 25 of 41









segments of the economy, or allow plaintiffs to revive deficient claims simply by



alleging that they arose in the "investment sphere."



First, the services provided by a defendant, or whatever label



Plaintiffs may wish to attach to them, cannot alter the fundamental defects in



Plaintiffs' theory, namely, the inability to establish reliance and loss causation



separately for each challenged act or omission by each defendant. Whether the



challenged transactions took place in the "investment sphere" or in the



"atmosphere" is immaterial because Stoneridge holds that Plaintiffs may not claim



to have relied upon the underlying transactions or services that were misreported or



unreported by HealthSouth, or to have been injured by some supposed DES act or



omission that was never revealed to investors. TSC Capital, 2008 WL 650385, at



*25 (Stoneridge bars claim against a party to a merger agreement).



Second, when setting forth the "conflict" among Circuit courts to be



resolved by the Stoneridge decision, the Supreme Court — citing only Regents (a



case against investment banks) and Homestore (a case against commercial



vendors) — indicated that its decision resolved the question of "when, if ever, an



injured investor may rely upon § 10(b) to recover from a party that neither makes a



public misstatement nor violates a duty to disclose but does participate in a scheme



to violate § 10(b)." Stoneridge, 128 S. Ct. at 767-68. In answering that question,



the Supreme Court held that a third party cannot be liable for an issuer's false



statements or inaccurate financials by virtue of having participated in "not so

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Case 2:03-cv-01500-K0B-TMP Document 1391 Filed 05/27/2008 Page 26 of 41









ordinary course" or "[u]nconventional" transactions designed to enable the issuer



to engage in the misrepresentation. Id. at 774. The Court did not distinguish



among the nature of the actors, or suggest that the "conflict" between Regents and



Hornestore was illusory because of the type of the transactions at issue. To the



contrary, the round-trip transactions found inactionable in Stoneridge were, in



essence, disguised loans, which, by Plaintiffs' own reasoning, fall squarely within



the "investment sphere." (Stockholders' Stoneridge Brief at 7-11). And, the



Supreme Court confirmed that no "investment sphere" exception exists by denying



certiorari in Regents notwithstanding identical arguments by those plaintiffs.



Third, the Court's holding was squarely premised on the narrow



private right of action available under Section 10(b), and not the identity of the



parties. The private right of action under Section 10(b) is not a statutory right, but



a judicially created right of action. 3 "Concerns with the judicial creation of a



private cause of action caution against expansion. . . . Though it remains the law,



the § 10(b) private right should not be extended beyond its present boundaries."



Stoneridge, 128 S. Ct. at 773 (emphasis added). Thus, the Supreme Court's



rejection of "scheme" liability was premised on "the narrow dimensions we must





3

For this reason, the rationale of SEC v. Zandford, 535 U.S. 813, 820 (2002)

— which this Court relied on for its "endorsement of an expansive construction of

section 10(b)" (September 6 Opinion, at 7, 8) — does not apply here because

Zandford involved the SEC's broad statutory enforcement rights, and not the more

limited implied private right of action.

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Case 2:03-cv-01500-K0B-TMP Document 1391 Filed 05/27/2008 Page 27 of 41









give to a right of action Congress did not authorize when it first enacted the statute



and did not expand when it revisited the law." Id. at 774.



Fourth, Plaintiffs' assertion that the Stoneridge decision "focuses on



the critical difference between § 10(b) and Rule 10b-5(a) and (c) in the context of



fraud perpetrated by financial professionals like DES versus ordinary vendor-type



business transactions like those in Stoneridge" is mystifying. (Stockholders'



Stoneridge Brief at 2, 5.) The Court did not "focus" on any difference between



Rule 10b-5 and Section 10(b) or even discuss it, but declared any difference



between the Rule and the statute to be entirely irrelevant, because an administrative



rule cannot expand the scope of a statute. "Rule 10b-5 encompasses only conduct



already prohibited by § 10(b)." Stoneridge, 128 S. Ct. at 768; Central Bank, 511



U.S. at 173 ("the private plaintiff may not bring a 10b-5 suit against a defendant



for acts not prohibited by the text of § 10(b)").



Finally, Plaintiffs' illogical assertion that the elements of a cause of



action might differ under Section 10(b) depending upon the industry in which the



defendant operates or the nature of the transactions engaged in, would turn



centuries of jurisprudence on its head. E.g., Matsushita Elec. Indus. Co. v.



Epstein, 516 U.S. 367, 383 (1996) (Congress intended Exchange Act "to achieve



greater uniformity of construction and more effective and expert application of that



law"); Davies Warehouse Co. v. Bowles, 321 U.S. 144, 155 (1944) ("uniform



operation of a federal law is a desirable end"); Rowinski v. Salomon Smith Barney

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Case 2:03-cv-01500-K0B-TMP Document 1391 Filed 05/27/2008 Page 28 of 41









Inc., 398 F.3d 294, 302 (3d Cir. 2005) (recognizing Securities Litigation Uniform



Standards Act's "goal of facilitating the uniform application of 'national standards



for securities class action lawsuits involving nationally traded securities')



(quoting 15 U.S.C. § 78a), United States v. Savin, 349 F.3d 27, 35 (2d Cir. 2003)



(observing the general "preference for the uniform application of federal law").



B. The "Extremely Persuasive" Regents Decision Remains Good

Law, and Requires Judgment for UBS.



1. Regents Remains a Correct Statement of the Law.



The Supreme Court expressly framed the issue to be decided in



Stoneridge as resolving a "conflict" between the Fifth Circuit's Regents decision



and the Ninth Circuit's Homestore decision concerning the extent of liability for



those who "participate in a scheme." Stoneridge, 128 S. Ct. at 767-68. The



Supreme Court unequivocally resolved that conflict by denying certiorari in



Regents, Regents of the Univ. of CaL v. Merrill Lynch, Pierce, Fenner & Smith,



Inc., 128 S. Ct. 1120 (2008), while at the same time vacating and remanding the



Homestore decision "for further consideration in light of Stoneridge." Avis Budget



Group, Inc. v. Cat State Teachers' Ret Sys., 128 S. Ct. 1119 (2008). Hence,



following Stoneridge, the Regents decision remains good law, while the Ninth



Circuit's Homestore decision was rejected by the Supreme Court. 128 S. Ct. at



774-75 (Stevens, J., dissenting) (noting that the majority rejected Homestore).









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Plaintiffs contend that any inferences from the Supreme Court's



varying treatment of the cases before it amounts to nothing more than reading tea



leaves. (Bondholder Plaintiffs' Response to DES Defendants' Submission of



Further Recent Legal Authority at 2 (filed Jan. 25, 2008) (hereinafter



"Bondholders' Jan. 25 Response")) But it was the Supreme Court that read those



leaves, not DES. The Supreme Court singled out Regents and Homestore as



representing the conflict to be resolved by its decision, and the Court left Regents



intact, and vacated Homestore. While it is true, as Bondholders argue, that the



denial of certiorari in Regents does not amount to an affirmance on the merits, that



does not mean that the Supreme Court's disparate treatment of the conflicting



decisions before it should be overlooked. Wells v. Meyer's Bakery, 561 F.2d 1268,



1274-75 (8th Cir. 1977) ("Although the denial of a writ of certiorari by the



Supreme Court has no particular significance, the fact that certiorari was denied in



Stewart. . . only four weeks after Teamsters was decided, cannot be overlooked.").



Thus, the conflicting, simultaneous treatment given to cases raising the same issue



"does reflect the Supreme Court's assessment of a . . . court's efforts to comply



with the Supreme Court's instructions." Presnell v. Zant, 959 F.2d 1524, 1532



(11th Cir. 1992).



Plaintiffs' efforts to minimize the significance of the Supreme Court's



denial of certiorari in Regents are understandable, because Stockholders' counsel



argued to the Supreme Court, without success, that the Court should grant

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Case 2:03-cv-01500-K0B-TMP Document 1391 Filed 05/27/2008 Page 30 of 41









certiorari in Regents and either (i) rule that Stoneridge should be limited to its



facts, or (ii) vacate and remand the case for further consideration by the Fifth



Circuit. (See Supplemental Brief in Support of the Petition, Regents of the



University of California v. Merrill Lynch, Pierce, Fenner & Smith, Inc., No. 06-



1341, dated January 17, 2008, at 1-3, attached hereto as Exhibit 1.) All of the



arguments presented by Plaintiffs in their submissions to this Court regarding the



Stoneridge decision were made — often verbatim — to the Supreme Court in support



of the Regents plaintiffs' plea to grant certiorari or vacate Regents. (See Ex. 1, at



2-9). Among other things, the Regents plaintiffs — represented by Stockholders'



counsel — implored the Court to grant certiorari in that case and "clariftyf that



Stoneridge applies only to claims against "mere customers or suppliers," but not to



claims against "investment bankers, underwriters and securities analysts." (Id. at



1.)



The Supreme Court declined that invitation to fashion a special rule



for investment banks, and left the Regents decision intact.



2. Regents Cannot be Distinguished From the Facts Alleged

Here and Requires Judgment for UBS.



In support of their "scheme" theory, Plaintiffs urged this Court — for a



time, successfully — to follow Judge Harmon's decision sustaining the same theory



of "scheme" liability with respect to a few of the investment bank defendants



alleged to have facilitated the massive financial fraud at Enron. (September 6



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Case 2:03-cv-01500-K0B-TMP Document 1391 Filed 05/27/2008 Page 31 of 41









Opinion at 4-5)4 Of course, the Fifth Circuit reversed, holding — in what this



Court characterized as a "compelling" and "extremely persuasive" opinion (Sept. 6



Opinion at 5, 10) — that "[t]he transactions in which the banks engaged at most



aided and abetted Enron's deceit by making its misrepresentations more plausible."



Regents, 482 F.3d at 390. The Fifth Circuit did so despite the fact that all of these



defendant banks operated in the "investment sphere," and all allegedly were far



more involved with the Enron fraud than DES supposedly was involved with



HealthSouth here.



Indeed, despite Bondholders' disingenuous attempt to dismiss Regents



as involving "allegations of attenuated conduct unknown to the public" or



defendants that "owed no duty of disclosure to the class of investors in Enron and,



in fact, made no statements to them and directed no deceptive conduct towards



them" (Bondholders' January 25 Response, at 3), it is beyond dispute that all of the



assertions lodged against DES here — and far worse — were considered and rejected



in Regents, including assertions that the Enron investment banks:



• "were fiduciaries with a duty to make full disclosures" (Ex. 1, at 4);



• "were underwriters [and] made several knowingly false

representations to the market" (id.);

4

Judge Harmon, however, rejected the Enron plaintiffs' "scheme" claims

against all of the Enron investment banks whose conduct remotely approached the

insubstantial allegations against DES here. (See, e.g., DES's Motion to Dismiss

Plaintiffs' Amended "Scheme" and Securities Act Theories at 39-42 (filed Aug.

21, 2006) (outlining the more substantial allegations against Deutsche Bank and

Barclays).)

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Case 2:03-cv-01500-K0B-TMP Document 1391 Filed 05/27/2008 Page 32 of 41









• "drafted and disseminated offering materials hiding debt and reporting

phony revenues that they themselves had contrived for Enron to

report" (id.);



• "framed and disseminated [offering documents] into the market for

the specific purpose of inducing investors to purchase Enron

securities" (id.);



• "spoke to the market by structuring and supporting off-the-books

special purpose entities and related party transactions" (id. at 5);



• "executed transactions so that they would have to be accounted for in

a way that both hid Enron's debt and falsified its revenues" (id.

(emphasis in original));



• "deliberately us[ed] the sham transactions they created to mislead

investors and defraud the market" (id. at 7);



• issued analyst reports that "publicly represented Enron stock as a

'Strong Buy,' based on its phonied financials" when its "private belief

. . . was that Enron was an absolute 'don't buy' (id. at 7-8);



• "spoke[] through analyst reports, and indeed, . . . touted Enron's false

results, which their transactions created while recommending

purchase of Enron stock" (id. at 9).



Despite the Enron investment banks' supposed involvement in Rule



144A offerings, equity research, various financings, and much more, the Fifth



Circuit explicitly rejected the claim that the defendant banks were fiduciaries or



otherwise owed Enron investors any duty of disclosure: "Enron had a duty to its



shareholders, but the banks did not." Regents, 482 F.3d at 390 (emphasis added).



The Fifth Circuit likewise rejected plaintiffs' numerous allegations



contending that Enron's banks "target[ed]" their deceptive conduct at Enron's



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Case 2:03-cv-01500-K0B-TMP Document 1391 Filed 05/27/2008 Page 33 of 41









investors or otherwise devised fraudulent transactions for the express purpose of



enabling Enron to report false financials. "The transactions in which the banks



engaged at most aided and abetted Enron's deceit by making its misrepresentations



more plausible. The banks' participation in the transactions, regardless of the



purpose or effect of those transactions, did not give rise to primary liability under



§ 10(b)." Id. (footnote omitted, emphasis added).



Indeed, the only even arguably relevant distinction between Regents



and this case is that Regents held that far greater entanglements by Enron's



investment banks in Enron's business or financial transactions nevertheless could



not render the banks liable for the issuer's financial fraud. In contrast to the basic



DES banking and financing services challenged here, the Enron banks were



alleged to have engaged in a host of other acts in furtherance of the Enron fraud



that extend well beyond any of the allegations against UBS here.5









5

Among other things, those banks supposedly (i) "helped Enron structure and

finance several of the illicit SPEs and partnerships Enron controlled"; (ii)

"creat[ed] some of the illicit SPEs which were the primary vehicles by which

Enron falsified its financial condition and misrepresented profits"; (iii) "made

disguised loans to Enron so that Enron's true credit situation, liquidity and debt

levels could be disguised"; (iv) "entered into two sets of bogus transactions with

Enron" where "[n]either of the 'transactions' had any economic purpose

whatsoever, other than to increase Enron's stock price and generate present and

future fees" for the bank; and (v) engaged in fictional transactions and "created

bogus power swaps." (First Am Compl. 694, 706, 707, 735, 742.7, In re Enron

Corp. Sec. Derivative & ERISA Litig., No. H-01-3624 (S.D. Tex. filed May 14,

2003) (Relevant excerpts attached hereto as Ex. 2.).)

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Case 2:03-cv-01500-K0B-TMP Document 1391 Filed 05/27/2008 Page 34 of 41









II. ONCE PLAINTIFFS' "SCHEME" CLAIMS ARE ELIMINATED,

THEIR REMAINING SECTION 10(B) CLAIMS ALSO ARE

DEFICIENT.

Plaintiffs also allege liability against DES and/or Howard Capek



based upon supposed public misstatements in HealthSouth's private placement



memoranda and DES equity research reports. Yet, Plaintiffs have never offered



any theory or allegation of reliance or loss causation with respect to these claims.



It is settled that Plaintiffs' misrepresentation claims cannot provide



the requisite loss causation or reliance to support their scheme claims. 6 Nor may a



"scheme" claim be relied upon as "a back door into liability" for a false statement



or omission under Section 10(b). In re Parmalat Sec. Litig., 376 F. Supp. 2d 472,



503 (S.D.N.Y. 2005). Hence, as with any other claim under Section 10(b),



Plaintiffs must establish each element of the statute with respect to their claim that



DES or Capek made some misstatement in violation of Section 10(b). Stoneridge,



128 S. Ct. at 769; Central Bank, 511 U.S. at 180.





6 See Lentellv. . Merrill Lynch & Co. Inc., 396 F.3d 161, 177 (2d Cir.)

("[P]laintiffs [cannot] cast. . . claims in terms of market manipulation, pursuant to

Rule 10b-5(a) and (c)[,] . . . where the sole basis for such claims is alleged

misrepresentations or omissions."), cert. denied, 546 U.S. 935 (2005); In re

Marsh & McLennan Cos. Sec. Litig., 501 F. Supp. 2d 452, 490-91 (S.D.N.Y. 2006)

(same); In re National Century Fin. Enters., Inc., Inv. Litig., No. 2:03-md-1565,

2006 WL 469468, at *21 (S.D. Ohio Feb. 27, 2006) (rejecting scheme claims that

"merely repeated the allegations made in support of [their] misrepresentation and

omission claim under Rule 10b-5(b)" (citing Lentell, 396 F.3d at 177)); JHW

Greentree Capital, L.P. v. Whittier Trust Co., No. 05 Civ. 2985 (HB), 2005 WL

3008452, at *7 n.11 (S.D.N.Y. Nov. 10, 2005) (same); In re Recoton Corp. Sec.

Litig., 358 F. Supp. 2d 1130, 1138 n.4 (M.D. Fla. 2005) (same).

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Case 2:03-cv-01500-K0B-TMP Document 1391 Filed 05/27/2008 Page 35 of 41









Here, however, Plaintiffs always have rested their theories of reliance



and loss causation on HealthSouth's overall accounting fraud, rather than any



discrete DES statement. Plaintiffs have never explained, for example, how they or



any "market" relied upon any statement in the confidential private placement



memoranda (which, by definition, are not "public" statements) or any DES



research report (which contained no new information and were distributed to a



limited audience). Plaintiffs thus have not, and cannot, plead reliance here.



Similarly, Plaintiffs' sole allegations and arguments relating to loss



causation contend only that the HealthSouth fraud caused their losses.' Even then,



Plaintiffs allege only that the fraud (or DES's supposed participation in it) caused



Plaintiffs to pay too much for their HealthSouth securities:



Plaintiffs and the other members of the Stockholder Class and Merger

Subclasses, as detailed herein, have suffered damages in that, in

reliance on the integrity of the market, they paid artificially inflated

prices in connection with their acquisition of HealthSouth securities.

(Stockholder Plaintiffs' Legal Theories and Claims 66, filed Apr. 30, 2007).

7

Throughout this action, Plaintiffs have claimed that they had satisfied the

loss causation requirement of Section 10(b) by citing simply "the fraudulent

scheme which inflated HealthSouth's stock." (Stockholders' 2006 Opp'n at 57;

see also Stockholders' Response to the DES Defendants' Submission of Recent

Legal Authority in Further Support of Their Motion to Dismiss at 2, 6, dated

February 6, 2006 (Docket No. 445), (claiming Stockholders have sufficiently

alleged loss causation by "alleg[ing] that the DES Defendants participated in a

scheme to defraud" and "detail[ing] the acquisition and integrated debt offering

scheme"); (Bondholder Plaintiffs' Opposition to DES Motion to Dismiss at 198

(filed Nov. 4, 2004) ("[T]he scheme — of which Capek's direct participation was an

integral and necessary part — was so pervasive that, without it, HealthSouth could

not have issued the Notes.").)



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Case 2:03-cv-01500-K0B-TMP Document 1391 Filed 05/27/2008 Page 36 of 41









As a result of the dissemination of the materially false and misleading

information and failure to disclose material facts, as set forth above,

the market prices of the Unregistered Notes and the Registered Notes

were artificially inflated during the Bondholder Class Period. In

ignorance of the fact that the market prices of the Unregistered Notes

and the Registered Notes were artificially inflated . . . Bondholder

Plaintiffs and the other members of the Bondholder Class acquired the

Unregistered Notes and the Registered Notes during the Bondholder

Class Period at artificially high prices and were damaged thereby.

(Bondholder Plaintiffs' Legal Theories and Claims 423, filed Apr. 30, 2007).



It is by now settled that claims of "purchase price inflation" such as



Plaintiffs make here are insufficient to establish loss causation. Robbins, 116 F.3d



at 1448. In fact, Plaintiffs' conclusory loss causation allegations are



indistinguishable from those rejected by the Supreme Court in Dura. Dura, 544



U.S. at 340 (rejecting loss causation allegation that alleged "[i]n reliance on the



integrity of the market, [plaintiffs] . . . paid artificially inflated prices for Dura



securities' and the plaintiffs suffered `damage[sf thereby").



Stripped of their blunderbuss "scheme" theory, Plaintiffs have offered



no allegations or theory of reliance or loss causation in connection with their



misrepresentation claims. For this reason, judgment also should be entered for



DES on these claims.



CONCLUSION

For all the foregoing reasons, all of Plaintiffs' Section 10(b) claims



premised on their "scheme to defraud" theory fail as a matter of law. In addition,



the Court should revisit the viability of Plaintiffs' remaining claims in the absence



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Case 2:03-cv-01500-K0B-TMP Document 1391 Filed 05/27/2008 Page 37 of 41









of the now-defunct scheme claims. Under settled precedent, those claims also fail



to allege any facts or viable theory supporting reliance or causation.







Respectfully submitted,



Of Counsel: s/ W. Michael Atchison

W. Michael Atchison (ASB-4005-T75W)

Robert J. Giuffra, Jr. Jay M. Ezelle (AZB-4744-Z72J)

Brian T. Frawley Robin H. Jones (ASB-0769-R51J)

Julia M. Jordan STARNES & ATCHISON LLP

Erin R. Chlopak 100 Brookwood Place, Seventh Floor

SULLIVAN & CROMWELL LLP Birmingham, Alabama 35209

125 Broad Street (205) 868-6000

New York, New York 10004

(212) 558-4000 Counsel for UBS AG, UBS Securities LLC,

Howard Cape/c, Benjamin D. Lorello and

Counsel for UBS AG, UBS Securities William C. McGahan

LLC, Howard Cape/c, Benjamin D.

Lorello and William C. McGahan

Helen Gredd

Daniel Gitner

Thomas Fitzpatrick LANKLER SIFFERT & WOHL LLP

LAW OFFICES OF THOMAS 500 Fifth Avenue

FITZPATRICK New York, New York 10110

500 Fifth Avenue, 33rd Floor (212) 921-8399

New York, New York 10110

(212) 930-1290 Counsel for William C. McGahan



Counsel for Howard Capek

Robert J. Anello

Richard F. Albert

MORVILLO, ABRAMOWITZ, GRAND,

IASON, ANELLO & BOHRER, P.C.

656 Fifth Avenue

New York, New York 10017

(212) 856-6000



Counsel for Benjamin D. Lorello







May 27, 2008







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Case 2:03-cv-01500-K0B-TMP Document 1391 Filed 05/27/2008 Page 38 of 41









CERTIFICATE OF SERVICE



I hereby certify that on this the 27th day of May, 2008, I electronically filed the

foregoing with the Clerk of the Court using the CM/ECF system which will send

notification of such filing to the following:



Richard Martin Adams parkman@parkmanlawfirm.com

Richard F. Albert ralbert@maglaw.com

Kelso L. Anderson kanderson@labaton.com

Robert J. Anello ranello@maglaw.com

William P. Ashworth washworth@wc.com

W. Michael Atchison wma@stameslaw.com

Patrick J. Ballard pjballard@ballardlawoffice.com

Edward J. Bennett ebennett@wc.com

Max W. Berger mwb@blbglaw.com

Stanley D. Bernstein Bemstein@bemlieb.com

Jeffrey R. Blackwood jblackwood@bradleyarant.com

Carmine D. Boccuzzi cboccuzzi@cgsh.com

Bruce R. Braun bbraun@winston.com

Charles F. Brega cbrega@lindquist.com

Vincent Briganti vbriganti@ldbs.com

Scott S. Brown scottbrown@maynardcooper.com

Carl S. Burkhalter cburkhalter@maynardcooper.com

Hope T. Cannon hcannon@bradleyarant.com

James A. Caputo jimc@csgrr.com

Michael J. Chepiga mchepiga@stblaw.com

John P. Coffey sean@blbglaw.com

Betsy P. Collins betsy.collins@alston.com

Bryan E. Comer bec@cbcbb.com

J. Erik Connolly econnolly@winston.com

Julia Boaz Cooper jbcooper@bradleyarant.com

N. Lee Cooper lcooper@maynardcooper.com

Patrick C. Cooper darceneaux@maynardcooper.com

Patrick J. Coughlin patc@csgrr.com

John T. Crowder, Jr. jtc@cbcbb.com

Robert T. Cunningham, Jr. rtc@cbycb.com

Stephen D. Dargitz sdargitz@skadden.com

Charles A. Dauphin cdauphin@bddmc.com

Manuel J. Dominguez jdominguez@bermanesq.com

David R. Donaldson DavidD@dglawfirm.com

Richard T. Dorman rtd@cbcbb.com

Russell Jackson Drake ecf@whatleydrake.com

Wayne W. Drinkwater jaltobelli@bradleyarant.com



-31-

Case 2:03-cv-01500-KOB-TMP Document 1391 Filed 05/27/2008 Page 39 of 41







Thomas A. Dubbs tdubbs@labaton.com

Robert D. Eckinger roberteckinger@arlaw.com

Jay M. Ezelle JME@stameslaw.com

Steven M. Farina sfarina@wc.com

Joseph A. Fawal jfawal@bellsouth.net

H. L. Ferguson, Jr. hlf@ffdlaw.com

Thomas Fitzpatrick tfitzpatrick@tfitzpatrick.com

Robert Fleishman rfleishm@steptoe.com

Joseph A. Fonti jfonti@labaton.com

Brian Thomas Frawley frawleyb@sullcrom.com

Lauren C. Freundlich lfreundlich@lswlaw.com

Henry Frohsin hfrohsin@bakerdonelson.com

Stephen J. Fuzesi sfuzesi@wc.com

Galloway & Somerville, LLC jgs@gallowaysomerville.com

Daniel M. Gitner dgitner@lswlaw.com

Robert J. Giuffra giuffrar@sullcrom.com

Paul Gluckow pgluckow@stblaw.com

Beata Gocyk-Farber Beata@blbglaw.com

Jonah H. Goldstein jonahg@csgrr.com

James L. Goyer, III jgoyer@maynardcooper.com

David C. Gray dgray@wc.com

Helen A. Gredd hgredd@lswlaw.com

David J. Guin davidg@dglawfirm.com

Jeffrey M. Haber haber@bemlieb.com

Anthony C. Harlow ach@stameslaw.com

J. Mark Hart jmh@hsy.com

David R. Hassel DavidH@blbglaw.com

Frederick G. Helmsing fgh@helmsinglaw.com

James F. Henry jhenry@bradleyarant.com

James F. Hughey, III jhughey@lfwlaw.com

Susan E. Hurd shurd@alston.com

Harriet Thomas Ivy hivy@bakerdonelson.com

B. Keith Jackson kj@rileyjacksonlaw.com

James W. Johnson jjohnson@labaton.com

G. Douglas Jones ecf@whatleydrake.com

Robin H. Jones RHJ@stameslaw.com

Julia M. Jordan jordanjm@sullcrom.com

Sheilah M. Kane skane@cgsh.com

Francis P. Karam Karam@bemlieb.com

M. Kay Kelley kaykelley@mindspring.com

Allison R. Kimmel akimmel@stblaw.com

Renu Kara Kripalani rkripalani@labaton.com

Jennifer Y. Lai jlai@csgrr.com

Othni J. Lathram ecf@whatleydrake.com



-32-

Case 2:03-cv-01500-KOB-TMP Document 1391 Filed 05/27/2008 Page 40 of 41







Jeffrey N. Leibell jeffl@blbglaw.com

William S. Lerach BillL@Lerachlaw.com

Nathan R. Lindell nlindell@csgrr.com

Ryan A. Llorens ryanl@csgrr.com

Don B. Long, Jr. dbl@jbpp.com

Mitchell A. Lowenthal mlowenthal@cgsh.com

Kallie C. Lunsford kallie@rileyjacksonlaw.com

Enu Mainigi emainigi@wc.com

Craig A. Martin cmartin@labaton.com

Alan Daniel Mathis adm@jbpp.com

Erskine Ramsey Mathis erskinelaw@aol.com

Lauren A. McMillan laurenm@blbglaw.com

Debra M. Mestre Mestregfc@aol.com

Judith L. Mogul jmogul@maglaw.com

Benjamin M. Moncrief bmoncrief@bradleyarant.com

Kan M. Nawaday knawaday@lswlaw.com

James L. O'Kelley jimokelley@bellsouth.net

Stephen C. Olen sco@cbcbb.com

Keith F. Park keithp@csgrr.com

James W. Parkman parkman@parkmanlawfirm.com

Michael J. Pucillo mpucillo@bermanesg.com

Maxwell H. Pulliam MHPulliam@csattomeys.com

Teresa T. Pulliam ttpulliam@msn.com

Barry A. Ragsdale barryrags@aol.com

M. Clay Ragsdale, IV clay@ragsdalellc.com

C. Lee Reeves lreeves@sirote.com

John J. Rice jrice@csgrr.com

Robert R. Riley, Jr. rob@rileyjacksonlaw.com

Michael P. Roche mroche@winston.com

Daniel 0. Rodgers dor@ffdlaw.com

Michael H. Rogers mrogers@labaton.com

Victoria Radd Rollins vrollins@wc.com

Nancy I. Ruskin nruskin@cgsh.com

Ann N Sagerson asagerson@wc.com

Michael Sansbury msansbury@spotswoodllc.com

Robert S. Saunders rsaunder@skadden.com

Andrew M. Schatz firm@snlaw.net

Jeffrey T. Scott scottj@sullcrom.com

Anne Marie Seibel aseibel@bradleyarant.com

Neil L. Selinger nselinger@ldbs.com

Maryanne Sexton msexton@maglaw.com

Jackson R. Sharman, III jsharman@lfwlaw.com

Kenneth 0. Simon KOS@csattomeys.com

Henry E. Simpson henry.simpson@arlaw.com



-33-

Case 2:03-cv-01500-KOB-TMP Document 1391 Filed 05/27/2008 Page 41 of 41







J. Callen Sparrow jcsparrow@hgdlawfirm.com

Beth A. Stewart bstewart@wc.com

Tammy McClendon Stokes tstokes@dglawfirm.com

Stephen A. Strickland sstrickland@rjaffelaw.com

Lawrence A. Sucharow lsucharow@labaton.com

Michael T. Tomaino tomainom@sullcrom.com

William H. Wagener wagenerw@sullcrom.com

Dan K. Webb dwebb@winston.com

Edward P. Welch ewelch@skadden.com

Joe R. Whatley, Jr. jwhatley@whatleydrake.com

William Calvin White, II wwhite@parkmanlawfirm.com

Laurent S. Wiesel wiesell@sullcrom.com

Thomas P. Windom twindom@wc.com

Nicole E. Wrigley nwrigley@winston.com

Debra J. Wyman debraw@csgrr.com





Respectfully submitted,



s/ Robin H. Jones

Robin H. Jones (ASB-0769-R51J)

STARNES & ATCHISON LLP

100 Brookwood Place, Seventh Floor

Birmingham, Alabama 35209

Telephone: (205) 868-6000

Fax: (205) 868-6099

E-mail: rhj@stameslaw.com









-34-

Case 2:03-cv-01500-K013-TMP Document 1391-2 Filed 05/27/2008 Page 1 of 16 FILED

2008 May-27 PM 06:43

U.S. DISTRICT COURT

N.D. OF ALABAMA









EXHIBIT 1

Case 2:03-cv-01500-K013-TMP Document 1391-2 Filed 05/27/2008 Page 2 of 16









No. 06-1341



IN THE

supreme Court of the U uittb ibtatess



THE REGENTS OF THE UNIVERSITY OF CALIFORNIA,

Petitioner,

V.

MEFIRILL LYNCH PIERCE FENNER & SMITH, INC.,

MERRILL LYNCH & COMPANY, INC.; CREDIT SUISSE

FIRST BOSTON (USA), INC ; CREDIT SUISSE FIRST

BOSTON LLC; PERSHING LLC; BARCLAYS PLC;

BARCLAYS BANK PLC; BARCLAYS CAPITAL, INC.

Respondents.



On Petition for Writ of Certiorari to the

United States Court of Appeals

for the Fifth Circuit



SUPPLEMENTAL BRIEF IN SUPPORT



PATRICK J. COUGHLIN *

HET EN J HODGES

BYRON S. GEORGIOU

ERIC ALAN ISAACSON

SPENCER A. Holm-10Lz

JOSEPH D. DALEY

ANNE L. Box

COUGHLIN STOIA GELLER

RUDMAN & BOBBINS LLP

655 West Broadway, Suite 1900

San Diego, CA 92101

* Counsel of Record (619) 231-1058



Counsel for Petitioner

(

WiLSON-EPES PRINTING CO., INC. - (202) 789-0096 - WASHINGTON D C 20002

e so

Case 2:03-cv-01500-K013-TMP Document 1391-2 Filed 05/27/2008 Page 3 of 16









TABLE OF CONTENTS

Page

TABLE OF AUTHORITIES

SUPPLEMENTAL BRIEF IN SUPPORT 1

CONCLUSION 10









(i)





Case 2:03-cv-01500-K013-TMP Document 1391-2 Filed 05/27/2008 Page 4 of 16









TABLE OF AUTHORITIES

CASES Page

Dolphin & Bradbury, Inc. v. SEC,

No. 06-1319, 2008 U.S. App. LEXIS 492

(D.C. Cir. Jan. 11, 2008) 4

First Virginia Bankshares v. Benson, 559

F.2d 1307 (5th Cir. 1977) 10

In re Enron Corp. Sec. Litig., No. H-01-

3624, 2006 U.S. Dist. LEXIS 43146 (S.D.

Tex. June 5, 2006) 7

Regents of the Univ. of Cal. v. Credit

Suisse First Boston, 482 F.3d 372 (5th

Cir. 2007) 2

Stoneridge Investment Partners, LLC v

Scientific-Atlanta, Inc., No. 06-43 (U.S

Jan. 15, 2008) 1, 2, 3, 5



STATUTES, RULES AND REGULATIONS

15 U. S. C.

§77k 3

§78j(b) 1, 2, 3, 7

Federal Rules of Civil Procedure

Rule 23(f) 7

U.S. Supreme Court

Rule 15.8 • 1

17 C.F.R.

§240.10b-5 2

Case 2 . 03-cv-01500-K013-TMP Document 1391-2 Filed 05/27/2008 Page 5 of 16









SUPPLEMENTAL BRIEF IN SUPPORT

Pursuant to Rule 15.8 of this Court, Petitioner The

Regents of the University of California respectfully

submits this Supplemental Brief In Support of its

Petition for a Writ of Certiorari, and in opposition

to the Supplemental Brief In Opposition filed by

Respondents on January 16, 2008. As set forth

below, this Court's Stoneridge opinion rejected the

rationale of the Eighth Circuit that the Fifth Circuit

followed in this case. Differences between Ston-

eridge, which involved liability of mere customers or

suppliers, and this case, where financial professionals

deliberately misled investors, make this case an

appropriate one to grant certiorari and clarify the

scope of §10(b) liability where it matters most—in

relationship to deliberately misleading conduct of

investment bankers, undenvriters and securities

analysts who had a duty to speak truthfully.

1. Respondents say there is no reasonable

possibility that the Fifth Circuit might meaningfully

reconsider in light of this Court's decision of

Stoneridge Investment Partners, LLC v. Scientific-

Atlanta, Inc., No. 06-43 (U.S. Jan. 15, 2008), as "the

Fifth Circuit's decision in this case relied extensively

on the Eighth Circuit decision now affinued in

Stoneridge." Supplemental Brief In Opposition at 2.

Yet the Eighth Circuit opinion says that only

misstatements, omissions by one who has a duty to

disclose, and manipulative trading practices (where

"manipulative" is a word of art) may be deemed

deceptive under §10(b). See Stoneridge, No. 06-43,

slip op. at 7.

In Stoneridge, this Court noted: "If this conclusion

were read to suggest there must be a specific oral or

written statement before there could be liability

Case 2 . 03-cv-01500-K08-TMP Document 1391-2 Filed 05/27/2008 Page 6 of 16









2

under §10(b) or Rule 10b-5, it would be erroneous."

Id. That, however, is precisely how the Fifth Circuit

read the Eighth Circuit's opinion, expressly following

its erroneous logic "that '"deceptive" conduct involves

either a misstatement or a failure to disclose by one

who has a duty to disclose.'" See Petition Appendix

("Pet. App.") at 21a [Regents of the Univ. of Cal. v.

Credit Suisse First Boston, 482 F.3d 372, 388 (5th

Cir. 2007)]. Indeed, the Fifth Circuit ruled that the

district court erred because it applied §10(b) and

Rule 10b-5 as written, and "by ascribing, natural,

dictionary definitions to the words of the rule," rather

than the contrived definition offered by the Eighth

Circuit. Pet. App. at 20a [Regents, 482 F.3d at 3871.

At a minimum, the Fifth Circuit should be allowed to

reconsider its holding in light of Stoneridge.

2, Far from warranting a denial of certiorari, this

Court's decision in Stoneridge demonstrates critical

differences between Enron and Stoneridge differ-



ences that warrant a grant of certiorari to detei mine

§10(b)'s scope not in the context of ordinary business

transactions addressed by Stoneridge, but in the con-

text of fraud perpetrated by financial professionals

engaged in fraudulent dealings in our securities

markets. Stoneridge holds that the §10(b) right of

action does not reach ordinary customer/supplier

companies when their partners in ordinary business

relations subsequently account improperly for the

transactions entered between or among them. It does

not rule out liability for fraud by financial profes-

sionals that is directed at securities transactions,

i.e., transactions structured and designed to make

quarterly and year-end numbers. Cf. Stoneridge, No.

06-43, slip op. at 16 (contrasting investors' lack of

reliance on suspicious transactions "in the market-

Case 2:03-cv-01500-KOB-TM P Document 1391-2 Filed 05/27/2008 Page 7 of 16









3

place for goods and services" with transactions taking

place "in the investment sphere").

Even more to the point, Enron simply is not a case

in which Petitioner seeks to apply §10(b) "beyond

the securities markets—the realm of financing

business—to purchase and supply contracts—the

realm of ordinary business operations." Stoneridge,

No. 06-43, slip op. at 10. Enron is, at its core, a case

about financial fraud, executed by financial

professionals targeting investors; it is not about

"ordinary business operations," Id. Although §10(b)

"does not reach all commercial transactions that are

fraudulent and affect the price of a security in some

attenuated way," Stoneridge, No. 06-43, slip op. at

11, it certainly does reach fraud by financial

professionals, in securities transactions—including

registered offerings—and other statements addressed

to the financial markets. Stoneridge emphasizes:

All secondary actors, furthermore, are not

necessarily immune from private suit. The

securities statutes provide an express private

right of action against accountants and under-

writers in certain circumstances, see 15 U. S. C.

§77k, and the implied right of action in §10(b)

continues to cover secondary actors who commit

primary violations.

Id. at 15.

This coverage, of course, includes an underwriter

who knowingly underwrites a fraudulent offering and

deliberately disseminates fraudulent offering docu-

ments, selling securities to the public. "'By par-

ticipating in an offering, an underwriter makes an

implied recommendation about the securities [that

it] . . has a reasonable basis for belief in the

Case 2:03-cv-01500-K013-TMP Document 1391-2 Filed 05/27/2008 Page 8 of 16









4

truthfulness and completeness of the key represen-

tations made in any disclosure documents used in the

offerings." Dolphin & Bradbury, Inc. v. SEC, No. 06-

1319, 2008 U.S. App. LEX1S 492, at *13 (D.C. Cir.

Jan. 11, 2008) (emphasis in original). In Enron, the

banks who were underwriters made several know-

ingly false representations to the market.

Respondents were Enron's underwriters for

numerous securities offerings, selling securities with

offering circulars, prospectuses and registration

statements containing false financial information.'

They drafted and disseminated offering materials

hiding debt and reporting phony revenues that they

themselves had contrived for Enron to report.

Investors were entitled to rely on the truthfulness of

the offering documents that Respondents framed and

disseminated into the market for the specific purpose

of inducing investors to purchase Enron securities.

And the Respondents as underwriters were fidu-

ciaries, with a duty to make full disclosures-





' Merrill Lynch underwrote sales of Enron stock and notes in

1999. First Amended Consolidated Complaint ("FACC") 1738.

Barclays acted as a placement agent and/or reedier with respect

to the public offering in February 2001 of Enron's $1.9

billion zero coupon notes. FACC 1752. In addition, Barclays

sold Enron-related securities: Yosemite Securities Co. Ltd.

L200 000 000 8.75% Series 2000-A Linked Enron Obligations.

FACC 11753. During the Class Period, CSFB was an under-

writer for one Enron stock offering and two debt offerings. In

addition, CSFB sold Enron-related debt, Osprey and Marlin.

FACC 111696-699. The summary judgment briefing, the letter

prefixed documents, the five-digit exhibit numbers, deposition

transcripts, analyst reports, complaints and sworn statements

cited herein are part of the record Petitioner submitted in the

Fifth Circuit Court of Appeals case, Regents v. Credit Suisse

First Boston, No. 06-20856 (5th Cir.).

Case 2:03-cv-01500-KOB-TM P Document 1391-2 Filed 05/27/2008 Page 9 of 16









5

completely unlike the independent customers and

suppliers in Stone ridge.

This Court's Stoneridge opinion emphasizes:

"First, if there is an omission of a material fact by one

with a duty to disclose, the investor to whom the duty

was owed need not provide specific proof of reliance."

Stoneridge, No. 06-43, slip op. at 8. "Second, under

the fraud-on-the-market doctrine, reliance is pre-

sumed when the statements at issue become public,"

as did the offering documents for Enron's public

offerings of securities. Id. Thus, though Respon-

dents deny it, facts supporting both of the pre-

sumptions on which reliance may be based are

present in this case.

3. In addition to being underwriters, these banks

spoke to the market by structuring and supporting

off-the-books special-purpose entities and related-

party transactions like Osprey, LJM1 and L,JM2 that

hid debt and provided false positive cash flow from

operations.' As this Court emphasized in Stoneridge,

in that case "nothing respondents did made it

necessary or inevitable for Charter to record the

transactions as it did." Id. at 10. In this case, by

contrast, Enron's bankers designed and then

executed transactions so that they would have to be

accounted for in a way that both hid Enron's debt and

falsified its revenues.' For example, Merrill Lynch



2 As investors have noted: "'My whole emphasis was, if

Merrill Lynch is selling it, it has to be good because they're the

biggest brokerage firm in the world,' said Joe Marsh, a Merrill

Lynch client. Paula Dwyer, Laura Cohn, Emily Thornton &

Wendy Zellner, Merrill Lynch: See No Evil, Business Week,

Sept. 16, 2002, at 3-4.

As CSF13 noted in 2000: As you probably know, Osprey is a

vehicle enabling Enron to raise disguised debt which appears as

Case 2:03-cv-01500-K0B-TMP Document 1391-2 Filed 05/27/2008 Page 10 of 16









6

and Andrew Fastow ("Fastow") structured and

launched LJM2 for the express purpose of engaging

with Enron in earnings and balance-sheet manage-

ment transactions—i.e., transactions designed to

deceive investors. LJM2 was designed and operated

as a "conduit" through which Merrill Lynch and

others indirectly engaged in these deceptive trans-

actions.° Having conceptualized, designed and

structured LJM2 for the deceptive purpose, according

to Fastow, of "managing [Enron's] earnings," Mei ill

Lynch is liable as a primary violator. At a minimum,

this case should be remanded to explore whether

these transactions meet this Court's causation

standards as set forth in Stoneridge.

4. Finally, Respondents note somewhat defen-

sively that this case also involves false statements



equity on Enron's balance sheet. . . Osprey serves the added

purpose for Enron of being an off-balance sheet parking lot for

certain assets." Ex. 10264. As Merrill Lynch noted in 1999

("Nigerian Barge"): "Jeff McMahon, EVP and Treasurer of

Enron Corp. has asked ML to purchase $7MM of equity in a

special purpose vehicle that will allow Enron Corp. to book

$12MM of earnings. Enron must close this transaction by

12/31199. Enron is viewing this transaction as a bridge to



pei inanent equity and they have assured us that we will be

taken out of our investment within six months. The investment

would have a maximum 22.5% return." MLBE0111776.

10/24/06 Deposition Transcript of Andrew Eastow ("10/24/06

Fastow Depo. Tr.") at 417:6-11. This testimony is corroborated

by numerous other facts, including the contemporaneous

documents showing that Merrill Lynch "approved" the year-end

1999 transactions—before it became a limited partner—and

that it was given detailed information as to each transaction

before it was asked to fund it. Moreover, Merrill Lynch

understood the deceptive purpose of the transactions and—

without any legitimate business purpose of its own—went

forward anyway.

Case 2:03-cv-01500-K0B-TMP Document 1391-2 Filed 05/27/2008 Page 11 of 16









7

issued by securities analysts in their employ—

including "buy" recommendations on Enron stock.

They say that the district court "dismissed the §10(b)

claims that were premised on statements of research

analysts on the entirely independent ground that

petitioner had not alleged that the specific employees

associated with the analyst reports had acted with

scienter," (Supplemental Brief In Opposition at 4)

(emphasis in original), but that Petitioner did not

cross-appeal the dismissals—as if Petitioner could

cross-appeal from an interlocutory dismissal order

when the only basis for appellate review was under

Federal Rule of Civil Procedure 23(0. The district

court directed the parties, in any event, to raise the

issue again on summary judgment if they so chose:

"If there is a question, it should be raised by motion

for summary judgment." In re Enron Corp. Sec.

Litig., No. H-01-3624, 2006 U.S. Dist. LEXIS 43146,

at *391 (S.D. Tex. June 5, 2006). Petitioner

accordingly cited Merrill Lynch's analyst reports in

its opposition to Merrill Lynch's currently pending

summary judgment motion and cited Credit Suisse

First Boston's ("CSFB") analyst reports in its op-

position to CSFB's pending summary judgment

motion. See Opposition to Merrill Lynch Motion for

Summary Judgment at 132 n.519; Opposition to

CSFB's Motion for Summary Judgment at 214-232.

The Petition for Certiorari, moreover, notes that

Merrill Lynch issued 15 analyst reports and CSFB

issued 19. Petition at 29 n.30.

The analysts' venality shows Respondents' du-

plicity in deliberately using the sham transactions

they created to mislead investors and defraud the

market. For example, CSFB publicly represented

Enron stock as a "Strong Buy," based on its phonied

financials, maintaining a target price of over $100

Case 2:03-cv-01500-K0B-TMP Document 1391-2 Filed 05/27/2008 Page 12 of 16









8

per share until July 2001, when it eventually lowered

the target to $84.' Its private belief, however, was

that Enron was an absolute "don't buy."'

In an October 2001 email from CSFB analyst

Brian Gibbons ("Gibbons") to analyst Andy DeVries

("DeVries"), Gibbons derided the illicit Enron

partnerships as "basic money laundering operations

in essence." Ex. 15637. Immediately thereafter, with

Enron shares trading at $35, Curt Launer and

DeVries issued an October 2001 analyst report rating

Enron a "Strong Buy" and issued a target price of

$54• 7 DeVries acknowledges that while he told his

friends not to pay even $35 a share for Enron, he told

CSFB's clients it was a great buy. See n.6.

Merrill Lynch did the same. According to Fastow,

he "drew a short straw" among Enron's senior

management in that he was asked to deliver the

message to Merrill Lynch as to its then-current

analyst John Olson ("Olson"), "that it would be

difficult, if not impossible, for Enron to give Merrill

the business of leading an equity offering for Enron

because their equity analyst was saying not to buy

the stock."' After Merrill Lynch fired Olson, it

appointed another equity analyst, Donato Eassey







Compare CSF8LLC006888291, CS113LLC006888293 with

CSFBLLC006888606, CSFBLLC006888608.

5/25/05 Deposition Transcript of Andy DeVries at 311:23-

312:19; accord Ers 15643 (DeVries email stating "I wouldn't

touch" Enron shares); Ex. 15647 (email communications evi-

dencing DeVries' personal "sell" recommendation to friends

saved them money).

CSFBI A C006844639, CSFBLLC006844641.

10/24/06 Fastow Depo. Tr. at 519:4-19

Case 2:03-cv-01500-K0B-TMP Document 1391-2 Filed 05/27/2008 Page 13 of 16









9

("Eassey"), to cover Enron 9 In Eassey's first report

on Enron, he upgraded Merrill Lynch's rating on

Enron stock from neutral to accumulate.'" Merrill

Lynch's reports contributed to statistically significant

stock price increases on January 19, 1999, April 13,

1999, November 9, 1999, January 20, 2000, January

21, 2000, January 24, 2000, April 12-13, 2000, July

27, 2000, January 22-23, 2001, April 18, 2001, May

18, 2001, June 27, 2001, and October 10, 2001. All

the while, Merrill Lynch was creating false revenues

for Enron to report through LJM2.

Having spoken through analyst reports, and indeed,

having touted Enron's false results, which their trans-

actions created while recommending purchase of

Enron stock (clearly satisfying the "in connection with"

requirement) unlike the defendants in Stoneridge,

the banks in this case had a duty to disclose what

each knew about those false results. This alone

raises a presumption of reliance based on "an omis-







9 5/21/03 Sworn Statement of Donato J. Eassey, former Vice

President in Securities and Research at Merrill Lynch, to Robb

Hellwid, A & B) at 14-15,

11) ELIB00000631-00001-04 (1120/99 Donato J. Eassey, Merrill

Lynch Comment: "Enron Corp.—Solid Results in a difficult

Environment"); 5/21/03 Sworn Statement of Donato J. Eassey at

27-28. See also Neal Batson Third Interim Report, Appendix I

at 22; 1119/99 Merrill Lynch Analyst Report at 1 ("Intermediate

Term: Accumulate") ("Enron Corp.—Solid Results In a Difficult

Environment"); 10/12/99 Merrill Lynch Analyst Report at 1

("Intermediate Term. Accumulate"); 1/20/00 Merrill Lynch

Analyst Report at 1 ("Intermediate Term. Accumulate"); 1/22/01

Men-ill Lynch Analyst Report at 1 ("Intermediate Term: Buy")

("Enron Corp.—Strength In Numbers and Then Some"); 4/18/01

Merrill Lynch Analyst Report at 1 ("Raising the Bar—Again")

("Vie reiterate our Buy opinions.").

Case 2:03-cv-01500-K0B-TMP Document 1391-2 Filed 05/27/2008 Page 14 of 16









10

sion of material fact by one with a duty to disclose."

Stoneridge, No. 06-43, slip op. at 8."

CONCLUSION

The fact is that Respondents are financial profes-

sionals who structured financial transactions that

deceived the market and were reported as structured.

In addition, Respondents did speak to the markets in

underwritings and analyst reports and as a result

had a duty to speak the full truth. This Court should

remove any doubt about what Stoneridge means by

granting certiorari to clarify when financial profes-

sionals may be liable for deliberately misleading

investors. At a minimum, the case should be

remanded for a fuller examination of the facts.

Respectfully submitted,

PATRICK J. COUGHLIN *

HELEN J. HODGES

BYRON S. GEORGIOU

ERIC ALAN ISAACSON

SPENCER A. BURKHOLZ

JOSEPH D. DALEY

ANNE L. Box

COUGHLIN STOIA GELLER

RUDMAN & ROBBINS LLP

655 West Broadway, Suite 1900

San Diego, CA 92101

* Counsel of Record (619) 231-1058

Counsel for Petitioner

January 17, 2008



""Silence, or omission to state a fact, is proscribed only in

certain situations: first, where the defendant has a duty to

speak, secondly, where the defendant has revealed some rele-

vant, material information even though he had no duty (i.e., a

defendant may not deal in half-truths)." First Virginia Bankshares

v. Benson, 559 F,2d 1307, 1314 (5th Cir. 1977).

Case 2:03-cv-01500-K0B-TMP Document 1391-2 Filed 05/27/2008 Page 15 of 16









CERTIFICATE OF SERVICE



No. 06-1341





THE REGENTS OF THE UNIVERSITY OF CALIFORNIA.,

Petitioner,



vs.



MERRILL LYNCH PIERCE FENNER & SMITH, INC., MERRILL LYNCH & COMPANY,

INC., CREDIT SUISSE FIRST BOSTON (USA), INC., CREDIT SUISSE FIRST BOSTON

LLC, PERSHING LLC, BARCLAYS PLC, BARCLAYS BANK PLC, BARCLAYS CAPITAL,

INC.

Respondents.









I, ERIC ALAN ISAACSON, a member of the Bar of this Court, hereby certify that on

January 17, 2008, I caused Wilson-Epes Printing Co., Inc. to serve three copies of the

Supplemental Brief In Support by first-class mail, postage prepaid, on the following persons:



Richard W. Clary E. Lawrence Vincent

CRAVATH, SWAINE & MOORE, LLP 3020 Legacy Drive, #100-324

Worldwide Plaza, Plano, TX 75023

825 Eighth Avenue (214) 680-1668

New York, NY 10019-7475 Attorneys for Archdiocese of Milwaukee

(212) 474-1000 Supporting Fund, Inc.

Attorneys for Credit Suisse First Boston

(USA), Inc., Credit Suisse First Boston

LLC, Pershing LLC



Stuart J. Baskin Michael J. Del Giudice

Stephen J. Marten CICCARELLO DEL GIUDICE &

SHEARMAN & STERLING LLP LAFON

599 Lexington Avenue 1219 Virginia Street, East, Suite 100

New York, NY 10022 Charleston, WV 25301

(212) 848-4000 (304) 343-4440

Attorneys for Merrill Lynch Pierce Attorneys for Employer-Teamsters Local

Fenner & Smith, Inc., Merrill Lynch & Nos. 175 & 505 Pension Trust Fund

Company, Inc.

Case 2:03-cv-01500-K0B-TMP Document 1391-2 Filed 05/27/2008 Page 16 of 16

,

,

'

,

David H. Braff Robert C. Finkel I

SULLIVAN & CROMWELL LLP WOLF POPPER LLP

125 Broad Street 845 Third Avenue

New York, NY 10004-2498 New York, NY 10022

(212) 558-4000 (212) 759-4600

Attorneys for Barclays PLC, Barclays Attorneys for Nathaniel Pulsifer

Bank PLC, Barclays Capital, Inc.



Sherrie R. Savett

BERGER & MONTAGUE, P.C.

1622 Locust Street

Philadelphia, PA 19103

(800) 424-6690

Attorneys for Slam Asset Management .





I also certify that I caused a copy of the above-referenced documents also to be served

electronically on January 17, 2008, on all counsel of record for the Respondents who have consented .,

to electronic service, and all other counsel of record for interested parties in the underlying ,

proceeding via the www.ESL3624.com website. This manner of electronic service is pursuant to the

United States District Court's Order in Newby v. Enron Corp., No. H-01-3624 (S.D. Tex.)



I further certify that all parties required to be served have been served.





COUGHLIN STOIA GELL 7

RUDMAN & ROBB As

le /



E--e,-1,t , n V,

ERIC ALAN —AACSON

655 West Broadway, Suite 1900

San Diego, California 92101

619/231-1058

Conte of Record for Petitioner

S:ICasesSlaranrontSupreme CournPOS for Response Supplemeal.doc

Case 2:03-cv-01500-K013-TMP Document 1391-3 Filed 05/27/2008 Page 1 of 12 FILED

2008 May-27 PM 06:44

U.S. DISTRICT COURT

N.D. OF ALABAMA









EXHIBIT 2

Case 2:03-cv-01500-K08-TMP Document 1391 -3 F iled 05/27/2008 Page 2 of 12







har Oita



MAY 1 4 7003 n

iidestmaiaut

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF TEXAS

HOUSTON DIVISION



In re ENRON CORPORATION SECURITIES § Civil Action No. H-01-3624

LITIGATION § (Consolidated)

This Document Rotates To:

CLASS ACTION

MARK NEWBY, et aL, Individually and On §

Behalf of All °there Similarly Situated,

§ FIRST AMENDED CONSOLMATED

Plaintiffs, § COMPLAINT FOR VIOLATION OF THE

§ SECURITIES LAWS

VS. •§





ENRON CORP., et al.,

• •

Defendants. I

THE REGENTS OF THE UNIVERSITY OF §

CALIFORNIA, et al., Inditridually and On .1

Behalf of All Others Similarly Situated,

••

Plaintiffs,

vs.

• f

KENNETH I.. LAY, JEFFREY K, sauna, I

ANDREW S. vAsrow, RICHARD A. §

CAUSEY, MARK A. FREVERT, STANLEY C. §

HORTON, KENNETH D. RICE, RICHARD B. §

BUY, LOU L. PAI, JOSEPH 144. PERKO,

(Caption continued an following page.)

Thb mitingipubliontlem is creative *tic fWly protactedby all applicable copyright len a nil as by acimpprupriatinn,

tads seam, unfair :competition end Wier applicable bin. The authors of this work hare added ithm co the underlying rowel

irazeisio herein dam* ate or more of the fallowing unique acid original aelacrion, ecordhatiom napiessloo. arthipmoent end

clamdflonlon of the Information.



No =might ia claimed lathe tem of ragulatiom, nod thy memo firm enalyrts' report' quoted within die watt



CoPriert 2002 by Wilhism B. Loath andhillbag Weill rientiedHynes &Lomb IL?. William & Laub ardLiilberg

Wee Borthed Hymn & Lath LLP wifl vigerently ddrad in of their tights to this thitharobliratica.



All tights rererved — imIndlog tha Pith to reproduce in vtbcdo cc In part in soy &am My Nut &mien in any fbnu by

anyone ate. memial othadoed hada "thous the permithan of Wilt S. Lark end Milborg We* BOXIbbi Hymn & lab

LLP la prohibited.

Case 2:03-cv-01500-K0B-TMP Document 1391-3 Filed 05/27/2008 Page 3 of 12









KEN L. HARRISON, STEVEN J. ICEAN, §

REBECCA P. MARK-JUSBASCHE, JEFFREY §

MCMAHON, CINDY K. OLSON, JOSEPH W. §

SUTTON, MARK E. KOENIG, KEVIN P. §

HANNON, LAWRENCE GREG WHALLEY, §

ROBERT A. BELFER, NORMAN P. BLAKE, §

JR., RONNIE C. CHAN, JOHN H. DUNCAN, §

WENDY L. GRAMM, ROBERT K. JAEDICKE, §

CHARLES A. LEMAISTRE, JOE H. FOY, §

JOHN MENDELSOHN, PAULO V. FERRAZ §

PEREIRA, JEROME J. MEYER, JOHN A. §

URQUHART, JOHN WAICEHAM, CHARLS E. §

WALKER, HERBERT S. WINOKUR, JR., §

FRANK SAVAGE, ALLIANCE CAPITAL §

MANAGEMENT L.P., JOSEPH F.§

BERARDINO, THOMAS H. BAUER, DAVID B. §

DUNCAN, DEBRA A. CASH, DAVID §

STEPHEN GODDARD, JR., GARY B. §

GOOLSBY, MICHAEL M. LOWTHER, §

MICHAEL C ODOM, JOHN E. STEWART, §

MICHAEL L. BENNETT, BENJAMIN S. §

NEUHAUSEN, RICHARD R. PETERSEN, §

WILLIAM E. SWANSON, MICHAEL D. §

JONES, ARTHUR ANDERSEN LLP, §

ANDERSEN WORLDWIDE, S.C., ANDERSEN §

CO. (INDIA), ARTHUR ANDERSEN-PUERTO §

RICO, ANDERSEN LLP (CAYMAN ISLANDS), §

ARTHUR ANDERSEN-BRAZIL, ARTHUR §

ANDERSEN (UNITED KINGDOM), VINSON & §

ELICINS, L.L.P., J.P. MORGAN CHASE & CO., §

JP MORGAN CHASE BANK, JP MORGAN §

SECURITIES INC., CITIGROUP, INC., §

CITIBANK, N.A., SALOMON SMITH §

BARNEY, INC., SALOMON BROTHERS §

EN FERNATIONALLIMI FED, CREDIT SUISSE §

FIRST BOSTON (USA), INC., PERSHING LLC, §

CREDIT SUISSE FIRST BOSTON CORP., §

CANADIAN IMPERIAL BANK OF §

COMMERCE, CIBC WORLD MARKETS §

CORP., CIBC WORLD MARKETS PLC, CIBC §



[Caption continued on following page.]

Case 2:03-cv-01500-K08-TMP Document 1391-3 Filed 05/27/2008 Page 4 of 12









OPPENHEIMER CORP., BANK OF §

AMERICA CORP., BANC OF AMERICA §

SECURITIES LLC, MERRILL LYNCH & §

CO., INC., MERRILL LYNCH, PIERCE, §

FENNER & SMITH, INC., BARCLAYS PLC, §

BARCLAYS BANK PLC, BARCLAYS §

CAPITAL, INC., DEUTSCHE BANK AG, §

DEUTSCHE BANK SECURITIES INC., DB §

ALEX. BROWN LLC, DEUTSCHE BANK §

TRUST COMPANY AMERICAS, LEHMAN §

BROTHERS HOLDING, INC. and LEHMAN §

BROTHERS INC.,



Defendants. § DEMAND FOR JURY TRIAL

Case 2:03-0/-01 500-K08-TMP Document 1391-3 Filed 05/27/2008 Page 5 of 12









CS First Boston, Merrill Lynch, JP Morgan and CitiGroup participated in setting up or were early



investors in LIM2. Merrill Lynch and JP Morgan were the main lenders to LJM2 entities.



461. LIM2 solicited prospective investors as limited partners using a confidential Private



Placement Memorandum ("PPM") detailing, among other things, the "unusually attractive



investment opportunity" resulting from the partnership's connection to Enron. The favorable terms



of the early LJM2 investors were an opportunity for some of Enron's bankers to be regarded with



extremely high risk fee returns. Thus, JP Morgan, Merrill Lynch, CIBC and CitiGroup were early



investors in LJM2. The PPM emphasized Fastow's position as Enron's CFO, and that LJM2's day-to-



day activities would be managed by Fastow, Kopper and Glisan. It explained that "Wile Partnership



expects that Enron will be the Partnership's primary source of investment opportunities" and that it



"expects to benefit from having the opportunity to invest in Enron-generated investment



opportunities that would not be available otherwise to outside investors." The PPM specifically



noted that Fastow's "access to Enron's information pertaining to potential investments will contribute



to superior returns." Merrill Lynch was the Placement Agent of the PPM and Kirkland & Ellis was



legal counsel to LJ1vI2.



462. The transactions between Enron and LIM2 that most misstated Enron's financial



statements involved four SPEs known as the "Raptors." Similar to the Rhythms transaction, Enron



improperly used the value of its own equity to counteract declines in the value of certain of its



merchant investments, violating a basic accounting principle. See APB No, 9128. Enron used the



Raptors to avoid reflecting losses in the value of some of its investments on the Company's income



statement. If the value of the investments declined, the Raptors were designed so that the value of



the corresponding hedge would increase by an equal amount. Consequently, the decline— which was



recorded each quarter on Enron's income statement — would be offset by an increase in income from







-340-

Case 2:03-cv-01500-K08-TMP Document 1391-3 Filed 05/27/2008 Page 6 of 12









[T]he now-infamous LJM2 partnership set up by Enron's former chief financial

officer, Andrew Fastow. It's been well-documented now ... that high-powered

finance firms such as CS First Boston, Merrill Lynch, JP Morgan and Citigroup, were

lured into the LJM2 partnership by the promise of potentially rich returns and the

chance to get an inside peek into Enron's mysterious deals.



* • *



... Wall Street — which got rich touting Enron — is still acting as if it has nothing

to answer for in the Enron mess.



So far, most Wall Street institutions have said little about the Enron debacle, issuing

either blanket "no comments," or denying any responsibility for the company's

collapse. CS First Boston, which underwrote more than $4.5 billion in Enron stock

and bond offerings — roughly 20% of Enron's total underwriting work since 1990 ...

has refused to say anything whatsoever. Men-ill Lynch, which lined up investors for

Fastow's LJM2 partnership and underwrote more than $4 billion in stock and bond

offerings for Enron, has been a bit more talkative — but only to say it's utterly

blameless.

* *



Between them, Citigroup and J.P. Morgan served as lead manager on more than $20

billion in syndicated bank loans to Enron over the past decade, with Citigroup also

underwriting more than $4 billion in stock and bond offerings for the company ....



... Wall Street has plenty of explaining to do. Jonathan Kord Lagemann, a securities

Lawyer and former general counsel for a brokerage firm, says the Enron affair exposes

the "enormous conflict of interest" inherent in these firms' efforts to be three things

at one time: underwriter, corporate analyst and stock seller. To start, there's the

obvious issue of whether pressure from their firms caused 10 of the 14 research

analysts who followed Enron to keep recommending the stock to investors, even as

the company was racing toward bankruptcy. A related issue is whether the analysts

knew or should've known just how dire the situation was at Enron, since many of

them work for firms that were invested in the partnerships that played a critical role

in Eaton's off-balance-sheet transactions.



646. One of the primary vehicles utilized by defendants to falsify Enron's financial



condition and results during the Class Period was a partnership called LIM2, which was secretly



controlled by Enron and was used to help create numerous SPEs (including the infamous Raptors)



with which Enron engaged in illusory transactions to artificially inflate Enron's profits while

1

concealing billions of dollars in debt that should have been on Enron's balance sheet, 14,11\ 112 was a



- 443 -

Case 2:03-cv-01500-K08-TMP Document 1391-3 Filed 05/27/2008 Page 7 of 12









privately held entity created by Enron with the help of Merrill Lynch, Andersen and Vinson & Elkins



at year-end 99. They knew, because LJM2 was going to be principally utilized to engage in



transactions with Enron where Enron insiders (Fastow, Kopper and Glisan) would be on both sides



of the transactions, that the LJM2 partnership would be extremely lucrative — virtually guaranteed



to provide huge returns to LIM2's partners. In fact, Fastow's dual role by which he could self-deal



on behalf of the partnership with Enron's assets was so important that investors in LJM2 were



assured that they did not have to make any additional capital contributions if Fastow's dual role



ended. As a result, Enron and Merrill Lynch decided that in raising the money to fund LIM2, they



would allow certain favored investment banks and/or high-level officers of those investment banks



to invest in LJM2 because they knew the investment was virtually guaranteed to produce



extremely good returns. In fact, the offering memorandum for the LJ1v12 partnership by which



Merrill secured investors into the partnership — which was not a public document — contained a



virtual invitation to benefit from the insider self-dealing transactions that LJM2 would engage in



It stressed the "unusually attractive investment opportunity" resulting from the partnership's



connection to Enron. It emphasized Fastow's position as Enron's CFO, and that LJM2's day-to-day



activities would be managed by Enron insiders Fastow, Kopper and Chum. It explained that "ill he



Partnership expects that Enron will be the Partnership's primary source of investment



opportunities" and that it "expects to benefit from having the opportunity to invest in Enron-



generated investment opportunities that would not be available otherwise to outside investors."



The Private Placement Memorandum ("PPM") specifically noted that Fastow's "access to Enron's



information pertaining to potential investments will contribute to superior returns." In addition,



investors were told that investors in a similar Fastow controlled partnership (JEW) that had done



deals with Enron like the ones LJM2 would do had tripled their investment in just two years! In







- 444 -

1

Case 2:03-cv-01 500-K013-TM P Document 1 391 -3 Filed 05/27/2008 Page 8 of 12









Barry S. Friedberg, $500,000

Chairman of global markets & investment banking



Richard Gordon, $500,000

Vice-Chairman, investment banking

(fired for refusing to cooperate with Senate investigation)



Daniel H. Bayly, $200,000

Head of Investment Banking



Robert J. McCann, $200,000

Head of Global Institutional Client Division



Thomas W. Davis, $150,000

President — Global Markets and Investment Banking



Brian Hehir, $150,000

Vice-Chairman, Investment Banking



Benjamin Sullivan, $150,000

Managing Director, Private Placements Group

(oversaw UM private placement)



742.7 But the creation of LJM2 alone could not adequately bolster Enron's 4thQ and year-



end 99 numbers, nor was it enough for Merrill Lynch to aid its relationship with Enron and rake in



investment banking fees. Consequently, Merrill Lynch entered two sets of bogus transactions with



Enron that falsely boosted Enron's 4thQ and year-end 99 profits approximately $72 million. In the



first transaction, Merrill Lynch "purchased" Nigerian barges from Enron in late 12199 to create fake



earnings for Enron of over $12 million, with a secret promise that Enron would buy the barges back



from Merrill Lynch six months later. In the second transaction, Merrill Lynch created bogus power



swaps on 12/31/99, to falsely inflate Enron's 4thQ and 99 profits $60 million. Neither of the



"transactions" had any economic purpose whatsoever, other than to increase Enron's stock price and



generate present and future fees for Merrill Lynch.









- 496-

Case 2:03-cv-01500-K08 -TM P Document 1391-3 Filed 05/27/2008 Page 9 of 12









illicit partnerships or SPEs, and helped Enron falsify its financial statements and misrepresent its



financial condition, while its securities analysts were issuing extremely positive — but false and



misleading — reports on Enron extolling its business success, the strength of its financial condition



and its prospects For strong revenue and earning growth in the future. In addition to the huge



underwriting, advisory and transactional fees, interest and commitment charges CitiGroup was



receiving from Enron and related entities, in return for CS First Boston's participation in the scheme,



CS First Boston executives were rewarded by being permitted to invest at least $223 million in the



lucrative LJM2 partnership.



694. CS First Boston's relationships with Enron were so extensive that top executives of



the firm constantly interacted with top executives of Enron, i.e., Lay, Skilling, Causey, McMahon



or Fastow, on almost a daily basis throughout the Class Period, discussing Enron's business, financial



condition, financial plans, financing needs, partnerships, SPEs and Enron's future prospects. CS



First Boston actively engaged and participated in the fraudulent scheme and furthered Enron's



fraudulent course of conduct in several ways. It participated in loans of over $4 billion to Enron



during the Class Period. It helped Enron raise over $3 billion from the investing public via the sale



of new securities during the Class Period. It helped Enron structure and finance several of the illicit



SPEs and partnerships Enron controlled, which were primary vehicles utilized by Enron to falsify



its reported financial results, and engaged in transactions with Enron to disguise loans to Enron and



help Enron falsify its reported financial condition, liquidity and creditworthiness.



695. In interacting with Enron, CS First Boston functioned as a consolidated and unified



entity. There was no so-called "Chinese Wall" to seal off the CS First Boston securities analysts



from the information which CS First Boston obtained in rendering commercial and investment



banking services to Enron. Alternatively, even if some restrictions were placed on the information







- 470 -

Case 2:03-cv-01500-K013-TMP Document 1391-3 Filed 05/27/2008 Page 10 of 12









705. In addition to its own direct liability for making false and misleading statements, CS



First Boston also participated in and furthered the fraudulent scheme by helping to finance or



otherwise participate in illicit transactions with Enron which it knew would contribute materially to



Enron's ability to continue to falsify its financial condition and thus continue the operation of the



Enron Ponzi scheme.



706. CS First Boston, like JP Morgan and CitiGroup, made disguised loans to Enron so



that Enron's true credit situation, liquidity and debt levels could be disguised. CS First Boston lent



Enron money using trades in derivatives. In 00, CS First Boston gave Enron $150 million to be



repaid over two years. Enron's payments would vary with the price of oil. Technically, the



transaction was a swap. But because CS First Boston paid Enron up front, the transaction was in fact



a loan — a reality admitted by CS First Boston. "It was like a floating-rate loan," said Pen



Pendleton, a CS First Boston spokesman. "We booked the transaction as a loan." Enron's



balance sheet misrepresented this transaction. Enron posted the banks' loans as "assets from price



risk management" and as "accounts receivable," admitted Charlie Leonard, a spokesman for



Andersen: The repayments that Enron owed the banks were listed as "liabilities from price risk



management" and possibly a small amount as accounts payable, Leonard said.



707. CS First Boston also knowingly engaged and participated in and, in furtherance of



the scheme, helped Enron by creating some of the illicit SPEs which were the primary vehicles by



which Enron falsified its financial condition and misrepresented profits. This was done by a group



of 10 bankers from CS First Boston who had joined CS First Boston from Donaldson Lufkin &



Jenrette in 98, led by Laurence Nath. Using the euphemism "structured products," Nath and his team



structured numerous illicit SPEs to engage in transactions with Enron to improperly boost Enron's



reported profits while moving billions of dollars of debt off Enron's balance sheet to the SPEs.







- 475 -

Case 2:03-cv-01500-K013-TMP Document 1391-3 Filed 05/27/2008 Page 11 of 12









These transactions included Marlin, Firefly, Mariner, Osprey, Whitewing, and the infamous Raptors.



With CS First Boston's help, Enron sold assets to these entities at inflated prices — prices that Enron



never could have obtained in arm's-length transactions with third parties, resulting in phony profits



while hiding billions of dollars of debt.



708. Nath and CS First Boston worked very closely with Vinson & Elkins and Andersen



to create and document these entities and these transactions. According to a former Enron employee,



"Monetise" was the buzzword. Everyone was always saying: "We have to monetise this." The



quick-fix solution was: "We'll sell it to LIM, or to Raptor, or to whatever the partnership of the



month was.... They'd pick up the phone and Larry Nash would come down to Houston for a week



or two and sit down with the ... accountants and come up with something." Nath would gather



with a group from Enron's treasury and global finance departments known inside the Company as



"Fastow's field marshals." This group included McMahon, Enron's former treasurer, and Glisan,



who took over from McMahon as treasurer.



709. Most of the vehicles that emerged from these meetings contained an unusual feature



created by Nath: they held Enron stock in order to comfort lenders and secure an investment grade



rating, but required Enron to inject more shares into the vehicles if the share price fell to certain



"trigger points" or prices i.e., $83-$19 per share They could also force their liquidation if Enron's



credit rating was downgraded and the debt of the SPEs became recourse to Enron in such



circumstances. "What I can't believe is that anyone ever got comfortable when you put all of this



stuff together. Taken in combination, these partnerships clearly posed a material risk for the



company," a knowledgeable banker has said. The trigger points inside the partnerships were a



time bomb. " There's no question that senior people at CFSB knew what was going on and that



it was a house of cards," one Enron insider has said. The triggers were discussed by senior







- 476-

Case 2:03-cv-01500-K0B-TMP Document 1391-3 Filed 05/27/2008 Page 12 of 12









733. CIBC knew that Enron was falsifying its publicly reported financial results and that



its true financial condition was much more precarious than was publicly known. It obtained this



knowledge due to its access to Enron's internal business and financial information as one of Eaton's



lead lending banks, as well as its intimate interaction with Enron's top officials which occurred



virtually on a daily basis.



734. Thus, C1BC is directly liable to the Class for making false and misleading statements



in Registration Statements and Prospectuses utilized by Enron and C1BC to raise billions of dollars



of new capital for Enron, for false and misleading statements in analysts' reports written and issued



by CIBC, which helped to artificially inflate the trading price of Ertron's publicly traded securities,



as well as for its knowing participation in a fraudulent scheme, course of conduct and fraudulent



course of business of Enron, which operated to defraud purchasers of Enron's publicly traded



securities during the Class Period.



F. Involvement of Merrill Lynch



735. Merrill Lynch is a huge financial services firm which had an extensive and extremely



close relationship with Enron. During the Class Period it provided investment banking services to



Enron, helped structure . and finance one or more of Enron's illicit partnerships or SPEs, while its



securities analysts were issuing extremely positive reports on Enron extolling its business success,



the strength o f its financial condition and its prospects for strong future earnings and revenue growth.



736. Merrill Lynch's relationships with Enron were so extensive that top executives of the



firm constantly interacted with top executives of Enron, i.e., Lay, Skilling, Causey, McMahon or



Fastow, on almost a daily basis throughout the Class Period, discussing Eruon's business, financial



condition, financial plans, financing needs, its partnerships and SPEs and Eaton's future prospects.



Schyler Tilney was the head of Merrill Lynch's Energy Investment banking operation. Schyler







- 489 -



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