IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF TEXAS,
HOUSTON DIVISION c:-
SEVERED ENRON EMPLOYEES COALITION
(SEEC), IARENCE R. JORDAN, DEBORAH S.
DEFFORGE, and DIANA PETERS, on behalf of
themselves and all others similarly situated; and
on behalf of the Enron Corporation Savings Plan,
PLAINTIFFS,
vs.
THE NORTHERN TRUST COMPANY,
NORTHERN TRUST RETIREMENT
CONSULTING, L.L.C., PHILIP J. BAZELIDES,
ROBERT A. BELFER, NORMAN P. BLAKE, JR., CLASS ACTION COMPLAINT
RONNIE C. CHAN, JOHN H. DUNCAN, LOU PAI,
KEN RICE, MARK FREVERT, JOSEPH SUTTON,
CLIFFORD BAXTER, JOSEPH M. HIRKO, BREACH OF FIDUCIARY DUTY
RICHARD A. CAUSEY, JAMES V. DERRICK, AND VIOLATION OF ERISA
MARK E. KOENIG, CINDY K. OLSON, STEVEN (Jury Demanded)
J. KEAN, RICHARD B. BUY, MICHAEL S.
MCCONNELL, JOE H. FOY, J. MARK MEl-TS,
STAN HORTON, WENDY L. GRAMM, KEN L.
HARRISON, ROBERT K. JAEDICKE, MARY K. Judge
JOYCE, KENNETH L. LAY, ANDREW FASTOW,
JEFF McMAHON, CHARLES A. LeMAISTRE,
REBECCA P. MARK-JUSBASCHE, JOHN
MENDELSOHN, JEROME J. MEYER, PAUL0 V.
FERRAZ PEREIRA, JAMES S. PRENTICE,
FRANK SAVAGE, JEFFREY K. SKILLING, JOHN
A. URQUHART, JOHN WAKEHAM, HERBERTS.
WINOKUR, ARTHUR ANDERSEN, L.L.P. and/or
ANDERSEN, L.L.P., JOHN DOE NOS. 1
THROUGH 10, and JANE DOE NOS. 11
THROUGH 20,
DEFENDANTS.
COMPLAINT
INTRODUCTION
1. Plaintiffs bring this class action under the Employee Retirement
SNIPPETS:
IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF TEXAS,
SEVERED ENRON EMPLOYEES COALITION, IARENCE R. JORDAN, DEBORAH S. DEFFORGE, and DIANA PETERS,
FRANK SAVAGE, JEFFREY K. SKILLING, JOHN A. URQUHART, JOHN WAKEHAM, HERBERTS.
Plaintiffs bring this class action under the Employee Retirement Income
on behalf of all current and former Enron Corporation
employees and the beneftciaries of the Enron Corporation Savings Plan (the "Plan" or the
Defendants are the Plan's former Trustee, the Plan's former recordkeeper, the
Severed Enron Employees Coalition is an association of former
participant in Enron's 401Plan and held Company stock directly or through the Enron
He is Co-Chairperson of SEEC.
Plaintiff Diana Peters is a resident of Houston,
Defendant The Northern Trust Company is a wholly-owned
served as the Plan's Trustee throughout the relevant time period.
Plan's terms and not contrary to the provisions of ERISA.
He is believed to have received approximately $51 million from the sale of his
Defendant Mark Frevert is a former Chairman of Enron North America.
Defendant Joseph Sutton is a former Vice-Chairman of Enron and is believed
the management and administration of the Plan and/or Defendants exercised control in the
various investment funds, thereby making it a fiduciary pursuant to ERISA $402(29
Participants directed the investment of their contributions, in 1% increments, to the various
Defendant John Mendelsohn was, during the relevant time period, a Director
Defendants breached their fiduciary duties with respect to providing sufficient
a fiduciary must always act
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