C] reptscas k here if~his claim a a previously filed claim dated:-

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1 In re (Name of Debtor) United States Bankruptcy Court ENRON CORP., at al, Southern District of Mew York PROOF OF CLAIM Case Number (AJG) NOTE: This farm should not ba used to ~ a claim for =administrative ae eris' after the oonunencerntait of the can. A ucat of t of an admiatahative erase ma be filed Pu2susiff to l I S. C. 5~ Name of Creditor Check box if you an more that anyone (The person or entity to whom the debtor owes money or property) else bas flied a f of claim mhw to f t Claimants in Newby Action Pending in Houston before Judge yo n ataim Attach copy o ste Melinda Hannon Set attachment for cx sloe Name and Addressee Wham Notices Should be Sent Cheek box if you have never receive d Cra P. Rieder, Esq. any nodose 5vm the benkruptey court c lo novese Joblove & Battista, P i as e.a. s c. 100 S.L Second Street, 36th Floor 0 Check box if the address differs fro m Miami, Florida 'the son the envelope seat to you by the Telephone No TIES &PAC IS FO R COURT USE ONLY ACCOUNT OR OTHER NUMBER BY WELCH CREDITOR IDENTIIIS DEBTOR; - 'Case No. H C] reptscas k here if~his claim a a previously filed claim dated:- 1. BASISFOR CLAIM 0 Retiree benefits as defined in 11 U.S.C (a) Goods sold Wages, salaries and compensations (Fill out below) Services performed Your social security number CD Money loaned Unpaid compensation for services performed Personal injurylwraugfnl death from to Q Taxes (date) ate Other (Describe briefly) Darns et dice to psk]dux flat-ed Prices for ou s securf tes. Claims are detailed in Consolidated Ca laint s attached for ca ti n 2. DATE DEBT WAS INCURRED : Class Period thrau h IF COURT JUDGMENT DATE OBTAINED : 4. CLASSIFICATION OF CLAIM. Under the Bankruptcy Code all claims are classified as one or more of the following: (1) Unsecured nonpriority, (2) Unsecure d Priori ( 3). Secured. It is ~o ssible for art of a claim to be in one category and part in another. CHECK THE APPROPRIATE BOX OR BOXES th at beat desc rib e your claim -iid, STATE THE AMOUNT OF THE CL AIM. Undeterimfaed - SECURED CLAIM 5 0 UNSECURED PRIORITY CLAIM S Attach evidence ofp as at sacun mweat Specify the priority of the claim B rief Descripti on of Collatera l Real Estate Motor Vebiclo o ther(describe briefly) Q w 1 g es, safari or eommjsajona (up to 54,340), wined not more than i go the bw&fwtcy cessa d e 3) th e b is bu ore ess, whicever is 1 1 J.S.C. 507() ( Amount of arrearage and other charges included in secure d claim above, if any 0 C otributions to an employee benefit plan - U.S.C. f 507(x)(4) 0 Up to 5900 of deposits toward purchase, lease, or rental ofproperty or semcaa for personal, family, or household use - 11 U.S.C. 507(x)( 0 'UNSECURED NONPRIOR ITY CLAIM Tu ca or penahies of governmental units - I 1 U.S.C (a)(7 ) A claim is unsecured if therc is no collateral or lien onproperty of the dchtnr Other - I 1 U_S.C. II 507 (a)(2), (a)(s) - (Describe bricfly) scouring the clarai or to the extent that the value o f a rh property is leas than the - amount of the claim. S. TOTAL AMOUNT OF CLAIM AT TIME S U deters ned S S - $ Undetermined CASE FILED: (unoccutedi eau non ~"- c ota Check Chia box if claim includes on charges in addition to the principal amount of the claim Attach itmniaed statement of all additional es. 6. CREDITS AND sm opfs : The amount of all payments on this claim has been credited and deducted for the purpose of making this proof ofelei m. In fi lin g th i s cl aim, cla imant has deducted all amounts that clainuot owes to debto r, 7. SUPPORTING DOCUMENTS: Attach wig gs rti g dgu such as promissory notes, purchase orders, invoices, itemized atetementa of running accwunu,'pn aa ttac sf -, oo udginon, ar evidence of security tntereais If the documents are no t ava i lable, explain. If the document, are voluminous, attach e swirmbfy. 8. TIME-STAMPED COPY: To receive an acknowledgment e e 8 g afyaur claim, tnaloaa a stamped, calf-addressed envelope MS SPACE IS FOR COURT USE ONLY Date June 23, 2002 Sign and print a name tla, if en for or other person authorized to fl1cv. this claim (a copy, ey, if any) y R T Craig P. Rl q. n c ; Ce-caaasel for the haft to the Newby Class Ac tion L ldiratinn -"< P nauyfor preaentiurgfraudu1ent claim : Fine of up to $500,000 or itnprisonmeat for up to 5 yeats,or both..15 U.S.C. If 152 and P. 4ZD INJ C:

2 ATTACHMENT TO PROOF OF CLAIM -!V1 ~.y f Inc c;iaimants in the Newby Consolidated Mass Action penamng in Houston before Judge Melinda Harmon are asserting their claims in each of the Enron Corp., et a[. Chapter 11 cases. The filing of this Proof of Claim should be deemed a filing of a Proof of Claim in each of the Chapter i I cases that are currently pending before the Court. The Class Action Claimants reserve their rights to amend the Proof of Claim., The Class Action Claimants intend to file a motion seeking Class Claim status in connection with this claim. A copy of the Newby Consolidated Class Action Complaint wb.ich sets forth the claims asserted against numerous debtors is available and will be provided at the request of interested parties.

3 4VTJ.L LEIXi I LKLLON OLL'.JJ.J21 FO1& E VV UI%x CvL' JL2%J2 T IS NOT BEING ATTACHED TO THIS PROOF OF CLAIM BECAUSE THE COMPLAINT IS VOLUMINOUS. ANY PARTY IN INTEREST SEEKING A FULL, COMPLETE COPY OF rrwv"i m I. FOtCLl O1TM T G L am. VL Lr1T.~Ali'I 1r1A T t. i i AC l RL u 1'NAJF.1-'0'Lks1.NJV'u, IN WRITING FOR A FULL, COMPLETE COPY. Craig P. Rieders, Esq. Genovese Joblove & Battista, P.A. Bank of America Tower 100 Southeast Second Street 36th Floor Miami, Florida Craig P. Rieders

4 UNTIED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK_ In re : ENRON CORP, et al., Debtors, Chapter 1 1 Case No [MG] Jointly Administered STATEMENT PURSUANT TO F.R. BANKR. P REGARDING REPRESENTATION O MULTIPLE S INTERES T Pursuant to Fed. R. Bankr. P. 2019, the law firm of Genovese Joblove & Battista, P.A., ("G]]3"} files this statement of multiple representation and states as follows : 1. G1B and Milberg Weiss Bershad Hynes & Lerach LLP are co-counsel for the plaintiffs in an dl LLUl1 pending in we UIULCU JW.LGJ L1SWIGL LOUfL, auulflc JJ1 51C16L UL.L CX.S, ELOU51UII L 1VISIUn SLy1Ca Newby v. Enron ; Regents v. Lay, et al., Civil Action No. H (Consolidated) Class Action. 2. GTE has not represented any of the above named parties in interest in matters unrelated t o this Chapter- 11 case. 3. To the knowledge of the undersigned, GJB does not hold any claim against Enron. G_lB reserves the right to supplement this Statement. Dated: June 23, 2002 Miami, Florida Respectfully submitted, GENOVESE JOBLOVE & BATTISTA, P.A. Co-counsel for Class Claimants in Newby Action Bank of America Tower 100 Southeast Second Street, 36`h Floor Miami, Florida Telephone: (305L Facsimile: (396)j49-.;5l 0 By : Craig P ' de sq. (CR 9012)

5 I, Craig P. Rieders, certify under penalty of perjury that the foregoing statement is true and correct to the best of my information, knowledge and belief. Executed on June 23, 2002 GENOVER9t JOBLOVE & BATTISTA, P.A. By: Craig P. icieders, Esq.