Both have pleaded not guilty

1. Both are accused of lying about Enron's financial health before the company crumbled
into bankruptcy upon revelations of hidden debt and inflated profits.Gaps in the counts
appear because the indictment included other counts against former Enron chief accounting
officer Richard Causey.

2.Conspiracy to commit securities and wire fraud(financial fraud involving the use of
telecommunications or information technology), against Lay and Skilling. Covers alleged
acts from late 1999.

3.Skilling allegedly approved quarterly and annual reports submitted to the Securities
Exchange Board of India that misstated revenues and earnings and conducted
misleading quarterly conference calls with National Stock Exchange. Lay allegedly lied to
employees, credit rating agencies and analysts with claims that Enron was healthy or that its
books had been sanitized of problems when he knew otherwise.

4.Securities fraud, against Skilling. Stems from so-called Raptors, four fragile financial
structures backed by Enron stock used to hedge inflated asset values and keep hundreds of
millions of dollars in debt off the energy company's books.

Prosecutors say Skilling knew the Raptors were wrongly treated as independent of Enron, so
should not have been kept off Enron's books, and that they were used to avoid public
disclosure of decreases in asset values.

5.Wire fraud, against Skilling. Refers to four wire transfers of funds to entities involved in the
Raptor hedging structures.

6.Wire fraud, against Lay. Stems from alleged false statements made to Enron employees via
the Internet or video teleconference. Prosecutors allege that as Lay assured employees in
online forum that third-quarter performance was "looking great" and "we will hit our
numbers," he knew Enron in mid-October would announce a massive loss and a $1.2 billion
writedown in shareholder equity. The government also alleges that while Lay told analysts in
a conference call days after the negative earnings announcement that he was disclosing all the
bad news he had found, he held back information on dire problems.
7.Securities fraud, against Skilling. Stems from quarterly and annual reports filed with
theNational Stock Exchange .

8.Prosecutors allege Skilling knew those reports were intentionally misleading about Enron's
revenues, earnings and business operations because accounting schemes hid the true picture.

9.Securities fraud, against Skilling. Allege Skilling omitted bad news or lied when he said
Enron's revenues from energy trading in California were small while touting Enron's
performance and financial health to analysts in several conference calls and an analyst
conference.

10.Securities fraud, against Lay. Allege Lay misled a credit rating agency representative days
before Enron announced massive quarterly losses, saying Enron's books had been scrubbed
when he knew otherwise. Also allege that on three subsequent conference calls with analysts
after the losses were announced that Lay minimized their impact and lied, claiming Enron
wasn't hiding anything when he knew the company's financial health was worse than
disclosed.

11.False statements to auditors, against Skilling.

Alleges he signed letters to auditors at Arthur Andersen LLP that were misleading about the
veracity of Enron's annual financial statements.

12.False statements to auditors, against Skilling.

Alleges he signed letters to auditors that were misleading about the veracity of Enron's
quarterly financial statements for the first three quarters of 2000 and the first quarter of 2001.

13.Insider trading, against Skilling. Alleges Skilling sold $62.6 million in stock when he
knew Enron shares were inflated by internal efforts to hide the company's true financial
condition. The counts pertain to nine trades about a month after he resigned from Enron.

14.bank fraud and making false statements to banks, against Lay, pertain to his personal
banking. The charges allege he obtained $75 million in loans from three banks and then
reneged on an agreement with the lenders that he wouldn't use the money to carry or buy
Enron stock on margin.