IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE ELIANA GIL RODRIGUEZ, Individually and On Behalf of All Similarly Situated Stockholders,

Plaintiff, v.

ALLAN MAYER, DAVID DANZIGER, ROBERT GREENE, ALBERTO CHEHEBAR, MARV INGLEMAN, WILLIAM MAUER, DAVID GLAZEK, THOMAS J. SULLIVAN, LAURA A. LEE, JOSEPH MAGNACCA, COLLEEN B. BROWN, JOHN J. LUTTRELL and STANDARD GENERAL L.P.

Defendants.

C.A. No. 10944-CB PUBLIC VERSION filed: April 29, 2015

VERIFIED CLASS ACTION COMPLAINT Plaintiff, Eliana Gil Rodriguez (Plaintiff), by her attorneys, brings the

following Verified Class Action Complaint (Complaint) individually and on behalf of all stockholders of American Apparel, Inc. (American Apparel or the Company) (the Class), other than Defendants (as defined below) and their affiliates, against American Apparels former board of directors (the Former Directors) and/or officers as of July 9, 2014, and current board of directors (the Board or the Individual Defendants) for breaching their fiduciary duties to the Companys public stockholders. The Complaint further alleges that Standard General L.P. (Standard General,) (collectively, the Former Directors, the Board,

EFiled: Apr 29 2015 04:14PM EDT Transaction ID 57157472

Case No. 10944-CB

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