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Table Of Contents

NATURE OF ACTION
PARTIES
JURISDICTION AND VENUE
BACKGROUND
I. THE MECHANICS OF MORTGAGE SECURITIZATION
ALLEGATIONS
IV. DEFENDANTS’ MATERIAL MISREPRESENTATIONS
A. Defendants’ Offering Materials
D. Defendants’ Misrepresentations Regarding Owner-Occupancy
E. Defendants’ Misrepresentations Regarding Credit Ratings
V. DEFENDANTS’ REPRESENTATIONS TO AIG WERE FALSE
A. Loan-to-Value Ratios Represented by Defendants Were False
B. Combined Loan-to-Value Ratios Represented by Defendants Were False
C. Owner-Occupancy Levels Represented by Defendants Were False
D. Defendants Engineered Inflated Credit Ratings
(1) All Deals Have Suffered Significant Credit Rating Downgrades
E. Defendants Ignored Stated Underwriting Guidelines
(1) Countrywide Ignored Its Underwriting Guidelines
(2) Merrill Ignored Its Underwriting Guidelines
(a) Merrill Seeks To Increase Its Market Share
(3) Bank of America Ignored Its Underwriting Guidelines
VI. THE DEFENDANTS KNEW THEIR REPRESENTATIONS WERE FALSE
A. Countrywide Knew Its Representations Were False
B. Merrill Knew Its Representations Were False
C. Bank of America Knew Its Representations Were False
VII. AIG’S DETRIMENTAL RELIANCE AND RESULTING DAMAGES
(2) The Actual Consolidation of Bank of America and Countrywide
(3) Bank of America is Countrywide’s Successor-in-Interest
B. Tolling of the Securities Act of 1933 Claims
(1) Tolling of 1933 Act Claims Against Countrywide
(2) Tolling of 1933 Act Claims Against Merrill
(1) Countrywide Financial and Countrywide Capital Markets
(2) Merrill Lynch & Co., Inc
PRAYER FOR RELIEF
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AIG Lawsuit

AIG Lawsuit

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Published by: bedhead0 on Apr 03, 2012
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