EFiled: Apr 29 2015 04:14PM EDT

Transaction ID 57157472
Case No. 10944-CB

IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE

ELIANA GIL RODRIGUEZ,
Individually and On Behalf of All
Similarly Situated Stockholders,

C.A. No. 10944-CB

Plaintiff,

PUBLIC VERSION filed:

April 29, 2015

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.

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,