SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK

AMERICAN INTERNATIONAL GROUP,
INC., AMERICAN GENERAL LIFE
INSURANCE COMPANY, AIG
SECURITIES LENDING CORP., THE
UNITED STATES LIFE INSURANCE
COMPANY IN THE CITY OF NEW YORK,
and THE VARIABLE ANNUITY LIFE
INSURANCE COMPANY,
Plaintiffs,

-against-

MAIDEN LANE II LLC,
Defendant.

excerpt:

Plaintiffs American International Group, Inc., American General Life Insurance
Company, AIG Securities Lending Corp., The United States Life Insurance Company in the City
of New York, and The Variable Annuity Life Insurance Company, by their attorneys, Quinn
Emanuel Urquhart & Sullivan, LLP, for their Complaint against Maiden Lane II LLC allege as
follows:

NATURE OF ACTION

1. This is an action by Plaintiff American International Group, Inc. and its named
affiliates (collectively, “AIG” or Plaintiffs) seeking a declaration from the Court as to the proper
interpretation of a contract between AIG and Defendant Maiden Lane II (“Maiden Lane II” or
“ML II”). Plaintiffs do not seek monetary damages.

2. AIG brings this action to eliminate damaging uncertainty recently and
unjustifiably created by or on behalf of Maiden Lane II concerning Plaintiffs’ ownership of
billions of dollars of fraud and other tort claims that exist against numerous financial institutions
that made material misrepresentations and omissions in securitizing and marketing to AIG
residential mortgage-backed securities (“RMBS”) between 2005 and 2007.

3. The financial institutions that created and/or sold the RMBS provided offering
materials that assured AIG that each mortgage loan underlying the RMBS met certain quality
standards. In reality, the financial institutions, driven by a single-minded desire to increase their
share of the lucrative RMBS market and the considerable fees generated by it, abandoned the
stated underwriting guidelines, ignored the represented credit quality metrics, and packed the
RMBS with thousands of defective mortgages. In 2008, when the defective loans experienced
unprecedented rates of delinquency, default, and foreclosure, the performance and value of the
RMBS plummeted, causing AIG and its subsidiaries great harm.

[…]

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