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 Apparel’s 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 Company’s public stockholders. The Co mplaint further alleg es 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