Fannie Mae-No Politics (FNMA)

[Hvp123]

2. As an alternative measure, Plaintiffs also asked Prof. Mason to evaluate damages
for the junior preferred stock holders based on a restitution theory under which Defendants would disgorge the net benefits they have received under the shareholder contracts, which would be unwound in their entirety. Plaintiffs would receive the present value as of August 2012 (the date of the Net Worth Sweep) of the sums initially paid for shares ("issuer-received cash flows"), and Fannie Mae and Freddie Mac would receive the present value as of the same date of dividends it paid since issuance ("purchaser-received cash flows"). Damages are equal to the issuer-received cash flows minus the purchaser-received cash flows, which amounts to $16.337 billion for owners of the Fannie Preferred prior to the application of prejudgment interest and $26.939 billion after the application of prejudgment interest, and S11.809 billion for owners of the Freddie Preferred prior to the application of prejudgment interest and $20.989 billion after the application of prejudgment interest.
3. Plaintiffs also seek reimbursement of attorneys' fees and expenses. Counsel will
present the Court with an application for attorneys' fees and costs after trial.