VIL.
PLAINTIFFS' ITEMIZATION OF DAMAGES
Plaintiffs claims total damages in the amounts as set forth below:
1. Plaintiffs seek expectancy damages arising from Defendants' breaches as a result of the Net Worth Sweep based on Fannie Mae's and Freddie Mac's realized performance up to the second quarter of 2021 and projected performance thereafter. This method seeks to measure the net present value of future dividends that Fannie Mae and Freddie Mac shareholders would have earned but for the Net Worth Sweep based on Prof. Mason's conservative assumptions. Under this method of expectancy damages, assuming no periodic commitment fee, damages are $10.321billion for owners of the Fannie Mae Preferred, S5.887 billion for owners of the Freddie Mac Preferred, and $11.002 billion for owners of the Freddie Mac Common. In a scenario where the Court determines that a periodic commitment fee would have been imposed, damages are $9.357 billion for owners of the Fannie Mae Preferred, $5.337 billion for owners of the Freddie Preferred, and $9.288 billion for owners of the Freddie Mac Common.'
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