SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK AIG FINANCIAL PRODUCTS CORP., Plaintiff, -against- No. ICP ASSET MANAGEMENT, LLC, ICP SECURITIES, LLC, INSTITUTIONAL CREDIT PARTNERS, LLC, TRIAXX SUMMONS PRIME CDO 2007-1, LTD., TRIAXX FUNDING HIGH GRADE I, LTD., MOORE, CAPITAL MANAGEMENT, LP, and JOHN DOES 1-10, Defendants. ICP ASSET MANAGEMENT, LLC 445 Park Avenue, 12th Floor ‘New York, NY 10022 ICP SECURITIES, LLC 1120 Avenue of the Americas, Suite 1507 ‘New York, NY 10036 INSTITUTIONAL CREDIT PARTNERS, LLC 360 Madison Avenue, 10" Floor New York, NY 10017 TRIAXX PRIME CDO 2007-1, LTD. c/o Walkers SPV Limited Walker House 87 Mary Street George Town, Grand Cayman KY1-9002 Cayman Islands ‘TRIAXX FUNDING HIGH GRADE I, LTD. Maples Finance Limited PO Box 1093GT Queensgate House South Church Street, Grand Cayman Cayman IslandsMOORE CAPITAL MANAGEMENT, LP 1251 Avenue of the Americas, 53" Floor 4 World Financial Center New York, NY 10020 YOU ARE HEREBY SUMMONED to answer the complaint in this action and to serve a copy of your answer on Plaintiff's attomeys within twenty (20) days after the service of this summons, exclusive of the day of service (or within thirty (30) days after the service is complete if this summons is not personally delivered to you within the State of New York). In case of your failure to appear, judgment will be taken against you by default for the relief demanded in the complaint. Plaintiff designates New York County as the place of trial, The basis of the venue designated is that Defendants do business in or derive substantial revenue from activities carried out in this County. DATED: New York, New York QUINN EMANUEL URQUHART & April 28, 2011 SULLIVAN, LLP 51 Madison Avenue, 22nd Floor New York, New York 10010-1601 Telephone: (212) 849-7000 Fax: (212) 849-7100 jonpickhardt@quinnemanuel.com jefiteybenner@quinnemanuel.com Attorneys for PlaintiffSUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK AIG FINANCIAL PRODUCTS CORP., Plaintiff, -against- ICP ASSET MANAGEMENT, LLC, ICP SECURITIES, LLC, INSTITUTIONAL CREDIT PARTNERS, LLC, TRIAXX PRIME CDO 2007-1, LTD., TRIAXX No. FUNDING HIGH GRADE I, LTD., MOORE CAPITAL MANAGEMENT, LP, Gury Trial Demanded) and JOHN DOES 1-10, Defendants. COMPLAINT Plaintiff AIG Financial Products Corp. (“AIG-FP” or “Plaintiff"), by it attorneys, Quinn Emanuel Urquhart & Sullivan, LLP, for its Complaint against (i) ICP Asset ‘Management, LLC (“ICP”), ICP Securities, LLC (“ICPS”), Institutional Credit Partners, LLC alk/a or d/b/a ICP, LLC or ICP Capital, LLC (“ICP Holdeo”), (collectively, the “ICP Defendants”), and (ji) Moore Capital Management, LP (“Moore Capital”), Triaxx Prime CDO 2007-1, Ltd. (“Triaxx-3”); Triaxx Funding High Grade I, Ltd. (“Triaxx Funding”), and John Does 1-10 (collectively the “Unjust Enrichment Defendants”), alleges as follows upon information and beli NATURE OF THE ACTION 1. This action arises from the wrongful self-dealing of ICP, an investment advisory firm, and certain of its affiliated corporate entities, that victimized American Intemational Group, and ultimately the American taxpayers, through its deceitful and