The 109-page complaint alleges that Lampert caused more than $2 billion of assets to be transferred to himself and Sears' other shareholders and beyond the reach of Sears' creditors in the years leading up to the retailer's bankruptcy. It asks that the transactions be ruled fraudulent transfers and says creditors should be compensated. "Had defendants not taken these illegal and improper actions, Sears would have had billions of dollars more to pay its third-party creditors today and would not have endured the amount of disruption, expense, and job losses resulting from its recent bankruptcy filing," the lawsuit alleges. The complaint points to five allegedly improper asset transfers, beginning in 2011 with Orchard Supply Hardware, Sears Hometown and Outlet Stores, and Sears Canada. Other transactions involved Lands' End and Seritage, the real estate investment trust created in 2015.