Wednesday, August 22, 2018




WHEREFORE, plaintiffs and the plaintiff class demand a jury trial and judgment and damages against the Defendants, jointly, severally, on the basis of market share liability, and/or in the alternative, as follows:(1)For an order certifying the plaintiff class alleged herein;

(2)For an accounting;

(3)For the appointment of an independent historic commission;

(4)For the imposition of a constructive trust;

(5)For restitution of the value of their ancestors' slave labor;

(6)For restitution of the value of their unjust enrichment based upon slave labor;

(7)For disgorgement of illicit profits;

(8)For compensatory damages in an amount to be determined by trial together with interest;

(9)For exemplary or punitive damages in an amount to be determined at trial;

(10)For attorneys' fees;

(11)For the cost of this action; and

(12)Such other and further relief justice so requires.


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