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311. Plaintiffs on behalf of themselves, their ancestors and all other descendants who are similarly situated, re-allege, as if fully set forth, each and every allegation contained in the preceding paragraphs.

312. At all time herein relevant the Defendant directly and through their predecessors had a duty to protect the enslaved Africans from the harms committed against them by the slave traders and others who profited from the enslavement of Africans in the United States.

313. Notwithstanding its duties, the defendant committed one or more of the following negligent conducts: i) failed to stop the transportation of Africans across State lines for purposes of enslavement; ii) failed to release and free enslaved Africans who were entrusted to their care, custody and control; iii) failed to cease and desist from providing finances necessary for continuation of slave trade after it became illegal to engage in such conduct; iv) failed to prohibit the collection of levies, tax and duties from slave traders who transported Africans across internal waters after slavery had been abolished; v) failed to cease and desist from issuing insurance policies for the lives of enslaved Africans to prevent the heinous act of enslavement of fellow human being; vi) failed to protect enslaved Africans who were placed under their care, custody and control from physical torture, assault, battery, humiliations, rape, murder and other horrendous acts, and committed other negligent acts and omissions.

314. As a result of one or more of the above listed wrongful acts and omissions, the Plaintiffs' and their deceased enslaved African ancestors suffered suffer emotional distress and mental anguish.

WHEREFORE, the Plaintiffs pray this Honorable Court to award damages in their favor and against the Defendants in an amount sufficient to satisfy the jurisdiction of this court and grant further relief that is just and equitable in this cause.


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