218. 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.

219. Defendants knew or should have known of the existence of corporate records that indicate their profiting from slave labor. Plaintiffs and the public have demanded that the defendants reveal their complete corporate records regarding same and that a just and fair accounting be made for profits derived from the slave trade.

220. There is no adequate remedy at law for the harm arising from the failure to provide corporate documentation related to slavery.

221. The tangible production of this documentation is essential to the victim classes:

a)to heal the continuing psychic harm associated with slavery;

b)to trace ancestral records;

c)to provide a public and historical record of the violent force necessary to maintain a hierarchy to support slavery

d)to provide evidence of past and subsequently established discrimination;

e)to provide a historical record of the economic benefits that accrued to the defendant private institutions as a result of slavery to more fully describe and document the connection between the institution of slavery and racist/discriminatory policies that still exist today.

f)to assist in stemming racial discrimination through the knowledge of the role slavery played in its root causes.

222. There is a fiduciary relationship that arose between the litigant classes and defendants by virtue of defendants' superior position, maintenance of those positions and, their holding in constructive trust, the proceeds of the unpaid labor of the plaintiffs and/or their ancestors.

223. Defendants have failed to provide said records and have failed to comply with plaintiffs' demands for same.

WHEREFORE, plaintiffs demand judgment requiring: (a) defendants make a full disclosure of all of their corporate records that reveal any evidence of slave labor or their profiting from same; (2) seeking the appointment of an independent historic commission to serve as a depository for corporate records related to slavery and; (3) directing defendants to account to plaintiffs for any profits they derived from slavery.