PRAYER FOR RELIEF
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.
