60. Plaintiffs and the plaintiff class are formerly enslaved African-Americans and descendants of formerly enslaved Africans.

Deadria Farmer-Paellmann - Class Representative

61. Plaintiff DEADRIA FARMER-PAELLMANN, is a New York resident and lead plaintiff in these consolidated actions, submits this complaint on behalf of all Africans enslaved in the United States, and to honor the memory of the many pioneers in the struggle for slavery reparations. Of particular note is the pioneer Queen Mother Audley E. Moore whose legacy of justice continues through the work of Queen Mother Dr. Delois N. Blakely, Community and Honorary Mayor of Harlem, New York.

62. Queen Mother Audley Moore was born on XX/XX/1898, in New Iberia, Louisiana. Her grandmother, Nora Henry, was born into slavery, the daughter of an African woman who was raped by her slave master who was a doctor. Queen Mother Moore devoted her life to active struggle on behalf of all people of African descent. She was recognized for having organized on many fronts, from the great influenza epidemic of 1918 in Muscle Shoals, Alabama, where she worked as a volunteer nurse, to the United Nations, where she presented petitions in the 1950's charging genocide and demanding reparations to descendents of former slaves. She was a life member of the Universal Negro Improvement Association (UNIA) and the National Moorish Council of Negro Women. She joined Marcus Garvey's UNIA while living in Louisiana. She participated in Garvey's first international convention in New York City, owned stock in the Black Star Line, and came to New York when UNIA launched the Black Star Line's first ship. On May 2, 1997, Queen Mother Moore, a life-long “Warrior Woman,” died at the age of 99.

63. Plaintiff Deadria C. Farmer-Paellmann is a law school graduate and political campaign manager. She is the great-great-granddaughter of Clara and Abel Hinds, Africans who were enslaved on a South Carolina sea island rice plantation. On the eve of the Civil War, Clara and Abel Hinds ran-away from their slave master. For two weeks they hid in swamps as they crept toward freedom. They later settled in Georgetown, South Carolina where three generations of their progeny were born including Farmer-Paellmann's: great-grandmother, Alice Hinds-Capers: grandfather, Willie Capers; mother, Wilhelmina Capers-Farmer; and her maternal aunt Rosa Capers-Jones. Farmer-Paellmann is a pioneer in the effort to uncover the connection between slavery and existing corporations and private estates. It is due to her groundbreaking research and public education efforts on the complicity of corporations in slavery that these lawsuits are possible. Many of the defendants in these consolidated actions were initially contacted by Farmer-Paellmann with requests for apologies and demands for restitution to be paid into a trust fund to benefit the 35 million descendants of enslaved Africans.

Mary Lacey Madison - Class Representative

64. Plaintiff MARY LACEY MADISON is a New York resident, born in Norfolk, Virginia in 1910, to James and Martha Doles Lacey whose ancestors were slaves in the agricultural industry in Virginia and North Carolina. Mary was told that her maternal grandfather was, as a child, given to his last owner as a Christmas present. Mary's paternal great aunt, Elizabeth Browning, used to tell Mary how at the end of slavery she went into the kitchen of her former mistress, mixed some yogurt and dared her “to slap me in the face,” which was what the mistress had regularly done during slavery.

65. As a teenager, Mary left Norfolk for New York City, where, although not completing high school, she began to work for the City as a hospital attendant, eventually achieving the position of Licensed Practical Nurse, who was delegated the responsibilities of a Registered Nurse. She has spent her adult life as an activist fighting for the betterment of her community.

Andre Carrington - Class Representative

66. Plaintiff ANDRE CARRINGTON is a Bronx, New York resident whose ancestors on both his mother and father's side, were slaves in North Carolina, and upon information and belief, were involved in the cotton and tobacco industries. Andre Carrington is 46 years old. He is a surface line dispatcher for the New York Metropolitan Transit Authority. His great-great grandfather, Charlie Wright Williams was a slave in Dublin County, North Carolina. The town is Wallace North Carolina. Charlie Wright was a slave until the age of 12. He was married to Phyllis Murry Williams. Charlie's mother, Martha Katherine was born a slave in 1835 and married Charlie's father, a slave named James Williams. Andre first became interested in this history when reading the tombstones at the family's cemetery in Wallace. He then researched birth and death records at the County Clerk's office. This research has been conducted over a number of years.

Richard E. Barber, Sr. - Class Representative

67. Plaintiff Richard E. Barber, Sr. is a New Jersey resident whose ancestors were enslaved in the agricultural industry and other industries. Plaintiff is a resident of Somerset, New Jersey. Mr. Barber is the grandson and great-grandson of enslaved Africans. His great-grandfather, Peter Barber, was born into slavery in 1820 in Trenton, North Carolina. His grandfather, William Mae Barber, was likewise born into slavery in 1840, along with his three sisters, Anna, Hula, and Julia and his two brothers, John and Seth. Peter Barber was a farmer and William Mae, was a master carpenter.

William Mae Barber built many of the stately homes that still stand along Route 58 South in Trenton, North Carolina. The plaintiff, Richard Barber, recalls delivering newspapers, cutting lawns and raking leaves of many of the residents of the homes his grandfather built. Richard Barber's father, John, was a sharecropper. Richard Barber recalls stories about slavery told to him by his great-Aunt Anna.

Hannah Jane Hurdle-Toomey - Class Representative

68. Plaintiff Ms. Hannah Jane Hurdle-Toomey lives in Belleview, Illinois, She is the youngest surviving daughter of Andrew Jackson Hurdle.

69. Andrew Jackson Hurdle was born on XX/XX/45 and died on 11/27/1935. He had 25 children, 3 of whom are still alive. Mr. Jackson Hurdle was 10 years old when he was sold away from his family and brought to Dangerfield, Texas as a playmate for T. H. Turner's son, James, who had a severe stutter. Hurdle spent some of his time using tiny pebbles to correct James' speech. In exchange, the family allowed Hurdle to read and write. Being a house slave, Hurdle did not suffer the beatings wielded upon those forced to work in the fields. Yet, this changed when he came face to face with an overseer determined to whip him. On that fateful day, the 16 year old became a runaway slave.

70. After spending days hiding in swamps, hungry for food and freedom, he happened upon a Union Army camp. There he was given a blue coat, food and a job tending the soldiers' horses until the civil war was over. After he returned to the community, he fled to find his sweetheart, Viney Sanders, whom he married.

71. Hurdle had 17 children with Sanders. After her death, he married Jessie Catherine Bailey. At the time of their marriage, she was 25, Hurdle was 65. Through this union, he had eight more children. Described as a “God-fearing” man, Hurdle spent the rest of his life supporting his family. He worked several jobs and was able to send all of his children to college. He purchased 500 acres of land, more that 10 times the 40 acres promised by the government but never provided, which was enough to divide among his offspring.

72.Ms. Hurdle-Toomey is an ordained minister and former African Missionary.

Marcelle Besteda Porter - Class Representative

73.Plaintiff Marcelle Besteda Porter is a native 72-year Chicagoan whose ancestors were enslaved. She is a registered nurse and was a representative at the Annual Conference of the United Nations Human Rights Commission in Geneva Switzerland, and at the World Conference Against Racism in Durban in September 2001. She is an advocate of reparations at home and abroad.

Julie Mae Wyatt-Kervin - Class Representative

74.Plaintiff Julie Mae Wyatt-Kervin was born on XX/XX/1903. She is the daughter of enslaved Africans, Jake Wyatt and Louise Wyatt. Both Jake and Louise Wyatt were slaves in Wharton County, as were their parents before them. In or about 1860, Wharton County had the distinction of having one of the highest slave populations in all of Texas. When Ms. Wyatt-Kervin's parents were freed from slavery on June 19, 1865, they became sharecroppers.

Emma Marie Clark - Class Representative

75. EMMA MARIE CLARK is a resident of Texas. On information and belief, she was enslaved in the agriculture industry in Louisiana from about 1927 through 1934. She does not know her precise age, but has been told she was born in Louisiana between 1904 and 1908. She was one of 10 children born to Mary Elizabeth Clark a Choctaw/Comanche Indian and William M. Clark, an African-American. Her mother took her and abandoned the other children and husband, who had become abusive. They sought refuge in the woods for several years. They lived with a family with a farm where they worked in exchange for housing and food. After an altercation with a member of the family, her mother abandoned her and the family. After the husband of that family died, the wife agreed to let her stay with a couple that operated a nearby dairy farm. That couple told her that they bought her and she was their slave. She was about 20-years-old at that time. Along with two other Black young women, she was forced to work 16 hours days in the dairy, doing housework, and looking after guests in a boardinghouse on the farm. She was never paid for her services and was severely beaten if the couple was not satisfied with her work. She was forced to have sexual relations with men. As a result of this, she got pregnant on two occasions and gave birth to two sons. One of those sons was forced to live amongst the farm animals while she worked during the day. The other son was taken from her at birth. A Dallas couple stayed at the boardinghouse. The wife wanted to give her a tip, but she refused, explaining that she does not get paid for her services. Shortly after that day, the FBI visited the farm to do an investigation and found her and the two other women being held as slaves. They were later released from the farm. She was subsequently reunited with her son who was taken from her at birth. Ms. Lewis in her own words describes her life as a slave:

when I got to the Darby's, Maggie or Old Miss they called her, hit me with a pipe and pulled out her pearl handled gun. She took me out behind the barn and showed me some ground. She said if I ever tried to run away from her she would find me, kill me and bury me there. I was about 20 years old. Maggie was a 375 pound white woman. She wore white linen princess style dresses starched so stiff a fly would break his neck landing on them. Everybody was afraid of her.Maggie took me into the den. She picked up the phone like she was talking to somebody. She held up a piece of paper that I couldn't read and said I was her new slave. She said that the piece of paper said she owned me. She had two other girls she held for slaves too--Lillie Mae and Maggie Lee. All of us were forced to run their family dairy, boarding house and do household chores. Lillie Mae had been a nurse for Ole Miss' niece and came to live there when the child's father died. Her mother reclaimed the child, after stories of abuse of the child reached her. But Lillie Mae, by then, was convinced that she too was a slave.

The Darby's had three children, James, Lily and Grace. Ms. Darby built a Methodist church and made her son James the pastor. She was some kind of missionary and traveled all over the States for conferences. I saw Bruce and Maggie put on the black clothes of the big leaders of the local KKK. Most others wore white, when they met out at the farm. Just top folks wore black. They stored the coal oil and containers of tar for their activities out in the barn. We stayed in our quarters.

We weren't allowed to go to our church. Ole Miss took us to her church so we wouldn't get wrong ideas from other Negroes. She had a special thing on her big car that held the car door open, but wouldn't let us get out. She could see us in the car parked right in front of the church. She bragged to everybody that she took her Negroes to church. We couldn't hear or see nothing, but it was a break from the farm.

Ole Miss dressed us in mattress ticking striped coveralls with the arms cut out and the legs cut above our knees. We had to keep our hair tied up in rags and had flour sack cotton gowns to sleep in. We had no shoes, but had rubber boots to wear in the winter. I would put my feet into the boots and then dip them in a pan of hot water to warm up my feet. By the time I reached the barn, there would be ice between my toes. Maggie said it took too long to comb our hair, so except for one time when she cut four strips across the top of our heads with the clippers, like railroad tracks, we never combed our hair. My long hair got more matted with each passing year.

When I was set free, a lady broke three forks trying to comb out my hair.

Bill Gene McGee - Class Representative

76. Mr. Billy Gene McGee resides in Dallas, Texas and is the guardian ad litem of his aunt, Ms. Julie Mae Wyatt-Kervin and brings this case as her representative.

Ina Bell Daniels Hurdle McGee - Class Representative

77. Plaintiff Ina Bell Daniels Hurdle McGee is a 69 year-old retired school teacher, who taught in the public school system in Dallas for 43 years. She resides in Dallas, Texas and is the great grand-daughter of Andrew Jackson Hurdle, an enslaved African. Her grandmother's name is Laura Elizabeth Hurdle and her father's name is Clarence Hurdle. See, the description of Andrew Jackson Hurdle provided under Hannah Jane Hurdle-Toomey.

C. Doe - Class Representative

89. ””C. DOE” is a resident of Louisiana. Upon information and belief, he was enslaved through the 1960's. His grandfather and father were also former slaves. His seven living children are former slaves. He never completed beyond a third grade education because he was subjected to forced labor without compensation. He and his family were forced to live on the slave quarters of a plantation that grew numerous agricultural crops such as cotton and rice. His trips with the master took him to drop off bales of cotton, next to train tracks that ran through Mississippi, and/or Louisiana. He dropped bales of cotton off at the cotton mills. The slave hut had no electricity and no running water. C. Doe, nor his children, were ever paid for their labor. In fact one of C. Doe daughters tells of the family being handed to slop bucket of left-over dinner scraps from the master's table. C. Doe experienced the horrors of slave life first-hand including, but not limited to, the murder of a relative by the slave master; physical beatings and physical intimidation purposely designed to prevent him from running away or reporting the criminal incidents to society C. Doe did not run away as he was afraid of the master beating on him.

90. Upon information and belief, during a portion of the time that C. Doe was enslaved namely in or about the 1920's-1930's some/or all of Defendants corporate entities doing business in Mississippi or Louisiana had reason to know of the construction of forms of slavery yet failed to take steps to eliminate same, while they continue to inure benefits form the illegal, but sanctioned system of servitude Post-Emancipation.

Class Representatives

C. Doe Jr., M.L. Doe, E.H. Doe, A.L. Doe, A. Doe, I. Doe, C.W. Doe.

91. C. Doe, Jr., M.L. Doe, E.H. Doe, A.L. Doe, A. Doe, I.Doe, C.W. Doe are all children of C. Doe, whose names are being withheld for security and safety reasons. All are residents of Louisiana, and all were formally enslaved. All endured the tragedy of slavery in that they were each forced to work for no pay. They were all intimidated through violence and through threats of same. One of the family members was repeatedly raped by her slave master resulting in permanent injury. They were slaves for the benefit of the cotton industry, sugar industry and rice industry to name of few. There father and grandfather were slaves and they were born into slavery.

Antoinette Harrell Miller - Class Representative

92. Antoinette Harrell Miller was born in New Orleans, Louisiana on XX/XX/1960. She is the daughter of Ms. Isabel Harrell Cook. She is the descendant of former slave, Carrie Richardson (great-great-great-great grandmother) and Thomas Richardson, her son. She spent ten years doing her genealogical research linking or tracing her ancestors to their former slave masters. She has lived in New Orleans for the past twenty-seven years.