GENERAL DESCRIPTIONS APPLICABLE TO ALL PLAINTIFFS
93. Plaintiffs are presently consumers of defendants. Due to unconscionable, fraudulent and deceptive public communications made by defendants, plaintiffs suffered the harm of being misled, confused, and deceived about the roles the defendants played in the enslavement of African people. Defendants are able to benefit from these communications by continuing business relationships with plaintiff customers and earning profits from these communications by continuing business relationships with plaintiff customers and earning profits they had told the truth about their connection to slavery.
94. Plaintiffs have suffered the harm of being unconscionably denied the benefits of a competitive market for the goods and services they purchase from defendants. Such products and services are produced today through the unconscionable and unfair trade act and practice of investing assets earned from the forced, uncompensated labor of enslaved people.
95. Plaintiffs have suffered segregation, lost opportunity, diminished self-worth and value, loss of property rights, loss of derivative property rights, and psychological harm from having witnessed the degradation of their ancestors and relatives.
96. Plaintiff C. Doe and other formerly-enslaved plaintiff class members experienced physical abuse, coercion, involuntary confinement, and severe emotional distress and the failure to be paid for his labor. His harm continues to this day based upon the deprivation of job opportunities, psychic harm, inability to inherit his father's and grandfather's wealth and other harms. Plaintiffs, formerly enslaved, have been directly affected by slavery.
97. Plaintiff African-American slave descendents have suffered, grieved, and were otherwise significantly effected by their ancestors who were unpaid for their labor and by those who were forced to endure by seeking out a meager existence as sharecroppers, peons or even slaves to support their families.
98. All plaintiffs suffered the harm of separate, but not equal, schools often characterized by torn books, dilapidated buildings and insufficient funding. Plaintiffs suffered lost opportunity by not being able to attend the universities that contemporary white students could attend.
99. Plaintiffs suffered by not being able to eat in the same restaurants or go to the same hotels, motels or lodging places as whites.
100. Plaintiffs were denied the economic wealth of their ancestors' labor.
101. They have a derivative and inherited property right in their ancestors' lost pay, and this right has never been rescinded, voided, altered or satisfied.
102. Plaintiffs' harm is not limited to the past, but continues on a daily basis. They still endure daily indignities from the legacy of slavery, including, but not limited to, racial profiling, racial slurs, and improper and hurtful assumptions regarding their overall status. Plaintiffs are also likely to encounter future harm, as they are more likely to have a shorter life expectancy; more likely go to jail; and are more likely to be murdered, than their white counterparts.
