123. In the state of Louisiana, slave labor was used to pick cotton, cut sugar cane, and perform countless more free labor. Even family units of the enslaved were not respected by the slavist society. Husbands, wives and children were routinely sold without regard to breaking up the family. Mothers crying for their children fell on uncaring ears.

124. Louisiana was formally identified as a slave state during the time of slavery in the United States. The City of New Orleans was a main port of importation of enslaved Africans and was a center of slavery business for named and unnamed defendants herein because at this filing many defendant corporations and companies that profited from doing slavery related business in New Orleans and throughout the State of Louisiana are unknown. According to the Civil Code of Louisiana:

A slave is one who is in the power of a master to whom he belongs. The master may sell him, dispose of his person, his industry, and his labor. He can do nothing, possess nothing, nor acquire anything, but what must belong to his master.