GENERAL DESCRIPTION OF DEFENDANTS

125. Defendant FLEETBOSTON is a Delaware corporation with its principal place of business located at 100 Federal Street, Boston, Massachusetts 02110. It does continuous and systematic business in all the jurisdictions named in the lawsuits. FLEETBOSTON is the successor in interest to Providence Bank which was founded by Rhode Island businessman John Brown. Brown owned ships that embarked on several slaving voyages and Brown was prosecuted in federal court for participating in the international slave trade after it had become illegal under federal law. Upon information and belief, Providence Bank lent substantial sums to Brown, thus financing and profiting from the founder's illegal slave trading.

126. Upon information and belief, FLEETBOSTON, through its predecessor bank, also collected custom fees due from ships transporting slaves, thus, further profiting from the slave trade. Upon information and belief, FLEETBOSTON, through its predecessor bank, also collected custom duties and fees due on ships transporting enslaved Africans in violation of Rhode Island and federal law, thus profiting from the illegal slave trade.

127. Upon information and belief, over 41,369 Africans were enslaved during the time that FLEETBOSTON, through its predecessor bank, collected customs duties and fees on ships engaged in the illegal slave trade. Providing loans to slave traders to engage in illegal slave trading, and the regular collection of duties and fees, earned in the illegal enslavement of Africans constituted aiding and abetting in the illegal slave trade. Such business practices were unlawful, and unfair business.

128. Upon information and belief, FLEETBOSTON was approached by various members of the general public to verify its historical connection to slavery. Its responses were either evasive, unclear, or denials, thereby constituting fraudulent business acts. Defendant withheld information or made misleading statements regarding their participation in and profiting from slavery.

129. FLEETBOSTON made various misleading statements to the Press from March 2000 to February 2002, attempting to disassociate its predecessor company from its current company.

130. Defendant FLEETBOSTON engaged in a self-concealed business enterprise so that the plaintiff class and/or plaintiffs' ancestors would not be aware of the existence of this enterprise without a specific disclosure by the plaintiffs as to the nature of participation and profit the defendant derived from slavery.

131. Defendant CSX is a Virginia corporation with its principal place of business located at 901 E. Cary Street, Richmond, VA 23219. It is a successor-in-interest to numerous predecessor railroad lines that were constructed or run, at least in part, by slave labor. Upon information and belief, it does continuous and systematic business in New York, Illinois, California, Texas, and Louisiana.

132. Defendant CSX withheld information or made a misleading statement to the Press regarding their participation in and profiting from slavery.

133. Defendant CSX engaged in a self-concealed business enterprise as the plaintiff class and/or plaintiff ancestors would not be aware of the existence of this enterprise without a specific disclosure by the plaintiffs as to the nature and level of participation and profit the defendant derived from slavery.

134. Defendant AETNA INC. (“AETNA”) is a corporation with its principal place of business located at 151 Farmington Avenue, Hartford, Connecticut 06156. Upon information and belief, AETNA's predecessor in interest, actually insured slave owners against the loss of their human chattel. AETNA knew the horrors of slave life as is evident in a rider through which the company declined to pay the premiums for slaves who were lynched or worked to death or who committed suicide. Additionally, AETNA insured enslaved Africans who worked in the agricultural industry of which many plaintiffs and plaintiffs' ancestors were enslaved. The writing of such policies constituted unfair business acts designed to help finance the immoral practices of domestic slavery as set forth by the cruel and inhumane Slave Codes created and enforced by states. AETNA, therefore, unjustly profited from the institution of slavery. Upon information and belief, it does continuous and systematic business in New York, Illinois, and New Jersey.

135. Defendant AETNA withheld information or made a misleading statement regarding their participation in and profiting from slavery.

136. Defendant AETNA engaged in a self-concealed business enterprise as the plaintiff class and/or plaintiff ancestors would not be aware of the existence of this enterprise without a specific disclosure by the plaintiffs as to the nature and level of participation and profit the defendant derived from slavery.

137. Defendant BROWN BROTHERS HARRIMAN & COMPANY (“BROWN BROTHERS HARRIMAN”) is a corporation with its principal place of business located at 59 Wall Street, New York, New York. It is the successor corporation to Brown Brothers & Co. The bank founders, James and William Brown, built their merchant bank by lending to Southern planters, brokering slave-grown cotton and acting as a clearinghouse for the South's complex financial system. The firm earned commissions arranging cotton shipments from Southern ports to mills in New England and Britain. It also loaned millions directly to planters, merchants and cotton brokers throughout the South. Company records also reveal that BROWN BROTHERS loaned to plantation owners who told the firm that they needed the cash to buy slaves. When those planters or their banks failed, it used its local agents to run repossessed plantations and manage the enslaved Africans working there.

138. Additionally, BROWN BROTHERS' enrichment from slave labor is further evidenced by Louisiana court records dating back to the 1840's that reveal the firm's ownership of at least two cotton plantations totaling 4,614 acres and the plantations' 346 slaves, each named in court records. Brown Brothers & Company merged with two other firms in 1931 to create BROWN BROTHERS HARRIMAN.

139. Additionally, Brown Brothers built their merchant bank by lending to Louisiana planters, brokering slave grown cotton, sugar cane and acting as a clearinghouse for the New Orleans based slavery business. Company records also reveal that Brown Brothers loaned money to New Orleans slaveholders who told the firm that they needed the cash to buy slaves. When those banks failed, Brown Brothers used New Orleans courts to seize slaveholders' slaves and then managed the slaves from slave owners who defaulted on debts. It does continuous and systematic business in New York.

140. Defendant BROWN BROTHERS HARRIMAN withheld information or made a misleading statement based upon press reports after the filing, trying to disassociate defendant from its predecessor's business.

141. Defendant BROWN BROTHERS HARRIMAN engaged in a self-concealed business enterprise as the plaintiff class and/or plaintiff ancestors would not be aware of the existence of this enterprise without a specific disclosure by the plaintiffs as to the nature and level of participation and profit the defendant derived from slavery.

142. Defendant NEW YORK LIFE INSURANCE COMPANY (“NEW YORK LIFE”) is a corporation with its general office located at 2 New York Plaza, 7th Floor, New York, New York 10004. NEW YORK LIFE's predecessor-in-interest, Nautilus Insurance, earned premiums from its sale of life insurance to slave owners. One third of its first 1,000 policies were to insure the lives of slaves. It insured slaves in the agricultural industry of which some of the plaintiffs' ancestors were a part. The writing of such policies also constitute unfair business acts designed to help finance the immoral practices of domestic slavery as set forth by the cruel and inhumane Slave Codes created and enforced by states. It does continuous and systematic business in New York, New Jersey, Texas, Illinois, and Louisiana.

143. Defendant NEW YORK LIFE withheld information or made misleading statements regarding their participation in and profiting from slavery.

144. Defendant NY LIFE withheld information or it did not report its slavery policies until it was legally required to do so under California law.

145. Defendant NEW YORK LIFE engaged in a self-concealed business enterprise as the plaintiff class and/or plaintiff ancestors would not be aware of the existence of this enterprise without a specific disclosure by the plaintiffs as to the nature and level of participation and profit the defendant derived from slavery.

146. Moreover, NEW YORK LIFE's predecessor company Nautilus, issued polices on the lives of slaves some 20 years after slavery had been abolished in New York.

147. Defendant NORFOLK SOUTHERN is a corporation with its principal place of business located at Three Commercial Place, Norfolk Virginia 23410-9227. It does continuous and systematic business in many states, including New Jersey. It is a successor-in-interest to numerous railroad lines that were constructed or run, in part, by slave labor.

148. Defendant LEHMAN BROTHERS is a corporation with its principal business at c/o King and Spalding, 1185 Avenue of the Americas, 30th Floor, New York, NY 10036. LEHMAN BROTHERS founder Henry Lehman began as a peddler in 1844, but shortly thereafter when his two brothers, Mayer and Emanuel joined him, they soon grew rich as middlemen in the slave-grown cotton trade. After Henry Lehman's death in 1856 and after the war, the remaining two brothers moved north and continued trading in cotton, oil, sugar and coffee, and then took a seat on the New York Stock Exchange in 1887. It does continuous and systematic business in New York, Illinois, Texas and New Jersey.

149. Defendant SOCIETY OF LLYOD'S, aka LLOYD'S OF LONDON, is an underwriting company with its principal places of business located at 1 Lime Street, London EC3M 7HA and at 590 5th Avenue, 17th Floor, New York, New York 10036. It was involved in insuring of ships utilized for the Trans-Atlantic slave trade. The writing of such policies was an unfair business designed to help finance the international slave trade, to provide states with human chattel who were subjected to the immoral practices of slavery as set forth by the cruel and inhumane Slave Codes created and enforced by states. LLOYD'S does systematic and continuous business in New York.

150. Defendant LLOYD'S engaged in a self-concealed business enterprise as the plaintiff class and/or plaintiffs' ancestors would not be aware of the existence of this enterprise without a specific disclosure by the plaintiffs as to the nature and level of participation and profit the defendant derived from slavery.

151. LLOYD'S withheld information in that failed to report any documents to the California registry as required, claiming a fire destroyed its documents.

152. Defendant UNION PACIFIC is a corporation with its principal place of business located at 1416 Dodge Street, Omaha, Nebraska 68179. It is a successor-in-interest to numerous predecessor railroad lines that were constructed or run in part by slave labor. It does continuous and systematic business in California, Texas, Illinois and Louisiana.

153. In or about, defendant UNION PACIFIC withheld information or made a misleading statement regarding their participation in profiting from slavery.

154. Defendant UNION PACIFIC engaged in a self-concealed business enterprise as the plaintiff class and/or plaintiffs' ancestors would not be aware of the existence of this enterprise without a specific disclosure by the plaintiffs as to the nature and level of participation and profit the defendant derived from slavery.

155. Defendant JP MORGAN CHASE is a corporation with its principal place of business at One Chase Manhattan Plaza, New York, New York. Two of its predecessor banks that merged to become JP Morgan Chase were behind a consortium to raise money to insure slavery. It does continuous and systematic business in New York, Texas and New Jersey.

156. Defendant JP MORGAN CHASE withheld information or made a misleading statement regarding their participation in and profiting from slavery.

157. Defendant JP MORGAN CHASE engaged in a self-concealed business enterprise as the plaintiff class and/or plaintiffs' ancestors would not be aware of the existence of this enterprise without a specific disclosure by the plaintiffs as to the nature and level of participation and profit the defendant derived from slavery.

158. Defendant JP MORGAN CHASE attempted to deny its association with slavery in the Press in or about January 2003 after other evidence, including a circular shows otherwise.

159. Moreover, JP MORGAN operated with the clear intent of taking in slave-related business after the abolition of slavery in the North. Manhattan Life, one of JP MORGAN's predecessors quoted a speech by a former President discussing what he believed to be one of the first group policies ever issued by an American insurance company that insured indentured workers. Id.

160. Defendant WESTPOINT STEVENS is a corporation with its principal place of business located at 1185 Avenue of Americas, New York, New York 10036. It is a successor-in-interest to Pepperell Manufacturing which utilized cotton from Southern planters farmed by enslaved Africans. Such use of enslaved Africans was an unfair business practice set forth by the cruel and inhumane Slave Codes created and enforced by states. Planters in turn purchased the finished product, a cheap, coarse cloth called “Negro cloth,” to clothe their human chattel. The fabric served as a reminder to enslaved Africans of their inferior status in life. It does continuous and systematic business in New York and Texas. Upon information and belief, it does continuous and systematic business in the other jurisdictions named in the lawsuit through their distribution of products to these jurisdictions.

161. Defendant, R.J. REYNOLDS TOBACCO COMPANY is a corporation with its principal place of business located at 401 North Main Street, Winston-Salem, North Carolina 27102. Upon information and belief, it does continuous and systematic business in all jurisdictions in which these lawsuits have been filed. R.J. REYNOLDS TOBACCO COMPANY is the beneficiary of assets acquired through the forced uncompensated labors of enslaved African-Americans. Such use of enslaved Africans was an unfair business practice set forth by the cruel and inhumane Slave Codes created and enforced by states. Hardin Reynolds, father of R.J. Reynolds owned and operated a tobacco factory at the plantation called “Rock Spring Plantation” - the present day Reynolds Homestead in Critz, Virginia. Just before the Civil War, Hardin Reynolds owned at least 88 slaves who provided labor on the plantation, including in the Rock Spring tobacco factory. Operating information on the Rock Spring factory shows that slave labor was used to produce tobacco and other goods for the tobacco factory. Hardin Reynolds continued operation of his tobacco factory during and after the Civil war, and was not broken by the war. Amongst other enterprises, he often engaged in business partnerships with his children. Hardin Reynolds' son, Richard Joshua Reynolds, founder of R. J. Reynolds Tobacco Company, worked at the Rock Spring tobacco factory after the Civil War, and later formed a business partnership with his father at the factory. The partnership was called “Hardin Reynolds and Son.” In the fall of 1874, R.J. Reynolds sold his interest in the Rock Spring Factory and purchased land in North Carolina in October 1874 upon which he built an R.J. Reynolds Tobacco Company factory. Records indicate that R. J. took half of two year's profit from the Rock Spring factory to found his new company R.J. Reynolds Tobacco Company.

162. On April 4, 1899, R. J. Reynolds Tobacco company became a subsidiary of the American Tobacco Company through its relationship with the Continental Tobacco Company, a holding company of the American Tobacco Company. The American Tobacco Company owned controlling shares of stock in R.J. Reynolds Tobacco Company thereby benefiting from and aiding in its already profitable operations. This relationship existed until 1911, when the U.S. Supreme Court issued a ruling that broke the old American Tobacco Company into several large competing companies. Upon information and belief, R.J. Reynolds Tobacco Company does continuous and systematic business in every jurisdiction in which the suits have been filed.

163. Currently existing companies, once part of the American Tobacco Company, and therefore beneficiaries of the slave labor include: R. J. Reynolds Tobacco Company, Brown & Williamson (formerly The American Tobacco Company via ownership of its predecessor by R.J. Reynolds Tobacco Company), Liggett Group Inc. (formerly Liggett & Myers Tobacco Company), and Lorillard Tobacco Company a subsidiary of Loews Corporation. All do continuous and systematic business in all the jurisdictions in which the cases have been filed.

164. It attempted to minimize its involvement in statements to the Press claiming its company was not founded until after slavery was abolished, misleading plaintiffs into believing that the company itself was not founded on the profits of slave labor.

165. Defendant BROWN AND WILLIAMSON TOBACCO CORP. (“BROWN & WILLIAMSON”) is a corporation with its principal place of business located at 200 Brown & Williamson Tower, Louisville, Kentucky 40202. Upon information and belief, it does continuous and systematic business in all jurisdictions where these actions have been filed. BROWN AND WILLIAMSON is a successor in interest to The American Tobacco Company. BROWN AND WILLIAMSON benefited from slave labor because it was formed out of the American Tobacco Company that benefited from assets acquired by R. J. Reynolds Tobacco Company from the uncompensated labor of enslaved Africans. Such use of enslaved Africans was an unfair business practice set forth by Slave Codes created and enforced by states. It does continuous and systematic business in all the jurisdictions in which the cases have been filed.

166. Defendant LIGGETT GROUP INC. is a corporation with its principal place of business located at 100 Maple Lane, Mebane, North Carolina. It does continuous and systematic business in California. LIGGETT GROUP INC. is a successor in interest to the American Tobacco Company. LIGGETT GROUP INC. benefited from slave labor because it was formed out of the American Tobacco Company that benefited from assets acquired by R. J. Reynolds Tobacco Company from the uncompensated labor of enslaved Africans. Such use of enslaved Africans was an unfair business practice set forth by Slave Codes created and enforced by states.

167. Defendant R.J. REYNOLDS engaged in a self-concealed business enterprise as the plaintiff class and/or plaintiffs' ancestors would not be aware of the existence of this enterprise without a specific disclosure by the plaintiffs as to the nature and level of participation and profit the defendant derived from slavery.

168. Defendant LOEWS CORPORATION is the parent corporation of Lorillard Tobacco Company with its principal place of business located at 667 Madison Avenue, New York, New York 10021. Upon information and belief, it does continuous and systematic business in all the jurisdictions in which it is sued. LOEWS CORPORATION is a successor in interest to the American Tobacco Company due to its ownership of Lorillard Tobacco Company. LOEWS CORPORATION benefited from slave labor because its subsidiary was formed out of the American Tobacco Company that benefited from assets acquired by R. J. Reynolds Tobacco Company from the uncompensated labor of enslaved Africans. Such use of enslaved Africans was an unfair business practice set forth by Slave Codes created and enforced by states.

169. Defendant CANADIAN NATIONAL RAILWAY CO. is a corporation with its principal place of business located at 935 de La Gauchetiere St. West, Montreal, QU H3B 2, Canada. It does continuous and systematic business in New York. It is the successor-in-interest to seven predecessor railroad lines, that were constructed and/or run in part by slave labor. Such use of enslaved Africans was an unfair business practice set forth by Slave Codes created and enforced by states.

170. Furthermore, upon information and belief, CANADIAN NATIONAL was approached by members of the general public to verify their historical connection to slavery. They denied any connection thereto.

171. Defendant CANADIAN NATIONAL engaged in a self-concealed business enterprise as the plaintiff class and/or plaintiff ancestors would not be aware of the existence of this enterprise without a specific disclosure by the plaintiffs as to the nature and level of participation and profit the defendant derived from slavery.

172. SOUTHERN MUTUAL INSURANCE CO. is a corporation with its principal place of business in Georgia. Upon information and belief it issued policies on the lives of slaves in Louisiana. Upon information and belief, it does systematic and continuous business in Louisiana.

173. Defendant AMERICAN INTERNATIONAL GROUP INC. (“AIG”) is a corporation with its principal place of business at 70 Pine Street, New York, New York, 10270. AIG is successor-in-interest to the United States Life Insurance Company in the City of New York, which earned premiums from its sale of life insurance on the lives of enslaved Africans with slave owners as the beneficiaries. In the California Department of Insurance's May 2002 Slavery Era Insurance Registry approximately 200 slaveholders' policies are associated with AIG's predecessor United States Life Insurance Company in the City of New York. (U.S.Life).

(See, http://www.insurance.ca.gov/SEIR/Slaveholder.htm)

GENERAL DEFENDANTS' DESCRIPTION

174. Defendants and the other known and unknown defendants used and/or profited from slave labor and have retained the benefits and use of those profits and products derived from that slave labor. Defendants knew that the plaintiff class was subject to physical and mental abuse and inhuman treatment at the time they earned those profits and since.

175. Defendants conspired with each other with intentions to violate plaintiffs' ancestors' basic human rights and by so doing, to profit from these violations.

MISCELLANEOUS UNIDENTIFIED DEFENDANTS

176. Defendants CORPORATE DOES NOS. 1-100 are other companies, industrial, manufacturing, financial and other enterprises that, like the named defendants, its/their predecessors, affiliates and/or assigns unjustly profited from slave labor. The designation CORPORATE DOES NOS. # 1-100 is used until such time as the specific identity of such additional companies, as they relate to this action, is ascertained through discovery and/or other means.