COUNT IV - 42 U.S.C. § 1982

299. Plaintiffs incorporate all allegations contained elsewhere in this complaint within this section as if fully set forth herein.

300. In conjunction with defendants' conduct as alleged elsewhere in this complaint that directly denied slaves of the fruits of their labor or otherwise resulted in defendants' profits directly related to slavery and the lives of slaves, the defendants' continuing conduct in restricting access to the defendants' records related to their activities and profits related and derived from slavery, the plaintiffs', their ancestors' and their descendants' rights to inherit and convey property under 42 U.S.C. § 1982 have been and continue to be violated.

301. Specifically, 42 U.S.C. § 1982. Property Rights of Citizens, Civil Rights Act of 1866, provides:

All citizens of the United States shall have the same right, in every State and Territory, as is enjoyed by white citizens thereof to inherit, purchase, lease, sell, hold, and convey real and personal property.

302. Defendants have engaged in conduct with the clear intent to deprive the plaintiffs, their ancestors and their descendants from having access to what is rightfully theirs which in turn denies them, in accordance with the defendants' clear intent, the opportunity to inherit and convey personal and real property representing their families' combined and accumulated wealth as do and have the white citizens of this country.

303. No non-slave or non-slave family has suffered the same or similar denial of wealth at the hands of the defendants' illegal profiting from slavery and continued pattern and practice of retaining this ill-gotten wealth by restricting from all members of the public access to information related to the defendants' activities and profits from slavery, as well as continued profits with this enormous and incomparable source of wealth.