GENERAL DESCRIPTIONS APPLICABLE TO ALL PLAINTIFFS
104. Some or all the 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.
105. Defendants are benefiting from these communications by continuing business relationships with plaintiff customers.
106. Some or all the Plaintiffs have suffered the harm of being unconscionably denied the benefits of a competitive market for the goods and services they purchase from defendants.
107. It is believed that 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.
108. Each plaintiff has 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.
109. Each Plaintiff 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.
110. Each Plaintiff continues to be harmed to the present day, in that each and others similarly situated are deprived job opportunities, caused psychic harm, denied ability to inherit his or her fore-parents wealth.
111. Each Plaintiff African-American slave descendent has suffered by the Defendants failure to pay their ancestors for their labor as slaves or as sharecroppers, peons or even slaves.
112. Each Plaintiff suffered the harm of being denied the wealth of their ancestors by the Defendants and thus being unable to purchase goods and services such as quality education at the elementary, secondary and university levels.
113. Each Plaintiff was denied the economic wealth of his or her ancestors' labor.
114. Each Plaintiff African-American slave descendant has derivative and inherited property rights in their ancestors' lost pay, and this right has never been rescinded, voided, altered or satisfied.
115. Each Plaintiff African-American descendants' 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.