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Complaint for Damages, Declaratory, Injunctive and Equitable Relief

 (N.D.Ill.) (Trial Pleading)

United States District Court, N.D. Illinois.

Bob BROWN (a.k.a. Robert Alfonzo Brown), On behalf of himself, on behalf of all other
persons similarly situated, and on behalf of the general public, Plaintiff,

v.

HIS HOLINESS POPE JOHN PAUL II; Father General Peter-Hans Kolvenbach SJ; Reverend
Monsignor William P. Fay; Fr. Bradley M. Schaeffer; King Juan Carlos V; President Jacques
Chirac; Queen Elizabeth II; George W. Bush; Mark Warner; Rod R. Blacojevich; M. L. Foster
Jr.; Jeb Bush; Rick Perry; Lloyd's Register; Port of Nantes; Port of London; Port of Bristol; Port
of Liverpool; Port of Boston; Ports of Virginia; Port of Providence; Port of New York; Port of
New Orleans; Colt; U.S. Repeating Arms; M.A. Patout & Son Limited, Parlange Plantation;
FLO-SUN Inc.; Tate & Lyle PLC; Bacardi Limited; Shirley Plantation; The Society of Jesus of
Maryland; Universal Corporation; Dimon Inc.; Standard Commercial Corporation; Lorillard
Tobacco Company Inc.; Philip Morris Companies Inc.; Ligget & Meyers Tobacco Company; RJ
Reynolds Tobacco Holdings Inc.; Brown & Williamson Tobacco Corporation; United States
Tobacco Inc.; Conwood Sales Company LP; King Ranch Corporation; Staple Cotton
Cooperative Association; Weil Brothers Cotton Inc.; Dunavant Enterprises Inc.; Cargill PLC.;
Avondale Mills Inc.; Burlington Industries Inc.; Continental Eagle Corporation; Chevrontexaco
Corporation; Canadian National Railway Company; Kansas City Southern Railroad; Burlington
Northern Santa FE Railway Company; Union Pacific Corporation; CSX Transportation; Inc.,
Norfolk Southern Corporation; Bank of England; Barclays Bank PLC; Inc Groep N.V.; Bank of
New York; Bank of America Corporation; N. M. Rothschild & Sons; J.P. Morgan Chase &
Company; Citigroup; Brown Brothers Harriman & Company; Deutsche Banc AG; The Dun &
Bradstreet Corporation; Lehman Brothers Holdings Inc.; First Data Western Union; Society of
Lloyds; And Does 1-1,000., Defendants.

No. 04 C 0094.

January 7, 2004.

Private Attorney General Class Action

Jury Trial Demanded

Complaint for Damages, Declaratory, Injunctive and Equitable Relief

Judge Zagel.

Magistrate Judge Levin.

Upon information and belief, Plaintiff, on behalf of himself, on behalf of his Ancestors, on
behalf of all person similarly situated, and on behalf of the general public, states as follows:

NATURE OF ACTION

1) This private attorney general class action arises under customary international law,
international treaties, agreements and obligations, and the constitutions, laws and statutes of the
Vatican, the Kingdom of Spain, the Republic of France, the United Kingdom of Great Britain
and Northern Ireland, and the United States.

2) Defendants, named and not named herein, as their predecessors have done for the past 568
years, continue to lie to, deceive, and conspire against People of African descent, in Africa and
the African Diaspora, and the general public, about their, their predecessors and co-prticipants,
participation in, and wrongful and unjust enrichment, by and through the 568-year historical and
continuing Maafa which was and is a violation of the laws of nature, cannon law, the
law of nations, and customary international law; which was and is a gross violation of the human
rights of Plaintiff, Class members, and their Ancestors; and which was and is a crime against
humanity.

3) Defendants, like their predecessors and co-participants have done for the past 568-years,
fraudulently misrepresented and deceived, and continue to fraudulently misrepresent and
deceive, African People, and the general public, about the historical and continuing immorality
and illegality of the Maafa; about its magnitude, scope, scale and duration; and about its
devastating, historical and continuing impact on Africa, and on more than 1 billion African
People who are scattered, suffering and struggling in every corner of the world.

4) Defendants, as their predecessors and co-participants did before them, have repeatedly denied,
and continue to deny, have minimized, and continue to minimize, their historical and continuing,
immoral and illegal role in the Maafa, which was and is a criminal enterprise, scheme, course of
conduct, hostile environment, and untold number of interrelated and ongoing serial acts, some of
which are set forth herein.

5) Defendants, as their predecessors and co-participants did before them, have repeatedly and
consistently refused, and continue to refuse, to acknowledge, apologize for, and stop their
tortuous and terroristic acts and terroristic conduct; to account for, and disgorge the unjust and
illicit gains which they have acquired by and through their historical and continuing participation
in the Maafa; and to repair the untold injuries and damages, pain and suffering, that Plaintiff,
Class members, and their Ancestors, have and continue to endure as a direct and proximate result
of Defendants, their predecessors and co-participants, 568-year and historical course of conduct
and acts.

6) In all relevant respects, Defendants, their predecessors and co-participants, acted in concert
with each other, conspired with each other, and aided and abetted each other, in order to further
their fraudulent conspiracy, scheme, and enterprise, which functioned, and continues to function,
as an association-in-fact for more than 568-years, through immoral, illegal, wrongful, and unjust
means, with the shared goals of maintaining, monopolizing, and maximizing their profits and
power, and avoiding the exposure of and consequences for their actions.

7) Defendants, their predecessors and co-participants, participants, participated in, and continue
to participate in, conspired, and continue to conspire, aided and abetted, and continue to aid and
abet, in the operation and management of this 568-year historical and continuing criminal
enterprise. Defendants, their predecessors and co-participants, have committed and continue to
commit numerous tortuous and terroristic acts in order to maintain and expand the enterprise,
and to acquire, convert, and maintain their unjust and illegal proceeds.

8) In order to plan, organize, expand and institutionalize this criminal enterprise and scheme;
avoid discovery of their fraudulent, wrongful and unjust conduct and acts; maintain and increase
their profits and power; acquire, increase, and retain control of their ill-gotten and unjust riches;
and evade justice, equity, and the rule of international law, Defendants, their predecessors and
co-participants, engaged in, and continue to engage in, a widespread, historical and continuing
scheme to frustrate public scrutiny by making false and deceptive statements, and by concealing
information and records that they knew would have exposed their crimes, their wrongful and
unjust enrichment, and their public campaign of deceit.

9) This 622-year historical and continuing scheme included, and continues to include, making
false and deceptive statements, and material omissions of fact to African People, and to the
general public, by and through their reports, publications, websites, statements, and press
releases, and by and through their participation in international, legislative, executive, and
judicial meetings, proceedings and tribunals.

10) Detailed evidence of the magnitude, scope, scale, and duration of Defendants', and their
predecessors' and co-participants', participation in, and wrongful and unjust enrichment by and
through this 568-year historical and continuing criminal enterprise has only recently become
accessible to African People, and the general public, as a result of the Internet, the disclosure and
declassification of archived documents, the advancement of scholarly research, growing public
concern and outrage, and the worldwide pressure and victories of the Human Rights, Holocaust
Restitution, and Reparations Movements.

11) Defendants', and their predecessors' and co-participants', immoral, unlawful and unjust
conduct and actions, and that of their predecessors and co-participants, has caused, and continues
to cause, Plaintiff, Class members, and their Ancestors, untold injury and damages; tangible and
intangible, defacto and dejure, and untold pain and suffering. Moreover, Defendants, and their
co-participants, continue to commit, conspire to commit, and continue to aid and abet in the
commission of similar conduct and acts against Africa, and against I billion African People
today.

12) Defendants, their predecessors and co-participants, unless ordered by this Court, will not
acknowledge, apologize, account for, or disgorge their illicit and unjust. enrichment; and are
likely to continue their unlawful and activities into the future, causing even more untold injuries
and damages, pain and suffering, to Africa and the masses of African People worldwide.

13) This private attorney general class action seeks to make clear that responsibility and
accountability for the 568-year historical and continuing Maafa rests not only with the
slave-raiders, the slave-catchers, the slave-traders, the slave-makers, the slave-masters, and the
slave-holders, but also with those who organized and continue to organize, promoted and
continue to promote, financed and continue to finance, sponsored and continue to sponsor,
participated in and continue to participate in, supported and continue to support, aided and
abetted and continue to aid and abet, in the commission of, and in the conspiracy to commit,
these historical and continuing tortuous and terroristic acts and crimes.

14) More importantly, this private attorney general action seeks to make clear that responsibility
and accountability for the 568-year historical and continuing Maafa also rests with Defendants,
their predecessors, coparticipants, and successors, who were and continue to be wrongfully and
unjustly enriched during, by and through the commission of these historical and continuing
crimes.

15) This private attorney general action upholds an elementary axiom: if you acquire or inherit
the assets, you also acquire or inherit the liabilities and accountability.

16) There is no statute of limitations on, or impunity for crimes against humanity; and therefore
there is no statute of limitations on or impunity for liability and accountability for them as well.

17) Justice, equity, and the rule of customary international law demands that the untold riches,
tangible and intangible, wrongfully and unjustly, acquired by and through the commission of
these historical and continuing crimes be disclosed, accounted for, and disgorged; and justice,
equity, and the rule of customary international law demands that the untold injury and damages,
pain and suffering, caused by Defendants, their predecessors and coparticipants, to Plaintiff,
Class members, and their Ancestors, be repaired.

18) Because of the magnitude, scope, scale, duration, and complex nature of the Maafa, and
because of Defendants', their predecessors' and co-participants', collective and individual
conduct and acts, giving rise to liability, Plaintiff has provided herein a detailed summary of
some of the facts currently known, which provide an abundant basis for this private attorney
general class action.

19) Defendants, and their co-participants, including, but not limited to those named in this
action, through their own conduct and acts, and through the conduct and acts of their
predecessors and co-participants, conspired with each other and other individuals and entities,
whose identities are not yet specifically identified, but which are described herein as DOES
#1-10,000, to commit and knowingly facilitate the commission of, to conspire to commit, and to
aid and abet in the commission of, violations of customary international law, gross violations of
human rights, and crimes against African and world humanity, as described herein, and to further
illicitly and unjustly profit from the Maafa, at the expense of, and to the harm of Plaintiff, Class
members, and their Ancestors

20) The collective voice of humanity and history, especially African humanity and African
history, appeals to this Court for recognition, redress, remedy, relief, reparations and
repatriation, the right to return.

21) The general public interest will be greatly served by and through the just, equitable and
timely adjudication of the issues of law and facts raised herein, as well.

PARTIES

PLAINTIFF

22) Plaintiff Bob Brown (a.k.a. Robert Alfonzo Brown) was born in and has offices in the City
of Chicago, Illinois. He is the Co-Director of Pan-African Roots, with offices in Chicago,
Illinois, Washington, DC, Baltimore, MD and Conakry, Guinea. He is an organizer and
researcher, who has worked, studied and struggled for 4years, within and for the Student, Civil
and Human Rights, Black Power, National Liberation, Pan-African, and Peace Movements. He
was a member, from 1963 to 1968, of the Chicago Chapter of the Congress of Racial Equality
(CORE); a director, from 1967 to 1968, of the Midwest Office of the Student Nonviolent
Coordinating Committee (SNCC); a co-founder and member, from 1968 to 1969, with
Congressman Bobby Rush and Tommy Carter, of the Illinois Chapter of the Black Panther Party
(BPP); and an organizer, from 1972 to 2002, for the All-African People's Revolutionary Party
(A-APPRP). Plaintiff served as a political secretary and research assistant to Kwame Ture,
formerly known as Stokely Carmichael, from 1967 to his transition in 1998.

23) Among other assignments and responsibilities, Plaintiff has served as an Advisor to the
"Rev. Willie Wilson for Mayor of Washington, DC Campaign" (2002); as advisor to Dr. J.
Archie Hargraves, Pastor of the South Shore Community Church and President of the
Commnuniversity (1995-2002); as the National Campaign Manager of the Pan-Africanist
Congress of Azania's (South Africa) "Local Government Elections Campaign" (2000); as an
Advisor to Dr. Conrad Worrill and the National Black United Front's "Project on Human Rights
and Genocide which took a petition to the United Nations in Geneva with 150,000 signatures
charging the U.S. Government with genocide (1997);" as an Advisor to Rev. Al Sharpton and the
National Director of the "Campaign to Cash the Check" which organized demonstrations at the
Democratic and Republican National Conventions (1996); as a Consultant to Minister Louis
Farrakhan and the National Coordinator of Logistics and Operations and National Field Director
of the "Million Man March and Stay-at-Home Campaign" (1995); as a Consultant to the "Carol
MosleyBraun for Senator of Illinois Campaign" (1993); as an Advisor Harold Washington and
an Organization Specialist for the "Harold Washington for Mayor of Chicago Campaign" (1983
and 1987); as a National Staff Member of the "Jesse Jackson for President Campaign" (1983); as
a Co-Coprdinator of Third World Outreach for the Mobilization for Survival and the "June 12th
Disarmament Campaign," which organized a million person demonstration at the United Nations
(1983); and as a participant in the 1965 "Chicago Freedom Movement" which was co-led by Bob
Lucas of Chicago CORE, Lawrence Landry of ACT, Monroe Sharpe of SNCC, Al Raby of the
Coordinating Council of Community Organizations, and Dr. Martin Luther King of the Southern
Christian Leadership Conference (SCLC).

24) Plaintiff has worked with and supported the Alliance for Global Justice, the American Indian
Movement/International Indian Treaty Council, the Azanian Peoples Organization, the Black
Conscious Movement of Azania, the Black Consciousness Movement of Brazil, the Committee
against Registration and the Draft, the Committee in Solidarity with the People of El Salvador,
the DC Hands off Cuba Committee, the DC-Havana Sister City Project, the Democratic Party of
Guinea, the Emancipation Support Committee of Trinidad, the Eritrean People's Liberation
Front, the Irish Republican Socialist Party, the La Raza Unida Party, the Movement for Justice in
Gambia, the National Joint Action Committee of Trinidad, the National Network on Nicaragua,
the Palestine Liberation Organization, the Puerto Rican Socialist Party, the Sandinista Liberation
Front, Sein Fein, the Young Koreans United, and a host of other organizations.

25) Plaintiff was one of more than 6,000 delegates, from every comer of Africa, the African
Diaspora. and the world, who participated in the Non-Governmental Forum of the 3rd World
Conference Against Racism (WCAR) which was held in Durban, South Africa from 27 August
to 1 September 2001.

26) Bob Brown has spent 40 years of his life, at considerable expense, personal, financial and
political, fighting on behalf of, and struggling to educate and organize African and other
Oppressed Peoples in the United States, Africa, the African Diaspora, and the world; and
fighting against the trafficking in human beings; slavery; slave-like conditions and practices;
colonialism, settler-colonialism, segregation and apartheid; racism and racial discrimination;
sexism, sexual exploitation and harassment, and sexual violence; xenophobia and related
intolerance.

27) He has been a Plaintiff in two major class action lawsuits, both of whom were filed in the
Federal Courts in Chicago (1967 and 1996) and both of whom were won; and Plaintiff
has served as a researcher and organizer for a host of other class action suits.

28) Moreover, Plaintiff, and his Ancestors, have been and continue to be victims of; and have
suffered and continue to suffer damages and injures caused by Defendants, their predecessors,
and co-participants. His life, and lifetime of study, work and struggle has prepared him to
adequately represent the interest of Class members, and the general public.

DEFENDANTS

THE CATHOLIC CHURCH DEFENDANTS

His Holiness Pope John Paul II

29) Defendant His Holiness John Paul II is the spiritual leader of Defendant the Roman Catholic
Church and the Head of Defendant the Vatican, an Italian corporation, with its principal office
located in Rome, Italy. The United States Headquarters of the Vatican is located at the Apostolic
Nunciature, 3339 Massachusetts Ave NW, Washington, D.C. 20008. The Chicago Office of the
Vatican is located at the Archdiocese of Chicago, 155 E. Superior Street, Chicago, IL 60611.
Upon information and belief, the Vatican conducts business within and with the City of Chicago.

30) Pope John Paul II is the successor-in interest to 49 Popes who have lead the Roman Catholic
Church and the Vatican since the beginning of the Maafa in 1435.

Father General Peter-Hans Kolvenbach SJ

31) Defendant Father General Peter-Hans Kolvenbach SJ is the Superior General of Defendant
The Society of Jesus, an Italian corporation, with its principle office located at the Curia
Generalizia in Rome, Italy. Jesuit affairs in the United States is administered by the U.S. Jesuit
Conference with its principal office located at 1616 P Street NW, Suite 300, Washington, DC
20036-1420. Jesuit affairs in Illinois, Indiana, Kentucky and Southwestern Ohio are administered
by the Chicago Province of the Society of Jesus with its principle office located at 2050 North
Clark Street, Chicago, IL 60614. Upon information and belief, the Society of Jesus conducts
business within and with the City of Chicago.

32) Defendant Father General Peter-Hans Kolvenbach SJ is the successor-in-interest to 29
Superior Generals who have lead the Society of Jesus since the beginning of the Maafa in 1435.

Reverend Monsignor William P. Fay

33) Defendant Reverend Monsignor William P. Fay is the General Secretary of Defendant the
United States Conference of Catholic Bishops, a District of Columbia corporation, with its
principal office located at 3211 4th Street, N.E., Washington, DC 20017-1194. The Conference
of Catholic Bishops administers the affairs of the Catholic Church in the United States and the
Virgin Islands. The Chicago Office of the Conference of Catholic Bishops is located at the
Archdiocese of Chicago, 155 E. Superior Street, Chicago, IL 60611. Upon information and
belief, the Catholic Church conducts business within and with the City of Chicago.

34) Many Bishops, Catholic Church officials, and/or their families, were major participants in,
and wrongfully and unjustly enriched by and through, every phase and level of the Maafa, in
Africa and the African Diaspora.

Fr. Bradley M. Schaeffer

35) Defendant FR. Bradley M. Schaeffer is the Chair and President of the U.S. Jesuit
Conference, the administrative arm of Defendant the United States Assistancy of the Society of
Jesus, with its principle office located at 1616 P Street, NW, Suite 300, Washington, DC
20036-1420. Jesuit affairs in Illinois, Indiana, Kentucky and Southwestern Ohio are administered
by the Chicago Province of the Society of Jesus with its principle office located at 2050 North
Clark Street, Chicago, IL 60614. Upon information and belief, the Society of Jesus conducts
business within and with the City of Chicago.

General Statement About Catholic Church Defendants

36) Defendants are being sued in their public capacity as the Heads of Catholic Church
Defendants, all of whom have been, and continues to be, involved at every level of, and
wrongfully and unjustly enriched by, the 568-year historical and continuing Maafa.

37) The Catholic Church, the Vatican and the Jesuits are charged with conspiracy, gross
violations of human rights, crimes against humanity, conversion, unjust enrichment, failure and
refusal to account, violation of the Chicago Slavery Era Disclosure Act, and consumer fraud, as
set forth herein.

THE FOREIGN STATE DEFENDANTS

King Juan Carlos V

38) Defendant King Juan Carlos V is the Head of the Spanish Royal Family, and of King of the
Kingdom of Spain, a sovereign nation and body politic, whose Embassy is located at 2375
Pennsylvania Avenue, NW, Washington, DC 20037. The Consulate General of Spain is located
at 180 N. Michigan Ave., Suite 1500, Chicago, IL 60601. Upon information and belief, the
Spanish Royal Family and the Kingdom of Spain conduct business within and with the City of
Chicago.

39) King Carlos V is the successor-in-interest to at least 24 members of the Spanish Royal
Family who have lead the Kingdom of Spain since the beginning of the Maafa in 1435.

President Jacques Chirac

40) Defendant President Jacques Chirac is the President of the French Republic, a sovereign
nation and body politic, whose Embassy is located at 4101 Reservoir Road, NW, Washington,
DC 20007. The Consulate General of France is located at 737 N Michigan Ave, Chicago, IL
60611. Upon information and belief, the French Republic conducts business within and with the
City of Chicago.

41) President is Jacques Chirac is the successor-in-interest to at least 45 Heads of State, who
have lead France since the beginning of the Maafa in 1435.

Queen Elizabeth II

42) Defendant Queen Elizabeth II is the Head of the British Royal Family, and the Queen of the
United Kingdom of Great Britain and Ireland, a sovereign nation and body politic, whose
Embassy is located at 3100 Massachusetts Avenue NW, Washington, DC 20008. The British
Consulate General is located at the 13th Floor of the Wrigley Building, 400 N Michigan Avenue,
Chicago, IL 60611 and/or at 161 E Chicago Ave, Chicago, IL 60611-2601. Upon information
and belief, Queen Elizabeth II, the British Royal Family, and the United Kingdom of Great
Britain and Ireland conduct business within and with the City of Chicago.

43) Queen Elizabeth II is the successor-in-interest to at least 15 members of the British Royal
Family who have lead the United Kingdom since the beginning of the Maafa in 1435.

General Statement About Foreign State Defendants

44) In regards to the allegations set forth herein, Foreign Heads of States, Royal Families,
Foreign States, and all of their branches (legislative, executive and judicial), and all of their
levels, (federal, provincial, state, county and municipal), have engaged in, and continue to
engage in, the Maafa, which was and is a commercial enterprises and set of activities, that
affected, and continue to affect, commerce and foreign trade in the United States, Africa, and the
world, as set forth herein.

45) These commercial activities, and the illicit and unjust gains acquired through their historical
and continuing participation in them, were and are private, not sovereign; and where and are in
gross violation of Plaintiff's, Class members', and their Ancestors', human rights, which were and
are recognized and protected by customary international law, and the constitutions, edicts,
statues, and laws of their respective states.

46) By engaging in, and continuing to engage in, these private commercial activities and
criminal enterprises, the above named Foreign States, and others not named herein, have
forfeited their immunity, with respect to the causes of action set forth herein.

47) By acting separately and/or in concert, by conspiring with, aiding and abetting each other, in
the 568-year historical and continuing Maafa, which includes, but is not limited to, the invasion
and colonization of the Western Hemisphere and Africa, the Trans-Atlantic Slave-Trades (which
is also known as the Atlantic Trade, the Triangle Trade, the Middle Passage, the West Indies
Trade, the Coastal Trade, etc.), slavery and slave-like practices and conditions, segregation and
apartheid, racism and racial discrimination, xenophobia and related intolerance, which are and
were crimes against humanity, the above named Foreign States and Heads of State, and others
not named, have violated, and continue to violate, Plaintiffs, Class members', and their
Ancestors', human rights, and have committed, and continue to commit, crimes against
humanity.

48) Defendants are being sued in their own right, in their private capacity as successor-in-interest
to and Heads of the Families named herein, and/or in their public capacity as the Heads of
Defendant Foreign States, all of whom have been, and continue to be, involved at every level of,
and wrongfully and unjustly enriched by and through the 568-year historical and continuing
Maafa.

49) Foreign State Defendants are charged with conspiracy, violation of the Foreign Sovereign
Immunities Act, gross violations of human rights, crimes against humanity, conversion, unjust
enrichment, failure and refusal to account, violation of the Chicago Slavery Era Disclosure Act,
and consumer fraud, as set forth herein.

THE UNITED STATES GOVERNMENT DEFENDANTS

George W. Bush

50) Defendant George W. Bush is the President of the United States, a sovereign nation and
body politic with its principal place of business located at The White House, 1600 Pennsylvania
Avenue NW, Washington, DC 20500. Upon information and belief, the United States
Government, and all of its Departments and agencies, conducts business within and with the City
of Chicago,

51) President Bush is the successor-in-interest to at least 43 Presidents, and untold number of
colonial governors and officials, who have lead the United States Government since the
beginning of the Maafa in 1435.

52) Additionally, at least 46 Vice-Presidents, 95 Secretaries of State, 73 Secretaries of the
Treasury, 79 Secretaries of War and Defense, 78 Attorney Generals, 254 Senators, 597
Congressmen, 112 Justices of the Supreme Court, and numerous other officials, have served the
U.S. Government since the beginning of the Maafa in 1435.

Mark Warner

53) Defendant Mark Warner is the Governor of the State of Virginia, a sovereign state, with its
principal place of business located at the Office of the Governor, State Capitol, 3rd Floor,
Richmond, Virginia 23219. Upon information and belief, the State of Virginia conducts business
within and with the City of Chicago.

54) Governor Warner is the successor-in-interest to at least 79 Governors who have lead the
State of Virginia since the beginning of the Maafa in 1435.

Rod R. Blagojevich

55) Defendant Rod R. Blagojevich is the Governor of the State of Illinois, a sovereign state, with
its principal place of business located at the Office of the Governor, 207 State House,
Springfield, IL 62706. Upon information and belief, the State of Illinois conducts business
within and with the City of Chicago.

56) Governor Blagojevich is the successor-in-interest to at least 39 Governors who have lead the
State of Illinois since the beginning of the Maafa in 1435.

M. L. Foster Jr.

57) Defendant M. L. Foster Jr. is the Governor of the State of Louisiana, a sovereign state, with
its principal place of business located at the Office of the Governor, 900 3rd Street, Baton
Rouge, LA 70802. Upon information and belief, the State of Louisiana conducts business within
and with the City of Chicago.

58) Governor Foster is the successor-in-interest to at least 60 Governors who have lead the State
of Louisiana since the beginning of the Maafa in 1435.

Jeb Bush

59) Defendant Jeb Bush is the Governor of the State of Florida, a sovereign state, with its
principal place of business located at the Office of the Governor, The Capitol, 400 South Monroe
Street, Tallahassee, FL 32399-0001. Upon information and belief, the State of Florida conducts
business within and with the City of Chicago.

60) Governor Bush is the successor-in-interest to at least 48 Governors who have lead the State
of Florida since the beginning of the Maafa in 1435.

Rick Perry

61) Defendant James Richard Perry is the Governor of the State of Texas, a sovereign state, with
its principal place of business located at the Office of the Governor, State Insurance Building,
1100 San Jacinto, Austin, Texas 78701. Upon information and belief, the State of Texas
conducts business within and with the City of Chicago.

62) Governor Perry is the successor-in-interest to at least 104 Governors and Presidents who
have lead the State of Texas since the beginning of the Maafa in 1435.

General Statement About United States Government Defendants

63) In regards to the allegations set forth herein, Defendant the United States Government, the
States set forth herein, other States not named, and all of their branches (legislative, executive
and judicial), and all of their levels, (federal, provincial, state, county and municipal), have
engaged in, and continue to engage in, the Maafa, which was and is a commercial enterprises and
set of activities, that affected, and continue to affect, commerce and foreign trade in the United
States, Africa, and the world, as set forth herein.

64) These commercial activities, and the illicit and unjust gains acquired by Defendant the
United States Government, all of its branches and levels, through their historical and continuing
participation in them, were and are private, not sovereign; and where and are in gross violation
of Plaintiff's, Class members', and their Ancestors', human rights, which were and are recognized
and protected by customary international law, and the constitutions, edicts, statues, and laws of
their respective states.

65) By engaging in, and continuing to engage in, these private commercial activities and
criminal enterprises, Defendant the United States, the above named States, and others not named
herein, have forfeited their immunity, with respect to the causes of action set forth herein.

66) By acting separately and/or in concert, by conspiring with, aiding and abetting each other, in
the 568-year historical and continuing Maafa, which includes, but is not limited to, the invasion
and colonization of the Western Hemisphere and Africa, the Trans-Atlantic Slave-Trades (which
is also known as the Atlantic Trade, the Triangle Trade, the Middle Passage, the West Indies
Trade, the Coastal Trade, etc.), slavery and slave-like practices and conditions, segregation and
apartheid, racism and racial discrimination, xenophobia and related intolerance, which are and
were crimes against humanity, the United States and the above named Slates, and others not
named, have violated, and continue to violate, Plaintiff's, Class members', and their Ancestors',
human rights, and have committed, and continue to commit, crimes against humanity.

67) The United States Government, and State Defendants, are charged with conspiracy, violation
of sovereign immunity, gross violations of human rights, crimes against humanity, conversion,
unjust enrichment, failure and refusal to account, Freedom of Information Act Request, violation
of the Chicago Slavery Era Disclosure Act, and consumer fraud, as set forth herein.

68) Upon information and belief, the Maafa, all of its components and phases, at all times
relevant to this complaint, was and is highly regulated, policed and taxed by the United States,
the above named States, and other states, counties and municipalities not named herein.
Voluminous amounts of contracts, reports, records, and other kinds of primary source
information were required to be maintained and submitted to various Government al agencies.

69) Upon further information and belief, these materials were archived and preserved; are
housed at the National Archives and Records Administration, federal records offices, federal
depository libraries scattered throughout the United States, and various state, county and
municipal archives; and are publicly available. These materials will document in abundant and
rich detail, Defendants, their predecessors and co-participants participation in, and wrongful and
unjust enrichment by and through the Maafa, as set forth herein. They will also prove, beyond
any doubt, the legal and factual allegations that are the basis of this claim.

70) Plaintiff therefore demands, in addition to the causes of action set forth above, and/or in the
alternative, that the Court order the United States Government, and the above named State
Defendants, to disclose any and all records or materials, at no cost to Plaintiff, pertaining to, or
referencing the Maafa, and all of its constituent elements and phases, for all times relevant to this
complaint, and/or any and all records and materials that pertain to, or reference Defendants, their
predecessors and co-participants, participation in the Maafa, and the causes of action set forth
herein.

71) A Freedom of Information Act request will be filed with the Office of the President of the
United States, the above named Governors and Federal Departments, and through the Office of
the President, all Departments and agencies under his command, requesting any and all records
and materials as set forth herein. [See Appendix A.]

72) In February of 2002, the City of Chicago, with a vote of 44 to 0, passed the Chicago Slavery
Era Disclosure Act, which requires all entities doing business with the City of Chicago to file a
Certification Regarding Slavery Era Business, verifying that:

"The Undersigned has searched any and all records of the Undersigned and any and all
predecessor entities for records of investments or profits from slavery, the slave industry, or
slaveholder insurance policies from the slavery era (including insurance policies issued to
slaveholders that provided coverage for damage to or injury or death of their slaves) and has
disclosed in this EDS any and all such records to the City. In addition, the Undersigned must
disclose the names of any and all slaves or slaveholders described in those records. Failure to
comply with these disclosure requirements may make the Matter to which this EDS pertains
voidable by the City."

73) Plaintiff understands that "an incomplete EDS will be returned and any City action will be
interrupted."

74) On 13 November, 2003, Plaintiff filed a Freedom of Information Act, pursuant to the
Chicago Slavery Era Disclosure Act, requesting "any and all Vendor Affidavits, and/or related
records, that have been filed with the Department of Procurement Services [of the City of
Chicago] pursuant to the requirements of the Chicago Slavery Era Disclosure Ordinance." [See
Appendix.] A reply, dated November 19, 2003, and postmarked on December 20, 2003,
acknowledged this request, and informed us that "the above referenced information can be found
on the City of Chicago website ..."

75) We were also informed verbally that the Department of Procurement Services "did not know
if the other City of Chicago Procurement Agencies had adopted the ordinance."

THE SHIPPING INDUSTRY DEFENDANTS

Lloyd's Register

76) Defendant Lloyd's Register is a British corporation with its principal office located at 71
Fenchurch Street, London EC3M 4BS, UK. Lloyd's Register's Chicago office is located at
Lloyd's Register North America Inc., 75 Executive Drive, Suite 112, Aurora, IL 60504. Upon
information and belief, Lloyd's Register conducts business within and with the City of Chicago.

Port of Nantes

77) Defendant the Port of Nantes is an agency or instrumentality of the French Republic, a
sovereign nation and body politic, with its principal United States office located at the French
Embassy, 4101 Reservoir Road, NW, Washington, DC 20007. The Consulate General of France
is located at 737 N Michigan Ave, Chicago, IL 6061 1. Upon information and belief, Lloyd's
Register conducts business within and with the City of Chicago.

Port of London

78) Defendant the Port of London is an agency or instrumentality of The United Kingdom of
Great Britain and Ireland, a sovereign nation and body politic, with its principal United States
office located at the British Embassy, 3100 Massachusetts Avenue NW, Washington, DC 20008,
The British Consulate General is located at the 13th Floor of the Wrigley Building, 400 N
Michigan Avenue, Chicago, IL 60611. Upon information and belief, The Port of London
conducts business within and with the City of Chicago.

Port of Bristol

79) Defendant the Port of Bristol is an agency or instrumentality of The United Kingdom of
Great Britain and Ireland, a sovereign nation and body politic, with its principal office United
States located at the British Embassy is located at 3100 Massachusetts Avenue NW, Washington,
DC 20008. The British Consulate General is located at the 13th Floor of the Wrigley Building,
400 N Michigan Avenue, Chicago, IL 60611. Upon information and belief, the Port of Bristol
conducts business within and with the City of Chicago.

Port of Liverpool

80) Defendant the Port of Liverpool is an agency or instrumentality of The United Kingdom of
Great Britain and Ireland, a sovereign nation and body politic, with its principal United States
office located at the British Embassy, 3100 Massachusetts Avenue NW, Washington, DC 20008.
The British Consulate General, which is located at the 13th Floor of the Wrigley Building, 400 N
Michigan Avenue, Chicago, IL 60611. Upon information and belief, The Port of Liverpool
conducts business within and with the City of Chicago. Port of Boston

81) Defendant the Port of Boston is an agency or instrumentality of the State of Massachusetts, a
sovereign state, with its principal office located at Massport, One Harborside Drive, Suite 200S,
East Boston, MA 02128-2909. Upon information and belief, the Port of Boston conducts
business within and with the City of Chicago. Ports of Virginia

82) Defendant the Ports of Virginia are agencies or instrumentalities of the State of Virginia, a
sovereign state, with their principal office located at Virginia Port Authority 600 World Trade
Center Norfolk VA 23510. Upon information and belief, the Ports of Virginia conduct business
within and with the City of Chicago. Port of Providence

83) Defendant the Port of Providence is an agency or instrumentality of the State of Rhode
Island, a sovereign state, with their principal office located at ProvPort Inc. #35 Terminal Road,
Suite 200, Providence, RI 02905. Upon information and belief, the Port of Providence conducts
business within and with the City of Chicago.

Port of New York

84) Defendant the Port of New York is an agency or instrumentality of the States of New York
and New Jersey, sovereign stales, with their principal office located at The Port Authority of
New York & New Jersey, 225 Park Ave South, New York, NY 10003. Upon information and
belief, the Port of New York conducts business within and with the City of Chicago.

Port of New Orleans

85) Defendant the Port of New Orleans is an agency or instrumentality of the State of Louisiana,
a sovereign state, with their principal office located at Port of New Orleans, P.O. Box 60046,
New Orleans, LA 70160. Upon information and belief, the Port of New Orleans conducts
business within and with the City of Chicago.

THE GUN INDUSTRY DEFENDANTS

Colt

86) Defendant Colt's Manufacturing Company Inc. is a corporation organized and existing under
the laws of the State of Connecticut with its principal office located at 545 New Park Avenue,
Hartford, Connecticut. Upon information and belief, Colt conducts business within and with the
City of Chicago. U.S. Repeating Arms

87) Defendant U.S. Repeating Arms Company Inc. is a corporation organized and existing under
the laws of the State of Utah with its principal office located at 275 Winchester Ave, Morgan,
Utah. Upon information and belief, U.S. Repeating Arms conducts business within and with the
City of Chicago.

THE SUGAR INDUSTRY DEFENDANTS

M.A. Patout & Son Limited

88) Defendant M.A. Patout & Son Limited is a Louisiana corporation with its principal office
located at 3512 Patout Bums Road, Jeanerette, LA 70544.

Parlange Plantation

89) Defendant the Parlange Plantation is a Louisiana corporation with its principal office located
at False River Road, New Roads, LA.

Flo-Sun Inc.

90) Defendant Flo-Sun Inc. is a Florida corporation with its principal office located at 1 North
Clematis Street, Suite 200, West Palm Beach, FL 33401. Domino Sugar Corp, 2905 S Western
Ave, Chicago, IL 60608. Upon information and belief, Flo-Sun conducts business within and
with the City of Chicago.

Tate & Lyle PLC

91) Defendant Tate & Lyle PLC is a British corporation with its principal office located at Sugar
Quay, Lower Thames St., London EC3R 6DQ, United Kingdom. TATE & LYLE NORTH
AMERICA is represented by A E Staley Manufacturing Co. 2200 East Eldorado St, Decatur, IL
62521. Upon information and belief, Tate & Lyle conducts business within and with the City of
Chicago.

Bacardi Limited

92) Defendant Bacardi Limited is a Bahamas corporation with its principal office located at 65
Pitts Bay Road, Pembroke HM 08, Jamaica. The office of Bacardi U.S.A Inc., its marketing arm
is located at 2100 Biscayne Blvd., Miami, FL 3137,5028. Upon information and belief, Bacardi
conducts business within and with the City of Chicago.

THE TOBACCO INDUSTRY DEFENDANTS

Shirley Plantation

93) Defendant the Shirley Plantation is a Virginia corporation with its principal place of business
located at 501 Shirley Plantation Road, Charles City, VA 23032907.

The Society of Jesus of Maryland

94) Defendant the Society of Jesus of Maryland is a Virginia corporation with its principal place
of business located at Maryland Province Jesuits, 5704 Roland Avenue, Baltimore, Maryland
21210.

Universal Corporation

95) Defendant Universal Corporation is a Virginia corporation with its principal place of
business located at 1501 North Hamilton Street, Richmond, VA 23230. Upon information and
belief, Universal Corporation conducts business within and with the City of Chicago

Dimon Inc.

96) Defendant Dimon Inc. is a Virginia corporation with its principal place of business located at
512 Bridge Street, Danville, VA 24541. Upon information and belief Dimon conducts business
within and with the City of Chicago.

Standard Commercial Corporation

97) Defendant Standard Commercial is a North Carolina corporation with its principal place of
business located at 2201 Miller Road, Wilson, NC 27893. Upon information and belief, Standard
Corporation conducts business within and with the City of Chicago.

Lorillard Tobacco Company Inc.

98) Defendant Lorillard Tobacco Company Inc. is a Delaware corporation with its principal
place of business located at 714 Green Valley Road, Greensboro, NC 27408-7018. It is a
subsidiary of The Loews Corporation with its principal place of business located at 667 Madison
Ave, New York, NY 10021-8087. Upon information and belief, Lorrilard conducts business
within and with the City of Chicago.

Philip Morris Companies Inc.

99) Defendant Philip Morris Companies Inc. is a Virginia corporation with its principal place of
business located at 120 Park Avenue, New York, NY 10017-5592. The Altria Group is the
parent company of the Philip Morris. Upon information and belief, Philip Morris conducts
business within and with the City of Chicago.

Ligget & Meyers Tobacco Company

100) Defendant Liggett & Myers Tobacco Company is a Delaware corporation with its principal
place of business located at 700 West Main Street, Durham, NC. Upon information and belief,
Ligget & Meyers conducts business within and with the City of Chicago.

RJ Reynolds Tobacco Holdings Inc.

101) Defendant RJ Reynolds Tobacco Company is a New Jersey corporation with its principal
place of business located at 401 North Main Street, Winston-Salem, NC 27101. Upon
information and belief, Reynolds conducts business within and with the City of Chicago.

Brown & Williamson Tobacco Corporation

102) Defendant Brown & Williamson Tobacco Corporation is a Delaware corporation with its
principal place of business located at 1500 Brown & Williamson Tower, Louisville, KY 40202.
Upon information and belief, Brown & Williamson conducts business within and with the City
of Chicago.

United States Tobacco Inc.

103) Defendant United States Tobacco Inc. is a Delaware corporation with its principal place of
business located at 100 W. Putnam Ave., Greenwich, CT 06830. Upon information and belief,
UST conducts business within and with the City of Chicago.

Conwood Sales Company LP

104) Defendant Conwood Sales Company LP is a corporation with its principal place of business
located at 813 Ridge Lake Blvd. #100, Memphis, TN 38129470. Upon information and belief,
Conwood conducts business within and with the City of Chicago.

THE COTTON, TEXTILE AND APPAREL INDUSTRY DEFENDANTS

King Ranch Corporation

105) Defendant King Ranch Corporation is a Texas corporation with its principal office located
at Highway 141 West, PO Box 1090, Kingsville, TX 78364-1090.

Staple Cotton Cooperative Association

106) Defendant Staple Cotton Cooperative Association is a Mississippi corporation with its
principal office located at 214 West Market Street, Greenwood, MS 38930. Upon information
and belief, Staple Cotton conducts business within and with the City of Chicago.

Weil Brothers Cotton Inc.

107) Defendant Weil Brothers Cotton Inc. is an Alabama corporation with its principal office
located at P O Box 20100, Montgomery, AL 36120. Upon information and belief, Weil Brothers
conducts business within and with the City of Chicago.

Dunavant Enterprises Inc.

108) Defendant Dunavant Enterprises Inc., is a Tennessee corporation with its principal office
located at 3797 New Getwell Road, Memphis, TN 38118. Upon information and belief,
Dunavant conducts business within and with the City of Chicago.

Cargill PLC.

109) Defendant Cargill PLC. is a Minnesota corporation with its principal office located at
Cargill office Center, P.O. Box 9300, Minneapolis, MN 55449300. Upon information and belief,
Cargill conducts business within and with the City of Chicago.

Avondale Mills Inc.

110) Defendant Avondale Mills Inc. is an Alabama corporation with its principal office located
at 900 Avondale Avenue, Sylacauga, AL 35150. Upon information and belief, Avondale Mills
conducts business within and with the City of Chicago.

Burlington Industries Inc.

111) Burlington Industries Inc. is a corporation with its principal place of business located at
3330 W. Friendly Ave., Greensboro, NC 27410-4800. Upon information and belief, Conwood
conducts business within and with the City of Chicago.

THE AGRICULTURAL EQUIPMENT INDUSTRY DEFENDANTS

Continental Eagle Corporation

112) Defendant Continental Eagle Corporation is a Minnesota corporation with its principal
office located at Continental Eagle Corp., 201 Gin Shop Hill Road Prattville, Alabama 36067.
Upon information and belief, Continental Eagle conducts business within and with the City of
Chicago.

THE MINING INDUSTRY DEFENDANTS

ChevronTexaco Corporation

113) Defendant ChevronTexaco Corporation, formerly known as Standard Oil Company, and
has its principal office located at 6001 Bollinger Canyon Road, San Ramon, CA 94583. Upon
information and belief, ChevronTexaco conducts business within and with the City of Chicago.

THE RAILROAD INDUSTRY DEFENDANTS

Canadian National Railway Company

114) Canadian National Railway Company is a Canadian corporation with its principal place of
business located at 935 de La Gauchetiere St. West, Montreal, QC H3B 2, Canada. The Illinois
Central Railroad Company, a wholly owned subsidiary of CN, is an Illinois corporation with its
principal place of business located at 455 City Plaza Drive, Chicago, IL 60611. Upon
information and belief, Canadian Nationalo conducts business within and with the City of
Chicago.

Kansas City Southern Railroad

115) Kansas City Southern Railroad, also known as the NAFTA railroad, is a Kansas corporation
whose principle office is located at 427 West 12th Street, Kansas City, MO 64105. Its Chicago
office is located at

116) Upon information and belief, Kansas City Southern Railroad conducts business within and
with the City of Chicago.

Burlington Northern Santa Fe Railway Company

117) Burlington Northern Santa Fe Corporation is a corporation whose principal office is located
al 2650 Lou Menk Dr., 2nd Fl., Fort Worth, TX. Its subsidiary, Burlington Northern Railroad,
has an office at 3611 W 38th St, Chicago, IL 60632. Upon information and belief, Burlington
Northern Santa Fe Corporation conducts business within and with the City of Chicago.

Union Pacific Corporation

118) Union Pacific Corporation has its principal office located at 1416 Dodge Street, Omaha,
Nebraska 68179. Its Chicago office is located at the Union Pacific Railroad Building (UP), 5525
Northwest Highway, Chicago, IL 60631. Upon information and belief, Union Pacific conducts
business within and with the City of Chicago.

CSX Transportation, Inc.

119) CSX Transportation, Inc. is a Virginia corporation with its principal place of business
located at 901 E. Cary Street, Richmond, VA 23219. Its Chicago office is located at CSX
Chicago Terminal, 733 W 136th St, Riverdale, IL 60827 Upon information and belief, CSX
Transportation conducts business within and with the City of Chicago.

Norfolk Southern Corporation

120) Norfolk Southern is a corporation whose principal office is located at Norfolk Southern
Railway Corporation, Three Commercial Place, Norfolk Virginia 23410-9227. Its Chicago office
is located at Norfolk Southern Corp., 358 E Marquette Rd, Chicago, IL 60637. Upon information
and belief, Norfolk Southern Corporation conducts business within and with the City of Chicago.

THE BANKING INDUSTRY DEFENDANTS

Bank of England

121) Defendant the Bank of England is a British corporation with its principal place of business
located at Threadneedle Street, London EC2R 8AH, United Kingdom. Upon information and
belief, The Bank of England conducts business within and with the City of Chicago.

Barclays Bank PLC

122) Defendant Barclays Bank PLC is a British corporation with its principal place of business
located at 54 Lombard Street, London EC3P 3AH. Its United States office located at Barclays
Bank of New York, 300 Park Avenue, New York, NY 10022. Its Chicago office located at
Barclays Capital Inc., 141 W Jackson Blvd # 3200, Chicago, IL 60604. Upon information and
belief, Barclays conducts business within and with the City of Chicago.

ING Groep N.V.

123) Defendant ING Groep N.V., the parent company of ING Barings is a Dutch company. It
United States office located at ING North America, 5780 Powers Ferry Road NW, Atlanta, GA
30327-4390. Upon information and belief, ING Barings conducts business within and with the
City of Chicago.

Bank of New York

124) Defendant the Bank of New York is a New York corporation with its principal office
located at One Wall Street, New York, NY 10286. Its Chicago office located at BNY Midwest
Trust Company, 209 West Jackson Boulevard Suite 700, Chicago, IL 60606. Upon information
and belief, the Bank of New York conducts business within and with the City of Chicago.

Bank of America Corporation

125) Defendant Bank of America is a North Carolina corporation with its principal place of
business located at Bank of America Corporate Center, 100 North Tryon Street, Charlotte, North
Carolina 28255. Its Chicago office located at Bank of America Center, 231 S LaSalle, Chicago,
IL 60606. Upon information and belief, Bank of America conducts business within and with the
City of Chicago.

N. M. Rothschild & Sons

126) Defendant N M Rothschild & Sons (C.I.) Limited, P.O. Box 58, St. Julian's Court, St. Peter
Port, Guernsey, Channel Islands, GYI 3BP. Its United States office located at Rothschild North
America, 1251 Avenue of the Americas 51st floor, New York, NY 10020. Upon information and
belief, Rothschild conducts business within and with the City of Chicago.

J.P. Morgan Chase & Company

127) Defendant J.P. Morgan Chase & Company is a Delaware corporation with its principal
office located at 270 Park Avenue, New York, New York 10017. Its Chicago office located at J
P Morgan & Co Inc., 227 W Monroe St # 27, Chicago, IL 60606. Upon information and belief,
JP Morgan Chase conducts business within and with the City of Chicago.

Citigroup

128) Defendant Citigroup, also known as Citicorp and Citibank is a New York corporation with
its principal place of business located at Citigroup, 399 Park Avenue, New York, NY 10043. Its
Chicago office located at Citigroup, 11 S. LaSalle Street, Chicago, IL 60603. Upon information
and belief, Citigroup does business with and within the City of Chicago. Upon further
information and belief, Saloman Smith Barney, a division of Citigroup, "issues more municipal
bonds than anybody else in Chicago."

Brown Brothers Harriman & Company

129) Defendant Brown Brothers Harriman & Company is a New York corporation with its
principal place of business located at 140 Broadway, New York, NY 10005-1101. Its Chicago
office located at Brown Brothers Harriman & Co., 125 South Wacker Drive, Suite 2150,
Chicago, Illinois 60606-4402. Upon Information and Belief, United States Steel conducts
business within and with the City of Chicago.

Deutsche Bane AG

130) Deutsche Bane AG is a German corporation with its principal place of business located at
Deutsche Banc, Corporate Center, Taunusanlage 12, 60325 Frankfurt am Main, Germany. Its
United States office located at Deutsche Bank, The USG Building Suite 1900, 222 West Adams
Street, Chicago, Illinois 60606. Upon information and belief, Deutsche Bank conducts business
within and with the City of Chicago.

The Dun & Bradstreet Corporation

131) Defendant The Dun & Bradstreet Corporation is a New Jersey corporation with its principal
place of business located at 103 JFK Pkwy, Short Hills, NJ 07078. Dun & Bradstreet Info Svc.,
55 W Monroe St # 2670, Chicago, IL 60603. Upon information and belief, Dun & Bradstreet
conducts business within and with the City of Chicago.

Lehman Brothers Holdings Inc.

132) Defendant Lehman Brothers Holdings Inc. is a corporation with its principal business at
745 Seventh Ave, New York, NY 10019. Its Chicago office located at Lehman Brothers, 190
South LaSalle Street, Chicago, IL 60603. Upon information and belief, Lehman Brothers
conducts business within and with the City of Chicago.

First Data Western Union

133) Defendant First Data Western Union is a Colorado corporation with its principal office
located at 6200 S. Quebec St., Ste. 320A, Greenwood Village, CO 80111. Its has numerous
locations in Chicago. Upon information and belief, First Data Western Union conducts business
within and with the City of Chicago.

THE INSURANCE INDUSTRY DEFENDANT

Society of Lloyds

134) The Society of Lloyds, also known as Lloyd's of London, is a British corporation with its
principal place of business located at Lime Street, London, EC3M 7HA, UK. It is represented in
the United States by Lloyd's America Inc. with its principal office located at 590 5th Ave., 17th
Floor, New York, NY 10036. Lloyds is represented in Illinois by R. Dean Conlin with its
principal place of business located at 115 South LaSalle Street Suite 2450, Chicago, IL 60603.
Upon information and belief, LLYODS conducts business with and with the City of Chicago.

JURISDICTION AND VENUE

135) This Court has subject matter jurisdiction based on the following:

28 U.S.C. § 1605 in that Defendants the Vatican, the Foreign States, their Heads of States, and
their agencies and instrumentalities, have forfeited their claim to sovereign immunity pursuant
to:

(136)1650(a)(2) "in which the action is based upon a commercial activity carried on in the
United States by the foreign state; or upon an act performed in the United States in connection
with a commercial activity of the foreign state elsewhere; or upon an act outside the territory of
the United States in connection with a commercial activity of the foreign state elsewhere and that
act causes a direct effect in the United States;"

(137)1650(a)(3) "in which rights in property taken in violation of international law are in issue
and that property or any property exchanged for such property is present in the United States in
connection with a commercial activity carried on in the United States by the foreign state; or that
property or any property exchanged for such property is owned or operated by an agency or
instrumentality of the foreign state and that agency or instrumentality is engaged in a commercial
activity in the United Stales;"

(138)1650(a)(4) "in which rights in property in the United Slates acquired by succession or gift
or rights in immovable property situated in the United States are in issue;" and

(139)1650(a)(5) [in which actions] "not otherwise encompassed in paragraph (2) above, in which
money damages are sought against a foreign state for personal injury or death, or damage to or
loss of property, occurring in the United States and caused by the tortuous and terroristic acts act
or omission of that foreign state or of any official or employee of that foreign state while acting
within the scope of his office or employment."

(140) 28 U.S.C § 1331, in that Plaintiff make claims against Defendants under federal common
law as it incorporates jus cogens customary international law and international treaties.

(141) 28 U.S.C § 1332 in that the matter in controversy exceeds the sum or value of §75,00 per
plaintiff and is between citizens of different States and in which citizens or subjects of a foreign
state are additional parties; and

28 U.S.C. § 1367 for any claims not otherwise covered by the aforementioned jurisdictional
bases.

136) Venue is proper in this Court because all Defendants are doing business and may be found
in this District within the meaning of 28 U.S.C. § 1391(b) and/or, as aliens, may be sued in any
district pursuant to 28 U.S.C. § 1391(d),

RELEVANT TIME PERIODS

137) The relevant time period for this civil action is from 1435 to 2003, the time-frame and
time-line of the 568years historical and continuing Maafa, which includes the following
component crimes and sub-periods:

The Trans-Atlantic Slave Trade, dejure from 1435 to 1886, and defacto 2003.

Slavery, dejure from 1435 to 1886.

Slave-like Practices and Conditions, dejure from 1435 to 1930s, and defacto to 2003.

Colonialism, dejure from 1435, and defacto to 2003.

Segregation, dejure from 1435 to 1969, and defacto to 2003.

Apartheid, dejure from 1948 to 1994, and defacto to 2003.

Racism and Racial Discrimination, dejure from 1435 to 1965, and defacto to 2003; and
Xenophobia and Related Intolerance, 2003.

STATUTES OF LIMITATIONS ARE TOLLED

1) Plaintiff's, and Class members' claims, are not time-barred, as the applicable statutes of
limitations have not yet begun to run, and/or they are tolled via one or more of the following
doctrines: Crimes against humanity, Foreign Sovereign Immunity Act, Outrageous
Governmental Misconduct, Federal Accrual/Discovery Rule, Equitable Tolling, Continuing
Violations, and/or Equitable Estoppel.

CRIMES AGAINST HUMANITY

2) Plaintiff incorporates by reference, as if fully set forth herein, the proceeding paragraphs.

3) It is well settled that statutes of limitations do not apply to certain crimes, including:
man-stealing, womanstealing, child abduction, kidnapping, escape from custody, murder, certain
types of frauds, etc.

4) Crimes against humanity, as set forth herein, which include: murder; extermination;
enslavement; deportation or forcible transfer of population; imprisonment or other severe
deprivation of physical liberty in violation of fundamental rules of international law; torture;
rape, sexual slavery, enforced prostitution, forced pregnancy, enforced sterilization, or any other
form of sexual violence of comparable gravity; persecution against any identifiable group or
collectivity on political, racial, national, ethnic, cultural, religious, gender as defined in
paragraph 3, or other grounds that are universally recognized as impermissible under
international law, in connection with any act referred to in this paragraph or any crime within the
jurisdiction of the Court; enforced disappearance of persons; the crime of apartheid; other
inhumane acts of a similar character intentionally causing great suffering, or serious injury to
body or to mental or physical health, are not subject to any statutory limitations or
retroactivity exceptions as well, pursuant to:

a) The Charter of the International Military Tribunal in Nuremberg.

b) The Charter of the International Military Tribunal for the Far East.

c) The Control Council Law No. 10, Punishment of Persons Guilty of War Crimes, Crimes
Against Peace and Against Humanity, 3 official Gazette Control Council for Germany 555,
1946.

d) The Convention on the Prevention and Punishment of the Crime of Genocide, 78 U.N.T.S.
277, entered into force Jan. 12, 1951.

e) The Convention on the Non-Applicability of Statutory Limitations to War Crimes and Crimes
against humanity (the Statute of Limitations Convention), G.A, res. 2391, XXIII), annex, 23
U.N. GAOR Supp. (No. 18) at 40, U.N. Doc. A/7218, 1968.

f) International Criminal Tribunal for Rwanda, Rules of Procedure and Evidence, U.N. Doc.
ITR/3/REV. 1, 1995), entered into force 29 June 1995.

g) Nuremberg Rules, in Agreement for the Prosecution and Punishment of the Major War
Criminals of the European Axis, 82 U.N.T.S. 279, entered into force Aug. 8, 1945.

h) Principles of International Co-Operation in the Detection, Arrest, Extradition and Punishment
of Persons Guilty of War Crimes and Crimes against humanity, G.A. res. 3074, XXVIII), 28
U.N. GAOR Supp. (30A at 78, U.N. Doc. A/9030/Add.l, 1973.

i) The Princeton Principles on Universal Jurisdiction 28, Princeton University Program in Law
and Public Affairs (200).

j) The International Criminal Court, Elements of Crimes, U.N. Doc. PCNICC/2000/l/Add.2,
2000).

k) The International Criminal Court, Rules of Procedure and Evidence, U.N. Doc.
PCNICC/2000/I/Add.l, 2000.

I) The Rome Statute of the International Criminal Court, U.N. Doc. A/CONF. 183/9, 1998),
entered into force July 1, 2002.

5) The Convention on the Non-Applicability of Statutory Limitations to War Crimes and Crimes
against humanity (the Statute of Limitations Convention) declares "that it is necessary and
timely to affirm in international law, through this Convention, the principle that there is no
period of limitation for war crimes and crimes against humanity, and to secure its universal
application." The United Nations General Assembly adopted the Convention to ensure
that "municipal law relating to the period of limitation for ordinary crimes" did not work to
prevent the punishment of those who had committed "the gravest crimes in international law.


6) Forty-five nations have ratified the Statute of Limitations Convention, thereby codifying the
nonapplicability of statutory limitations periods to crimes against humanity.

7) Although the United States has not yet signed nor ratified the Statute of Limitations
Convention, at least one United States federal court has recognized that the United States would
recognize non-applicability of time limits as a binding principle under customary international
law. In Handel v. Artukovic, 601 F. Supp. 1421, C.D. Ca. 1985), the court noted that "[f]rom the
proceedings in the United Nations General Assembly, it appears that the United States did
support the principle of a statute of no limitations." Id. at 1430. The court explained:

"The reasons enumerated by the delegation for opposing the draft convention do not suggest that
the United States had any reservations about this initial purpose [to make clear that under
international law there are no periods of limitation applicable to war crimes and crimes against
humanity]. Indeed, in a prior press release, the [United States] delegation had ‘urge[d] the
Committee to reconsider whether it would not be better to return to the original purpose of this
item - namely, to produce a convention limited simply to non-application of statutes of
limitations to war crimes and crimes against humanity.' Press Release US-UN 161, 1968),
October 9, 1968. Thus, while the United States did not sign the resulting convention, it appears
to recognize the principle that a statute of no limitation should be applied to the criminal
prosecution of war crimes and crimes against humanity. Id. at 1430."

8) Article 29 of the Rome Statute of the International Criminal Court also provides "that crimes
against humanity shall not be subject to any statute of limitations."

9) The principles, of the non-applicability of statutes of limitations and non-impunity for crimes
against humanity, have attained the status of customary international law. "[U]nder customary
international law, which is supreme ... law [in the United States], there is no statute of limitation
properly applicable to war crimes, and the same should generally hold true with respect to other
international criminal activity.") (footnotes omitted; Restatement Third (Foreign Relations) §
111, cmt. e ("[C]ustomary international law [is] federal law and as such [is] supreme over State
law.)."

10) Additionally, crimes against humanity are exempt from statutory limits because universally
condemned offenses generally are not subject to time limits on prosecution. In addition, the fact
that universal offenses are not subject to statutes of limitations is demonstrated by comment (a)
to § 404 of the Restatement (Third) Foreign Relations entitled, "Universal Jurisdiction to Define
and Punish Certain offenses," which provides that "[u]niversal jurisdiction for additional
offenses is provided by international agreements.... A universal offense is generally not subject
to limitations of time." See Restatement § 102, comment f (emphasis added; see also Report of
the Special Rapporteur, U.N. Commission on Human Rights, Sub-Commission on Prevention of
Discrimination and Protection of Minorities, 50th Sess., Agenda Item 6, at ¶ 87, U.N. Doc.
E/CN.4/Sub.2/1998/13, 1998) ("It is well established that there are no statute of limitation
barriers to prosecutions for serious crimes under international law.").

11) In Deinjanjok v. Petrovsky a United States District Court traced the principle of universal
jurisdiction back to the Nuremberg Trials, and found that the "...principle that the perpetrators of
crimes against humanity... are subject to universal jurisdiction found acceptance in the aftermath
of World War II." The United States Sixth Circuit Court of Appeals, affirming the lower court
ruling in Demjanjuk found that "under this jurisdictional premise, neither the nationality of the
accused or the victim(s), nor the location of the crime is significant. The underlying assumption
is that the crimes are offense against the law of nations or against humanity and that the
prosecuting nation is acting for all nations."

12) Plaintiff therefore suggests that the Court "should apply the well-established Charming Betsy
rule of" statutory construction which requires that [[they] generally construe Congressional
legislation to avoid violating international law. Weinberger v. Rossi, 456 U.S. 25, 32, 1982)
(citing Murray v. The Schooner Charming Betsy, 6 U.S. (2 Cranch) 64, 117-118, 1804)). See,
e.g., Jordan J. Paust, International Law As Law of the United States 107-08 n.9, 1996;
Restatement (Third) of the Foreign Relations Law of the United States Q114, 1987). [Courts]
have reaffirmed this rule on several occasions. In United States v. Thomas, 893 F.2d 1066, 1069,
9th Cir. 1990), [the court] explained that we adhere to this principle "out of respect for other
nations." Id. at 1069, citing Chua Han Mow v. United States, 730 F.2d 1308, 1311(9th Cir. 1984;
see also In re Simon, 153 F.3d 991, 998, 9th Cir. 1998).

13) Even if the Court takes the position that a statutory limitations period can be applied to
crimes against humanity despite clear international law to the contrary, there are alternative
bases for holding that that time period be tolled for many of the offenses set forth herein.

FOREIGN SOVEREIGN IMMUNITY ACT

14) Plaintiff incorporates by reference, as if fully set forth herein, the proceeding paragraphs.

15) No statute of limitations applies to this action because it is well settled that "Congress
directed in the AntiTerrorism and Effective Death Penalty Act of 1966 that ‘The Amendments
made by this subtitle, [to the Foreign Sovereign Immunity Act], shall apply to any cause of
action arising before, on or after the date of the enactment of this Act (April 24, 1966;' and
because ‘a finding of civil liability and the attendant imposition of compensatory damages does
not suffice to make the retrospective application of a law invalid'. [See Landgraf v. USI Film
Prods., 511 U.S. 244, 281, 1994) and United States v. Ward, 448 U.S. 242, 248-49, 1980)]."

16) No statute applies to this action because the States, domestic and foreign, as set forth herein,
"have impliedly or explicitly waived sovereign immunity as it applies before 1952 by imposing
retroactive application of the Foreign Sovereign Immunity Act, and reparations generally, to
Axis Powers after World War II. To the extent that [States, foreign and domestic] have justly
held, [and continue to justly hold], Germany retroactively accountable for reparations to Jewish
victims of the Holocaust, [States, foreign and domestic, historically and currently], have exposed
themselves to retroactive accountability" for the Maafa as well.

17) "Swiss Banks and German companies have been and are being held accountable for their
collusion and conspiracy with the Nazis, although they were acting within the bounds of
international, positive and municipal laws at the time."

18) Plaintiff reminds the Court that it is well settled that the overarching permanent moral
framework of equity, justice and international law is that it must and does apply equally to all
wrongdoers, and equally to the pleas of all victims of all wrongs, at all times.

INEFFECTIVE COURT SYSTEM

19) Plaintiff incorporates by reference, as if fully set forth herein, the proceeding paragraphs.

20) Statute of limitations presumes that the country where the alleged offender resides, or where
the crime was committed, has a court system amenable to prosecution. International law clearly
establishes that statutes of limitation for offenses are tolled because a court system is ineffective
or unwilling to prosecute and/or because it denies the victims their human and
inalienable right:

"To equal recognition as a person before the law;"

"To be treated as an equal before the Courts and tribunals;" and

"To have an effective remedy, notwithstanding that the violation[s] [have] been committed by
persons acting in an official capacity."

1) Defendants, and their predecessors, tortured, raped, murdered, kidnapped, exploited and
discriminated against Plaintiff, Class members, and their Ancestors; stole and converted to their
own use the value of our bodies, labor, lands and resources, in every corner of Africa and the
African Diaspora; and forced us to live under slavery, colonialism, segregation, apartheid and
genocide-like conditions, in blatant disregard for and violation of the laws of nature, cannon law,
the law of nations, customary international law, international treaties, agreements and
obligations; and in blatant disregard for and violation of their own edicts, proclamations,
declarations, preambles, constitutions and municipal laws.

2) Defendants, and their predecessors, created all manner of legal fictions and historical myths to
justify and hide their 568-years of historical and continuing crimes against Africa, African
People, and humanity, and their wrongful and unjust enrichment at our expense. These legal
fictions and historical myths continue today, and form the basis for this complaint, as evidenced
by Plaintiff's, and Class members allegations, fact and causes of action, and Defendants response
and defense.

3) Defendants, and their predecessors, claimed, and continue to claim, that we were sold to them
as prisoners of war and convicts, or given to them by thankful chiefs; but not once, in any court
of law, diplomatic forum or history book, have they produced a contract, a bill of sale, a treaty,
or their thank you note.

4) All manner and untold amounts of documents and information about the Maafa, about the
Trans-Atlantic slave trade and slavery, can now be found by literally surfing millions of
webpages on the Internet, by browsing thousands of online library and archival catalogues, or
through accessing hundreds of CD-ROMs which can be now be found at local libraries or for
sale on Amazon.com, as Plaintiff discovered while researching this complaint. Why can we not
find one contract, one bill of sale, one treaty, one thank you note, that can validate Defendants',
and their predecessor's, claim?

5) At no time, have Defendants, or their predecessors, explained to us, or our Ancestors, or
documented in a court of law, the justness and legality of these alleged penal laws and alleged
tribal wars; their justness and legality as defined by Grotius, Vatel, Blackstone, and others,
whose writings were accepted and implemented at that time, as canon, customary international,
and municipal law. Not once have Defendants, or their predecessors, explained their role in
fomenting and profiteering from these unjust wars, and creating the conditions for these alleged
crimes.

6) According to Defendants', and the predecessor's story, they just happened to be innocently
passing by, thousands of miles from home, on ships laden with guns, chains, and trinkets to
trade. Defendants, their predecessors, and their co-participants simply said their story was true,
and the Courts, and we, believed, heard, felt, believed, wished, or knew it to be other wise.

7) Slave-raiders, slave-traders, slave-holders, slave-masters, their co-participants, and
successors, including Defendants who are named herein, "created" hundreds and perhaps
thousands of legal fictions, including, but not limited to the Code Noir, the Codigo Negro
Espanol, the Barbados Code, the Virginia Code, the Louisiana Code (1724), the Texas Code, the
Black Codes and Black Laws, the Jim Crow Laws, the Colonial Laws, the Segregation Codes,
the Apartheid Codes, and similar laws still in force today, in order to "legalize," regulate, and
justify their 568-year historical and continuing crime against African and world humanity.

8) Defendants, especially the Vatican and State Defendants, knew then and know now, that these
Bulls, codes and laws, like the Nazi codes and laws of the 1930s, were and are odious and
repugnant to civilized humanity, to the laws of nature, canon law, the law of nations, customary
international law, and international treaties, agreements and obligations as they existed then, and
now, and that these laws and codes were and are null and void. Plaintiff cites herein several
examples which prove that Defendants knew and know, or should have known and should know,
this fact.

9) Time after time, beginning in 1435 as set forth herein, Defendants, especially the Vatican and
the State Defendants, foreign and domestic, and their Heads of States, instrumentalities and
agencies, all of whom traded in and held slaves, and were unjustly enriched by and through the
Maafa issued countless promises, proclamations, edicts and laws, as set forth herein, promising
us freedom, protection, security, dignity, and land, and our most basic and fundamental civil,
political, economic, social, cultural and spiritual rights.

10) Time after time, as set forth herein, these promises, proclamations, edicts and laws were
willfully, intentionally, and maliciously not implemented, with impunity; and time after time, as
set forth herein, these promises, proclamations, edicts, laws, duties and trust were arbitrarily and
summarily revoked or breached, for the sole purpose of maintaining and extending Defendants',
and their predecessor's, power, and enriching themselves, their Families, their corporations, their
institutions, and their nations at the expense of Plaintiff, Class members, and their Ancestors.

11) It is undeniable, and documented herein, that from 1435, Plaintiffs, Class member's, and their
Ancestors', most basic and fundamental rights, liberties and freedoms; our humanity, personality
and dignity, were egregiously alienated, abridged and denied. Plaintiff offers here, one of the
most egregious of these alienations, abridgements and denials. Chief Justice Taney, a member of
a slaveholding family as was four other members of the U.S. Supreme Court at the time, in the
majority opinion for the Dred Scott decision, proclaimed that:

"The Africannegro race never have been acknowledged as belonging to the family of nations;
that as amongst them there never has been known or recognized by the inhabitants of other
countries anything partaking of the character of nationality, or civil or political polity; that this
race has been by all the nations of Europe regarded as subjects of capture or purchase; as
subjects of commerce or traffic; and that the introduction of that race into every section of this
country [and every country in the Western Hemisphere] was not as members of civil or political
society, but as slaves, as property in the strictest sense of the term."

12) Plaintiff, and Class members, argue in this complaint, that this alienation, abridgment and
denial continues today, albeit in more sophisticated and diplomatic forms and ways.

13) The Dred Scott decision was the "law of the land," until changed by the Civil War, at a total
direct cost of $6.7 billion, $1.5 billion in physical capital destruction in the south, $3.3 billion in
human capital destruction ($1.6 billion for 618,000 dead and $.63 billion for 500,000 wounded,
and the loss of $.434 billion in insurance risk premiums); and by the 13th Amendment
to the United States Constitution, which prohibited slavery, and yet pennitted slave-like
conditions and practices to continue, even today. The price that was paid by 4 million slaves,
whose humanity and dignity was once again denied, and whose enslavement and misery was
once again prolonged, and the price that their Descendants---Plaintiff and Class members,
continue to pay, for this wrongful and unjust Supreme Court decision, must and will be assessed
as well.

14) The Dred Scott decision was the law of the land, but civilized world humanity, then and
now, knew and know that this opinion, this decision, this law, was and is odious and repugnant
to cannon law, to the municipal laws of most European States and many countries in the Western
Hemisphere, and to customary international, as it was and is settled then and now, and therefore
was and is null and void. Civilized humanity knew then, and know now, that the slave trade and
slavery was and is a crime against humanity as well.

15) The Republican Party, and Abraham Lincoln, knew that the slave trade and slavery were and
are odious and repugnant to civilized humanity, openly admitted this, campaigned for, and won
the presidency of the United States in 1860 on a National Platform, which declared in Paragraphs
8 and 9, that:

"Thai the normal condition of all the territory of the United Slates is that of freedom. That as our
Republican fathers, when they had abolished slavery in all our national territory, ordained that
no person should be deprived of life, liberty or property, without due process of law," it becomes
our duty by legislation, whenever such legislation is necessary, to maintain this provision of the
Constitution against all attempts to violate it; and we deny the authority of Congress, of a
territorial legislature, or of any individuals, to give legal existence to slavery in any territory of
the United States." [Emphasis added.]

"That we brand the recent re-opening of the Africanslave trade, under the cover of our national
flag, aided by perversions of judicial power, as a crime against humanity and a burning shame to
our country and age; and we call upon Congress to take prompt and efficient measures for the
total and final suppression of that execrable traffic." [Emphasis added.]

16) Time after time, Defendants, their predecessors, and co-participants, especially the Vatican
and State Defendants, their Heads of States, instrumentalities, agencies, and agents, admonished
us, often at the pain of injury, imprisonment or death, that God and the law was on their side, not
ours; that there was nothing that we could, should or would be permitted to do to change or
improve our situation; that we should just make do with what we have, forget the past, and pray
for a better day; that Defendants, and their predecessors, would not, and could not, be held
responsible for their wrongful and illegal acts; and that they would not, and could not, be
compelled to account for, and disgorge their illicit and unjust gains. The evolution and recent
development of human rights and international law proves these admonishments to not be true,
and to have never been so.

17) For 568-years, fundamental notions and principles of the concept of human rights, and of the
evolving development and status of customary international law, were and are being deliberately,
wrongfully and unjustly "turned on their head;" and state complicity in gross violations of
human rights and crimes against humanity, coverup, and other obstructions, has affected, and
continues to affect the very possibility of justice.

18) The violations of international law and the crimes against humanity, historically and
currently, as set forth herein, exposes the impact of the role of States, foreign and domestic, as a
significant element of the circumstances of justice and equity, which has been, and is still being,
compromised.

19) It is well settled that statute of limitations is tolled pending the availability of a court system
to prosecute for such crimes. See Hanger v. Abbott 73 U.S. 532, 540 (1867) (Mem.) (finding that
the statute of limitation for enforcing a creditor's claim is "suspended during the period the
creditor is prohibited, by the existence of the war and the law of nations, from enforcing his
claim.;" 51 Am. Jur. 2d Limitation of Actions § 175).

20) It is also well settled that continuing violations in absence of judgement and punishment,
especially those that include state complicity, conspiracy, conversion, and cover-up; were the
ostensible custodians of justice were and are its violators; and where they benefited from, and
continue to benefit from, the commission, cover-up and denial of the gross and long-term acts
and course of conduct stated herein, justifies lifting ordinary time limits on prosecution of the
violations of international law, crimes against humanity, as set forth herein.

FEDERAL ACCRUAL/DISCOVERY RULE

21) Plaintiff incorporates by reference, as if fully set forth herein, the proceeding paragraphs.

22) It is well settled, that where plaintiff would have had difficulty discerning the fact or cause of
injury at the time it was inflicted, the so-called "diligence-discovery rule of accrual applies."

23) Although intimately and painfully aware of the horrific practices and conditions of the
568-year historical and continuing Maafa, and of the injuries and damages, pain and suffering,
which they were forced to endure under, during and through the Maafa, which includes, but is
not limited to: the Trans-Atlantic Slave Trade; slavery and slave-like conditions and practices;
colonialism, segregation and apartheid; racism and racial discrimination; sexual exploitation,
harassment and violence; and xenophobia and related intolerance, Plaintiff, and Class members,
have remained in ignorance of vital information essential to pursue and win their claims, without
any fault or want of diligence or due care on their part.

24) Governmental, family, corporate, and institutional histories and records have been
inaccessible to Plaintiff, and Class members, until recently. Research documenting the
magnitude, scope, scale, and duration of the tortuous and terroristic acts herein described, and
tracing the monetary and other benefits derived by Defendants, their predecessors, and
co-participants, in the commission of the herein described crimes, have been deliberately and
maliciously denied to Plaintiff, and Class members, and have only recently become accessible
and affordable to Plaintiff, Class members, and the general public.

25) Defendants', their predecessor's, and co-participant's, actions in willfully and intentionally
concealing, omitting, and misrepresenting their participation in, aiding and abetting of, and
unjust enrichment by and through their, and their predecessor's, participation in the Maafa; in
failing to disclose and make public the truth about the Maafa, its illegality and immorality; and
their conspiracy of silence, denials, misrepresentations of fact, material omissions, fraud and
deceit, constitutes deliberate, continuous, and continuing crimes. The conduct and acts of each of
Defendant, their predecessors, and co-participants, by their deliberate, wrongful and unjust
failure and refusal to provide an accounting to Plaintiff, and Class members, and their failure and
refusal to disgorge the illicit and untold profits that were reaped, and continue to be reaped, as a
result of this 568-year historical and continuing conspiracy, constitutes continuing torts that toll
the statute.

26) Moreover, knowing that their behavior violated and continues to violate customary
international law; and that said conduct and acts were and are crimes against humanity with no
statute of limitations and no immunity or impunity, Defendants, their predecessors and
co-participants, have willfully and repeatedly refused and failed, and continue to refuse and fail,
to acknowledge and make an apology for their criminal conduct and acts, or negotiate or
legislate redress, remedy, restitution, reparations, repatriations, and the right to return.
Defendants are therefore estopped from interposing any type of time bar defense to these claims.

27) Plaintiff, and Class members, have only recently become aware of our right to be recognized
by, and to raise before this Court, the questions of law and fact set forth within. We have only
recently begun to gain access to the information and analysis required to properly raise and
successfully adjudicate these questions of law and fact. It is only now therefore, that real
discovery, through no lack of dues diligence on the part of Plaintiff, Class members, or their
Ancestors, can begin; and therefore the statute of limitations has begun to run only now.

28) Delayed discovery by Plaintiff, and Class members, through no lack of diligence or fault of
their own, of the true and full extent of the harm caused by the Defendants, their predecessors,
and co-participants; the willful and malicious failure and refusal of Defendants, their
predecessors, and co-participants to disclose vital documents and information needed to state
Plaintiffs, and class members, claims, therefore tolls or suspends the statute of limitations against
all Defendants as to all claims set forth herein.

EQUITABLE TOLLING

29) Plaintiff incorporates by reference, as if fully set forth herein, the proceeding paragraphs.

30) It is well settled that:

a) "The essence of the doctrine of equitable tolling is that a statue of limitations does not run
against a plaintiff who is unaware of his cause of action."

b) A "[c]laim will accrue when the plaintiff knows, or should know, enough of the critical facts
of injury and causation to protect himself by seeking legal advice. A claim does not accrue when
a person has a mere hunch, hint or suspicion, or rumor of a claim..." Kronisch v. United States.
150 F.3d 112, 121, 2d Cir. 1998), cert denied, 531 U.S. 1078, 2001). Accrual may be postponed
until the plaintiff has or, with reasonable diligence, should have discovered the critical facts of
both his injury and its cause."

c) Statue of limitations does not begin to run "until the concept of prohibition of the causes of
action set forth herein, were recognized as a fact of the jus cogens body of international law, and
until they reach a sufficient level of general knowledge and acceptance."

2) The doors to the court houses and legislatures of the United States and the world, have been,
and remain effectively closed, with respect to the claims, the class, legal and factual questions
and allegations, and the causes of action which Plaintiff, and Class members, raise in the instant
litigation.

3) Plaintiff, Class members, and their Ancestors, have been repeatedly told that we were seeking
access to and redress from the wrong forum; that the Maafa, the Trans-Atlantic Slave Trade and
slavery was legal; that causes of action and injuries in fact did not exist; that victims,
perpetrators, and witnesses were long dead, and that evidence never existed or was long
destroyed. Access to judicial, legislative, executive and international forums for seeking
recognition, remedy, restitution, reparations, repatriation and relief has been, and continues to
be, effectively denied.

4) Defendants named herein, and unnamed, have had, and continue to have, an extraordinary
lifespan. They have participated in, and continue to participate in every aspect of the Maafa.
They have been, and continue to be, wrongfully and unjustly enriched by and through their
participation in every aspect it. They should therefore be held accountable for any and all illegal
conduct and acts, for the crimes against humanity, that they, or their predecessors, and
co-participants, engaged in, and/or continue to engage in, and for any and all wrongful and
unjust enrichment that has been, and continues to be gained, from such illegal conduct and
actions.

5) Plaintiff, Class members, and their Ancestors, have been victimized for an extraordinary
amount of time, and should not be further penalized by or for Defendants, their predecessors, and
their coparticipants, historical and continuing concealment, misrepresentations, omissions, lies,
fraud and deceit

6) The extraordinary set of circumstances, economic, social, political and legal, which Plaintiff,
Class members, and their Ancestors, have endured over the past 568 years, and which continues,
albeit in different, more subtle and sophisticated forms and ways today, which prevented and
continues to prevent Plaintiff, and Class members, from gaining equal recognition before, equal
access to, and an effective remedy from the justice system, are sufficiently unique and
extraordinary so as to warrant the application of equitable tolling to any and all applicable statute
of limitations, in the interest of fairness, equity, justice, and the rule of customary international
law.

7) Man-stealing, woman-stealing, child abduction, kidnapping, piracy, the slave trade, slavery
and slave-like practices and conditions, colonialism, segregation and apartheid, racism and racial
discrimination, and crimes against humanity, were and are prohibited, and illegal, under the laws
of nature, cannon law, the law of nations, and customary international law, as set forth herein,
whether the victims and the perpetrators recognized, knew or accepted this fact or not.

8) Crimes against humanity have risen to the status of jus cogens in customary international law,
and are obligations erga omnes. Barcelona Traction, Light and Power Company, Limited.
Second Phase. Judgement. I.C.J. Report 1970, p. 32, paras 33-4. (See also The Appearance of the
Concept of Obligations Erga Omnes on the Agenda: the dictum of the International Court in the
Barcelona Traction Case.]

9) Equitable tolling is therefore mandated as this complaint presents one of "those rare instances
where - due to circumstances external to the party's own conduct --- it would be unconscionable
to enforce the limitation period against the party and gross injustice would result."

CONTINUING VIOLATIONS

10) "The continuing violations doctrine tolls the running of the statute of limitations on all
[wrongful] acts until the defendant has taken its last [[wrongful] act." The continuing
violations doctrine also allows for claims outside a given limitations period if there is a "shared
nexus" between that conduct and conduct occurring within the limitations period.

11) Moreover, the United States Supreme Court, in Thompson v. Metropolitan Life Ins. Co.,
with Justice Thomas delivering the opinion, has ruled that:

"A charge alleging a hostile work environment will not be time barred if all acts constituting the
claim are part of the same unlawful practice and at least one act falls within the filing period; in
neither instance is a court precluded from applying equitable doctrines that may toll or limit the
time period."

"A plaintiff can establish a continuing violation that allows recovery for claims filed outside of
the statutory period in one of two ways. First, a plaintiff may show ‘a series of related acts one or
more of which are within the limitations period.' ... Such a ‘serial violation is established if the
evidence indicates that the alleged acts of discrimination occurring prior to the limitations period
are sufficiently related to those occurring within the limitations period.' ... The alleged incidents,
however, ‘cannot be isolated, sporadic, or discrete.' ... Second, a plaintiff may establish a
continuing violation if he shows ‘a systematic policy or practice of discrimination that operated,
in part, within the limitations period--a systemic violation."

"A discrete retaliatory or discriminatory act ‘occurred' on the day that it ‘happened.' A party,
therefore, must file a charge within either 180 or 300 days of the date of the act or lose the ability
to recover for it. ... Hostile environment claims are different in kind from discrete acts. Their
very nature involves repeated conduct. See 1 B. Lindemann & P. Grossman, Employment
Discrimination Law 348-349, 3d ed. 1996) (hereinafter Lindemann) (‘The repeated nature of the
harassment or its intensity constitutes evidence that management knew or should have known of
its existence'). The ‘unlawful employment practice' therefore cannot be said to occur on any
particular day. It occurs over a series of days or perhaps years and, in direct contrast to discrete
acts, a single act of harassment may not be actionable on its own. (See Harris v. Forklift Systems
Inc., 510 U. S. 17, 21, 1993)."

"Determining whether an actionable hostile environment claim exists requires an examination of
all the circumstances, including the frequency of the discriminatory conduct; its severity;
whether it is physically threatening or humiliating, or a mere offensive utterance; and whether it
unreasonably interferes with an employee's work performance. Id., at 23. The question whether a
court may, for purposes of determining liability, review all such conduct, including those acts
that occur outside the filing period, turns on the statutory requirement that a charge be filed
within a certain number of days ‘after the alleged unlawful employment practice occurred.'
Because such a claim is composed of a series of separate acts that collectively constitute one
‘unlawful employment practice,' it does not matter that some of the component acts fall outside
the statutory time period. Provided that an act contributing to the claim occurs within the filing
period, the entire time period of the hostile environment may be considered for the purposes of
determining liability. That act need not be the last act. Subsequent events may still be part of the
one claim, and a charge may be filed at a later date and still encompass the whole. Therefore, a
court's task is to determine whether the acts about which an employee complains are part of the
same actionable hostile work environment practice, and if so, whether any act falls within the
statutory time period."

12) The recent Supreme Court decision, National Railroad Passenger Corp. v. Morgan, 122 S.
Ct. 2061, June 10, 2002), provides further guidance on the application of the continuing
violations doctrine. In Morgan, the Court distinguished between claims alleging discrete
retaliatory or discriminatory acts and hostile work environment claims. Id. at 2070. The Court
held that, for purposes of a hostile work environment claim under Title VII, 42 U.S.C. §
2000e-5(e)(1), if any act that is "part of the actionable hostile work environment practice" falls
within the statutory time period, plaintiffs claim will be viable. 122 S. Ct. at 2076.

13) Plaintiff and Class members, aver that the 568-year historical and continuing Maafa, was and
is an criminal, economic enterprise, scheme and course of conduct; and was and is an extremely
hostile and unlawful work environment, practice and condition.

14) Plaintiff, and Class members, also aver that the causes of actions as set forth herein, which
constituted, and continue to constitute a series of literally hundreds of thousands of related and
illegal acts, were committed by Defendants, and their predecessors, during the 568-year
historical and continuing Maafa, from 1435 to today, and at all time periods and sub-periods
relevant to this complaint; and that Defendants, and their co-participants, continue to commit, aid
and abet. and/or be wrongfully and unjustly enriched by and through a series of related and
illegal actions as set forth herein, today.

15) Defendants, their predecessors and their co-partners, historical and continuing failure to stop
their tortuous and terroristic acts and hostile acts, and to acknowledge and apologize for them;
their historical and continuing efforts to withhold documents and information; their affirmative
concealing and selfconcealing conduct; their historical and continuing failure to provide a full
and transparent accounting, and to disgorge their illicit and unjust gains; their historical and
continuing failure to make restitution; and their historical, continuing and fraudulent
misrepresentations that the moral, legal and material basis for restitution is not identifiable and
required, constitute a continuous and continuing violation of the law.

16) It is settled that the nature of Plaintiff's claim is such that the continued denial of their assets,
as well as facts and information relating thereto, if proven, constitutes a continuing violation."

17) It is also settled that continuing violations in absence of judgement and punishment,
especially where state complicity and cover-up are involved; where the ostensible custodians of
justice, equity and the rule of law are included among its violators; and where Defendants
benefited from, and continue to bcnefit from, these violations, complicity and cover-up, justifies
lifting the ordinary time limits on the prosecution of the causes of action as set forth herein.

18) The statute of limitations has not therefore begun to run, because the causes of action as set
forth herein, which constitute a series of related, historical and continuing unlawful acts,
including the consumer protection and Chicago Slavery Era Disclosure Act claims; and which
constitute a 568-year historical and continuing hostile work environment, practice and condition,
are continuing.

EQUITABLE ESTOPPEL

19) From the preceding Federal Accrual/Discovery Rule and Equitable Tolling sections related
to Defendants efforts to withhold documents and information, and with respect to their
fraudulent misrepresentations and omissions of material facts, Plaintiff argues that Defendants
are equitable estopped from asserting a statute of limitations defense because Defendants, their
predecessors, and their coparticipants, at all time periods and sub-periods relevant to this
complaint, including in the years 2002 and 2003, fraudulently misrepresented and/or concealed
material facts as set forth herein.

20) Defendants, their predecessors, and their co-participants, knew, or had reason to know, the
falsity of their misrepresentations and concealment.

21) Plaintiff, Class members, and their Ancestors, did not know, or have reason to know, that
Defendants misrepresentations or concealment was false.

22) Defendants, and their Ancestors, intended, or expected that Plaintiff, Class members, and
their Ancestors would detrimentally rely on Defendants', and their predecessor's
misrepresentations or concealment.

23) Plaintiff's, Class members, and their Ancestor's, detrimental reliance was reasonable and in
good faith; and Plaintiff, and Class members, would be prejudiced if Defendants were permitted
to avoid accountability for the falsity or their misrepresentations or concealment.

24) Defendants, their predecessors and co-participants, withheld documents and information
related to the 568-year historical and continuing Maafa, and/or lied about the legality of it, about
their participation and role in it, and their wrongful and unjust enrichment by and through it; and
they continue to withhold documents and information and lie about today.

25) Defendants, their predecessors and their co-participants benefited from concealing these
documents and information, and the concealment was so thorough and complete, that its is
impossible to believe that they ere not aware of and deliberate in their concealment.

26) Plaintiff did not know, or have concrete proof, of the Defendants, their predecessors and
coparticipants conduct or illegal profits and therefore could not have known of, or proven, the
concealment and misrepresentation.

27) Defendants, their predecessors and co-participants, knew that their concealment would shield
them from accountability for their actions, and having to disgorge their illicit gains.

28) Plaintiff's, Class members, and their Ancestors lack of knowledge and proof was reasonable
and in good faith given Defendants, their predecessors, and their co-participants, 568-year
historical and continuing conduct, and given the unique, horrific and limiting economic, social,
political and legal conditions that Plaintiff, Class members, and their Ancestors, were forced to
live under and endure for 568years, and given the horrific conditions that the overwhelming
majority of Class members are forced to live under in Africa and the Africa Diaspora today.

29) Equity, justice, and the rule of law could not be served, by allowing Defendants, and their
coparticipants to continue to benefit from the affirmative concealing and self-concealing
behavior and conduct as measured against the extreme harm and suffered by Plaintiff, Class
members, and their Ancestors.

30) It is a well settled and deeply rooted principle of equity, justice and customary international
law, that estoppel to plead the statute of limitations is often invoked on the broad general
principle that one may not take advantage of one's own wrong.

31) Defendants, their predecessors and co-participants, especially the Vatican and State
Defendants, have a moral and legal obligation to stop their continuing and tortuous and
terroristic acts scheme, course of conduct and acts, and a "duty to speak" against these injustices,
past and current, and against those who commit, aid and abet, and/or are wrongfully and unjustly
enriched by them.

32) Defendants', their predecessor's, and co-participant's, silence, misrepresentations, omissions,
lies, fraud and deceit, historically and currently, are enough to move taking statute of limitations
problems off the stage.

33) Finally, the magnitude, scope, scale and duration of the 568-year historical and continuing
Maafa; its transcendent moral evil and truth; the untold horrors, injuries and damages, pain and
suffering that has been and continues to be endured by the Plaintiff, Class members, and their
Ancestors; the role of Defendants, especially State Defendants, in participating in, conspiring to
participate in, aiding and abetting, and being wrongfully and unjust enrichment by and through
this 568 criminal enterprise, scheme and course of conduct, this 568-year immoral and illegal
commercial commerce and trade, which is continuous and continuing; and the growing moral
concern and outrage as evidenced at the 3rd World "Conference Against Racism, are tormenting
and extraordinary facts and circumstances" which warrant application of the doctrine of
equitable estoppel.

34) Plaintiff, and Class members, aver that the application by this Court of the doctrine of
equitable estoppel to the causes of action set forth herein is required and demanded in the name
of equity, justice, and the rule of customary international law; and that said judgement is in the
general public interest, in the United States, the Africa Diaspora, Africa, and the world.

35) Plaintiff, and Class members, further aver, that to not do so, would be to commit another
crime against African and world humanity.

SECONDARY LIABILITY

AIDING AND ABETTING LIABILITY

36) United States courts "have long recognized that individuals may be held civilly liable for
tortuous and terroristic acts violations of customary international law even if they did not direct
or actively participate in such acts. In The Amiable Nancy, (1 F. Cas. 765, Cir. Ct., D. N.Y.,
1817), for example, the Circuit Court considered whether victims of piracy could sue the owners
of the ship whose crew had preyed upon them. According to the Circuit Court,

"[l]t has long been regarded as a general principle of maritime law, and not resulting from any
special contract, that owners of a privateer are liable for torts committed by captains whom they
may employ; and whatever doubt may have once existed as to the extent of this responsibility, it
is now well settled, that it is not limited by the value of the privateer, which would often prove a
very inadequate compensation, but that they are personally accountable for the whole of the
injury committed." Id. at 768. This position was affirmed by the U.S. Supreme Court, which held
that the owners were liable, notwithstanding the fact that they were "innocent of the demerit of
this transaction, having neither directed it, nor countenanced it, nor participated in it in the
slightest degree." I The Amiable Nancy, 16 U.S. 546, 559, 1818). See also Harmony v. United
States, 43 U.S. 210, 234-235, 1844)."

The finding of liability in above cited cases is "supported by several federal statutes, including
18 U.S.C. § 1657, which establishes criminal liability for" "[w]hoever consults, combines,
confederates, or corresponds with any pirate or robber upon the seas, knowing him to be guilty
of any piracy or robbery...," and 18 U.S.C. § 1654, which establishes criminal liability for
"whoever purchases any interest in any" private vessel of war or privateer "with a view to share
in the profits thereof..." See also United States v. Howard, 26 F. Cas. 390 (C.C. Pa. 1818)."


"Recent cases have emphasized the notion of individual liability for violations of international
law in more emphatic terms. In Easlman Kodak Co. v. Kavlin, 978 F. Supp. 1078, S.D. Fla.
1997), for example, the district court noted that customary international law prohibits conspiring
to commit violations of international human rights law, even when such conspiracy occurs
between private individuals and foreign Government s."

"As a matter of initial impression, the Court believes that it would be a strange tort system that
imposed liability on state actors but not on those who conspired with them to perpetrate illegal
acts through the coercive use of state power. Although the negative prohibitions of our own
Constitution generally extend only to state action, those who conspire with state actors to invade
the constitutional rights of others may be held liable along with the state actors."

37) International law also recognizes secondary liability for aiding and abetting. Article 11(2) of
Control Council Law No. 10, Punishment of Persons Guilty of War Crimes, Crimes Against
Peace and Against Humanity, Dec. 20, 1945, of the Nuremberg Military Tribunals "authorized
the prosecution of persons guilty of war crimes, crimes against peace, and crimes against
humanity, identified several forms of individual acts that could give rise to liability."

"Any person without regard to nationality or the capacity in which he acted is deemed to have
committed a crime as defined in paragraph 2 of this Article, if he was (a) a principal or (b) was
an accessory to the commission of any such crime or ordered or abetted the same or (c) took a
consenting part herein or (d) was connected with plans or enterprises involving its commission
or (e) was a member of any organization or group connected with the commission of any such
crime or (f) with reference to paragraph l(a), if he held a high political, civil or military
(including General Staff) position in Germany or in one of its Allies, co-belligerents or satellites
or held high position in the financial, industrial or economic life of any such country."

38) "In Prosecutor v. Furundzija, IT-95-17/1-PT (Dec. 10, 1998), reprinted in 38 I.L.M. 317,
1999), for example, the Trial Chamber for the International Criminal Tribunal for the former
Yugoslavia indicated that ‘not only the commission of rape or serious sexual assault, but also the
planning, ordering or instigating of such acts, as well as aiding and abetting in the perpetration,
are prohibited.' Id. at para. 187. ... In sum, the Trial Chamber holds the legal ingredients of
aiding and abetting in international criminal law to be the following: the actus reus consists of
practical assistance, encouragement, or moral support which has a substantial effect on the
perpetration of the crime. The mens rea required is the knowledge that these acts assist the
commission of the offence."

39) The Rome Statute of the International Criminal Court contains similar provisions that
establish individual criminal liability for various forms of participation. Rome Statute of the
International Criminal Court, July 17, 1998, U.N. Doc. A/CONF.183/9. (1998), Article 25, for
example, provides that a person shall be criminally responsible and liable for punishment for a
crime within the jurisdiction of the Court if that person: (a) Commits such a crime, whether as an
individual, jointly with another or through another person, regardless of whether that other
person is criminally responsible; (b) Orders, solicits or induces the commission of such a crime
which in fact occurs or is attempted; (c) For the purpose of facilitating the commission of such a
crime, aids, abets or otherwise assists in its commission or its attempted commission, including
providing the means for its commission; (d) In any other way contributes to the commission or
attempted commission of such a crime by a group of persons acting with a common purpose.
Such contribution shall be intentional and shall either;.(I) Be made with the aim of furthering the
criminal activity or criminal purpose of the group, where such activity or purpose involves the
commission of a crime within the jurisdiction of the Court; or (ii) Be made in the knowledge of
the intention of the group to commit the crime."

40) Finally, "the Supplementary Convention on the Abolition of Slavery, the Slave Trade, and
Institutions and Practices Similar to Slavery, art. 6, Sept. 7, 1956, 266 U.N.T.S. 3, establishes
liability for enslaving another person or inducing another person, or attempting these acts, or
being accessory thereto, or being a party to a conspiracy to accomplish any such acts."

41) The degree of participation in a particular enterprise, scheme, course of conduct, or act, from
passive conduct to active participation is generally expressed in the range of punishment
accorded to such acts.

42) Defendants aided and abetted others in the furtherance of the commission of crimes against
humanity, including the crimes of-slavery, forced labor, extrajudicial killing, torture, cruel,
inhuman and degrading treatment and punishment and the tort of intentional infliction of
emotional distress, and other acts as set forth herein, and should be held accountable and liable
for their acts accordingly.

CRIMINAL ENTERPRISE LIABILITY

43) International and domestic law impose liability for participation in a criminal enterprise,
inter alia, a party acted in furtherance of a particular enterprise in which the crime is committed
by reason of the accused's function and with knowledge of the nature of the enterprise and intent
to further the enterprise.

44) It is well settled in international law, that "irrespective of the nature of the joint criminal
enterprise - whether broadly defined or temporally and geographically limited - a person incurs
criminal liability solely when that person's participation makes a substantial contribution to the
functioning or endeavours of the enterprise. ... According to the Trial Chamber, the
most important of which includes the role played by the accused in terms of the gravity and
scope of the crimes committed. Individual criminal responsibility is thus preserved by
the Tribunal with regard to the accused's participation in the joint criminal enterprise:

"In sum, an accused must have carried out acts that substantially assisted in or significantly
affected the furtherance of the goals of the enterprise, with the knowledge that his acts or
omission facilitated the crimes committed through the enterprise in order to be criminally liable
as a participant in a joint criminal enterprise. The culpable participant would not need to know of
each crime committed. Merely knowing that crimes are being committed within a system and
knowingly participating in that system in a way that substantially assists or facilitates the
commission of a crime or which allows the criminal enterprise to function effectively or
efficiently would be enough to establish criminal liability. The aider or abettor or
co-perpetrator of a joint criminal enterprise contributes to the commission of the crimes by
playing a role that allows the system or enterprise to continue its functioning."

45) The variety of factors which determine degree of liability includes "... the size of the
criminal enterprise, the functions performed, the position of the accused, the amount of time
spent participating after acquiring knowledge of the criminality of the system, efforts made to
prevent criminal activity or to impede the efficient functioning of the system, the seriousness and
scope of the crimes committed and the efficiency, zealousness or gratuitous cruelty exhibited in
performing the actor's function. It would also be important to examine any direct evidence of a
shared intent or agreement with the criminal endeavour, such as repeated, continuous, or
extensive participation in the system, verbal expressions, or physical perpetration of the crime."


OTHER STANDARDS OF LIABILITY

46) In addition to and independent of aiding and abetting liability, domestic law imposes liability
on third parties for the wrongful acts of another where there is a joint venture, an agency
relationship, negligence or reckless disregard.

47) "Reckless disregard" encompasses: "objective recklessness" and "subjective recklessness"
and imposes liability when one party acts with reckless disregard for the welfare of another.

48) "Objective recklessness" imposes liability on a person who acts in the face of an
unjustifiably high risk of harm that is either known or so obvious that it should be known.

49) "Subjective recklessness" imposes liability on a person who knows a substantial risk that
was subsequently disregarded.

50) Reckless does not require proof of intent, but only that a party acted in conscious disregard
of known dangers.

51) Third party liability is also imposed when a third party acts with deliberate indifference to a
substantial risk or harm to another.

CLASS ALLEGATIONS

52) This action is brought and may be properly maintained as a class action pursuant to the
provision of Federal Rules of Civil Procedure 23(a), 23(b)(2) and 23(b)(3). Plaintiff seeks
certification of the following class and subclasses:

Descendants of all enslavedAfricans, in Africa and the African Diaspora, whose Ancestors were,
and/or who are today, victims of the 568-year historical and continuing Maafa, from 1441 to the
present, which included, and continues to include, the invasion, pillage and destruction of Africa;
the Trans-Atlantic Slave-Trade (also referred to as the Atlantic Trade, the Triangle Trade, and
the Middle Passage; slavery; slave-like conditions and practices (which includes, but is not
limited to involuntary servitude, compulsory and forced labor, convict-lease, chain-gang labor,
prison labor, the worst forms of child labor, sweat shop labor, migrant labor, the trafficking in
human beings; colonialism, segregation and apartheid; racism and racial discrimination; violence
against women and sexual harassment and exploitation; xenophobia, and related intolerance.

All Descendants of all enslavedAfricans in the United States whose Ancestors were:

i. Among the more than 500,000 Africans who were illegally held in slavery in the 13 British
colonies of the United States from 1619 to 1776, and whose Descendants were then illegally held
in slavery under the United States Government until 1865, and slave-like conditions and
practices, and segregation until today.

ii. Among the more than 1,5000 Africans were illegally held in slavery in the Northwest
Territories of the United States, especially, but not limited to, the more than 1,000 Africans who
were llegally held in slavery in Illinois, from 1720 to 1787, and whose Descendants were then
illegally held in slavery under the United States Government until 1865, and slave-like
conditions and practices, and segregation until today.

iii. Among the more than 40,000 Africans who were illegally held in slavery in the French
colony of Louisiana, from the 1720s to 1803, and whose Descendants were then illegally held in
slavery under the United States Government until 1865, and slave-like conditions and practices,
and segregation until today.

iv. Among the more than 15,000 Africans who were illegally held in slavery in the Spanish
colony of Florida 15xx to 1821, and whose Descendants were then illegally held in slavery under
the United States Government until 1865, and slave-like conditions and practices, and
segregation until today.

v. Among the more than 200,000 Africans who were illegally held in slavery in the Spanish
colonies of Mexico, and its provinces in Texas and the Southwestern portion of the United States
from 15xx to 18xx, and whose Descendants were then illegally in slavery under the United
States Government until 1865, and slave-like conditions and practices, and segregation until
today.

vi. Among the more than 250,000 Africans were illegally imported into the United States after
the International and United States ban on the slave trade in 1807 and 1808, and the Congress of
Vienna in 1815 and the Congress of Verona in 1822.

g) All Descendants of all enslavedAfricans in the United States who can identify the persons
who enslaved their Ancestors; the industry group(s), company(ies), and/or institution(s) for
whom their enslaved Ancestors worked.

h) All Descendants of all enslavedAfricans who worked for, and/or continue to work for
Defendants, and who currently suffer, or have suffered in the recent past, from slave-like
practices and conditions; racism and racial discrimination; sexism, sexual harassment or sexual
violence; and/or a hostile work environment

i) All Descendants of all enslavedAfricans who currently live and/or work in the City of
Chicago; and

j) All Descendants of all enslavedAfricans who purchased products from Defendants, or used
their services, and who would not have done so had Defendants fully and accurately described
their, their Ancestors, and co-participants, involvement in, and wrongful and unjust enrichment
by and through the Maafa.

2) The exact number of the Class members is not known to Plaintiff, but it is estimated that they
are so numerous and geographically dispersed throughout the United States, the African
Diaspora, and Africa, that joinder of individual members is impracticable as required. The
number and identities of the Class members can only be ascertained through appropriate
investigation and discovery.

3) Questions of law and fact are common with respect to each Class member, which predominate
over any questions affecting individual members. Common questions of law and fact include, but
are not limited to the following:

Whether man-stealing; woman-stealing; child abduction; kidnapping; piracy; murder;
extermination; enslavement; deportation or forcible transfer of population; imprisonment or
other severe deprivation of physical liberty in violation of fundamental rules of international law;
torture; rape, sexual slavery, enforced prostitution, forced pregnancy, enforced sterilization, or
any other form of sexual violence of comparable gravity; persecution against any identifiable
group or collectivity on political, racial, national, ethnic, cultural, religious, gender, or other
grounds that are universally recognized as impermissible under international law; enforced
disappearance of persons; the crime of apartheid; and other inhumane acts of a similar character
intentionally causing great suffering, or serious injury to body or to mental or physical health,
were and are illegal; whether they were and are crimes against humanity, under- the laws of
nature, cannon law, the law of nations, customary international law, international treaties,
obligations and agreements, and the Constitutions, statutes and laws of Britain, Canada, France,
Spain, Mexico, and the United States; and if so, why, when, how and by whom was this decision
made; and to whom does it apply.

a) Whether Africa, and Africans in every corner of the world, were and are without the pale of
the laws of nature, cannon law, the law of nations, customary international law, international
treaties, obligations and agreements; and if so, why, when, how, and by whom was this decision
made.

b) Whether the Slave Codes, the Code Noir, the Code Negro Espanol, the Barbados Code, the
Virginia Code, the Virginia Code, the Illinois Code, the Louisiana Code, the Florida Code, the
Texas Code, the Black Codes and Laws, the Jim Crow Laws, the Segregation Laws, the
Apartheid Laws, and other such codes and laws, which are similar to the Nazi Codes and Laws,
were and are odious and repugnant to the laws of nature, cannon law, the law of nations,
customary international law, international treaties, obligations and agreements, and the
constitution, statutes and laws of Britain, France, Spain, and the United States, and therefore
were and are null and void; whether they were and are gross violations of human rights and
crimes against humanity; and if not, why, when, how, and by whom was this decision made.

c) Whether Defendants, and their predecessors, especially States, foreign and domestic, illegally
acquired, trafficked in, and held Plaintiffs and Class member's Ancestors in slavery; violated
their most basic and fundamental human rights; and/or committed crimes against African and
world humanity; and whether Defendants, their predecessors, and co-participants, had, continue
to have, and should have immunity and impunity from accountability and prosecution, civil
and/or criminal.

d) Whether Defendants acts, where and are a proximate cause of Plaintiff's, Class members, and
their Ancestor's injuries and conditions, pain and suffering; and whether Defendants, their
predecessors, and co-participants, are liable to Plaintiff, and to Class members, for their 568-year
historical and continuing conduct and acts against, their untold injuries and damages to, and the
pain and suffering of, Plaintiff and Class members' Ancestors, pursuant to customary
international law, and international treaties, agreements, and obligations.

e) Whether Defendants, their predecessors, and co-participants, have been and continue to be
wrongfully and unjustly enriched by and through the 568-year historical and continuing Maafa,
and by and through their intentional and systematic use and exploitation of enslaved, and
slave-like labor. f)Whether Defendants, their predecessors, and co-participants, wrongly
converted to their own use and for their own benefit, the bodies and lives, the slave, slave-like,
forced and compulsory labor of Plaintiff, Class members, and/or their Ancestors.

g) Whether Defendants, their predecessors, and co-participants have failed, and continue to fail,
to account for, and disgorge their wrongful and unjust profits and gain.

h) Whether Defendants have made false statements, material omissions of fact, and
misrepresentations as part of their reporting, public relations, media, marketing and sales
campaigns, diplomatic efforts; whether Defendants have committed and continue to commit
fraud and deceit; and whether Defendants have engaged in, and continue to engage in
unconscionable and unfair business or trade practices, and untrue and misleading advertising.

i) Whether, as a result of this horrific and wrongful conduct by Defendants, their predecessors,
and co-participants, Plaintiff, and Class members, are entitled to recognition, remedy, restitution,
reparations, repatriation/the right to return, and other declaratory, injunctive and equitable relief.

j) Whether Defendants, and their co-participants, are liable to Plaintiff, and Class members for
compensatory, exemplary and/or punitive damages, and if so, in what amount.

2) As required by Fed. R.Civ.P. 23(a)(3), the claims of Plaintiff are typical of the claims of the
Class members. Plaintiff, members of the Class members and their Ancestors have been and
continue to be similarly affected by Defendants, and their predecessors, common conspiracy,
Enterprise, scheme and course of conduct and members of the Class members have similar
claims against Defendants. The claims of all Class members depend on a showing of
Defendants', and their predecessors, and co-participants', 568-year historical and continuing
common Enterprise, scheme and course of conduct, as set forth herein, which gives Plaintiff,
individually and as Class representative, the right to the relief sought herein.

3) There is no conflict as between Plaintiff, other members of the Class, or the general public
with respect to this action or the claims for relief. Plaintiff knows and understands his asserted
rights, and his role as class representative and public attorney general.

4) Plaintiff is committed to the vigorous prosecution of this action, and will retain competent
counsel experienced in the prosecution of complex class actions of this type. Accordingly,
Plaintiff is an adequate representative of the Class, and an adequate public attorney general in
general public, and will fairly and adequately protects the interests of the Class, and the general
public.

5) Prosecution of separate actions by individual Plaintiff will create the risk of inconsistent and
varying adjudication and will establish incompatible standards of conduct for Defendants, and
their predecessors, in that different Courts may order Defendants, and their predecessors, to
provide different types of accounting or take other inconsistent actions.

6) Prosecutions of separate actions by individual Plaintiff or other proposed Class members not
party to the adjudication will substantially impair or impede their ability to protect their interest
in that, for example, Defendants, and their predecessors, may exhaust their available funds in
satisfying the. claims of earlier Plaintiff to the detriment of later Plaintiff.

7) Defendants, and their predecessors, have acted and refused to act on grounds generally
applicable to the proposed Class, making final injunctive relief and correspondent declaratory
relief appropriate with respect to the Class as a whole in that Defendants, and their predecessors,
have been unjustly enriched by participation in acts that were known to be immoral and
inhumane, and that Defendants: (a) prevented and or refused restitution to the proposed Class
members; (b) prevented and refused to disgorge wrongfully gained and earned profits and
benefits; or (c) refused to provide a full and complete accounting and disclosure of the extent of
their aforesaid actions.

8) Common questions of law and fact predominate in the claims of all Class members, including
the named Plaintiff. These claims depend on proving that Defendants, and their predecessors, are
liable for their acts and omissions based, in part, on evidence of a common scheme. Plaintiff and
the Class members' proposed evidentiary showings would be based on the same documents and
testimony concerning Defendants' actions.

9) This Court can and should certify this lawsuit as a class action pursuant to Fed. R.Civ.P.
23(b)(3). A class action is superior to the other available methods for the fair, just and efficient
adjudication of the controversy. Plaintiff and the Class members have no interest in individually
controlling the prosecution of separate actions and, instead are on the whole incapable as
practical matter of pursuing individual claims. Even if individual class members had the
resources to pursue individual litigation, it would be unduly burdensome to the Courts in which
the individual litigation would proceed. Individual litigation magnifies the delay and expenses to
all parties in that the Court system of resolving the controversies engendered by Defendants
individual and common course of conduct. The class action device allows a single Court to
provide the benefits of unitary adjudication; judicial economy and the fair and equitable handling
of all Plaintiff; claims in a single forum. The conduct of this action as a class action conserves
the resources of the parties and of the judicial system, and reserves the rights of each Class
member. Furthermore, for most class members, a class action is the only feasible mechanism that
allows them an opportunity for legal redress and justice. A large concentration of proposed class
members is estimated to reside in this District and the nearby states. The management of the
litigation as a class would pose few problems for this Court.

10) Certification of Class members is appropriate under Fed. R.Civ.P. 23(a) and also under
23(b)(2), 23(b)(3).

FACTUAL ALLEGATIONS

11) It is axiomatic that:

"By the Law of Nature all men are born free." [Dig., 1. 1. Inst., 1. 1, tit. 2. and Instit., 1. 1, tit 2, §
1.]

a) "Gross outrages, in open defiance of Magna Charta and common law, have been continued
through generations;"

b) Law "is designed to disrupt" practice, so "customs and usage do not define or create law, but
should be controlled by it [189 U.S. 468, 470;23 S. Ct 622, 623; 47 L Ed 903, 1903]"

c) "What ought to be done is fixed by a standard... whether it usually is complied with or not
[189 U.S. 468, 470;23 S. Ct 622, 623; 47 L Ed 903, 1903)];" and that

d) A practice, custom or usage, "not based upon any rule of law" must be reversed and rejected
[119 Michigan App 667; 326 NW2d 598, 1982); The T.J. Hooper, 60 F2d 737, 740 (CA 2,
1932)].

2) The slave-trade, slavery and slave-like conditions and practices existed and continue to exist
on all continents, in all nations and societies, and among all Peoples, with varying degrees of
scope, scale, severity and duration, at different and uneven periods throughout history.

3) Plaintiff cites here a few examples:

a) The Greeks preferred women and children slaves, and simply slaughtered the men.

b) In 200 BC, Rome had 400,000 slaves for 1.5 million citizens. Middle class Roman citizens
reportedly owned an average of eight slaves, with women costing fifty times the price of a man.

c) During the 1St Century, Caesar is reported to have sold 1,000,000 slaves in 10 years. Many of
these slaves were from North Africa.

d) Sicily was brought to its knees by a series of slave revolts, the most famous of which was
Spartacus. When these revolts were finally crushed, 6,000 slaves were crucified all along the
Appian way from Rome to Capua.

e) On June 4, 131 BC, a mob led by Ferrand Martinez surrounded and set fire to the Jewish
quarter of Seville, Spain. The surviving Jews were sold into slavery.

f) On November 9, 694, Spanish King Egica accused the Jews of aiding Moslems and sentenced
them to slavery.

g) In 800, Vikings sold slaves from all over Europe to Moslems in the eastern Mediterranean.

h) In 904, Thessalonica was plundered by Leo of Tripoli who kidnapped and sold 20,000 people
into slavery.

i) In 973, Jewish merchants sold white female slaves in the marketplace at Mainz, and at other
slave markets throughout the Middle East.

j) in 1086, the great Domesday Book reported that 9 percent of England's population were
slaves, (20 percent in some western counties, such as Cornwall), and 85 percent were serfs.

k) Between 1200 and 1500, Normans and Venetians produced sugar on Cyprus, Crete and Sicily
using primarily white slaves.

4) European and Christian slaves, and their supporters, waged a long and bitter struggle, for
more than 12 centuries, for their liberation, to declare the slave trade and slavery illegal, and to
abolish it.

THE MAAFA WAS AND IS A CRIME AGAINST HUMANITY

Because God Makes No Slaves In The Womb

5) The prohibition of the slave-trade is well settled, in The King James Bible (Authorized
Version), which commands that:

"If a man be found stealing any of his brethren of the children of Israel, and maketh merchandise
of him, or selleth him; then that thief shall die; and thou shalt put evil away from among you."
Deuteronomy 24:7.

"He that stealeth a man, and selleth him, or if he be found in his hand, he shall surely be put to
death." Exodus 21:16.

6) Rev. John G. Fee in his book An Anti-Slavery Manual, or, The Wrongs of
American Slavery Exposed By the Light of the Bible and of Facts, with A Remedy for the Evil,
admonished all slave-traders, slave-masters, and slave-holders that "God Makes No Slaves in the
Womb." He answered, for the 1850s and for all times, two of the most fundamental arguments
that Defendants, their predecessors, and co-participants used, and continue to use, to justify their
crimes against God, their crimes against humanity:

"But," says [the slave-masters, slave-holders], "my slaves were not kidnapped; they were born
slaves." [Rev. Fee] answer[ed]: (1) "God did not make them slaves in the womb." (2.) The civil
law does not compel you to hold them as slaves; and if they are slaves you have made them
slaves, and are now guilty of the acknowledged sin."

The slave-masters, slave-holders, "in another effort of vindication, say, ‘The civil law makes the
slave my property?' We answer, the moral law, as we have seen, does not; the civil law cannot."


To further prove both his point, Rev. Fee explained that: "Civil law, like the moral law is given,
not to invest [create] rights, but to protect rights in man [and woman] already invested [existing].
[William] Blackstone says man [and woman] ... has natural, or absolute rights; and the ‘primary
object of law is to maintain and regulate these absolute rights of individuals.' And by these
absolute rights, [Blackstone] says, ‘we mean such as would belong to man [and woman], in a
state of nature, and which EVERY MAN [AND WOMAN] is entitled to enjoy, whether in
society or out of society."

7) Upon information and belief, the Vatican was at the forefront of the struggle to abolish the
slave trade and slavery in Europe. Several Popes and Councils of the Roman Catholic Church
published at least 31 Papal Bulls, Encyclicals, Letters, and other documents, between 441 and
1102, against the trafficking in, "trading," and enslavement of Europeans, especially Christians,
including:

340, Manichean Christians had been inciting slaves of the Roman Empire to take charge of their
destiny and emancipate themselves... In response, the Christian Council of Gangra issued a
statement supporting slavery: "If anyone, on the pretext of religion, teaches another man's slave
to despise his master and to withdraw from his service, and not serve his master with good will
and all respect, let him be anathema." This resolution became part of the Catholic church's canon
law concerning slavery and was quoted as an authoritative source until the middle of the 18th
century.

(1) 400, St. Augustine speaks of the granting of freedom to slaves as a great religious virtue, and
declares the Christian law against regarding God's rational creation as property.

(2) 441, censuring slavers.

(3) 452, 506, 549, 585,589, 633 and 615, manumission in ecclesiis, and freedom by other
processes.

(4) 511, 517, 538, 549, protection of maltreated slaves who take refuge in the church.

(5) 539, an edict that masters had no power to separate Families in the sale of slaves, and that it
was a crime.

(6) 541, 581, 625, 589, 633 and 656, prohibition of Jews to possess Christian slaves.

(7) 549, use of church buildings as refuges for escaping slaves.

(8) 566, excommunication-of-slavers proviso.

(9) 578, 585, 650, 691 and 697, rest for slaves on Sundays and feast days.

(10) 583, church issuance of freedom papers.

(11) 595, freeing entrants to monastic life.

(12) 604, slavery pronounced "a cruel evil," "a great crime," and a severe punishment was
declared upon the bishops who authorized it in their bishoprics.......

(13) 616, liberty restoration proviso.

(14) 625, ban the acquisition of new slaves, use church property to free current slaves.

(15) 625, banning new slaves, use church property to. free current slaves.

(16) 625, prohibition against reducing a freeman to slavery.

(17) 644 and 650, suppression of traffic in slaves by forbidding their sale outside the kingdom.

(18) 655, declaration that children of clerics were. to be enslaved.

(19) 666, banning the shaving of slaves.

(20) 752 and 759, confirmed the validity of marriages between free persons and slaves.

(21) 7th century, Saint Bathilde (wife of King Clovis II) became famous for her campaign to stop
slavetrading and free all slaves

(22) 844, use of church property to free slaves.

(23) 851, Saint Anskar began his efforts to halt the Viking slave trade

(24) 873, rulers of Sardinia ordered to restore freedom to slaves bought from the Greeks.

(25) 922, defining slave-trade as homicide.

(26) 1009-1095, Saint Wulfstan forbade the enslavement of Christians.

(27) 1027-1087, William the Conqueror forbade the enslavement of Christians.

(28) 1033-1109, Saint Anselm forbade the enslavement of Christians.

(29) 1066, denouncing the enslavement of (English) Christians.

(30) 1102, calling for a ban on the slave trade.

1) "During the pontificate of Pope Innocent XI several questions were asked of the Holy Office
concerning Africanenslavement:

"Is it permitted to capture by force blacks who have not harmed anyone? Is it permitted to buy
and sell blacks who have been made captive against their will? Is it permitted to buy blacks who
have been unjustly captured?

"Pope Innocent XI replied that it was not permitted to engage in any of the above actions. He
also said that buyers of slaves were compelled to inquire into the circumstances of how the
slaves had been captured and to set them free if they were captured by force or deceit."

2) Pope Pius VII, "warned ]and adjure[d] earnestly in the Lord faithful Christians of every
condition that no one in the future dare to vex anyone, despoil him of his possessions, reduce to
servitude, or lend aid and favour to those who give themselves up to these practices, or exercise
that inhuman traffic by which the Blacks, as if they were not men but rather animals, having
been brought into servitude, in no matter what way, are, without any distinction, in contempt of
the rights of justice and humanity, bought, sold, and devoted sometimes to the hardest labour..
We reprove, then, by virtue of Our Apostolic Authority, all the practices above mentioned as
absolutely unworthy of the Christian name. By the same Authority We prohibit and strictly
forbid any Ecclesiastic or lay person from presuming to defend as permissible this traffic in
Blacks under no matter what pretext or excuse, or from publishing or teaching in any manner
whatsoever, in public or privately, opinions contrary to what We have set forth in this Apostolic
Letter."

3) Plaintiff understands that "the Churches of Gaul, Spain, Britain, and Italy were incessantly
busy, in numerous councils, with the affairs of slaves; protection of the maltreated slave who has
taken refuge in a church (Councils of Orleans, 511, 538, 549; Council of Epone, 517; those
manumitted in ecclesiis, but also those freed by any other process (Council of Arles, 452; of
Agde, 506; of Orleans, 549; of Macon, 585; of Toledo, 589, 633; of Paris, 615; validity of
marriage contracted with full knowledge of the circumstances between free persons and slaves
((Councils of Verberie, 752, of Compiegne, 759; rest for slaves on Sundays and feast days
(Council of Auxerrre, 578 or 585; of Chalon-sur-Saone, middle of the seventh century; of Rouen,
650; of Wessex, 691; of Berghamsted, 697; prohibition of Jews to possess Christian slaves
(Council of Orleans, 541; of Macon, 581; of Clichy, 625; of Toledo, 589, 633, 656; suppression
of traffic in slaves by forbidding their sale outside the kingdom (Council of Chalon-surSaone,
between 644 and 650; prohibition against reducing a free man to slavery (Council of Clichy,
625). Less liberal in this respect than Justinian (Novella cxxiii, 17), who made tacit consent a
sufficient condition, the Western discipline does not permit a slave to be raised to the priesthood
without the formal consent of his master; nevertheless the councils held at Orleans in 511, 538,
549, while imposing canonical penalties upon the bishop who exceeded his authority in this
matter, declare such an ordination to be valid. A council held at Rome in 595 under the
presidency of St. Gregory the Great permits the slave to become a monk without any consent,
express or tacit, of his master."

4) Plaintiff further understands that

(e) "The Roman Catholic] ‘Church redeemed slaves out of its common resources. Heroic
Christians sold themselves into slavery to deliver slaves, and that many enfranchised all the
slaves they had."

(f) "The Christians in Asia Minor at a very early period decried the lawfulness of [slavery],
denounced slaveholding as a sin, a violation of the law of nature and religion." and that they give
"fugitive slaves asylum, and openly offer them protection."

(g) "Maximus preached and wrote against [slavery, and counseled] those who entered upon a
religious life gave freedom to their slaves."

(h) "The early Christian Church leaders united their exertions to enlist even the barbarian princes
in the cause of the slave." "St. Remigius, the Archbishop of Reims, wrote to [King)
Clovis asking him to ‘let the gate of your palace be open to all, that every one may have recourse
to you for justice, [[and to] [e]mploy [his] great revenues in redeeming slaves."

(i) "St. Remolasco, and established more especially in France and Spain, redeemed 490,736
slaves between the years 1218 and 1632.... St. Vincent of Paul had been a slave at Algiers in
1605, and witnessed the sufferings and perils of Christian slaves. At the request of Louis XIV, he
sent them, in 1642, priests of the congregation which he had founded.... From 1642 to 1660 they
redeemed about 1,200 slaves [in Algiers and Tunis] at an expense of about 1,200,000 livres."


(i) 1435, Pope Eugene IV, as set forth in more detail above, issued a bull, Sicut Dudum,
threatening to excommunicate all Spaniards involved in the slave trade and slavery..

5) Because of the anti-slavery work of the Vatican and the Roman Catholic Church,
"Constantine gave authority to the bishops to manumit slaves, and [as Emperor) granted Roman
citizenship to many of those set free;" King Charlemagne, "issued a decree against slavery;" and
Emperors Constantine and Constantinus, "both made the subjection of females to slavery a
capital crime; William the Conqueror supported English Bishops in denouncing enslavement of
(English) Christians in 1066; and by 1200, slavery was gone from England.

6) By the 11th and 12th centuries, the slave-trade and slavery had been effectively abolished in
Northern Europe, was greatly reduced in Southern and Eastern Europe, and had been declared to
be a violation of the municipal laws of most of the countries of Europe, as set forth herein. By
13th & 14th centuries, the slave trade and slavery captured Christian Europeans, Muslim slaves,
and Africans was abolished in southern Europe, in Spain and Portugal in the.

7) Upon information and belief, "from the fall of the Roman Empire and the definitive beginning
of modern European states, [or perhaps the Congress of Vienna of 1815], the greatest influence
working for recognition of International Law among all peoples, [especially with on the problem
of the slave trade and slavery in Europe] was the [Roman Catholic] Church.... [I]t followed
naturally that the Head of the Church, the Pope holding the Divine commission, should become
the universal arbiter in disputes among nations."

8) Upon information and belief, "for centuries the great offices of state, especially those having
to do with foreign nations, were held by Bishops learned in canon law, which was based upon
Roman law and especially adapted to the Government of the Church whose jurisdiction was not
bounded by state lines, it naturally suggested many of the rules that have found a place in
International Law. The Pope became the natural arbitrator between nations, and the power to
which appeals were made when the laws of justice, and morality were flagrantly violated by
sovereigns either in relation to their own subjects or to foreign nations.... The decrees of the
Councils of the Church were confirmed as laws of the empire to secure their being put in force
by the civil power, and the sentence was pronounced at Chalcedon (451) that imperial laws that
were contrary to cannon law should be null and void." [Emphasis added.]

9) The school of Salamanca in Spain, we are told, "most notably in the person of the Dominican
theologian Francisco de Vitoria, began to elaborate what has developed into modem
international law and human rights-and the modem prohibition of slavery."

10) The Vatican, several Popes and the Roman Catholic Church published at least 39 additional
Papal Bulls, Encyclicals, Letters, and other documents, between 1435 and 1890, prohibiting the
trafficking in, "trading," and enslavement of Indigenous Peoples and African People, including:


(11) 1435, Pope Eugene IV in a letter written in 1435 to Bishop Ferdinand of Lanzarote in his
Bull, Sicut Dudum, said:

"They have deprived the natives of their property or turned it to their own use, and have
subjected some of the inhabitants of said islands to perpetual slavery, sold them to other persons
and committed other various illicit and evil deeds against them... We order and command all and
each of the faithful of each sex that, within the space of fifteen days of the publication of these
letters in the place where they live, that they restore to their earlier liberty all and each person of
either sex who were once residents of said Canary Islands...who have been made subject to
slavery. These people are to be totally and perpetually free and are to be let go without the
exaction or reception of any money." [See Panzer, page 8; also pages 75-78 with original critical
Latin text].

(12) 1462, Pius II declared slavery to be "a great crime" (magnum scelus).

(13) 1474-1566, Dominican Bartolome de Las Casas waged a bitter and quite successful
campaign against enslaving Indians, during which he proposed that slaves be brought from
Africa instead. Later he came to deeply regret this proposal and expressed doubt as to whether
God would pardon him for this terrible sin.

(14) 1511, Antonio de Montesinos, a Dominican priest, denounced to his Spanish parishioners
their treatment of Indians:

"This voice says that you are living in deadly sin for the atrocities you tyrannically impose on
these innocent people. Tell me, what right have you to enslave them? What authority did you use
to make war against them who lived at peace on their territories, killing them cruelly with
methods never before heard of? How can you oppress them and not care to feed or cure them,
and work them to death to satisfy your greed? And, why don't you look after their spiritual
health, so that they should come to know God, that they should be baptized, and that they should
hear Mass and keep the holy days? Aren't they human beings? Have they no rational soul? Aren't
you obliged to love them as you love yourselves? Don't you understand? How can you live in
such a lethargical dream? You must rest assured that you are in no better state of salvation than
the Moors or Turks who reject the Christian faith."

(15) 1519, Bartholomew De Las Casas, a Dominican, argued against slavery. "No one may be
deprived of his liberty nor may any person be enslaved" He was ridiculed, silenced and ignored.

(16) 1534-1549, Pope Paul III wrote a bull against New World slavery, saying that Satan was the
cause of slavery:

[Satan,] "the enemy of the human race, who always opposes all good men so that the race may
perish, has thought up a way, unheard of before now, by which he might impede the saving word
of God from being preached to the nations. He has stirred up some of his allies who, desiring to
satisfy their own avarice, are presuming to assert far and wide that the Indians of the West and
the South who have come to our notice in these times be reduced to our service like brute
animals, under the pretext that they are lacking in the Catholic faith. And they reduce them to
slavery, treating them with afflictions they would scarcely use with brute animals. Therefore,
We... noting that the Indians themselves indeed are true men... by our Apostolic Authority decree
and declare by these present letters that the same Indians and all other peoples-even though they
are outside the faith... should not be deprived of their liberty or their other possessions... and are
not to be reduced to slavery, and that whatever happens to the contrary is to be considered null
and void. (My italics) In a second bull on slavery, Paul imposed the penalty of excommunication
on anyone, regardless of their ‘dignity, state, condition, or grade... who in any way may presume
to reduce said Indians to slavery or despoil them of their goods."

(17) 1537, condemning the enslavement of the Indigenous Peoples of the Western Hemisphere
by an "evil, unheard of before now, to the enemy of the human race, Satan," and
excommunicating of the slavers).

(18) 1539, repetitions of condemnations of slavery.

(19) 1537, Pope Paul III issued a Bull against slavery, entitled Sublimis Deus, to the Universal
Church, declaring that:

"... The exalted God loved the human race so much that He created man in such a condition that
he was not only a sharer in good as are other creatures, but also that he would be able to reach
and see face to face the inaccessible and invisible Supreme Good... Seeing this and envying it,
the enemy of the human race, who always opposes all good men so that the race may perish, has
thought up a way, unheard of before now, by which he might impede the saving word of God
from being preached to the nations. He (Satan) has stirred up some of his allies who, desiring to
satisfy their own avarice, are presuming to assert far and wide that the Indians...be reduced to our
service like brute animals, under the pretext that they are lacking the Catholic faith. And they
reduce them to slavery, treating them with afflictions they would scarcely use with brute
animals... by our Apostolic Authority decree and declare by these present letters that the same
Indians and all other peoples - even though they are outside the. faith -...should not be deprived
of their liberty... Rather they are to be able to use and enjoy this liberty and this ownership of
property freely and licitly, and are not to be reduced to slavery. ... Even though he retracted [t]his
Brief, Popes Gregory XIV, Urban VIII and Benedict XIV still recognized and confirmed its
authority against slavery and the slave trade."

(20) 1537, May 29, Paul III wrote a Letter Apostolic, under the seal of the Fisherman, to the
Cardinal Archbishop of Toledo, Spain, and afterwards, another Letter, more detailed,
denouncing slavery. He also supported a Royal edict issued by Charles V of Spain that
endeavored to halt mistreatment of Indians. Pope Paul III stated:

"Therefore, attending to the fact that the Indians themselves, although they are outside the bosom
of the Church, have not been and should not be deprived of their liberty or of ownership of what
is their own, and that, since they are men and therefore capable. of faith and salvation, they are
not to be given into servitude, but rather by preaching, good examples and the like should be
invited to eternal life. We...command that anyone of whatever dignity, state, condition, or grade
who works against what is done through you or others to help the Indians in the aforementioned
matters incurs the penalty of excommunication."

(21) 1540s, Bartolome de Las Casas challenged Juan Gines de Sepulveda to an open debate
before the King of Spain and other members of the clergy.

"Sepulveda justified Indian enslavement on the following grounds: the gravity of sins of the
Indians, especially idolatry; the rudeness of the natives which made it necessary for more refined
people like the Spanish to educate them; the goal of spreading the faith; protection of weaker
Indians who were subject to human sacrifice and cannibalism."

"Las Casas responded: God did not command war against idolators; Indians had rich, vibrant
civilizations and sophisticated cultures; peaceful conversion was the most effective means of
spreading Catholicism; although human sacrifice was evil, indiscriminate warfare was more evil.

Las Casas also presented abundant evidence during the debate that Spaniards in the New World
were not seeking to enlighten Indians, but to work them to death through enslavement."

(22) 1542, Papal influence and lobbying by Las Casas, led to a royal proclamation of the New
Laws of the Indies which forbade all future enslavement of Indians. The New Laws met with
violent opposition from settlers. Riots, petitions, and even open rebellion caused the monarchy to
back away from immediate enforcement of the laws.

(23) 1548, Pope Paul III confirmed that any individual may freely buy, sell and own slaves.
Runaway slaves were to be returned to their owners for punishment.

(24) Before his death in 1566, Las Casas addressed a memorandum to the King which declared
that:

"All wars called conquests are unjust. The system of encomiendas is tyrannical. The King can
not justify wars in the Anericas against peaceful peoples. All gold and silver taken from the New
World is stolen. Indians have a right to fight against invasion of their land by Spanish
conquerors."

"In the closing pages of his massive history of Spain's conquests in the New World, Las Casas
warned his fellow countrymen that in seeking to acquire riches they risked losing their souls:

"I say and hold it certain that all the crimes committed by the Spaniards against these people
with such perverse cruelties, have been against the pure and most righteous law of Jesus Christ,
and against all natural reason, and to the greatest infamy of His name, and the Christian religion,
and the total destruction of the faith....And I believe for these impious and ignominious works, so
unjustly and tyrannically barbarously committed....God will pour His fury and anger upon Spain
if she does not perform a great penance."

(25) 1591-1741, Popes Gregory XIV (Cum Sicuti, 1591), Urban VIII (Commissum Nobis, 1639)
and Benedict XIV (Immensa Pastorum, 1741) also condemned slavery and the slave trade,
promising excommunication of clergy who participated in the slavery trade and slavery.

(26) 15th century, striving for the abolition of ignominious traffic in human beings.

(27) 1639, April 22, Pope Urban VIII wrote a letter to the Collector Jurium of the Apostolic
Chamber of Portugal condemning those who should dare ‘to reduce to slavery the Indians of the
Eastern and Southern Indies,' to sell them, buy them, exchange them or give them, separate them
from their wives and children, despoil them of their goods and properties, conduct or transport
them into other regions, or deprive them of liberty in any way whatsoever, retain them in
servitude, or lend counsel, succour, favour and co-operation to those so acting, under no matter
what pretext or excuse, or who proclaim and teach that this way of acting is allowable and
co-operate in any manner whatever in the practices indicated.

(28) 1639, April 22, Pope Urban VIII, at the request of the Jesuits of Paraguay issued a bull
Commissum nobis reaffirming the ruling by "our predecessor Paul III" that those who reduced
others to slavery were subject to excommunication," and forbing the enslavement of Indians.

(29) 1686, March 20, the Congregation of the Holy office (the Roman Inquisition) ruled on the
matter of slavery, in the form of questions and answers. It is asked, they ruled:

"Whether it is permitted to capture by force and deceit Blacks and other natives who have
harmed no one? Answer: no!

"Whether it is permitted to buy, sell or make contracts in their respect Blacks or other natives
who have harmed no one and been made captives by force of deceit? Answer: no!

"Whether the possessors of Blacks and other natives who have harmed no one and been captured
by force or deceit, are not held to set them free? Answer: yes!

"Whether the captors, buyers and possessors of Blacks and other natives who have harmed no
one and who have been captured by force or deceit are not held to make compensation to them?
Answer: yes!"

(30) 1741, December 20, Pope Benedict XIV, in an Apostolic Letter addressed on December 20,
1741, to the Bishops of Brazil and some other regions, once again, forbidding the enslavement of
Indians.

(31) 1794, degree by the French National Assembly during the French Revolution, at the
instigation of a Catholic priest, the Abbe H. Gregoire, abolishing slavery and the slave trade in
all French colonies.

(32) 1815, Pope Pius VII demanded that the Congress of Vienna prohibit and suppress of the
slave trade.

(33) 1829, Papal request for Mexico to abolish slavery, which Mexico did, throughout its
dominions, including Texas and the Southwestern region of the United States.

(34) 1838, condemning all forms of colonial slavery and the slave trade, calling it inhumanum
illud commercium, and forbidding all Catholics to propound views contrary to this.

(35) 1839, Pope Gregory XVI issued a Bull, entitled In Supremo, condemning slave trading and
racial slavery, and prohibiting and strictly forbidding any Ecclesiastic or lay person from
defending or participating in the slave trade and slavery:

"We, by apostolic authority, warn and strongly exhort in the Lord faithful Christians of every
condition that no one in the future dare bother unjustly, despoil of their possessions, or reduce to
slavery Indians, Blacks or other such peoples."

(36) 1887, claiming that the Catholic Church struggled from the beginning "to see a slavery
eased and abolished which was oppressing so many people."

(37) 1888, recalling the Church's unceasing efforts over centuries to get rid of colonial slavery
and the slave trade and expressing satisfaction that Brazil had at last abolished it; and.

(38) 1888, Cardinal Lavigerie founded the Societe Antiesclavagiste.

(39)1888, Leo XIII wrote a letter to the Brazilian bishops, exhorting them to banish from their
country the remnants of slavery.

(40) 1890, condemning slavery once again, calling for its abolition in all Catholic Missions, and
founding the Anti-Slave League of France for the combating of slavery and the slave trade on an
international basis.

(41) 1890, by an Encyclical once more condemning the slave-traders and "the accursed pest of
servitude", ordered an annual collection to be made in all Catholic churches for the benefit of the
anti-slavery work.

(42) 18th century, in the Bull of Canonization of the Jesuit Peter Claver, one of the most
illustrious adversaries of slavery, Pope Pius IX branded the "supreme villainy" (summum nefas)
of the slave traders.

11) Defendants the Vatican, the Pope, the Roman Catholic Church, and the Society of Jesus, in
the United States and worldwide, knew and know, or should have known and should know, that
the Maafa, especially the slave trade and slavery, was and is illegal, was and is a crime against
God, a crime against humanity, because they lead the struggle to prohibit and abolish them, and
to declare them illegal under the laws of nature, cannon law, the laws of nations, customary
international law, and international treaties, agreements and obligations.

12) The Catholic Church's historical and continued silence, their historical and current failure
and refusal to admit these undeniable facts, is itself a continuing violation of Plaintiff's, Class
members, and their Ancestors, most basic and fundamental human rights, a continuing crime
against God, a continuing crime against humanity.

13) Plaintiff, and Class members, therefore call upon His Holiness Pope John Paul II, on behalf
of the Catholic Church worldwide, to stand before this Court and the world, and honestly admit
for once and for all, that slavery and the slave trade was and is illegal Vatican law, and that the
Maafa was and is a crime against humanity, and that they were, and continue to be wrongfully
and unjust enriched by and through their participation in this crime.

14) Plaintiff, and Class members, further call upon King Carlos V to stand before this court, and
the world, and admit that the slave codes and bulls were and are odious and repugnant to the
laws of the God, the Catholic Church,. and civilized humanity, and therefore null and void.

15) Plaintiff, And Class members, call upon the President of the United States, the Govemors of
the States, and all Defendants, set forth herein, to make this declaration as well.

16) Full, truthful, and immediate accounting and disclosure is also required and demanded,
pursuant to the Freedom of Information Act, the Chicago Slavery Era Disclosure Act, the Illinois
UDAP, etc.

Because The King Of Spain Gave Liberty To All

17) Upon information and belief, "the fundamental law of society-- human rights--was urged in
Spain, against slavery in the eighth century with much energy and effect, and by the fourteenth
century nearly every civil society Europe had gone far towards universal emancipation. Kings
were not unwilling to declare the equal rights of their enslaved subjects, and to exert themselves
for the overthrow of domestic bondage. [See Bodde Repub. C. 5.]"

18) Upon further information, the King of Spain, on numerous occasions between 1435 and
1888, prohibited the slave trade and slavery, and "gave liberty to all men as well as all women,"
in Spain and the Spanish Empire. But these edicts and proclamations were not
implemented, as the following timeline documents:

1435, Pope Eugene IV, as set forth in more detail above, issued a bull, Sicut Dudum. Under
threat of excommunication, he gave all Spaniards involved fifteen days from receipt of his Bull:

"To restore to their earlier liberty all and each person of either sex who were once residents of
said Canary Islands... These people are to be totally and perpetually free and are to be let go
without the exaction or reception of any money."

(1) 1462-76, the Vatican opposed the efforts of Spanish slave traders at the Port of Seville to
begin the trade in large numbers of slaves.

(2) 1503, October 30, Queen Isabella of Spain banned violence against Indians.

(3) 1514, Pope Leo X issued a bull denouncing slavery and the slave trade.

(4) 1515, Bishop Bartolome de Las Casas, the first Spanish priest to be ordained the Western
Hemisphere, returned to Spain from Hispaniola to plead King Carlos I on behalf of enslaved
Indians. Las Casas requested that each Spanish resident Santo Domingo (now known ad Haiti)
be granted a license to import twelve Africanslaves order to release the natives from slavery. He
argued that "there can be neither slaves by nature, nor people without freedom and power, nor
people without sovereignty.

(5) 1516, the Castilian regent Jiminez forbade the importation of Africanslaves into Spanish
colonies but Carlos I grants his courtiers licenses to import slaves into Spanish colonial islands.
Cardinal De Cisneros banned the importation of enslavedAfricans into Spain's colonies the
Americas.

(6) 1517, King Charles V ended the enslavement of Indians.

(7) 1517, King Charles V granted an exclusive patent to the Flemish Nobility to import 4,000
Africans annually into Hispaniola, Cuba, Jamaica, and Puerto Rico. It was said that:

"This great prince was not, all probability, aware of the dreadful evils attending this horrible
traffic, nor of the crying injustice of permitting it; for 1542, when he made a code of laws for his
Indian subjects, he liberated all Negroes, and by a word put an end to slavery. When, however,
he resigned his crown and retired into a monastery, and his minister of mercy, Pedro de la Gasca,
returned to Spain, the imperious tyrants of these new dominions returned to their former
practices, and fastened the yoke on the suffering and unresisting Negroes. [See: Goodwin. Page
185, and Thomas Clarkson's History, page 28-29,]

(8) 1526, the Spanish Crown considered that African slavery could be made to last a few years,
and that each slave would have become free after a while. This measure failed because the
Spanish colonial slave masters refused to implement it.

(9) 1530, King Charles V issued the first prohibition of Indian slavery.

(10) 1537, following Las Casas and Spanish theologians, Pope Jules III condemned all doubt
about the full humanity of the Indians.

(11) 153940, Viceroy Mendoza "dispatched the Franciscan Fray Marcos de Niza to inform the
native tribes that an effectual stop had been put to the enslavement of the Indians.... The
command was given to Francisco Vasquez de Coronado. But Coronado did not carry out the
intention of Mendoza regarding the Indians."

(12) 1540, Emperor Charles V "ordered all the slaves the American Isles to be set free; and they
were accordingly manumitted by Lagasca the governor of the country, on condition of
contSinuing to labour for their masters. But this attempt proved unsuccessful, and on Lagasca's
return to Spain domestic slavery revived and flourished as before;" It is claimed that Lagasca
"returned to Spain with such a tale for the Emperor as induced him to consent to the
re-establishment of this crime. [See: Bodde Repub. 1.1, c.5.]."

(13) 1542, Bartolome de Las Casas was named Bishop of Chiapas southern Mexico. He writes
Devastation of the Indies to push the New Laws to reform treatment of Indians. Cabeza de Vacas
Relation published.

(14) 1550, Bartolome de Las Casas and Sepulveda debated the question of slavery. King Charles
V emancipates all West Indies slaves.

(15) 1552, Bartolome de Las Casas published Brief Relations of the Destruction of the Indies,
his account of the oppression of the South American Indians.

(16) 1556, Domingo de Soto, De Justicia Et De Jure Libri X (Ten Books on Justice and Law),
argued that it is wrong to keep slavery any person who was born free.

(17) 1573, a Spanish, Mexican lawyer, Bartoleme Frias de Albornoz, published Arte de Los
Contratos (The Art of Contracts), which casts doubt on the legality of the slave trade, total
condemnation of the trade, Fray Bartolome de Albornoz. The Spanish King Philip II s rulings,
the conquista term is replaced by the pacification one.

(18) 1600, King Philip III outlawed the use of Native American slaves in Spanish colonies.

(19) 1627, a Spanish Peruvian Jesuit, Alonso de Sandoval, published Naturaleza, Policia, ..
Costumbres i Ritos, Disciplina, i Catechismo Evangelico de todos Etiopes (The Nature, Policy,
... Customs and Rituals, Disciplines, and Gospel Catechism of all Ethiopians), which argues that
slavery combines all the worlds evils.

(20) 1693, King Charles II issued a royal proclamation giving liberty to all runaway
Africanslaves Florida who became practicing Catholics and helped protect the colony of Britain.

(21) 1693, King Charles II issued a royal proclamation giving liberty to all runaway
Africanslaves Florida who became practicing Catholics and helped protect the colony of Britain.

(22) 1695, November 7, King Charles II issued the first official edict proclaiming that the
Spaniards would "be giving liberty to all...men as well as the women...so that by their example
and by my liberality others will do the same;" However, Antonio De Benavides, the new Spanish
governor of Florida, refused to implement this edict, and began selling African people back into
slavery. Massive slave rebellions were organized Georgia and the Carolinas, in response,
including the Stono Rebellion.

(23) 1738, 100 Africans who had escaped from slavery, formed a militia and build Fort Mose in
St. Augustine, Florida to protect themselves from the slave catchers of Georgia and the
Carolinas.

(24) 1739, James Oglethorpe, the founder of the British colony of Georgia, invaded Florida,
attacked and seized control of Fort Mose. The Africans retreated into the swamp, returned six
months later with Spanish troops and their Seminole allies, defeated Oglethorpe's army what
became known as the battle of "Bloody Mose," and retook control of the Fort.

(25) 1762, 3-Nov, Spain acquired Louisiana. Free mulattos and blacks are conscripted into the
newly established Colonial Spain regular army.

(26) 1783, King Charles III began to issue documents called cedulas de gracias al sacar to
cleanse persons of impure origins, principally Indians and Africans. The drive to purchase a new
racial identity with Colonial Spain increases; non-Spaniards paid 700 to 1000 pesos to purchase
a certificate, which elevated their social status.

(27) 1790, Spain allegedly rescinded its policy of religious sanctuary Florida for Africans who
had escaped from slavery. But runaway Africanslaves kept coming, and the Seminoles and
Spanish, continued to harbor them, and refused to send them back. The United States
Government sent numerous delegations to Spain and Florida to request that the Seminoles and
Spain stop encouraging and harboring runaway slaves, give them back, and/or pay
compensation. Again, the Seminoles and Spain refused, which led to the Seminole Wars.

(28) 1809 to 1811, Ecuador, Chile, Columbia, Argentina and El Salvador declared their
independence from Spain.

(29) 1810, Mexico declared its independence from Spain, who waged a 11 -year war to prevent
that it. Independence was declared on August 23, 1821.

(30) 1811, slavery was abolished in Spain and in the Spanish Colonies. Abolition was violently
opposed Cuba and not enforced throughout the Spanish Empire.

(31) 1815, Spain and Portugal agree to treaties with Britain for the gradual abolition of trade;
Portugal agrees to limit trade to south of the Equator. Spain outlaws the slave trade all of its
provinces to the north of the Equator.

(32) 1817, September 30, Spain promised to abolish the slave trade by October 31, 1820, in all
Spanish territory. England pays Spain an indemnity of 400,000, and slavery was outlawed in the
newly independent Latin American republics; slavery declines through free womb laws and
manumissions with apprenticeship.

(33) 1823, United States issues the Monroe Doctrine which warning Europe against the
re-colonization of the newly independent Spanish American republics.

(34) 1821, Peru declared its independence, followed by Bolivia in 1825. All former Spanish
colonies in Latin America independent except Cuba and Puerto Rico.

(35) 1821, United States Government attempted to negotiate a treaty with the Mexican
Government, of behalf of the Texas settlers, for the return of fugitive slaves, but the Mexican
Congress refused to ratify it.

(36) 1822, November 14, the Congreso Constituyente Mexicano passed an article in its Texas
Colonization Bill which said that:

(37) "There shall not be permitted, after the promulgation of this law, either purchase or sale of
slaves that may be introduced into the empire. The children of such slaves, who are born with the
empire, shall be free at fourteen years of age."

(38) 1824, Spain abolishes slavery once again in Central America.

(39) 1824, July 13, the sovereign general Constituent Congress of the United Mexican States
issued a decree which included the following:

"Commerce and traffic slaves, proceeding from any country and under any flag whatsoever is
forever prohibited the territory of the United Mexican States.

"Slaves that are introduced contrary to the tenor of the above article are free virtue of the mere
act of treading Mexican territory.

"Every ship, whether domestic or foreign, which slaves are transported to or introduced into
Mexican territory, shall be irremissibly confiscated, with the remainder of its cargo; and the
owner, the purchaser, the captain, the master, and the pilot shall suffer the penalty of a year's
imprisonment.

"This law shall take effect from the day of its publication, but the penalties prescribed the above
article shall be suspended for six months with reference to those colonists who, virtue of the law
of the fourteenth of October last upon the colonization of the isthmus of Guazacoalco, may land
slaves with the intention of introducing them into Mexican territory;"

(40) 1824, July 13, Mexican Government issues a decree, and ratifies constitutional provisions,
that confer Mexican citizenship on the newly freed slaves; and obligates Mexico to afford them
equal recognition and equal protection.

(41) 1825, March 24, 1825, the colonization law under which all the contracts in Texas were
governed, was approved. Article 46 of that law required that "new settlers shall subject
themselves to the laws that are now, and shall hereafter be established on the subject" of the
slave trade and slavery."

(42) 1827, March 11, the Thirteenth Article of the Mexican Constitution was adopted, which
reads as follows:

"From and after the promulgation of the Constitution the capital of each district, no one shall be
born a slave the state, and after six months the introduction of slaves under any pretext shall not
be permitted."

(43) 1827, September, the Mexican Congress issued a decree ordering all municipalities to make
a list of the slaves with their limits, make a report every three months, emancipate a tenth of the
slaves when ownership changes which could only be done through inheritance, and provide "the
best education that. can be given" to the emancipated children."

(44) 1829, September 15, Mr. Vicente Guerrero, the President of the Mexican Republic, signed a
decree that declared that "slavery was abolished, that all negroes were henceforth free, and that
owners would receive compensation at some future time." [See: Dublan y Lozano, Legislacion
Mexicana, II, 151.]

(45) 1830, Mexico forbade the further colonization of Texas Territory and prohibited the further
importation of slaves into the Territory. The United States Government attempted once again, to
negotiate a treaty with the Mexican Government for the return of fugitive slaves, but, the
Mexican Congress refused to ratify it.

(46) 1830, President Guerro ordered a military occupation of Texas to enforce the anti-slavery
measure.

(47) 1842, slavery abolished once again, in Uruguay.

(48) 1843, slavery abolished once again, in Argentina.

(49) 1844, Mexican Congressman Lucas Alaman reportedly took "the view that all slaves
brought to Texas after the [July 13, 1824] degree was published should have gained their
freedom by virtue of the provision of section 2 of the decree. [See: Iniciativa de ley, etc., a
message to Congress, printed Filisola's Guerra de Tejas. Volume II. Page 595.]"

(50) 1844, October, the United States Government threatened to invade Mexico if she continued
her refusal to recognize the independence of Texas. The Mexican Foreign Minister is reported to
have replied:

"While one power is seeking more ground to stain by the slavery of an unfortunate branch of the
human family, the other is endeavoring, by preserving what belongs to it, to diminish the surface
which the former wants for this detestable traffic. Let the world now say which of the two has
justice and reason on its side."

(51) 1844, Professor von Holst, in his Constitutional and Political History of the United States.
Volume II, confirms that the July 13, 1824, decree prohibited the further importation of slaves
into the Mexican province of Texas. The emancipation decrees, however, were not obeyed
Texas, because

"Texas was a great way off, and the arm of the Mexican Government was not long. Now, as
before, settlers carne with their slaves from the slave states to Texas. [See: Constitutional and
Political History of the United States. Volume II. Page 553.]."

(52) 1844, October, in response to the United States Government's threat to invade Mexico if she
continued her refusal to recognize the independence of Texas, and stop harboring runaway
slaves, the Mexican Foreign Minister is reported to have said:

"While one power is seeking more ground to stain by the slavery of an unfortunate branch of the
human family, the other is endeavoring, by preserving what belongs to it, to diminish the surface
which the former wants for this detestable traffic. Let the world now say which of the two has
justice and reason on its side."

(53) 1845-48, the United States Government wages war against Mexico.

(54) 1848, Subsequent to Articles VIII and IX of the 1848 Treaty of Guadalupe Hidalgo, which
ended the war between Mexico and the United States, it was agreed that all Mexican citizens,
including Africans:

"Who shall prefer to remain in the said territories [of Texas and what is now the Southwestern
region of the United States] may either retain the title and rights of Mexican citizens, or acquire
those of United States citizens," and will "be admitted at the proper time ... to the enjoyment of
all the rights of citizens of the United States, according to the principles of the Constitution; and
the meantime, shall be maintained and protected the free enjoyment of their liberty and property,
and secured the free exercise of their religion without restriction."

(55) 1854, slavery was abolished once again in Peru.

(56) 1870, slavery was abolished once again, in Cuba.

1) Defendant the Kingdom of Spain, knew, or should have known, that the Maafa, especially the
slave trade and slavery, was and is illegal, was and is a crime against humanity, because the
Kings of Spain prohibited slavery and the slave trade on numerous occasions, as set forth above,
and declared them illegal under the laws of the Kingdom of Spain, and under international
treaties and agreements to which Spain was and is a signatory; and because the Kings of Spain
promised freedom to, and liberated all men as well as all women, including all Africanslaves in
Spain, the Spanish Empire, and its colonies of Florida and Mexico, which included Texas and
the Southwestern part of the United States.

2) Upon information and belief, 15,000 Africans were illegally held in slavery in Florida on the
eve of the Florida Purchase in 1819, and that 200,000 Africans were illegally held in slavery in
the Texas Province of Mexico, and in the Southwestern Region of the United States on the eve of
Texas Independence in 1836.

3) The Kingdom of Spain's historical and continued silence, its historical and current failure and
refusal to admit these undeniable facts, is a continuing violation of Plaintiff's, Class members,
and their Ancestors, most basic and fundamental human rights, is a continuing crime against
humanity.

4) Plaintiff, and Class members, therefore call upon King Carlos V, and behalf of the Kingdom
of Spain, to stand before this Court and the world, and to honestly admit for once and for all, that
the Kings of Spain promised liberty, freedom and protection to all slaves within Spain and the
Spanish Empire, and that slavery and the slave trade was and is illegal under Spanish law, that
the Maafa was and is a crime against humanity, and that they were, and continue to be
wrongfully and unjust enriched by and through their participation in this crime, and that they
were, and continue to be wrongfully and unjust enriched by and through their participation in
this crime.

5) Plaintiff, and Class members, further call upon King Carlos V to stand before this court, and
the world, and admit that the Codigo Negro and the slave codes of Florida, Mexico and Texas
were and are odious and repugnant to the laws of civilized Spain and humanity, and therefore
null and void.

6) Plaintiff, And Class members, call upon the President of the United States, the Governors of
the States, and all Defendants, set forth herein, to make this declaration as well.

7) Full, truthful, and immediate accounting and disclosure is also required and demanded,
pursuant to the Freedom of Information Act, the Chicago Slavery Era Disclosure Act, the Illinois
UDAP, etc.

Because The French National Assembly Abolished Slavery

8) it is axiomatic, according to Montesquieu, that:

"Slavery is contrary to the fundamental principle of all societies." [See: Spirit of Laws, b.15, ch.
2.]

9) Upon information and belief, King Louis X of France issued an edict in 1315, abolishing
slavery and enfranchising the people. He declared that:

"As all men are by nature free born, and as this kingdom is called the Kingdom of Franks
[freemen], it shall be so in reality. It is therefore decreed that enfranchisements shall be granted
throughout the whole kingdom upon just and reasonable conditions." [See: Bodin de Repub., c.
5. and Ordon, tom. i. page 653.]

10) Three years later, King Philip V, the brother of Louis, confirmed the same edict. [See:
Ordon, tom. i. page 583.]

11) Upon further information and belief,

"In France, all the noted writers on law, at an early period, decided that slavery was contrary to
the common law, and that no slave could touch French soil without instantly becoming a
freeman. Even a foreign ambassador was not authorized to hold a man in involuntary servitude.
The slave of a Spanish minister was pronounced a freeman by the French judges. Nor could the
distinguished position of the claimant have any influence upon the Court to allow his claim.
Some complained of this want of respect to his office and rank, though the correctness of the
principle was universally conceded." [See: Hargrave, in the case of Somerset, page 62; Bodin de
Repub., 1. 1, c. 5.and Kircher, de Legat., 1. 2, c. I, n. 233. Binkershock Juge compet. des. Amb.,
ed. par Barbyr, c. 15, s. 3.]

12) The following timeline documents the struggle against the slave trade and slavery in France,
the French Empire, the West Indies and Louisiana:

1) 1571, the Parliament of Bordeaux frees all African and Moorish slaves, declaring slavery
illegal in France.

2) 1628, the Petition of Right is passed.

3) 1629, slavery forbidden in France.

4) 1716, prohibition against bringing slaves into France.

5) 1738, prohibition against bringing slaves into France tightened.

6) 1749, Montesquieu writes The Spirit of Laws, which condemns slavery as "contrary to the
fundamental principle of society."

7) 1771, May 15, Africans in French colonies who are born of free parents are declared equal in
civic rights with whites.

8) 1786, Louis XVI orders an improvement in the slave's fate.

9) 1789, France's new Constitution abolishes slavery; but Napoleon allegedly revokes it later.

10) 1789, Aug 25, the French National Assembly adopts the Declaration of the Rights of man
and of the citizen, but again, napoleon allegedly repudiates this Declaration later.

11) 1790, March 28, the French Constituent Assembly, which takes the place of the French
National Assembly, considers the colonies a part of the French empire, and subject to its laws.

12) 1791, The French National Assembly grants all Africans born of free parents in the French
west Indies voting rights and the same privileges as all citizens.

13) 1792, November 19, the French Convention declares its willingness to help all subjected
peoples achieve their liberation.

14) 1792, April 4, French National Assembly issues its "final" decree giving all free Africans
full citizenship.

15) 1793, August 29, Sonthonax arrives in Saint-Dominique (now known as Haiti), "as part of a
commission to enforce King Louis XVI's edict that both the mulattos and the slaves of
Saint-Dominque were to be freed."

16) 1794, February 4, the French National Assembly abolishes slavery in France and the French
colonies, one again, where there are no slaves, according to the decision of Louis XIV, and
confers full citizenship on more than 500,000 Africans in the French West Indies and 40,000
Africans in Louisiana colony; but once again, Napoleon allegedly re-establishes slavery in 1802
and revokes their citizenship.

17) 1794, June 2, Victor Hugo arrives in Guadeloupe and abolishes slavery.

18) 1796, July 18, Baco et Burnel lands in Mauritius, and abolishes slavery, but is forced to sail
away; and slavery therefore remained in effect in Mauritius and Reunion.

19) 1801, On July 26, Toussaint published and promulgated a new constitution for San
Domingue which abolished slavery.

20) 1802, May 20, Napoleon sent General LeClerc, his brother-in-law, with 30,000 French
soldiers to overthrow Toussaint and re-impose slavery in Haiti, the entire French West Indies,
and Louisiana.

Napoleon asked Leclerc: "Which has been the most prosperous regime for the colonies?"

Leclerc responded: "The previous one."

"Well, then, put it back," Napoleon decided.

21) 1802-03, with this illegal command, Napoleon attempts to reestablish the Code Noir and
slavery, after 8 years of freedom and citizenship, in the French Empire, including in Louisiana

22) 1802, July, "Toussaint joined other black leaders in coming to terms with France, ... [and
laid] down his arms only after extracting a promise from Leclerc that slavery would never be
reinstated in Haiti. Shortly afterward he was tricked into a meeting with one of Leclerc's generals
and made a prisoner.

23) 1803, Leclerc is defeated in Haiti, which declares its independence, and Napoleon decides to
sell Louisiana to the United States.

24) 1815, March 29, Napoleon agrees to abolish the French slave trade, which continues for
another 16 years.

25) 1815, November 20, at the 2nd Peace of Paris Conference, Napoleon reconfirms his
commitment to abolish the French slave trade by 1819, and limit the trade to her own colonies
until then.

26) 1818, France abolishes the slave trade, effective in 1826; but it is still allegedly illegal for
slaves to live in France, where there are no slaves.

27) 1823, France prohibits her ships from transporting slaves.

28) 183 1, all French free people are once again declared equal.

29) 1843, France introduces engage or forced labor emigration to colonies to evade the
Anti-Slavery Treaties which it is a signatory to.

30) 1848, April 27 or March 4, France once abolishes slavery, once again, in all of its colonies,
freeing 74,000 people in Martinique, and promising compensation to the slave holders.

31) 1859, France abolishes the engage system of forced labor in its colonies.

32) Defendant the French Republic, knew and knows, or should have known and should know,
that the Maafa, especially the slave trade and slavery, was and is illegal, was and is a crime
against humanity, because the Kings and the National Assembly of France prohibited slavery
and the slave trade on numerous occasions, as set forth above, and declared them illegal under
the laws of France, and under international treaties and agreements to which France is a
signatory; and because the Kings and National Assembly of France liberated all Africanslaves in
France and the French Empire in Africa and the African Diaspora, including its colonies in the
West Indies, New France (Canada), and Louisiana.

33) France's historical and continued silence, its historical and current failure and refusal to
admit these undeniable facts, is a continuing violation of Plaintiffs, Class members, and their
Ancestors, most basic and fundamental human rights, is a continuing crime against humanity.

34) Upon information and belief, 40,000 Africans in Louisiana on the eve of the 1803 Purchase,
were free and citizens of France, and that they and their Descendants were held illegally and
immorally in slavery.

35) Plaintiff, and Class members, therefore call upon President Jacques Chirac, and behalf of the
Republic of France, to stand before this Court and the world, and to honestly admit once and for
all, that the Kings and National Assembly of France promised liberty, freedom and protection to
all slaves within France and the French Empire, and that slavery and the slave trade was and is
illegal under French law, that the Maafa was and is a crime against humanity, and that they were,
and continue to be wrongfully and unjust enriched by and through their participation in this
crime.

36) Plaintiff, and Class members, further call upon President Jacques Chirac to stand before this
court, and the world, and admit that the Code Noir and the Louisiana code were and are odious
and repugnant to the laws of civilized France and humanity, and therefore null and void.

37) Plaintiff, And Class members, call upon the President of the United States, the Governors of
the States, and all Defendants, set forth herein, to make this declaration as well.

38) Full, truthful, and immediate accounting and disclosure is also required and demanded,
pursuant to the Freedom of Information Act, the Chicago Slavery Era Disclosure Act, the Illinois
UDAP, etc.

Because The Air Of Britain Is Too Pure For A Slave To Breathe

39) Upon information and belief:

"The battle against slavery was long and arduous in England, sometimes extremely bloody; for
the proslavery party was always active, and consisted of the most unprincipled men of the
kingdom. They fought against the fundamental law of society, in order to-maintain their own
unjust assumptions."

"The friends of justice and freedom improved every advantage to give supremacy to this law and
to overthrow slavery. No man was authorized to be tried on a question inVolumeving his
personal rights without a jury of twelve men. No claimant of a slave could touch the man till
twelve peers had set in judgment upon the case; and they were always, when fairly chosen, on
the side of freedom. It was by the institution of jury trial that slavery was completely annihilated.


"Laws, too, were enacted by Parliament for increasing the advantages in favor of freedom,
though not without the most strenuous opposition of the slavemasters. Many [villeins) were
manumitted by positive enactments in the days of Edward I (1272-13071. Every possible legal
obstruction was thrown in the way of the claimant, whilst all possible advantage was given to the
alleged slave." [See: Co. Litt. 139,--Fitzh. Nat. Br. 78, C. D. 13th Edw. 2, 408. Litt. s. 20-209, &
2 Ro. Abr. 735-737. and Britt. Capage 31.-Mirror of Justice, c. 2, s. 38.]

The English law said, "Impious and cruel is he to be esteemed who favors not liberty." [See:
Cod. Lit., 124.]

"A bad custom or usage is to be abolished," said the English law; and away went slavery. [See:
Jenk Cent., 93. and Cod. Lit.,l41.]

40) The following timeline documents the struggle to prohibit the salve trade and slavery in
Britain:

a. 1000, 7% of the inhabitants of England were slaves, but the institution had practically
disappeared by the Middle of the 17th Century.

b. "Even as early as 1102, shortly after the accession of Henry I (111135) of England, the
anti-slavery spirit was so strong in that nation, that, in a national ecclesiastical council, held at
Westminster, under Archbishop of Canterbury, Saint Anselm (1033-1109), ‘it was forbidden to
sell men like cattle, which had been too generally practised in England,' especially since the
conquest (1066) of William of Normandy (1066-1087)."

c. Between 110 and 1350, slavery as a custom and practice had disappeared in England.

d. "Henry I, on taking the throne, promised the people their natural rights. To make sure of that,
they required him to give them a charter of those rights and his solemn oath to maintain it. He
complied. This charter of English liberties was regarded as the law of the land. It recognized the
great primal law of nature, guaranteed justice and right to every man, and prepared the way for
the total abolition of slavery in the kingdom."

e. 1170, "the great Synod of Ireland, under the leadership of St. Lawrence O'Toole, denounced
the ‘slave trade in which the Irish had made bond slaves of the English, contrary to the right of
Christian freedom.' declaring, also, that ‘they had purchased of robbers and pirates, as well as of
merchants-a crime for which God took vengeance upon the nation by delivering them into like
bondage. and therefore unanimously decreed and ordained, that all the English throughout
Ireland in a state of slavery, should be restored to their natural freedom.' Thus Ireland has the
honor of the first general emancipation act known in history. [See:.. id Moore, History of Ireland,
Volume 2, page 232; Chronica Hiberniae. Cott. Lib Dom. A. 18; and Stephens, West Indian.
Slavery, Volume 1, page 6.]"

f. 1562, when Queen Elizabeth first heard that John Hawkins had committed an act of piracy,
kidnapped and traded in slaves, and thereby launched England involvement in the slave trade,
she reportedly detested the slave trading voyages as "detestable ventures." She is alleged to have
been critical and to have "commented that he would have to pay a very high price for dealing in
human lives. Hoever, when she was confronted with a copy if his profit ledger, her moral
indignation softened," and became a business partner.

g. 1569, the Courts decided that "England was to pure an air for slaves to breathe in," a
decision that ended slave trade and slavery in Lngland, Britain and the British colonies for all
peoples, and for all times.

h. 1600, Butts vs. Penny declared that "there could be no property in the person of a Man ... but
by compact or conquest."

i. 1645, English Parliament passed an Ordinance prohibiting kidnapping.

10) 1662, it was declared that "any of His Majesty's subjects of England, Ireland and His
Plantations are to be accounted English and no other." [14. Car. 11., C.II, paragraph 5.]

11) 1600s, Lord Mansfield declared:in Rev vs. Cowle that the "supremacy of English courts
extends itself over its Dependencies." He also declared aht "the British legislaturem as to the
power to make laws, represents the whole Vritish Empire, and has authority to bind every part
and every subject without the least distinction, whether such subjects have the right to vote or
not, or thether the law binds places within the realm, or without."

12) 1706, a decision that English "common law takes no notice of the negroes [[see] for being
different from others as, by the common law no man can have property in another except in
special instances."

m. 1772, in the landmark Somerset vs. Stewart decision, Lord Mansfield declared that the
common law of England was incompatible with slavery and neither recognized it nor permitted
its existence in England. He also declared that "the state of slavery is of such a nature, that it is
incapable of being [[legally] introduced [established] on [for] any reasons, moral or political, but
only by positive [written] law, which preserves its force long after the reasons, occasion, and
time itself from whence it was created, is erased from memory. It [slavery] is so odious that
nothing can be suffered to support it, but positive law. Whatever inconveniences, therefore, may
follow from the decision, I cannot say this case is allowed or approved by the law of England;
and therefore the black must be discharged." The Somerset decision liberated 15,000
slaves in England.

n. 1807, March 25, British Parliament passed the Abolition of the Slave Trade Act, which
included Lord Greenville's declaration that the slave trade was "contrary to the principles of
justice, humanity and sound policy," and he admonished his fellow parliamentarians for "not
having abolished the trade long ago."

o. 1808, Trans-Atlantic slave trade was abolished within the Empire and also in the United
States.

p. 1827, Britain declares the slave trade as piracy making it punishable by death.

q. 1833, slavery was abolished throughout Europe and the Emancipation Act went through
British parliament. It still took another 11 years until 1838 before slavery was fully abolished
within the British Empire. British slave masters were paid £20,000,000 (20 million pounds) as
compensation for their former slaves, whose enslavement continued, under a new set of
apprenticeship laws.

18) Anett G. Lindsay, a student of Dr. Carter G. Woodson at Howard University in 1919, claims
that "the humanitarian spirit of Great Britain which, by the celebrated decision of Lord
Mansfield in the Somerset case in 1772 guaranteed to everyman his freedom as soon as he set
foot on British soil, extended beyond the limits of the empire. Although this decision of the
judge evoked some unfavorable comment, for slavery was the ‘normal' condition of the Negro,"
his ideas were disseminated by the military authorities defending the Crown in America. During
the Revolutionary War many of the British commanders issued proclamations of freedom to the
Negroslaves. Lord Dunmore, the dethroned Governor of Virginia, was among the first to issue a
proclamation of freedom to all Negroes who would fight for the King. Soon thereafter, Clinton,6
the Commander-in-chief of the British forces in America, issued a proclamation to the same
effect. Still later, Cornwallis issued a proclamation specifying the grant of "freedom and
protection" to all Negroes who would seek his command. Whatever motive prompted the
issuance of these orders, it is evident that the status of the Negro during this "emergency" as
regarded by Great Britain was that of a freeman." [Emphasis added.]

19) Defendant the United Kingdom, knew and knows, or should have known and should know,
that the Maafa, especially the slave trade and slavery, was and is illegal, was and is a crime
against humanity, because the Parliament of the United Kingdom prohibited slavery and the
slave trade on numerous occasions, as set forth above, and declared them illegal under the
United Kingdom, and under international treaties and agreements to which France is a signatory;
and because the Kings and National Assembly of France liberated all Africanslaves in Britain
and the British Empire in Africa and the African Diaspora, including its colonies in the West
Indies and the 13 British Colonies in the United States.

20) The United Kingdom's historical and continued silence, its historical and current failure and
refusal to admit these undeniable facts, is a continuing violation of Plaintiff's, Class members,
and their Ancestors, most basic and fundamental human rights, is a continuing crime against
humanity.

21) Upon information and belief, there were 428,000 Africans in the West Indies, 700,00 in the
13 British colonies of North America, and 100,000 in Cape Town, and their Descendants were
held illegally and immorally in slavery,

22) Plaintiff, and Class members, therefore call upon Queen Elizabeth II, and behalf of the
United Kingdom, to stand before this Court and the world, and to honestly admit once and for
all, that the English Parliament gave liberty, freedom and protection to all slaves within Britain
and the British Empire, that slavery and the slave trade was and is illegal under British law, and
that the Maafa was and is a crime against humanity, and that they were, and continue to be
wrongfully and unjust enriched by and through their participation in this crime.

23) Plaintiff, and Class members, further call upon President Jacques Chirac to stand before this
court, and the world, and admit that the Barbados code, the Massachusetts Code, the Virginia
code, and all other slave codes were and are odious and repugnant to the laws of civilized Britain
and humanity, and therefore null and void.

24) Plaintiff, And Class members, call upon the President of the United States, the Governors of
the States, and all Defendants, set forth herein, to make this declaration as well.

25) Full, truthful, and immediate accounting and disclosure is also required and demanded,
pursuant to the Freedom of Information Act, the Chicago Slavery Era Disclosure Act, the Illinois
UDAP, etc.

Because Slavery Was Prohibited In The Northwest Territory

26) in 1720, "the first ship load of slaves ... was landed at St. Philip by Philip Francis Renault a
cargo of 500 negroslaves from San Domingo, which he afterward soldto the inhabitants of the
Illinois country. At the time of the session of the Illinois country to England, it is estimated there
were in that country 900 negroslaves. Many of the French, with their slaves, shortly thereafter
moved west of the Mississippi River, and in 1770 there remained in the Illinois country not to
exceed 600 negroslaves."

27) By Article VI of the Northwest Ordinance of 1787 it was provided: "There shall be neither
slavery nor involuntary servitude in the said territory, otherwise than in the punishment of
crimes, whereof the party shall have been duly convicted."

28) "Illinois Governor St. Clair, and subsequently Governor Harrison, took the position,
however, that the Ordinance of 1787 should ... did not affect the status of slaves held in the
Northwest territory prior to 1787, and that view was apparently acquiesced in by the people and
courts in that territory for many years ... At the time the territory of Illinois was organized there
were found therein French negroslaves, indentured negroslaves, and free negroes.

29) "From 1835-1860, during which latter period such lawyers as Abraham Lincoln, Lyman
Trumbull, Gustav Koerner, James H. Collins, W. T. M. Davis, Nathaniel Niles, John M. Palmer
and others advised the negroes held in bondage in Illinois that they were not legally held as
slaves and that they were entitled to their freedom .... Cases, however, involving the legal rights
of negroes held as slaves found their way into the courts, especially the courts of last resort in
Illinois, slowly."

30) In 1845, "the case of Jarrot v. Jarrot (2 Gilm., 1) was decided. The plaintiff in the Jarrot case
was a blackslave named Joseph Jarrot. Angelique the plaintiffs grandmother had been held as a
slave by Joseph Trotier at Cahokia prior to the year 1784. Louis Lebrun, who had married a
daughter of Joseph Trotier afterwards held Angelique as a slave at Cahokia until the year 1798.
In that year Lebrun sold Angelique and her daughter Pelaque to Nicholas Jarrot of Cahokia.
Nicholas Jarrot died in 1818 and willed all his property to his wife Julia (the defendant). The
plaintiff was born after the death of Nicholas Jarrot and while his mother Pelaque was held as a
slave by the defendant."

31) "The plaintiff brought an action of assumpsit for work and labor in the St. Clair County
Circuit Court. He claimed that his labor for the past five years was worth five dollars above his
clothing and his board. The issue of Joseph's freedom was joined and the county court held for
the defendant. The decision was then taken to the Illinois Supreme Court."

32) "The Illinois Supreme Court held that Article VI of the Ordinance of 1787, contrary to the
views expressed by Governors St. Clair and Harrison and acted upon by the people and the lower
courts for many years, to be retroactive in its operation, that is, it applied to all negroslaves in the
Northwest territory at the time of its passage."

33) "The Illinois Supreme Court decided the Jarrot case in favor of the plaintiff in the following
language, ‘If words are not mere empty sounds, if they mean anything, then the plaintiff is free
by virtue of the express declaration of the Northwest Ordinance and the Constitution of Illinois."


34) "The effect of this decision was to liberate all the trench negroslaves and their children in
Illinois from the bondage which for fifty-eight years had illegally deprived them and their
ancestors of their freedom." The Court also ordered the Jarrots to pay Joseph the $5
owed him for five years of slave wages.

35) Plaintiff, and Class members, demand that the State of Illinois investigate this precedent
closely, and make full disclosure on all findings, including but not limited to:

a) Where all of the slaves freed?

b) Where all of the slaves paid for their 58 years of slave labor, and if so, how much?

c) Who committed this crime against humanity, and how much were they wrongfully and
unjustly enriched? Plaintiff suggests that the Jarrot Family, the State of Illinois, and the Illinois
Central Railroad, in particular, be held liable and accountable for this crime.

d) How was their money converted, and to what use?

e) Did any of the Defendants named herein, participate in this crime against humanity, and/or
were any of them unjustly enriched?

f) Should that money be awarded to the Descendants of these wrongfully and unjustly held
slaves, and if so, in what amount?

UNJUST ENRICHMENT AND UNJUST IMPOVERISHMENT

2) Joe R. Feagin, in his working paper Documenting the Costs of Slavery, Segregation,
and Contemporary Discrimination. Are Reparations in Order for African Americans? suggests
that "the rationale for group compensation lies in the stolen labor and lives of the millions
enslaved, the stolen labor and lives of those legally segregated, and the continuing theft of labor
and lives of those who face contemporary discrimination. This theft of labor and lives was
carried out not only by whites acting as individuals, but also, for at least its first 350 years, by
various local, state, and federal governments. Whites have been involved individually and
collectively in the exploitation and oppression of African Americans for nearly four centuries."

3) "The concept of unjust enrichment," according to Feagin, "is an old legal idea traditionally
associated only with relationships between individuals. From a legal perspective, unjust
enrichment involves circumstances that "give rise to the obligation of restitution, that is, the
receiving and retention of property, money, or benefits which in justice and equity belong to
another" (Ballentine 1969: 1320). In U.S. court decisions the defendant has been required to give
up the unjust enrichment, including gains later made from it (see Kull 1995). For example, U.S.
law does not generally permit a thief's children to benefit from the father's theft. Some have
suggested extending the idea of remedies for unjust enrichment to the conditions of group
oppression, including that faced by African Americans over several centuries... Indeed, it does
make moral sense and might conceivably be one basis for new legal institutions aimed at
restitution and reparations for the enrichment stemming from past "crimes against humanity."


4) "Under this latter circumstance," he suggests, "group remedies should encompass stopping the
unjust extraction of benefits now and in the future as well as the making of restitution to the
victim group for past oppression. Implicit here is the counterpart idea of unjust impoverishment,
which describes the conditions of those Who Have Suffered From Those Being Unfairly
Enriched

Lives Stolen Under The Slave Trade

5) Thomas Cooper in his book Supplement to Mr. Cooper's Letter on the Slave Trade,
Dr. W.E.B. DuBois in his book The Suppression of the Slave Trade, Toni Morrison in
her novel Beloved, and Piers Larsen in his Museum of Slavery in the Americas,
estimates that 180 million, 100 million, 60 million, or 28 to 42 million Africans,
respectively, were murdered or enslaved in the Trans-Atlantic slave trade between 1435 and
1880.

6) Piers Larsen estimates that one-half of these Africans, two women for every man, an
estimated 14 to 90 million African people, were held in slavery in Africa.

7) Portugal and Brazil, Spain, the Netherlands, Britain, France, the United States, Denmark,
Canada, the Bradenburgers of Germany, Russia, and other European nations organized,
controlled, and were, and continue to be unjustly enriched by the Trans-Atlantic slave-trade (also
called the Triangle Trade), the colonialism out of which it was born, and the slavery and
slave-like practices, the segregation and apartheid, the racism and racial discrimination that it
nurtured and intensified. The Vatican licensed them, gave them religious and ideological
justification, and was and continues to be unjustly enriched by them as well. Corrupt African
Kings, Queens, and traitors participated in, and were unjustly enriched as well, even if unequally
and at the lowest level,

8) David Eltis estimates that Britain was responsible for ¶ percent of the Trans-Atlantic slave
trade, and that British flags flew on ??? percent of the 27,252 slave voyages that sailed from the
ports of London, Liverpool, Bristol, Lancaster, Whitehaven, and other ports from 1527 to 1867.
Britain was therefore responsible for the mutilation, rape, murder, kidnapping and
enslavement of 6 to 77 million victims of the Trans-Atlantic slave trade.

9) Eltis also estimates that the Netherlands and the United States were responsible for 4.5 percent
and 6.3 percent of the Trans-Atlantic slave trade, respectively. The Netherlands and
the United States were therefore responsible for the mutilation, rape, murder, kidnapping and
enslavement of 630,000 to 8.1 million and 882,000 to 11.3 million victims of the Trans-Atlantic
slave trade, respectively.

10) Larsen estimates that 4 to 6 million Africans were murdered at different points along what
Joseph Miller called the "way of death," (the initial invasions of villages, the point of
enslavement, the forced march to the coast, the waiting period at the forts on the coast, the
transfer to the ships, the Middle Passage, the arrival in the Americas, and during the seasoning
period). Larsen suggests an average mortality rate of 40 percent.

11) Cooper estimated that "for each slave taken, 10 were lost due to warfare in Africa, 1/5th died
in passage and another 2/3rds during ‘seasoning,' for a total of 170 million deaths, a mortality
rate of 1,700 percent." Joseph Miller estimates that "of 100 people seized in Africa,
75 would have reached the marketplaces in the interior; 85 percent of them, or about 64 of the
original 100, would have arrived at the coast; after losses of 11 percent in the barracoons, 57
would have stepped onto Brazilian soil, and 48 or 49 would have lived to behold their first
master in the New World. The full ‘seasoning' period of 3-4 years would leave only 28 or 30 of
the original 100 alive and working," a mortality rate of 70 to 72 percent.

12) Ghana, formerly called the Gold Coast, was the headquarters of the Dutch and British slave
trade. Thirtysix of the forty-two slave fortresses were located in Ghana. The Trans-Atlantic
slave-trade and slavery impacted on all regions of Africa, especially eight specific historic
regions, including Senegambia (4.5 percent), Sierra Leone (3.7 percent), the Windward Coast
(1.7 percent), the Gold Coast (9.4 percent), the Bight of Benin (8.4 percent), the Bight of Biafra
(13.7 percent), West Central Africa (44.2 percent) and South East Africa. A few corrupt African
kings and queens and chiefs, empires, states and countries, participated in the slave trade and
slavery. The present day countries of Nigeria, Angola, Ghana, Senegambia, Sierra
Leone and all of the other African regions accounted for 24 percent, 24 percent, 16 percent, 11
percent, 6 percent and 6 percent of the slaves, respectively.

13) Untold numbers of families, clans, tribes, societies, villages, nations and civilizations in
Africa were disrupted, pillaged, raped, and destroyed during the slave-trade and colonialism.
And the disruption, pillage, rape and destruction of Africa, the same regions and countries,
continues and intensifies today, 549-years later.

14) The Netherlands, Britain and the United States are responsible for 42.5 percent, - -,
respectively of this illicit and ill-gotten wealth from the Trans-Atlantic slave-trade, and we have
not yet accounted for the compensation required, for the material, social, cultural, spiritual,
environmental, mental and other damages that Africa and African people suffered. Nor have we
calculated the amount of punitive damages legally and morally required.

15) This unjust enrichment, created on the backs of the Trans-Atlantic slave-trade, helped the
slave-trading European countries recover from the so-called "Black Plague," and to grow and
develop, economically and socially, at the expense of Africa, which stagnated, declined, and
de-developed.

16) This illicit and ill-gotten wealth, flowed from Africa to Europe, and from the peoples and
nations of Africa into the hands of the royal, founding and leading Families, corporations and
nations of Europe. It was transferred and maintained through inheritance, re-investment,
mergers, and monopolization, through the building and development of palaces and plantations,
churches, universities and other not-for-profit institutions and organizations. This illicit and
ill-gotten wealth exists and is controlled by the Defendants today, Plaintiffs deserve, legally and
morally, and demand a full accounting, restitution and disgorgement.

17) Philip D. Curtin and Joseph E. Inikori estimate that 10 to 15 million
slaves were landed alive in the Western Hemisphere, two men for every woman.

18) Eltis suggests that fifteen regions in the Western Hemisphere received slaves, including the
British Mainland of North America, the British Leewards, the British Windwards and Trinidad,
Jamaica, Barbados, Guyana, the Spanish American Mainland, the Spanish Caribbean, Northeast
Brazil, Bahia, Southeast Brazil and other areas in the Americas. According to Anika
Francis, "half of all slaves were sold to South America, 42 percent to the Caribbean, 7 percent to
British North America, and 2 percent to Central America."

19) All of the countries in the Western Hemisphere participated, to some degree or another, in
the TransAtlantic slave-trade and slavery, especially the fifteen regions in the America's who
received slaves: 40.6 per cent were shipped to Brazil, 29 percent to the British colonies in the
Caribbean and North America, 14.3 percent to the Spanish colonies in the Americas, 12 percent
to the French colonies, and 2.7 percent to the Dutch Americas.

20) Plaintiff avers that the Maafa, especially the Trans-Atlantic Slave Trade and slavery, was and
is a crime against humanity, and cites here several arguments to prove the correctness of this
position.

Labor Stolen Under Slavery

21) Joe R. Feagin says that, "for some fifteen generations the exploitation and oppression of
African Americans have redistributed income and wealth earned by black labor to generations of
white Americans, leaving the former relatively impoverished as a group and the latter relatively
privileged as a group. Consider just the value of the African American labor that was
expropriated. The white owner's cost for maintaining an enslavedAfrican American was
generally very low, and under many circumstances large profits could be generated off the labor
of such a subordinated worker (DuBois 1992 [1935]). Larry Neal has calculated that the current
(1983) value of the slave labor expropriated by whites from 1620 to 1865 ranges from about $1
trillion to as much as $97 trillion, depending on the rate of interest chosen (Swinton 1990: 156)."


22) "James Marketti has estimated." according to Feagin, "the dollar value of the labor taken
from enslavedAfrican Americans from 1790 to 1860 at, depending on the historical assumptions,
from $7 billion to as much as $40 billion. Such a figure roughly indicates what black individuals
and families lost in income because they did not control their labor.3 Marketti suggests that, if
that stolen income is multiplied by taking into account lost interest from then to the present, the
current (1983) economic loss (income diverted) for black Americans ranges from $2.1 to $4.7
trillion (Marketti 1990: 118).4 Updating these 1983 estimates places the current value of the
diverted labor income in the trillions of U.S. dollars."

Labor Stolen Under Segregation

23) "Under legal segregation, according to Feagin, ‘the economic losses for black Americans
were again high. One research study estimated the cost of labor market discrimination for
1929-1969 (in 1983 dollars) at $1.6 trillion (Swinton 1990: 156). Calculating the cost of
anti-black discrimination from the end of slavery in 1865 to the year 1969, the end of legal
segregation, and putting that calculation into year-2000 dollars would likely increase that
wage-loss estimate to several trillion dollars."

Continuing Theft Of Labor Today

24) "Since the end of official segregation," according to Feagin, Africans in America "have
suffered additional economic losses. A number of economic studies have suggested how much
African American workers annually lose from continuing discrimination and informal
segregation in employment. For one year in the 1970s the estimate of the cost of continuing
racial discrimination in employment has been put in the range of $94-123 billion (Darity 1990:
11). Estimating a dollar figure for the period since the end of segregation to the present day
would doubtless bring this figure of lost income and purchasing power from continuing
discrimination to another several trillion dollars."

25) "Clearly," Feagin concludes, "the sum total of the worth of all the black labor stolen by
whites through the means of slavery, segregation, and contemporary discrimination is
staggering--many trillions of dollars. The worth of all that labor, taking into account lost interest
over time and putting it in today's dollars, is perhaps in the range of $5 to $24 trillion."


THE SHIPPING INDUSTRY DEFENDANTS

Lloyd's Register

26) Upon information and belief, Defendant Lloyd's Register Society was founded in 1760 by
merchants, marine underwriters and other customers of Edward Lloyd's coffee house in London
where they exchanged information about the condition of the vessels they insured and chartered.
Lloyd's printed its first Register of Ships in 1764. By 1840, Lloyd's had surveyed and certified
some 15,000 vessels.

27) Upon further information and belief, Lloyd's was and is a major participant in the Maafa,
especially in the Trans-Atlantic slave trade, which is also known as the Atlantic Trade, the
Triangle Trade, the Middle Passage, the Colonial Trade, the West Indies trade, etc. It maintained,
and still holds, records on at least 11,200 slave voyages, some 41 percent of the 27,233 slave
voyages that are documented in Trans-Atlantic Slave Trade Database.

Port of Liverpool.

28) Upon information and belief, more than 1,500,000 Africans, more than 10 percent of the
total volume of the Trans-Atlantic slave trade, were kidnapped and forcibly transported across
the Atlantic in chains, from 1700 to 1807, by 4,891 Liverpool slave voyages, organized by 8
major slave traders, whose investors included at least I member of parliament, 41 councilors, and
8 mayors.

29) Upon further information and belief, Defendant the Port of Liverpool was and is responsible
for 48 percent of the British slave trade, and its colonial, return trade. As one Minister put it, "the
whole city of Liverpool was built by the blood of the poor African."

30) The Port of Liverpool was and is a major participant in the Maafa, especially in the
Trans-Atlantic slave trade, which is also known as the Atlantic Trade, the Triangle Trade, the
Middle Passage, the Colonial Trade, the West Indies trade, etc.

Port of London

31) Upon information and belief, 747,396 Africans were kidnapped and forcibly transported
across the Atlantic in chains, by at least 2,699 London slave voyages. At least 121,637 Africans
were murdered during the Middle Passage, and 625,759 were landed alive and forced to live in
slavery in the Americas.

32) Upon further information and belief, Defendant the Port of London was and is responsible
for 21 percent of the British slave trade, and its colonial, return trade. "Slavery was [and is] at
the heart of the wealth of London." For more than 200 years, it was the commercial
and financial center of Europe and the world.

33) The Port of London was and is a major participant in the Maafa, especially in the
Trans-Atlantic slave trade, which is also known as the Atlantic Trade, the Triangle Trade, the
Middle Passage, the Colonial Trade, the West Indies trade, etc.

Port of Bristol

34) Upon information and belief, 525,044 Africans were kidnapped and forcibly transported
across the Atlantic in chains, by at least 2,144 Bristol slave voyages. At least 88,240 Africans
were murdered during the Middle Passage, and 436,804 were landed alive, and forced to live in
slavery in the Americas.

35) Upon further information and belief, Defendant the Port of Bristol was and is responsible for
18 percent of the British slave trade, and its colonial, return trade.

36) The Port of Bristol was and is a major participant in the Maafa, especially in the
Trans-Atlantic slave trade, which is also known as the Atlantic Trade, the Triangle Trade, the
Middle Passage, the Colonial Trade, the West Indies trade, etc.

Port of Glasgow

37) Upon information and belief, while only 5 slave ships departed from Defendant the Port of
Glasgow, it benefited immensely, and continues to benefit, from the Maafa, from the slave trade
and slavery, especially from the tobacco and cotton trades.

38) Upon further information and belief, Glasgow won control of the French tobacco market in
1740, and by the 1770s, it controlled over one-half of Britain's trade in tobacco, which was
grown in the United States by slaves. By the 1780s, 17 percent of Scottish textile mills were
financed by colonial merchants, who employed 20,000 weavers in their mills. For 250 years,
Scotland provided the general staff for the British empire, and Glasgow merchants played the
role of middlemen, as factors, and as growers in Virginia's slave-driven tobacco economy.

39) The Port of Glasgow was and is a major participant in the Maafa, especially in the
Trans-Atlantic slave trade, which is also known as the Atlantic Trade, the Triangle Trade, the
Middle Passage, the Colonial Trade, the West Indies trade, etc.

Port of Nantes

40) Upon information and belief, 1,456,400 Africans were kidnapped and forcibly transported
across the Atlantic in chains, 13.17 of the total volume of the Trans-Atlantic slave trade, by at
least 2,000 Nantes slave voyages from 1651 to 1867. At least 192,700 Africans were murdered
during the Middle Passage, and 1,263,700 Africans, 13.6 percent of the total volume, were
landed alive, and forced to live in slavery in the Americas.

41) Upon further information and belief, Defendant the Port of Nantes was and is responsible for
50 percent of the French slave trade, and its colonial, Triangle trade in slave produced products
and services.

42) The Port of Nantes was and is a major participant in the Maafa, especially in the
Trans-Atlantic slave trade, which is also known as the Atlantic Trade, the Triangle Trade, the
Middle Passage, the Colonial Trade, the West Indies trade, etc.

Port of Boston

43) Founded in 1630, Defendant the Port of Boston is the oldest port, and was the largest and
busiest in the Western Hemisphere. Boston slave traders kidnapped and forcibly transported
2,401 Africans across the Atlantic in chains. At least were 334 murdered during the Middle
Passage, and 2,067 were landed alive in the Americas, mostly the Caribbean, and forced to work
for the rest of their lives to feed Boston and Europe's thirst for sugar and rum.

44) Until surpassed by the Port of New York, the Port of Boston controlled, and was wrongfully
and unjustly enriched by and through the Triangle Trade, the West Indies Trade, the Colonial
Trade, the Coastal Trade, etc., in sugar, rum, cotton and turpentine. Boston shipping merchants
invested the profits gained from these illegal, immoral and unjust ventures into the China Trade,
including the smuggling and distribution of opium throughout the world.

45) Upon information and belief, several Boston families, including the English, Faneuil, Cabot,
Lowell, Crowinshield, Derby, Perkins, Cushing, Sturgis, Russell, and other families, owned,
controlled, and were, and continue to be, wrongfully and unjustly enriched by and through their
participation in the Maafa. Joseph Peabody had accumulated more than $1.2 million by 1825,
James and Thomas Perkins had accumulated $16 million by 1875, and Robert Bennett Forbes
had accumulated $2.5 million by 1875. These families, and others not named, must,
and ultimately will, be held accountable and liable for their participation in the Maafa as well.

Port of Providence

46) Upon information and belief, the Ports of Rhode Island, Bristol, Newport and Defendant the
Port of Providence, were major participants in, and wrongfully and unjustly enriched by and
through their participation in the Maafa, especially in the Trans-Atlantic slave trade and the
Triangle Trade.

47) According to Sam Nitze, a staff writer for the Providence Journal, "From 1769 to 1820, three
generations of DeWolfs built a fortune on the slave trade. Mark Anthony DeWolf and his three
sons sailed to West Africa with barrels of rum, which they traded for slaves. They returned with
men, women and children to be sold in Havana or Charleston, S.C. Some of the slaves were put
to work on the family's sugar and coffee plantations in rural Cuba. Molasses made at the sugar
plantations was brought to the family's distilleries in Bristol and converted into rum, completing
a cycle known as the Triangle Trade. Between 1784 and 1807, the DeWolfs financed 88 slaving
voyages, twice the number of their nearest Rhode Island competitors.

48) "Without a doubt," Jay Coughtry writes in his book, The Notorious Triangle. Rhode Island
and the AfricanSlave Trade, 1700-1807, "the DeWolfs had the largest interest in the
Africanslave trade of any American family before or after the Revolution. Theirs was one of the
few fortunes that truly rested on rum and slaves."

49) Upon further information and belief, "James DeWolf, son of Mark Anthony, eventually
became a U.S. senator and secured political favors from President Thomas Jefferson that allowed
him to continue the family business ling after the slave trade was outlawed in Rhode Island.
After he finally withdrew from the trade, DeWolf invested in and operated a textile mill the used
cotton provided by slave labor. When he died, DeWolf was the second-richest man in the United
States."

50) At least 937 slave voyages began at Rhode Island Ports, and were responsible for kidnapping
and enslaving more than 116,288 Africans, of whom were murdered during the Middle Passage,
with 99,671 landed alive in the Americas, especially Cuba, Barbados, the Carolinas, Jamaica,
Georgia, Rhode Island, etc.

51) All of the ports and cities of Rhode Island, and New England, were and are major
participants in the Maafa, especially in the Trans-Atlantic slave trade, which is also known as the
Atlantic Trade, the Triangle Trade, the Middle Passage, the Colonial Trade, the West Indies
trade, etc.

52) Several Rhode Island families owned, controlled, were, and continue to be wrongfully and
unjustly enriched by and through their participation in the Maafa. Captain James Brown had
accumulated $166 million by 1925, Robert Hale Ives had accumulated $25 million by 1889,
Elizabeth Hope Slate had accumulated $17 million by 1925, Harold Brown had accumulated $10
million by 1900, Eliza Anthony Gammell had accumulated $8.5 million by 1925, and Thomas
Poynton Ives Goddard had accumulated $1.5 million by 1875. These families, and
others, must, and ultimately will be held accountable for their crimes as well.

Port of Virginia Authority

53) Upon information and belief, at least 650,000 Africans were kidnapped and transported to
the United States during the Maafa. Defendants the Ports of Virginia imported more slaves than
any other port, with the possible exception of Charleston and Augusta.

54) At least 13 slave voyages began in Virginia, which left Africa with 2,443 slaves, of whom
were murdered during the Middle Passage, and 2,185 landed alive in the Americas. The
Trans-Atlantic Slave Trade Database records 435 voyages, transporting 101,925 slaves from
Africa, 17,678 of whom were murdered during the Middle Passage, and 84,247 landed alive in
Virginia. The true magnitude of Virginias participation in the Trans-Atlantic slave trade is much
higher.

55) All of the ports and cities of Virginia, especially Chesapeake, Hampton, Lower James River,
Rappahannock, South Potomac, Upper James and the York River, were and are major
participants in the Maafa, especially in the Trans-Atlantic slave trade, which is also known as the
Atlantic Trade, the Triangle Trade, the Middle Passage, the Colonial Trade, the West Indies
trade, especially in the transportation of tobacco.

Port of New York Authority

56) Upon information and belief, 98 slave voyages began in Defendant the Port of New York,
21,902 Africans were kidnapped in Africa, 3,095 were murdered during the Middle Passage, and
18,807 Africans were landed alive, sold, and forced to languish and toil on the slave plantations
of the Americas, for the rest of their lives.

57) The Port and City of New York were wrongfully and unjustly enriched by the Maafa,
especially the Triangle Trade, the West Indies Trade, the colonial Trade, the Coastal Trade, etc.

58) In 1871, 27 merchant and shipping firms controlled the Port of New York in 1871. The
Livingston, Vanderbilt, Ogden, Howland & Aspinwall, Costers, Griswolds, Schermerhorn,
Rockefeller, and other New York families were, and continue to be wrongfully and unjustly
enriched by and through their participation in the Maafa. Howland & Aspin had amassed $21.3
million by 1875, Joseph Peabody had accumulated $1.2 million by 1850, and N.L & G. Griswold
& Company had accumulated $2.7 million by 1850.

59) When he died, Commodore Vanderbilt was worth more than $100 million, which he had
accumulated through his participation in, and control over the shipping and railroad industry, and
on the blood and sweat of Africanslaves.

Port of New Orleans

60) Upon information and belief, Defendant the Port of New Orleans was the second leading
port in the United States, behind only the Port of New York, and the fourth leading port in the
world. It "was the transfer point for American and foreign goods. Wheat, lard, pork, furs and
hides, whiskey, hemp, and lead from the upper Midwest [via Chicago and St. Louis] and cotton,
sugar, molasses, and tobacco from the South flowed down the Mississippi River and its
tributaries on steamboats, flatboats, and keelboats to New Orleans, ... and then was shipped to
the Northeast, Europe, and the Caribbean. In reverse, manufactured and luxury goods, salt,
coffee, West Indian and Brazilian sugar, gold and silver, and a wide variety of items entered the
Crescent City from foreign and United States ports. ... By the 1850s around 3,000 steamboats
docked at New Orleans each year."

61) By 1861, "there were more than 450 commission merchants and cotton factor firms in New
Orleans, [including Lehman Brothers], handling transactions for over 9,300 planters in
Louisiana, Arkansas, Mississippi, and Texas alone. ... Sixty-five New Orleans law firms, tried to
keep their clients business affairs operating within the limits of the law, and its six insurance
companies assumed some of the risks-and profits-associated with shipping large quantities of
slaves, agricultural products, and manufactured goods.... New Orleans was the financial center of
the Mississippi Valley. From 1835 to 1842 its banking capital exceeded that of New York ...
[and its] twenty-six banking companies in 1855 loaned money for the construction of railroads,
expansion of plantations, purchase of goods, and many other enterprises." These
railroads included several predecessor lines of Defendant Illinois Central Railroad.

62) In 1810, just seven years after the illegal and fraudulent Louisiana Purchase of 1803,
two-thirds of New Orieans population was African, overwhelmingly enslaved. By 1860,
two-thirds of all U.S. cotton, one-quarter of all cotton in international commerce, was shipped
from the Port of New Orleans to the textile miles of New England and Europe.

63) The Port and City of New Orleans, and the larger Mississippi River economy which it
served, was built and maintained on slave, slave-like, and other forms of involuntary, forced and
coerced labor, illegally, wrongfully, and unjustly extorted from African people. It was and is a
major participant in the Maafa, especially in the Trans-Atlantic slave trade, which is also known
as the Atlantic Trade, the Triangle Trade, the Middle Passage, the Colonial Trade, the West
Indies trade, etc.

General Statement About Shipping Industry Defendants

64) Upon information and belief, at least 600 locations or ports, worldwide were involved in, and
unjustly and wrongfully enriched by the Trans-Atlantic slave trade and the Triangle Trade: 92
departure and return ports in 20 countries in Europe, 400 points of embarkation in 9 regions in
Africa, 482 places of disembarkation in 15 regions in the Americas, and 98 additional ports of
call.

65) Shipping Industry Defendants and ports, named herein, and not named, are responsible,
individually, severally, and/or jointly for their, and their countries share, of the death and
destruction in Africa, of the 100 million Africans who were murdered and enslaved during the
Trans-Atlantic slave trade, of the I million who were murdered during the Middle Passage, and
the 15 million who were landed alive as slaves in the Americas; and they are therefore
co-responsible for their, and their countries, share of the injuries and damages, the pain and
suffering, that these Africans, and their Descendants, endured and continue to endure today.

66) Upon further information and belief, 13 of the 55 Founding fathers of the United States were
merchants or shippers: Blount, Bloom, Clyner, Dayton, Fitzsimmons, Gery, Gilman, Gorham,
Langdom, Robert Morris, Pierce, Sherman, Wilson; and more than 10,000 slaves, and hundreds
of thousands of involuntary and forced laborers, worked in the shipping industry.

67) Shipping Industry Defendants were, and continue to be, wrongfully and unjustly enriched by
and through the Maafa, especially the slave trade; and by and through the shipping of sugar,
tobacco, cotton, and countless other products that were produced by slave and slave-like labor,
from the 1600s and continuing today.

68) Defendant Shipping Industry and Ports, named and unnamed, are therefore charged by and
through this complaint, with conspiracy; violation of the Foreign Sovereign Immunities Act;
gross violations of human rights; crimes against humanity; conversion; unjust enrichment;
failure and refusal to account for, and disgorge its illicit and unjust gains; and violation of the
Chicago Slavery Era Disclosure Act.

THE GUN INDUSTRY DEFENDANTS

Colt's Manufacturing Company Inc.

69) Upon information and belief, Samuel Colt, the founder of Defendant Colt's Manufacturing
Company, "was born into a Hartford family of merchant bankers. His maternal grandfather, John
Caldwell, was a founder of the city's first bank and his father, Christopher Colt, had made and
lost a fortune in the West India Trade." Colt invested his inheritance from the Maafa, in the
manufacture of firearms which were used to maintain slavery, and the slave economy in the
South. Colt Manufacturing made millions of dollars selling guns to both sides in the Civil War,
and in the United States war with Mexico.

70) At the time of his death, Colt employed 1500 people in his armory and a nearby furniture
factory. Samuel colt's heirs, Elizabeth and Christopher had accumulated $25 million each by
1900.

U.S.?????? Repeating Arms Company

71) Upon information and belief, Oliver Fisher Winchester, founder of Defendant U.S.
Repeating Arms Company, made his initial fortune as a merchant and shirt manufacturer, from
slave-grown cotton. George Winchester establishes first shirt-making factory In the U.S.,
employing 800 workers.

72) Founded in 1855 as the Volcanic Repeating, U.S. Repeating Arms Company, which is a
subsidiary of the Olin Company, made a fortune selling Winchester rifles to the slave masters
and slave catchers of the South, and to the U.S. army and settlers who committed genocide
against the Indigenous peoples in the U.S. West.

73) U.S. Repeating Arms is a successor-in-interest to the Whitney Arms Company, which was
founded by Eli Whitney, the inventor of the cotton gin. Even though he lost the opportunity to
become rich through the control of the patent and production of cotton gins, Eli Whitney made a
fortune by producing and selling guns to slaveholders and slave catchers.

74) Eli Whitney had accumulated $10 million by 1900, Dorothy (Whitney) Straight Elmhurst
had accumulated $15 million by 1925, and Oliver Winchester had accumulated $30 million by
1900.

THE SUGAR INDUSTRY

75) The first sugar refinery was opened in 1730 in New York by Nicholas Bayard. Sugar refining
was New York's most profitable manufacturing industry, processing 58% of the United States'
imported raw sugar in 1872 and 68% by 1887. The American Sugar Refining Company, which
was known as the Sugar Trust, was incorporated in 1891 in New Jersey by Henry O. Havemeyer.
By 1907, it controlled, directly and indirectly, 98% of the U.S. production of sugar. The U.S.
sugar industry was controlled by such prominent families as the Livingstons; the Bayards; the
Cuylers; the Roosevelts, the Stewarts, the Van Cortlandts; the McKnights; the Spreckles; who
were worth more than $42 million in 1925, and the Havemeyers, who were worth more than
$125 million. A large part of the Havemeyer Estate was bequeathed in 1929, to The Metropolitan
Museum of Art in New York.

M.A. Patout & Son Limited

76) Defendant M.A. Patout & Son Limited is a Louisiana corporation whose principal office is
located at 3512 Patout Burs Road, Jeanerette, LA 70544. It is the oldest and largest continuously
operating, family-owned sugar plantation and producer of molasses in the United States. Pierre
Simeon Patout came to Louisiana from France in 1829, acquired slaves and began planting sugar
cane. The plantation is still owned and run by the fifth generation of his descendants. It was
convicted in 1996, for "holding undocumented worker eligible for workers compensation
benefit." (See: Artiga v. M.A. Patout & Son, 671 So. 2d 1138 (La. Ct. App. 1996)).

Parlange Plantation

77) Defendant the Parlange Plantation is a Louisiana corporation whose principal office is
located at False River Road, New Roads, LA.

78) Built in 1750 by Marquis Vincent De Temant, Parlange is the oldest plantation in Louisiana.
The Parlange Family owned 127 slaves in 1860. The plantation originally grew indigo and
cotton, with slave labor, now sugarcane, soybeans, corn and Brahmin cattle. The descendants of
first owner still live there. Flo-Sun Inc.

79) Defendant Flo-Sun Inc. is a Florida corporation whose principal office is located at I North
Clematis Street Suite 200, West Palm Beach, FL 33401. Domino Sugar Corp, 2905 S Western
Ave, Chicago, IL 60608.

80) Flo-Sun is owned by Alfonso, Jose, Andres And Alexander Fanjul, who are known as the
Sultans of Sugar, and who control 40% sugar production in Florida, (180,000 acres of land), and
in many parts of the Caribbean, including the Dominican Republic, which ships about 100,000
tons of raw, duty-free sugar each year to the U.S. The Fanjuls also own Domino Sugar, Florida
Crystals Corporation, And Refined Sugars.

81) Their father and grandfather, Alfonso Fanjul Sr. and Jose Gomez-Mena, presided over one of
the largest sugar and slave plantations Cuba. They continued to exploit and oppress Africans in
the sugar fields until the victory of the Cuban revolution.

82) In 1989, 20,000 sugarcane harvesters, most of them Jamaican, who used to work for Florida's
largest sugar companies, including Florida Crystals, sued "Big Sugar" for years of massive wage
cheating and for what has been called 50-years of "modern-day slavery." In May 1992, a Florida
court awarded the migrant workers $51 million dollars in a summary judgement. One year later,
Flo-Sun mechanized its fields and replaced most, if not all, of its migrant workers. The Fanjul
companies are also accused of exploiting Haitian workers in the Dominican Republic. [See" The
Kingdom of Big Sugar by Marie Brenner and Bygrave v. Okeelanta.]

Tate & Lyle PLC

83) Defendant Tate & Lyle PLC, whose predecessors include Henry Tate & Sons and Abram
Lyle & Sons, is the successor-in-interest to more than 120 British sugar refineries that were
producing 30,000 tons of sugar, of "white gold," in 1750.

84) From 1641, when Britain invaded and colonized Barbados, and 1673, when the first sugar
refinery was built in Britain by Allyn Smith, to the present, the United Kingdom Of Great Britain
And Northern Ireland dominated and controlled the world's sugar industry. Sugar, more than any
other commodity, was the main reason for the slave trade, slavery and colonialism, accounting
for more than 70% of the slaves.

85) The British sugar tax in 1781 totaled 326,000 pounds and rose to 3,000,000 pounds in 1815.
By 1864, there were 64 refineries in Britain, and the sugar industry was dominated by many
families, including, the Macfies, Martineaus, Fairies, Walkers and Kerrs.Tate & Lyle currently
produces over one million tons of cane sugar yearly. Henry Tate found the University Library at
Liverpool and the Tate Gallery.

Bacardi Limited

86) Bacardi U.S.A. is the US import, sales, and marketing arm of Defendant Bacardi Limited,
one of the world's leading wine and spirits producers. Bacardi U.S.A. markets Bacardi rums (the
#1 rum in the world) and Martini & Rossi and Martini wines and spirits, including vermouth. It
also sells other liquid assets such as Dewar's Scotch whisky, Bombay gins, and DiSaronno
Amaretto. Its Hatuey beer is popular among Cuban-Americans. Originally founded in New York
in 1916, the company liquidated its assets during Prohibition by distributing cases of rum to
shareholders. It changed its name from Bacardi-Martini U.S.A. to Bacardi U.S.A. in 1999.

87) Founded in Cuba in 1862 by Facundo Bacardi Y Maso, Bacardi is the largest rum distiller in
the world. Cuba was and is the sugar and rum producing capital of the world. Slavery was not
abolished in Cuba until the 1870s; and segregation ended in 1960, when Fidel Castro came to
power.

88) The $2.8 billion Bacardi empire is currently owned and controlled by 500 of Facundo's
descendants, the sixth generation. The Bacardi Family is one of the biggest financiers of
right-wing movements and causes in the world today; and is directly responsible for numerous
human rights violations, and for crimes against humanity in every comer of the world.

THE TOBACCO INDUSTRY DEFENDANTS

89) The tobacco industry in the United States, Britain, and the world today, is a highly
concentrated and tightly controlled monopoly that is dominated by 12 major U.S. and
British owned and controlled tobacco companies, including American Tobacco, Brown &
Williamson, Conwood, Liggett & Meyers, Lorillard, Philip Morris, RJ Reynolds and UST

90) In the South's "production of money crops for export," tobacco was the first of the South's
"principal staples of export. From 1619 to the 1820s, the overwhelming majority of
slaves worked on the tobacco plantations. "A planter would consider it a good year if each field
slave produced a profit of $250," twice the annual pay of $125 for white workers."

91) "It has been long held that both the social and economic structure of the South was fixed by
tobacco long before cotton became king, and that the large fortunes of the landed aristocracy of
the South, the first in [the United States], were acquired by exploitation of tobacco land and
slave labor." The following timeline proves this assertion.

92) In 1492, Columbus "discovered" tobacco, which had long been used as a medicinal and
spiritual plant by the Indians. Tobacco was introduced to Spain in 1559. The commercial
cultivation of tobacco began in Santo Domingo in 1531 and in Cuba in 1580. In 1606, King
Phillip III of Spain decreed that tobacco could only be grown in Cuba, Santo Domingo,
Venezuela and Puerto Rico. Sale of tobacco to foreigners was punishable by death. By 1614,
King Philip III had established Seville as the tobacco center of the world. In 1636, Tabacalera,
the oldest tobacco company in the world was established.

93) In 1562, tobacco was introduced into France. In 1566, Catherine de Medici of France began
to use snuff. In 1629,.Richelieu taxes tobacco. In 1637, King Louis XIII repealed his earlier
restrictions on the use of tobacco products, especially snuff. In 1674, King Louis XIV
established a tobacco monopoly. In 1843, Seita, the French tobacco.monopoly, began the
manufacture of cigarettes.

94) In 1562, tobacco was introduced to Queen Elizabeth I by John Hawkins. In 1615, "King
James I made the import.of tobacco a royal monopoly, in open breach of the law as decisively
stated in 1602, and farmed it out for a yearly.rent of 14,000 sterling pounds."

95) In 1616, Virginia sent 3,000 pounds of tobacco to London, 19,000 pounds in 1918 and
25,000 pounds by 1620.

96) In 1623, King Charles I licensed the 7,000 tobacco retailers in London. By 1992,
there were 615,000 retailers who sold tobacco products in the United States, including 3,664
retail tobacco outlets, 82,300 convenience stores.with $10.9 billion in sales; and 400,000
vending machines with $2 billion in sales in 1994.

97) The expansion of African slavery allowed Virginia to expand its production six fold between
1663 and 1699.

98) In 1776, the American Revolution was also know as the "Tobacco War." 1780-81
Lord Comwallis tried to destroy that economy be freeing all slaves.

99) In 1794, the United States Congress passed the first tax on tobacco, 8 cents on snuff, which
was 60 percent of its.selling price.

100) In 1781, Thomas Jefferson suggests tobacco cultivation in the "western country on the
Mississippi" River.

101) In 1788, the Spanish found New Orleans as a port for the exportation of tobacco grown in
the Mississippi Valley.

102) Slave prices were 600 each in 1810, $1,000 each in 1840, $1,200 in 1850 and $1,800 on the
eve of the Civil War. The price of a slave represented ten times the yearly earnings of "free"
wage earners.

103) 1860 census showed 588,000 "mulatto women," the overwhelming majority of whom were
the product of rape. They were sold for $2,500, twenty times the normal pay for a white worker.


104) Glascow was known as "The Second City of the British Empire," mostly because of
tobacco. The "Tobacco Lords," including William Cunninghame

105) In 1860, the census for Virginia and North Carolina listed 348 tobacco factories, virtually
all producing chewing tobacco. By 1994, there were 114 factories in 21 states, with 42,900
persons employed in tobacco manufacturing, 88 percent of whom are employed in cigarette
manufacturing.

106) On May 29, 1911, the United States Supreme Court declared Duke's "Tobacco Trust" a
monopoly in violation of the 1890 Sherman Antitrust Act; dissolved the American Tobacco
Company which was valued at $502 million and controlled 92 percent of the world tobacco
market; and created four "new" companies: the "new" American Tobacco Company, which
retained 37 percent of the U.S. tobacco market; RJ Reynolds, which received no cigarette market
or brands, but was awarded 20 percent of the U.S. plug trade; Ligget & Meyers, which received
37% of the U.S. cigarette market; Lorrilard, which received 15 percent of the U.S. tobacco
market; and BAT (British American Tobacco), which ......

107) In 1994, there were 124,000 tobacco growers and 500,000 tobacco quota holders in 23
states and in Puerto Rico; who harvested 674,300 acres and 1.32 billion pounds of tobacco. In
1994, there were also 272 warehouses in 33 states.

108) Tobacco was the seventh largest crop in 1995, worth almost $2.3 billion dollars,
approximately 2.7 percent of the total for all cash crops and farm commodities. In 1998 U.S.
consumers spent $59.3 billion on tobacco products, $55.7 billion on cigarettes, $1 billion on
cigars, $2.5 billion on smoking tobacco, chewing tobacco and snuff. Annual tobacco
sales are currently in excess of $330 billion worldwide.

109) Tobacco kills more than two and a half million people every year. Smoking causes about
30% of all cancers.

Shirley Plantation

110) Defendant the Shirley Plantation is Virginia's oldest, still operating, family owned
plantation. Settled in 1613 on the James River between Richmond and Williamsburg by Sir
Thomas West, it operated as a tobacco and grain farm 1613-1952. It was acquired in 1638 by
Edward Hill and managed by ten generations of his descendants ever since.

111) Upon information and belief, "Robert ‘King' Carter had a passion for accumulating land,
wealth, and power. At his death, he owned around 300,000 acres, 45 plantations, and was one of
the wealthiest men in Virginia. His power was derived from his wealth, political and civil
positions. He was the treasurer of the colony, Naval Officer of the Rappahannock, a Member of
the House of Burgesses as well as the Speaker of the House, President of Governor's Council,
and interim Governor of Virginia. In 1702 he was appointed as the salaried agent and Virginia
representative for Lord Fairfax, whose holdings encompassed five-and-one-half million acres. ...
When Robert died he left 10,000 pounds sterling, 734 slaves, 2,266 head of cattle, sheep, hogs,
and horses. ... Robert ‘King' Carter's include three signers of the Declaration of Independence:
Carter Braxton, Thomas Nelson Jr., and Benjamin Harrison; two U.S. Presidents: William Henry
Harrison and Benjamin Harrison; General Robert E. Lee; a Supreme Court Justice, and eight
Governors of Virginia."

The Society of Jesus

112) Defendant the Society of Jesus of Maryland was the "largest slaveholder on the Eastern
seaboard and had four [tobacco] plantations in Maryland." According to John Carroll,
the first bishop of the new United States, "the Catholic population in Maryland in the [19th
century], was about 15,800, about 3,000 children, and the same number are slaves of all ages,
who come from Africa."

113) "The two purposes of the Jesuit plantations in Maryland were to support the Jesuit mission,
[of building the Catholic Church in Baltimore, Maryland and the United States], as well as
support Georgetown College," now known as Georgetown University.
"Slaves were sold to maintain the solvency of the University. In the late 1830s, the Jesuits sold
all of their slaves, [272 slaves to Louisiana slaveholders] and in the process, many
families were broken up. The money from the sale was used to pay the uniiversity's debt and to
create an endowment. ... Students were allowed to bring slaves with them to the university to aid
in housekeeping. Additionally, the university probably held slaves for campus beautification
projects." Rev. Thomas F. Mulledy, S.J., a slaveholder and alumnus of Georgetown
University, "believed that slavery was the best thing for African-Americans. Mulledy Hall of the
Jesuit Residence bears his name."

John Whitley Farm

114) Founded, in 1742,.Defendant John Whitley Farm is the oldest farm in North Carolina, now
in its eighth generation. Upon information and belief, slave labor was used to grow tobacco on
the farm. Family mementos include original deed with wax seal of King of England and a note
from Theodore Roosevelt thanking the Whitleys for lending him their binoculars. Their land is
still leased to grow tobacco.

Universal Corporation

115) Defendant Universal is the world's largest buyer and processor of leaf tobacco in the U.S.
and 40 nations, including Brazil, Italy, Korea, Malawi and Zimbabwe. The leaf is then sold to
cigarette manufacturers.

116) J.P. Taylor Company, one of Universal's predecessor companies, was known in 1886, "as a
great leaf shipping and exporting establishment, one of the largest in the South," It
was a successor-in-interest to the tobacco factors who financed and controlled Virginia's
slave-driven, convict-lease driven, and peonage-based tobacco economy.

117) Upon information and belief, in 1911, the U.S. Supreme Court ordered the break up James
Duke's American Tobacco Company under the provisions of the Sherman Antitrust Act of 1890.
In 1918, Virginia tobacco baron Jacquelin P. Taylor, and six other leaf merchants, including
William A. Willingham and Thomas B. Yule, formed Universal Leaf Tobacco Company
Incorporated.

118) Upon further information and belief, Universal was one of eight tobacco companies
charged once again in 1940, with Sherman Antitrust Act violations, including price manipulation
in the purchase and sale of leaf tobacco at auction. The eight companies were found guilty as
charged, paid a $250,000 fine, and returned to business as usual. In 2003, a class of 500,000
tobacco growers charged Universal and other tobacco companies with price fixing again.
Universal, and all of the companies, except Defendant RJ Reynolds, agreed to pay $7 billion to
settle the class action suit out of court.

Dimon Inc.

119) Defendant Dimon Inc. is the second largest leaf dealer in the world, controlling about
one-third of the world market for leaf tobacco, including in Brazil, the Dominican Republic and
Zimbabwe. Altria Group and Japan Tobacco are Dimon's two largest customers, accounting for
about 35% of its revenues of. Other customers include Lorrilard Tobacco Company and RJ
Reynolds.

120) Upon information and belief, Dimon was "formed through the 1995 merger of Dibrell
Brothers, which was founded in 1904, and Monk-Austin Inc., which was founded as AC Monk
& Company in 1920. Richard H. Dibrell was a tobacco merchant in Richmond, Virginia in the
late 1850's. His two sons went became leaf-tobacco brokers in Danville in 1873. Prior to 1876,
Albert C and J.Y Monk's farther was a tobacco grower outside Durham, North Carolina. In 1876,
Albert became a speculator, commission buyer and shipper. He and his brother incorporated AC
Monk in 1920."

121) Upon further information and belief, "Dibrell's major customers were the five
manufacturers who dominated the 1870s and 1880s: Washington Duke Sons & Company, Allen
& Ginter, Kinney Tobacco Company, William S. Kimball & Company, and Goodwin &
Company. Known as the Tobacco Trust, these five companies formed the American Tobacco
Company which dominated the tobacco industry until the U.S. Supreme Court issued the
dissolution decree in 1911."

Standard Commercial Corporation

122) Upon information and belief, Ery Kehaya, the founder of Defendant Standard Commercial
Corporation, sold oriental tobacco to Defendant RJ Reynolds, from 1900 to 1917, in exchange
for stock. He married Grace Whitaker, the daughter of a prominent North Carolina tobacco
merchant. Family, held stock in the Axton-Fisher Tobacco Company of Louisville, Kentucky
until it was sold by Defendant the Bank of America, and purchased the Jas. I. Miller Tobacco
Company of North Carolina in 1978.

123) Upon further information and belief, Standard Commercial is the successor-in-interest to
the tobacco factors and merchants who financed and controlled the slave-driven, convict-lease
driven and peonage-based tobacco economy of North Carolina. Standard and its predecessor
firms were part of Duke's Tobacco Trust.

Lorillard Tobacco Company Inc.

124) Defendant Lorillard Tobacco Company Inc. is the #4 cigarette maker in the United States,
with a 9.3% share of the U.S. market. Founded in 1760 in New York by French immigrant Pierre
Lorillard, Defendant Lorillard is the oldest tobacco manufacturer in the United States.

125) More than any other tobacco company, Defendant Lorillard Tobacco Company and The
Lorrilard Family, have profited from, and continues to profit from the Maafa, slavery; slave-like
conditions and practices; colonialism, segregation and apartheid; and racism and racial
discrimination, for over 240 years.

126) Newport cigarettes, Defendant Lorillard's largest selling brand, accounted for
approximately 85% of its sales in 2001. Upon information and belief,

127) "The success of Newport's ... brand growth was driven by "black people (all ages) and
‘young adults (usually college age)' ... Newport succeeded because Lorillard relentlessly focused
its ads at blacks living in the Northeast, according to industry analysts. A 1969 memo by rival RJ
REYNODS noted that Lorillard's ‘Negro market budget was increased 87 percent over 1968.'
The majority increase went to build Newport among black Americans. ... ‘By 1978,' according
to the RJR report, ‘Newport's regional spending against Blacks equaled Kool's national Black
market spending. Newport had picked, Kool's prime market, with a size it could afford, and
essentially bought it. The results among younger adult smokers, especially younger adult Blacks,
were immediate."

Philip Morris Companies Inc.

128) Defendant Philip Morris Companies Inc. is the largest cigarette manufacture in the world,
with 45 percent of the United States market, and 12 percent of the world market.

129) Philip Morris was founded in 1847 as a London tobacconist and importer, "Morris sold fine
Havana ‘seegars' and Virginia pipe tobacco to the carriage trade." Upon information
and belief, this Virginia tobacco was grown by slaves, and Philip Morris is the
successor-in-interest to the slave-driven, convict-lease driven, and peonage-based British
tobacco industry.

Ligget & Meyers Tobacco Company

130) Defendant Ligget & Meyers Tobacco Company is the fifth largest cigarette manufacturer in
the United States, with 1.6 percent of the market in 1997.

131) Ligget & Meyers was founded as a snuff manufacturer in Belleville, Illinois in 1822. In
1873, John Edmund Ligget, grandson of the firm's founder, joined with George S. Meyers to
form Ligget & Meyers, which began producing cigarettes.

132) Ligget & Meyers is a successor-in-interest to James Duke's Continental Tobacco Company,
and the larger Duke Tobacco Trust.

133) Upon information and belief, the tobacco used to manufacture Ligget's snuff was grown by
slave, convict and peonage labor.

RJ Reynolds Tobacco Holdings Inc.

134) Defendant RJ REYNOLDS is the second largest cigarette manufacturer in the world, with
four of the ten U.S. leading brands.

135) Upon information and belief, "Hardin Reynolds, father of RJ 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. ...
[H]alf of two year's profit from the Rock Spring factory [was used] to found ... R. J. Reynolds
Tobacco Company."

136) On September 4, 2002, Maura Payne, a spokeswoman for RJ Reynolds, said the allegations
of their use of, and wrongful and unjust enrichment by and through slavery, are "completely
without merit" because the company was founded in 1876, a decade after slavery was
abolished." Payne further said that "all of our employees since the company has existed have
been paid for their work time."

137) Upon further information and belief, RJ Reynolds is a successor to Dukes Tobacco Trust
and the American Tobacco Company.

Brown & Williamson Tobacco Corporation

138) Defendant Brown & Williamson Tobacco Corporation is the #3 US cigarette maker, with
about 11% of the U.S. cigarette market. It was founded in 1894 by George Brown with $10,000
given to him by his father, Rufus D. Brown, a well-known and respected tobacco merchant
George and his brother William opened the Brown Brothers Tobacco Manufacturing Company
in Winston Salem, North Carolina. Robert Williamson, George's brother-in-law, was the son of
T.F. Williamson, who owned factories in Castle County and Winston Salem, North Carolina. It
is also the successor to the successor to PJ. Sorg Company.

139) Brown & Williamson is also the agent of, successor to, and/or subsidiary of BAT PLC, also
known as British American Tobacco PLC, B.A.T. Industries, British American Investments
LTD, British American Tobacco Company LTD, which was the overseas arm of the U.S.
Tobacco Trust.

140) Upon information and belief, Brown & Williamson, and its predecessor companies
purchased their tobacco from planters/farmers who used, and be wrongfully and unjustly
enriched by and through slave, slave-like, peonage, and other forms of involuntary, compulsory
and forced labor.

141) Moreover, Kool cigarettes, one of Brown & Williamson's brands, dominated and became
the "king" of menthol market through its penetration of the African community, 70 percent of
which smoked menthol cigarettes. U.S. Smokeless Tobacco Company

142) Defendant U.S. Smokeless Tobacco Company manufactures, advertises and sells
approximately UST is also the worlds' leading producer and marketer of smokeless tobacco
products. Its brands include Bruton, Copenhagen, Happy Days, Red Seal, Skoal and WB Cut, in
1995, U.S. Smokeless Tobacco's sales in the United States were $4.2 billion, generating profits
of $721 million,

143) Upon information and belief, U.S. Smokeless Tobacco is the successor in interest to the
plug tobacco monopoly of the Duke Tobacco Trust and the American Tobacco Company.

144) Copenhagen and Skoal, each account for more than $1 billion at retail. Copenhagen, U.S.
Smokeless Tobacco Company "flagship brand, was introduced in 1822 and owns one of
America's oldest trademarks." Upon further information and belief, the tobacco used
in the manufacture of Copenhagen was grown by slave, slave-like, peonage and other forms of
involuntary, compulsory and forced labor.

Conwood Company LP

145) Upon information and belief, Defendant Conwood Company LP is the successor in interest
to Levi Garret & Sons, William E. Garrett Company, the W.E. Garrett & Sons Scotch Snuff
Company, the American Snuff Company, the plug tobacco monopoly of the Duke Tobacco Trust
and the American Tobacco Company.

146) Plaintiff understands that "Garrett snuff trace bapkc to the efforts of John Garrett who built
several mills (grist, lumber, and snuff) on the banks of Red Clay Creek near Yorklyn, Delaware
in 1726. His son, Levi Garrett, inherited the snuff mill (the only one that made money). Levi is
referred to as a tobacconist with offices in Philadelphia (if you look on the Levi Garrett chewing
tobacco pouch you will see his store). Levi had two sons, Willams Evans Garrett and George
Howell Garrett. The snuff business was renamed Levi Garrett and Sons, from where the name of
the rappee snuff derives. W.E. stuck with the snuff, but George split. W.E. changed the name of
the company to William E. Garrett Company, from whence the name of the Scotch and Sweet
Snuff brand name derives. In 1857, with the maturation of his sons, the name is changed to
William E. Garrett and Sons. The W.E. Garrett and Sons Scotch Snuff is trademarked in 1870,
being one of the first ten trademarks in US history, number 7, and the oldest trademark still in
use in the US. After the death of William E. Garrett and William Garrett Jr., the remaining
brother Walter sold the snuff mill to three of his employees for one dollar. That was the end of
the Garrett name in ownership."

147) Plaintiff also understands that "James ‘Buck' Duke bought up every tobacco producer in
the US in the late 1800's, including the Garrett snuff brands, as the American Tobacco Company.
His monopoly was busted up by Teddy Roosevelt in 1907, and the snuff side became American
Snuff Company. The other companies were George W. Helme, who I've never heard of, and the
United States Tobacco Company, which nowadays produces Skoal, Copenhagen, and related
products. The American Snuff Company moved to Memphis in 1912. After buying up some
small producers in North Carolina, the company changed names to Conwood Company, LP, to
reflect the new diversity in 1966. In 1975 Levi Garrett chewing tobacco was introduced as a
tribute to the founder of American tobacco production."

148) Conwood has been and continues to be wrongfully and unjustly enriched by and through
the Maafa, especially by and through slave and slave-like labor which produced its predecessor
company's snuff.

THE COTTON, TEXTILE AND APPAREL INDUSTRY DEFENDANTS

149) From 1790 to 1860, 835,000 enslaved workers were driven into new cotton areas of the
South, from Alabama to Texas. More than 600,000 slave families were destroyed during this
movement during 1820-1860.

150) There were 2.5 million slaves in the United States in 1850, and 4 million in 1860, an
increase of 1.5 million through natural population growth, and forced breeding T

151) In 1860, there were 630,429 farms in the South; 359,100 slave-holding families out of a
total 1,388,182 families, and 4 million slaves. Slaves were selling for $1,000 each on the New
Orleans slave market. The total estimated market value for these slaves was $4 billion

152) Upon information and belief, at least 90% of all slaves in the United States toiled in cotton
production; 86% of cotton grown on farms with 100 acres or more.

153) 1,815,000 Africans were enslaved on cotton plantations, 350,000 tobacco, 150,000 sugar,
125,000 rice, and 60,000 hemp in 1860. Between 1802 and 1860, the value of crops produced by
slaves rose from $14.68 to $101.69. The total value of plantations, land, implements and
machinery, livestock, orchard products, market garden products, home-made manufactures, and
animals slaughtered was estimated at $3.1 billion

154) About 45,000 slave-holders owned 20 or more slaves and were regarded as "very rich,"
among the top 5% of white families in the South.

155) In 1860, the South produced 2/3 of world's cotton; the Midwest supplied $30 million worth
of food products to feed the cotton producing South; the Northeast textile industry produced
$100 million worth of cloth from slave-produced cotton; the North sold $150 million of
manufactured products to the South; and Northern ships transported cotton, tobacco, sugar and
other slave-produced products to every comer of the world.

156) In 1845, 80 men who were known as the Boston Associates, owned 31 New England textile
mills that accounted for 20% of United States Textile industry, and 1/3 of all slave-produced
cotton. At least 17 of them served as directors of banks which owned 40% of Boston's banking
capital, 20 of them were directors of 6 insurance companies that controlled 38% of
Massachusetts's insurance industry, and 11 of them sat on the board of 5 railroad companies.


157) Cotton was King, sitting on a throne that was made with the blood, sweat and tears of 4
million slaves, and cotton created thousands of millionaires, including James Stillman who had
accumulated $70 million in 1918, the Richardson family of Louisiana who had accumulated $15
million in 1875, Marshall and Stanley Field who had accumulated $322 million by 1925, Eugene
Higgins who had accumulated $30 million b7 1925, Baibara Hutton, $16 million by 1925, Potter
Palmer who had accumulated $24 million by 1900, Levi Zeigler Leiter who had accumulated
$50 million by 1900, the Lowells of Massachusetts who accumulated $2 million by 1875, the
singer Family who had accumulated $45 by 1925, the Slater family who had accumulated $20
million by 1900, the A.T. Stewart Family who had accumulated $50 million by 1875, the
Woolworth family who had accumulated $102 million by 1925, the Abraham Family who had
accumulated $4.5 million by 1900, the Harriman Family who had accumulated $5 million by
1900, the Rosenwald Family who had accumulated $80 million by 1925, the Livingston Family
who had accumulated $30 million by 1889, the Clark Family who had accumulated $42.8 million
by 1900, and others.

158) Dr. W.E.B. DuBois wrote in 1904, that:

"The present industrial development of America is built on the blood and brawn of unpaid Negro
toil in the 17th, 18th, and nineteenth centuries."

159) England kidnapped, transported and sold the slaves; owned and controlled the slave-driven
plantation economy, sugar, tobacco and cotton, 80% of which was exported to England; and she
employed 1.5 million exploited and oppressed English workers, mostly women to in English
textile mills. Her newspapers openly bragged:

"That the prosperity of Manchester is dependent on the treatment of slaves in Texas, Alabama
and Louisiana is as curious as it is alarming."

160) Cotton is grown in 17 states today, 14 of them former slave holding and convict-lease
states. There are 7 sectors of the cotton industry: producers/growers, gins, warehouses,
merchants, crushers, manufacturers, distributors, wholesale and retail. There were 300,000
cotton farms in the United States, and only 30,000 in 2000. Many of these farms are owned by
the descendants of slave masters and slave-holding families.

Juanita M. Joiner Farm

161) Founded in 1783, Defendant Juanita M. Joiner Farm is a 1,200 acre farm that still grows
cotton after eight generations of joiners who included a cousin of one of King Henry VIII's
wives, a Colonial governor, a governor of North Carolina, and the founder of Swainsboro,
Georgia. Upon information and belief, the Joiner Farm is one of the oldest, still operating cotton
farms in Georgia. Upon further information and belief, it used, was, and continues to be
wrongfully and unjustly enriched by and through slave labor.

King Ranch Corporation

162) Defendant King Ranch was "founded in 1853, by Richard King, a riverboat captain who
made his fortune during the Civil War by ‘running cotton' to Mexico in violation of the U.S.
Naval blockade of the Port of New Orleans. ... During the Civil War, King (a staunch
Confederate) and his partners entered into several contracts with the Confederate Government to
supply European buyers with cotton. In return, the firm, Kenedy, Stillman & King, supplied the
Confederates with beef, horses, mules, imported munitions, medical supplies, clothing and shoes.
Placing their steamboat interests under Mexican registry and moving their operations into
Matamoros, Mexico, they, for the most part, successfully avoided the Union blockade and earned
considerable fortunes. ... Flush with Civil War profits, King and Kenedy revolutionized the
economics of South Texas ranching with the introduction of fencing, livestock drives to northern
markets, large-scale cattle, sheep, mule and horse raising and the scientific breeding and
upgrading of livestock. Between 1869 and 1884, Richard King sent more than 100,000 head of
cattle up the trails to northern markets, helping to stock the developing ranges of the American
West and to create the American ranching industry. ... King invested heavily in railroads
(especially the Corpus Christi, San Diego and Rio Grand narrow Gauge Railroad."

163) According to Murphy Givens, a radio columnist in Corpus Christi, Texas, "hustling cotton
made [James] Stillman, a yankee trader, the richest man in America. He used his profits to start a
bank in New York City the National City Bank, a predecessor to Defendant J.P Morgan Chase].
[Richard] King and [[Mifflin] Kenedy used theirs to enlarge their land holdings. When King died
he left a ranch of 614,000 acres, it was a ranch built on King Cotton - and the war profits of three
riverboat partners from the Mexican War," which in the final analysis was a war to
extend slavery into the Southwestern region of what is now the United States.

Staple Cotton Cooperative Association

164) Defendant Staple Cotton Cooperative Association is a cooperative in Greenwood,
Mississippi that serves more than 12,000 member-owners in 41 states, and is the second largest
privately held business in Mississippi, and markets about 57 percent of Mississippi's 1.5 million
bales of cotton, grown on 930,000 acres; 24 percent of the 8.5 million bales grown in the
Mid-South and southeast; 11% of all cotton grown in the United States. t sells about 3,000,000
bales of cotton annually to textile mills who make men's underwear, T-shirts, sheets, towels and
denim, including Fruit of The Loom and Levi-Strauss & Company.

165) Staple Cotton was founded in 1921 by Oscar Bledsoe, Will Gerrard, Senator Leroy Percy,
William L. Percy, Leroy Percy, W. A, Percy II, Dr. C. R. Sayre, H, L. Hodges, George C.
Cortright, Aven Whittington, and other Mississippi Delta growers.

166) Upon information and belief, the Percy Family arrived in Greenville, Mississippi in the
1830s, and was one of the largest land owning and slave-holding families in the Mississippi
Delta. Senator Leroy Percy was a lawyer for the Illinois Central Railroad.

167) Woods Eastland, the President of Staple Cotton, is the son of Senator James Eastland, and
the owner and manager of the 5,000-acre family farm in Doddsville, Mississippi. In 1964, Fannie
Lou Hammer, and other African sharecroppers, were beaten and evicted from Eastland's
plantation for daring to register and vote, Doddsville is a major stop for the Yazoo Delta
Railroad, which became a part of Illinois Cenral Railroad.

Delta & Pine Land Company

168) In 1927, Defendant Delta & Pine Land Company was the largest cotton plantation in the
world, with about 12,000 acres in cotton, 8,000 in forage crops, 9,000 in woodland and lakes,
1,000 tenant Families to work the land, and 1,000 mules. Delta Pine is the successor-in-interest
to the Fine Cotton Spinners and Doublers Association, a textile mill in Manchester, England and
the Mississippi Delta Planting Company, the Triumph Planting Company, and the Lake Vista
Planting Company. Oscar Johnston, Delta Pines' manager, served as a director of Illinois Central
Railroad.

169) Upon information and belief, Delta & Pine Land is a successor-in-interest to the British
textile interests who made their profits off of slave-trade, slavery, slave-like and other forms of
involuntary, compulsory and forced labor in the United States. The extent of their dependence of
slave-produced cotton is documented by the following statement:

"Let any great social or physical convulsion visit the United States, and England would feel the
shock from Land's End to John O'Groats. The lives of nearly two millions of our countrymen are
dependent upon the cotton crops of America their destiny may be said, without any kind of
hyperbole, to hang upon a thread. Should any dire calamity befall the land of cotton, a thousand
of our merchant ships would rot idly in dock, ten thousand mills must stop their busy looms, and
two thousand thousand mouths would starve, for lack of food to feed them."

Weil Brothers Cotton Inc.

170) Defendant Well Brothers Cotton Inc. and Weil Brothers & Ster Ltd. its Liverpool-based
partner, are international cotton merchants, successors-in-interest to the cotton merchants and
cotton factors who controlled the worldwide cotton and textile trade, and the slave, slave-like,
involuntary, compulsory and forced labor that produced it, from their base in Liverpool.

171) Since 1853, four generations of Stem Family members have been "involved" in the cotton
trade, and by extension, the slave trade, slavery, the Triangle Trade, etc. Three family members
have been past presidents of the Liverpool Cotton Exchange.

172) Upon information and belief, the Well Family, were heavily involved in cotton factoring
and merchandising before abolition of slavery. Robert Schoenhof Weil is married to Virginia
Loeb, a heir to A. Loeb and Company of Montgomery, a cotton factor and merchant firm.

Dunavant Enterprises Inc.

173) Defendant Dunavant Enterprises Inc. is a fifth generation, privately owned cotton merchant
firm, one of the largest in the world, handling in excess of 4 million bales of cotton yearly. It is
the largest privately owned fum in Memphis. Dunavant Enterprises is a member of the Chicago
Board of Trade, the New York Cotton Exchange, and the New York Stock Exchange.

174) According to the Dunavant Website, "Mr. Dunavant's maternal grandfather, the late
Woodson Thomas Knight, owned large acreage in and around Tunica, Mississippi. Mr.
Dunavant's paternal father, the late Colonel William P. Dunavant, and William Bedford Forrest
started one of the first railroads built in Mississippi, which later became the Frisco Railroad and
was used extensively in the early days for transporting cotton."

175) Upon information and belief, William Bedford Forrest is the son of Confederate General
Nathan Bedford Forrest, who founded the Klu Klux Klan; and the Frisco Railroad is one of the
predecessor lines of Defendant Union Pacific Railroad.

Cargill PLC

176) Founded in 1865, Defendant Cargill PLC is the world's largest privately held company. It
buys and sells grain, poultry, beef, steel, seeds, salt, cotton, and other commodities on six
continents. Fourth and fifth generation descendants of the Cargill and MacMillan Families still
own and run the $47.6 billion company

177) Upon information and belief, the United Kingdom division of Cargill Cotton was founded
in London in 1818 by John and Eustace Ralli to "trade in a variety of commodities from cotton
and silk to metals. ... During the early history of cotton trading the port of Liverpool soon
emerged as the principle trading centre and in 1865 Smith, Coney and Barrat was founded in the
city where it was perfectly placed to service the demand of the burgeoning Lancashire spinning
industry. Ralli Brothers and Smith, Coney and Barrat continued to trade successfully and by the
middle of the twentieth century they had grown to became two of the United Kingdom's leading
cotton merchants. In 1962 the two companies agreed a merger and Ralli Brothers and Coney was
formed."

178) Cargill Cotton UK is currently based in Liverpool, the traditional home of cotton trading,
and is a successor-in-interest to the slave-driven British cotton industry. It is one of the three top
cotton merchant firms in the world.

179) Upon further information and belief, the US division of Cargill Cotton, formerly Hohenberg
Bros. Company, which was incorporated in 1879, is one of the world's largest cotton merchants.
"Mr. Hohenberg came to Selma in 1910 and at his death [in 1928] was president of the Selma
Cotton Exchange. He also was chairman of the board of directors of the First National Bank of
Wetumpka."

180) Hohenberg Bros Company is a successor-in-interest to the cotton merchants and factors
who controlled and financed the slave-driven and convict-lease driven cotton economy in the
Selma area. Avondale Mills Incorporated

181) Avondale Incorporated, with its operating company, Defendant Avondale Mills Inc., with a
corporate history reaching back to 1845, is the oldest, and continuously operating textile
manufacturing concern in the United States.

182) Avondale was founded and lead by Braxton Bragg Comer, a former governor of Alabama
who owned one of the largest slave plantations in Alabama. He was president of the Alabama
Railroad Commission from 1904-07, a member of the Klu Klux Klan, and a beneficiary of
Alabama's convict-lease system after the civil war.

183) Several letters that are part of the Braxton Bragg Comer Papers at the University
of North Carolina at Chapel Hill reveal his and Avondale's role in the convict-lease system:

(a) 1922 - a letter to Governor Kelly expressing interest in buying a cotton mill from him and
mentioning the use of "convicts for mill labor until we could build the houses for free labor."

(b) 1923 - to J.S. Wanamaker, president of the American cotton Association, "about the
feasibility of revising the convict lease program to include turpentine companies, lumber yards,
and coal mines."

(C)3 March 1924 - "any negro who violates his contract with you, make him pay up before he
leaves of beat him to death. I mean that literally."

Burlington Industries

184) The origins of Burlington Industries can be traced to the Edwin M Holt Mill, which was
founded in 1737 in Alamance County, North Carolina. Upon information and belief, it is still
functioning today.

185) In 1879, Burlington Industries had 6 mills operating in Alamance County, with 15,624
spindles, 298 looms and 594 employees. By 1886, it had 13 mills, 31,236 spindles and 1,238
employees.

186) Upon further information and belief, these mills were feed with cotton produced by slave,
slave-like, convict-lease, peonage and other forms of involuntary, compulsory and forced labor,
and Burlington Industries was wrongfully and unjustly enriched by and through the use,
oppression, and exploitation of this labor.

THE AGRICULTURAL EQUIPMENT INDUSTRY DEFENDANTS

Continental Gin Company

187) Founded in 1832, Defendant Continental Eagle Corporation, formerly known as
Continental Gin Company of Prattville, Alabama, is the largest cotton gin manufacturer in the
world.

188) Slavery in the United States would have died of natural and gradual causes by the early
1800s, had it not been for the invention of the cotton gin.

189) Upon information and belief, "the cotton gin was a simple device, yet it's impact on the
American economy, [and on slavery] was tremendous. From less than 6000 bales, produced in
the year before Whitney's invention, cotton production soared to 167000 by 1806. Cotton
became the main agricultural produce of the South and was soon the major export commodity of
the Nation. By 1860, the value of cotton exports alone reached 192 million $ and represented
61% of total US exports. One can only imagine what Miller & Whitney's fortunes would have
looked like, if they had been able to secure just a 1% fee on all cotton cleaned thanks to their
invention."

190) Continental Eagle is the successor-in-interest to the Daniel Pratt Gin Company, Samuel
Griswold & Company, Daniel Pratt Gin Company, Continental Gin Company, Continental /
Moss-Gordin Company, Bush Hog / Continental Gin. In 1926 the Woodruff family, who own
Coca-Cola, purchased controlling stock in the Continental Gin Company.

191) Through all of the years since 1832, a descendant of Daniel Pratt has been active in the
Company until Mr. Merrill Pratt, great grandson, retired. Upon information and belief,
Continental Eagle was unjustly enriched by and through the manufacture and sale of thousands
of the cotton gins that were used on the plantations in Alabama, Mississippi and Louisiana,
before and after the Civil War.

THE MINING INDUSTRY DEFENDANT

ChevronTexaco Company

192) Upon information and belief, Jacob A. Bostwick, was the founding secretary of the
Standard Oil Company, predecessor to Defendant ChevronTexaco Company, and remained so
until his death in 1892.

193) He started business as a cotton broker in Cincinnati, and relocated in 1864 located to New
York where he owned American Cotton Docks at Staten Island and was a founding member of
the New York Cotton Exchange.

194) Bostwick invested the money that he made by trading in slave-grown cotton in oil wells in
Pennsylvania, and organized the firm of J. A. Bostwick and Company, oil refiners and shippers,
which was merged into John D. Rockefeller's Standard Oil Company in 1872.

195) Bostwick had wrongfully and unjustly accumulated $10 million by his death in 1892, and
gave $70,000 to Wake Forrest College in North Carolina in 1886, and $25,000 to Richmond
College in Virginia in 1887.

THE RAILROAD INDUSTRY DEFENDANTS

196) By January 1861, 8,783 miles of track had been built in 10 southern, slave-holding states,
out of a United States-wide total of 31,168 route miles, at a cost of $237,138,482 for the
construction of southern railroads, compared to a United States-wide cost of $1,77,993,818.


197) The State of Alabama had constructed 643 route miles at a cost of $26,845 per mile; the
State of Florida had 327 miles at $24,000 per mile; the State of Georgia had 1,400 miles at a cost
of $19,709 per mile; the State of Louisiana had 328 at $40,333 per mile; the State of Mississippi
had 797 route miles at a cost of $28,841 per mile; the State of North Carolina had 900 route
miles at $19,161 per mile; the State of South Carolina had 1,000 route miles at $24,000 per mile;
the State of Tennessee had 1,284 route miles at $24,000 per mile; the State of Texas cost
$31,186 per mile; and he State of Virginia had 1,800 miles at $38,548 per mile.

198) Upon information and belief, the involuntary, forced and compulsory labor of 10,000 to
20,000 yearly from the 1830's to 1865, and of hundreds of thousands of wrongly
convicted former slaves, through the convict-lease system after the Civil War, was wrongfully
and unjustly used to build, rebuild, expand and/or maintain the railroads in the United States,
especially in the slave-holding states; and to transport products and services that were produced
by slave, slave-like, convict-lease, and other forms of slave-like labor. These railroads were
financed in whole or in part by monies wrongfuliy and unjustly stolen and converted from this
enslaved labor.

199) The North American rail industry, a highly concentrated monopoly, is a $42 billion dollar
business today. The six class one railroad companies, that dominate the North American rail
industry, were built through the merger and acquisition of 2,902 predecessor rail lines: 658
predecessor rail lines for Burlington Northern Santa Fe, 255 for Canadian National Railway, 828
for CSX Transportation, 55 for Kansas City Southern, 496 for Norfolk Southern, and 610 for
Union Pacific.

200) It has been estimated that a minimum of 90 to 120 of these predecessor lines were built
and maintained, wholly or in part, by slave-labor: at least 7 to 9 predecessor lines for
Canadian National, 39 for Norfolk Southern, 37 for CSX, and 12 for Union Pacific. We
summarize herein, some of the evidence that we have found to substantiate these claim. Further
disclosure is required.

Canadian National Railway Company

201) The Illinois Central Railroad, a component of Defendant Canadian National's Gulf
Division, owns or operates 2,544 miles of track, 1,389 miles or 54.6% of which is located in five
former slave-holding states, 2.9% of the total track mileage in those five states: 844 route miles
in Mississippi, 42% of the state's total 2,929 route miles; 258 miles in Louisiana, 9.7% its total
3,192 route miles; 151 miles in Tennessee, 6.5% of its total 2,929 miles; 102 miles in Kentucky,
4.2% of its total 2,962 miles; and 34 miles in Alabama, 1.1% of its total 3,687 miles.

202) This land was cleared, improved and maintained, and the railroads, telegraph lines, roads,
water and sewerage systems, counties and cities that were built on it, were constructed and
maintained, wholly and/or in part, by slave, involuntary, forced and compulsory labor. Canadian
National owns or controls this land, and was and is unjustly enriched, by this ownership and
control.

203) Illinois Central is the successor-in-interest to at least 186 predecessor lines.
Upon information and belief, at least 23 of these predecessor lines, some of Illinois Central's
most valuable property, were built, maintained, and/or run, wholly and/or in part, by slave-labor,
including, but are not limited:

1 predecessor line and 2 subsidiaries in Illinois: the Illinois and St. Louis Railroad, the Wiggins
Ferry, and the Illinois Central Steamboat Service.

2 predecessor lines in Alabama: the Mississippi, Gainesville and Tuscaloosa Railroad and the
Mobile and Ohio Railroad in Alabama.

2 predecessor lines in Kentucky: the Mobile and Ohio Railroad in Kentucky and the New
Orleans and Ohio Railroad.

4 predecessor lines in Louisiana: the Clinton and Port Hudson Railroad, the New Orleans,
Jackson and Great Northern Railroad, the Vicksburg, Shreveport and Texas Railroad, and the
West Feliciana Railroad.

9 predecessor lines in Mississippi: the Canton and Jackson Railroad, the Central Mississippi
Railway, the Commercial and Railroad Bank of Vicksburg, the Gulf and Ship Island Railroad,
the Jackson and Brandon Railroad, the Mississippi Central Railroad, the Mississippi Central and
Tennessee Railroad, the Vicksburg and Jackson Railroad, and the Vicksburg and Brandon
Railroad.

3 predecessor lines in Tennessee: the Mississippi Central Railroad of Tennessee, the Mobile and
Ohio Railroad of Tennessee, and the New Orleans and Ohio Railroad.

1) Some of Illinois Central's slave-built predecessors include:

2) Wiggins Ferry, a wholly or partly owned IC subsidiary, was chartered by the State of Illinois
to transport products and goods people from East St. Louis, across the Mississippi River, to fuel
and feed the slave-built and slave-driven economy of St. Louis. Upon information and belief,
Wiggins Ferry, used slave labor, on both sides of the river, in its daily operations; and it was
financed, wholly or in part, by monies obtained by and through the trafficking in slaves, and use
of slave, involuntary, forced and compulsory labor. Disclosure will document the role played by
McKnight and Brady, one of the largest slave-trading and slave-holding firms in St. Louis, in the
building and operation of Wiggins Ferry, and detail their unjust enrichment. This Ferry, and its
predecessor today, remains critical to the growth and success of Defendant Canadian National
Railway.

3) The Illinois Central Steamboat Service was launched by Illinois Central to provide steamboat
transportation on the Mississippi River, from the IC railroad terminal at Cairo, Illinois to New
Orleans. Samuel Clemens, known as Mark Twain, wrote extensively about his life as an ICC
steamboat captain, and about slavery in the Mississippi River Delta. Further
disclosure will reveal the depth of the Illinois Central's participation in, and unjust enrichment by
this slave-driven river economy.

4) The Illinois and St. Louis Railroad, one of the IC's earliest predecessor lines, was chartered on
March 29, -1837, by 3 5-man syndicate that included John Reynolds and Vital Jarrot, in order to
haul over 300,000 bushels of coal yearly, food and other raw materials to Illinoistown, (now
known as East St. Louis), and then by the Wiggins Ferry across the Mississippi river to St.
Louis. By 1873, though a succession of changes of ownership and names, this line had become a
"part of the Illinois Central System known as the Cairo Short Line, ... the richest dollar-permile
railroad in America."

5) John Reynolds was a former Governor of Illinois, a justice of the Illinois Supreme Court,
member of the Illinois State Legislature, and one of its Congressional Representatives. Like
many of the first Governors and officials of the State of Illinois, Reynolds owned slaves, and
proudly said so in his autobiography, My Own Times. His wife, Julien Dubuque and her family,
were descendants of the original French settlers, one of the largest slaveholding Families in
southern Illinois. In a letter dated May 14, 1815, Governor Reynolds asked a St. Louis
newspaper to run the following advertisement:

"Fifty dollars reward will be given to any person who will deliver to me in Cahokia a negro boy
named ‘Moses,' who ran away from me in Cahokia about two months since. He is about 16 years
old, well made and did belong to McKnight and Brady, in St. Louis, where he has been seen
frequently, and is supposed to be harbored there or about there. He had on a hunting shirt when
he left me."

6) Vital Jarrot was a descendant of the original French settlers in Illinois. His father and mother,
Nicolas and Julia Jarrot, founded one of the largest land and slave-holding Families in Southern
Illinois--St. Clair County, Cahokia, and East St. Louis. The land, upon which Wiggins Ferry was
built, was originally part of the Jarrot estate. Julia's family, the Beauvais, "owned eighty slaves,
and furnished to the royal magazine eighty-thousand weight of flour, which was only part of
one's year's harvest."

7) The Jarrot family, Governor Reynolds, and other Families in Southern Illinois, illegally,
wrongfully and unjustly held at least 1,000 Africans , and their Descendants, in
slavery, involuntary, forced and compulsory servitude, in blatant and arrogant violation of the
Constitution and laws of France and Britain, the former colonial powers, the Northwest
Ordinance of 1787, and the Constitutions and laws of United States and the State of Illinois, until
at least 1845. The illicit gains wrongfully and unjustly extorted from these 1,000 slaves, and their
Descendants, was used to finance and build one of the Illinois Central's most valuable
predecessor lines, as set forth below.

8) The West Feliciana Railroad, which was chartered in Mississippi and Louisiana in 1828 and
1831 is also one of Illinois Central's oldest predecessor lines. "The line ran a distance
of 28-miles from Woodville, Mississippi to Bayou Sara, Louisiana. It was constructed,
maintained and financed by slave labor, in order to transport to New Orleans, the crops that were
grown by more than 10,000 slaves who toiled on 227,367 areas of plantations in the area: about
35,000 acres of cotton, 5,000 of sugar cane, and 19,000 acres of corn. By 1860, the value of the
cotton crop in the Feliciana parishes of Louisiana was assessed at $30 million. The plantation
owners and slave masters of the parish were ranked among the richest Families in Louisiana,
second only to the cotton, sugar, and shipping merchants of New Orleans. Several of these
Families, including the Barrows of Afton Villa Plantation and the Ruffins of Magnolia
Plantation," were investors in, and directors of the West Feliciana Railroad.

9) The Clinton and Port Hudson Railroad was chartered in 1833, By its completion in 1840,
through the use of slave labor, it began exporting 25,000 bales of cotton annually, and sugar and
molasses. At the time, it was claimed "that Clinton had more business transactions than any
other town of its size in the south."

10) The Mobile and Ohio railroad was chartered in Alabama, Mississippi, Tennessee and
Kentucky in 184748, to provide fast and reliable transportation to New Orleans. It was absorbed
by Illinois Central on August 10, 1972. The Mobile and Ohio was estimated to have "lost"
$199,691 in value, $2.2 million at today's value, to the emancipation of their slaves in 1865.


11) The Alabama and Vicksburg Railroad was chartered in 1848. It was "first called the
Southern Railroad, then the Vicksburg and Meridian line. The railroad was built almost entirely
with slave labor. Defendant Western Union's, and other telegraph companies, telegraph lines
were also built by slave and convict-lease parallel to the railroad, and the postal telegraph."


12) The Gulf and Ship Island Railroad began operations in 1838. In 1887, prisoners contracted
through the State Penitentiary convict-lease system constructed the railroad until December
1888, when the board of control revoked the lease, citing inhumane treatment of workers.


13) The Mississippi Central Raili oad was chartered in 1840. "The right-of-way and station site
in Vaiden was purchased for $50.00 from the Estate of the late Louis Whitfield Herring, with Dr.
C.M. Vaiden its Executor. Dr. Vaiden became a large stockholder in the Mississippi Central.
Both Dr. Vaiden and Louis Herring were large land and slave owners."

14) Moreover, the Illinois Central Railroad knew then, and knows now, that the slave-trade and
slavery was and is illegal, and was and is a crime against humanity:

15) Lynn Trumbull, the attorney for the Jarrot v. Jarrot case referred to above, was also one of
Illinois Central's attorney's, and was elected to Congress with Illinois Central's organizational
and financial support, where he became known as the Father of the 13th Amendment. Lynn
Trumbull knew, and Illinois Central therefore should have also known, that slavery was illegal in
Illinois, that the labor of those slaves was wrongfully and unjustly extorted, and that the Illinois
Supreme Court ordered the Jarrot Family, and by precedent all other slave-holding Families in
the Northwest Territory, to compensate the people who were illegally held in slavery, for the
wages not paid. Upon information and belief, that Court order was never implemented, and the
900 people who were illegally held in slavery, and their Descendants, were never paid, a wrong
which must be corrected today.

16) Illinois Central helped organize and finance the 1860 Republican National Convention, as set
forth herein in more detail, and participated in the decision to include in the 9 paragraph of the
1860 Republican National Platform, branding "the recent re-opening of the Africanslave trade,
under the cover of our national flag, aided by perversions of judicial power, as a crime against
humanity and a burning shame to our country and age; and we call upon Congress to take prompt
and efficient measures for the total and final suppression of that execrable traffic."

17) Illinois Central's, co-participants, historical and currently, include a who's who of
incorporators, directors, officers, bankers, brokers, investment houses, insurance companies, and
subsidiaries; cotton, textile, sugar, and grain companies; telecommunications and utilities
companies; construction companies; locomotive and equipment companies; express companies;
iron and coal companies; and others, who were, and continue to be, wrongfully and unjustly
enriched by this crime. The list of non-Government al institutions and organizations
that have profited from and continue to profit from this criminal enterprise and scheme is too
large to set forth here.

18) By 1925 Stuyvesant Fish had accumulated more than $7 million, and the Harriman Family
had accumulated almost $300 million, largely through their ownership and control of
Illinois Central Railroad. Further disclosure will reveal the untold amount of wealth that was,
obtained through the exploitation of slave and convict-lease labor; the names of other
co-participants who were wrongfully and unjustly enriched; where that wealth is today, and who
owns and controls it.

19) Upon further information and belief, dozens of Illinois Central's predecessor lines, were
rebuilt, improved and expanded after the Civil War, through the wrongful and unjust use of the
labor of newly freed slaves through such illegal schemes as convict lease, and other forms of
involuntary, forced and compulsory labor.

20) A spokesman for Canadian National said that it "takes very seriously claims that slave labor"
was used to build some of its early rail lines. "We are actively researching the issue," the
spokesman stated, and "invite any party to share with CN any relevant information or
documentation."

21) CN spokesman Jack Burke said "any reparations suit against CN is wholly without merit and
CN will defend itself vigorously." He emphatically stated that "neither CN nor Illinois Central,
which was acquired by CN in 1999, ever employed slave labor." "In fact," he proclaimed,
"Illinois Central was at the forefront of the war against slavery during the Civil War and played a
central role in rebuilding the U.S. South."

Union Pacific Corporation

22) Defendant Union Pacific currently operates and/or owns an estimated 9,872 miles of track,
29.9% of its total 33,035 track miles, in 5 former slave-holding and convict-lease states: 1,452
track miles in Arkansas, 53.5% of its total; 977 miles in Louisiana, 36.8% its total; 1,221 miles
in Missouri, 33.8% of its total; and 54.4% in Texas.

23) Union Pacific has 811 predecessor railroads, including the St. Louis Southwestern Railway
(The Cottonbelt), the Missouri-Kansas-Texas Railroad (The Katy), the Missouri Pacific, and the
Southern Pacific (The Frisco).

24) Upon information and belief, a large percentage of Union Pacific's 9,872 track miles as set
forth above, and at least 16 of is predecessor lines were built by slave labor," including the Baton
Rouge; Grosse Tete & Opeloosa Railroad; Buffalo Bayou Brazos & Colorado Railway; Eastern
Texas Railway; Houston & Texas Central Railroad; Houston Tap & Brazoria Railroad; Memphis
& Little Rock; Memphis, El Paso & Pacific Railroad; Missouri Kansas & Texas Extension
Railway; Missouri Kansas & Texas Railway; Missouri Kansas & Texas Railway [of Texas];
Missouri, Kansas & Texas Railroad; Missouri Kansas & Texas Railway [of Texas]; New
Orleans, Opelousas & Great Western Railroad; Pacific Railroad of Missouri; Southern Pacific
Railroad of Texas; Texas and New Orleans Railroad; and the Virginia Central.

25) Upon further information and belief, the involuntary, forced and compulsory labor of
thousands of slaves, before the Civil War, and of wrongly convicted former slaves, under the
convict-lease system after the Civil War, was used to build, rebuild, expand and/or maintain the
Union Pacific railroads; to transport products and services that were produced by slave,
slave-like and convict-lease labor; and were financed in whole or in part by monies wrongfully
converted from slave, slave-like, and convict-lease labor.

26) Union Pacific admitted that "it owns nine of the 12 railroads the [[Professor Theodore]
Kornweibel identified as UP lines that owned or leased slaves. Ownership of the lines today has
‘no relevance' to how they were built," UP spokesman John Bromley said. "We have no way of
knowing, and we have no intention of researching that issue."

CSX Transportation Inc.

27) Defendant CSX currently operates and/or owns an estimated 13,431 miles of track, 58.4 %
of its total 23,000 track miles, in 15 former slave-holding and convict-lease states: 1,243 track
miles in Alabama, 39.5% of the state's total track miles; 21 miles in the District of Columbia,
61.8% its total miles; 1,746 miles in Florida, 92.1% its total miles; 1,276 miles in Georgia,
47.2% its total; 1,880 miles in Kentucky, 77% its total; 43 miles in Louisiana, 1,6% its total; 13
miles in Missouri, 4% of its total; 1,302 miles in South Carolina, 61.2% of its total; and 150
miles in Texas, 64.8% of its total.

28) CSX is the successor-in-interest to 828 predecessor lines, 37 or more of which were built
and/or maintained by slave labor, including 2 in Alabama; 4 in Florida; 7 in Georgia; 2 in
Kentucky; 1 in Maryland, 5 in North Carolina; 5 in South Carolina; 5 in Tennessee; and 3 in
Virginia. These lines predecessor include: Alabama & Florida Railroad of Flbrida; Alabama,
Florida & Georgia Railroad; Atlanta & West Point Railroad; Atlantic & Gulf Railroad;
Baltimore & Ohio Railroad; Brunswick & Florida Railroad; Central Southern Railroad;
Charleston & Savannah Railroad; Chatham Railroad; Cheraw & Darlington Railroad; Covington
& Ohio Railroad; Florida Railroad; Georgia Railroad & Banking; Louisa Railroad; Macon &
Warrenton Railroad; Memphis & Ohio Railroad; Milledgeville Railroad; Mobile & Great
Northern Railroad; Montgomery & West Point Railroad; Nashville & Chattanooga Railroad;
Northeastern Railroad of South Carolina; Raleigh & Gaston Railroad; Richmond & Petersburg
Railroad; Richmond, Fredericksberg & Potomac Railroad; Seaboard & Roanoke Railroad; Selma
& Roanoke Railroad; South & North Alabama Railroad; Tallahassee Railroad; Tennessee &
Alabama Railroad; Virginia Central Railroad; Western & Atlantic Railroad; Wilmington &
Manchester Railroad; Wilmington & Weldon Railroad; Wilmington, Charlotte & Rutherford
Railroad; and Winchester & Potomac Railroad.

29) Upon information and belief, the involuntary, forced and compulsory, and illegal labor of
thousands of slaves, before the Civil War, and of wrongly convicted former slaves, under the
convict-lease system after the Civil War, was used to build, rebuild, expand and/or maintain
CSX's railroads; to transport products and services that were produced by slave, slave-like and
convict-lease labor; and were financed in whole or in part by monies wrongfully converted from
slave, slave-like, and convict-lease labor.

30) "CSX said that the lawsuit against them is ‘wholly without merit and should be dismissed.
The claimants named CSX because slave labor was used to construct portions of some U.S. lines
under the political and legal system in place more than a century before CSX was formed in
1980 Courtrooms are the wrong setting for this issue.' CSX claims that it can verify the names of
only a handful of the 19th century rail lines that make up its network. ‘As to the basic issue of
reparations, we're not going to discuss that,' spokeswoman Kathy Bums said."

31) CSX further said that the impacts of "slavery cannot be attributed to any single industry or
company."

32) Plaintiff wholeheartedly agrees with this fact, as proven by this complaint, and the facts set
forth herein. However, companies, Families and individuals, especially those who dominate and
control these industries, and have been and are unjustly enriched by and through this domination
and control, must be held accountable and liable for their actions, and should not be permitted to
hide behind these industrial shells.

Norfolk Southern Corporation

33) Defendant Norfolk Southern currently operates and/or owns an estimated 10,910 miles of
track, 50.7 % of its 21,500 total track miles is located in 15 former slave-holding and
convict-lease states: 1,393 track miles in Alabama, 44.2% of the states 3,149 total mile; 203
miles in Delaware, 44.2% of the states 246 total miles; 13 miles in the District of Columbia,
38,2% of its 34 miles; 149 miles in Florida, 7.9% of its 1,895 miles; 1,872 miles in Georgia,
52.8% of its 3,548 miles; 82 miles in Louisiana, 3.1% its 2,656 miles; 269 miles in Maryland,
32.2% of its 835 miles; 213 miles in Mississippi, 10.6% of its 2,011 miles; 410 miles in
Missouri, 11.3% of its 3,616 miles; 1,450 miles in North Carolina, 56% of its 2,588 miles; 825
miles in South Carolina, 38.8% of its 2,127 miles; 1,043 miles in Tennessee, 44.7% of its 2,331
miles; 21,45 miles in Virginia, 67.1% of its 3,195 miles; and 842 miles in West Virginia, 35.2%
of its 2,391 miles.

34) Norfolk Southern is the successor-in-interest to 224 predecessor lines, 39 or more of which
were built and/or maintained by slave labor, including 13 in Alabama; 2 in the District of
Columbia; 2 in Florida; 5 in Georgia; 6 in Kentucky; 1 in Louisiana; 1 in Maryland; 7 in
Mississippi; 7 in North Carolina; 3 in South Carolina; 5 in Tennessee; and 6 in Virginia. These
lines include: the Alabama & Mississippi Rivers Railroad Company; Alabama & Tennessee
Railroad; Alabama Great Southern Railroad Company; Alexandria, Loudoin & Hampshire
Railroad; Atlantic & North Carolina Railroad; Augusta & Savannah Railroad; Augusta to
Columbia Railroad; Central of Georgia Railroad; East Tennessee & Georgia Railroad Company;
East Tennessee & Virginia Railroad Company; Greenville & Columbia Railroad Company;
Hiwassee Railroad Company; Kings Mountain Railroad; LaGrange & Memphis Railroad;
Macon & Brunswick Railroad Company; Macon & Western Railroad; Manasas Gap Railroad;
Memphis & Charleston Railroad Company; Mobile & Girard Railroad; Muscokegee Railroad;
Norfolk & Petersburg Railroad Company; North Carolina Railroad Company; North East &
South West Alabama Railroad; Orange & Alexandria Railroad Company; Piedmont Railroad
Company; Richmond & Danville Railroad Company; Roanoke Valley Railroad Company; Selma
& Meridian Railroad Company; South Carolina Central Railroad; Southern Pacific Railroad;
Southside Railroad Company; Southwestern Railroad; Thomaston & Barnesville Railroad;
Virginia & Tennessee Railroad; Western & Atlantic Railroad; and the Western North Carolina
Railroad Company.

35) Upon information and belief, the involuntary, forced and compulsory, and illegal labor of
thousands of slaves, before the Civil War, and of wrongly convicted former slaves, under the
convict-lease system after the Civil War, was used to build, rebuild, expand and/or maintain the
Norfolk Southern railroads; to transport products and services that were produced by slave,
slave-like and convict-lease labor; and were financed in whole or in part by monies wrongfully
converted from slave, slave-like, and convict-lease labor.

36) The Garret Family, owners of the Baltimore &-Ohio Railroad, were worth $44 million
dollars in 1925. The Hopkins Family, who were also owners of the B & O were worth $15
million in 1875. The Hopkins Family donated a great deal of their money to Defendant John
Hopkins University.

37) Upon information and belief, the involuntary, forced and compulsory, and illegal labor of
thousands of slaves, before the Civil War, and of wrongly convicted former slaves, under the
convict-lease system after the Civil War, was used to build, rebuild, expand and/or maintain the
Kansas City Southern railroads; to transport products and services that were produced by slave,
slave-like and convict-lease labor; and were financed in whole or in part by monies wrongfully
converted from slave, slave-like, and convict-lease labor.

38) Norfolk Southern "declines to confirm ownership of individual rail lines from the 19th
Century but says it owns ‘80% or more' of the 39 lines identified by Kornweibel. It won't
comment on whether the lines were built and run with slave labor or related questions."


Burlington Northern Santa Fe Railway Company

39) Defendant Burlington Northern has 658 predecessor railroads, and currently operates and/or
owns an estimated 33,386 miles of track, 8,581 miles of which, 25.7% is located in 6 former
slave-holding and convict-lease states: 356 track miles in Alabama, 11.3% of the state's total
3,149 miles; 1,045 track miles in Arkansas, 38.6% of its 1,045 miles; 380 miles in Louisiana,
14.3% its 2,656 miles; 179 miles in Mississippi, 6.7% of its 2,011 miles; 17 miles in
Tennessee,.7% of its 2,331 miles; and 4,806 miles in Texas, 42.2% of its 11,377 miles.

40) "On November 21, 1980, Burlington Northern acquired The St. Louis-San Francisco
Railway Company (The Frisco) once owned by the Santa Fe in the 1890's, whose main line
formed an X from St. Louis through to Oklahoma to Texas and from Kansas City to Birmingham
and Pensacola, (making Burlington Northern and successor Burlington Northern Santa Fe a true
transcontinental railroad)... The Frisco was chartered in 1849 as the Pacific Railroad of Missouri,
when discovery of gold at Sutter's Mill in California fanned America's long-smoldering desire
for a connection with the markets of the Orient. Construction began in 1855, but bogged down
until the Civil War ended, ... [and] it went bankrupt."

41) The website of Dunavant Enterprises Inc. the largest cotton merchant firm in the world, 5th
generation privately owned, informs us that "Mr. Billy Dunavant's paternal grandfather, the late
Colonel William P. Dunavant, and William Bedford Forrest started one of the first railroads built
in Mississippi, which later became the Frisco Railroad and was used extensively in the early
days for transporting cotton." Upon information and belief, William Bedford Forrest
is the son of Nathan Bedford Forrest, the Confederate General who founded the KIu Klux Khn.

42) Upon information and belief, the involuntary, forced and compulsory, and illegal labor of
tens of thousands of slaves, before the Civil War, and of tens of thousands wrongly convicted
former slaves, under the convict-lease system after the Civil War, was used to build, rebuild,
expand and/or maintain the Burlington Northern's railroads, especially the Frisco Railroad; to
transport products and services that were produced by slave, slave-like, and convict-lease labor;
and were financed in whole or in part by monies wrongfully converted from slave, slave-like,
and convict-lease labor.

Kansas City Southern Railroad

43) Kansas City Southern currently operates and/or owns 2,728 track miles, some 2,526 miles of
which, 93% of its total, are located in 5 former slave-holding and convict-lease states: 123 miles
in Alabama, 3.9% of the state's total; 217 miles in Arkansas, 8.0% of its total; 916 miles in
Louisiana, 34.5% of its total; 681 miles in Mississippi, 33.9% of its total; 21 miles in Tennessee,
9% of its total; and 381 miles in Texas, 3,3% of its total.

General Statement About Railroad Industry Defendants

44) More than any other city in North America, Chicago has benefited, directly and indirectly,
and continues to benefit, directly and indirectly, from this slave, slave-like, convict-lease built
railroad industry, and larger economy. Chicago is, according to World Business Chicago, the
"transportation hub and distribution capital of North America, ... the nation's busiest rail hub ...
[[the] only gateway where all six Class-One North American railroads can interchange traffic ...
[with] 75% of U.S. rail freight pass[ing] through Chicago's rail yards ... [and with] 1,300 freight
trains and 39,000 carloads and 2.5 million tons of rail freight leav[ing] Chicago each day."
World Business Chicago claims that: "Chicago has dominated the North American transportation
and distribution scene since the 1850s. In the past 20 years, it has become the major crossroads
of America's global trade."

45) Upon information and belief, Defendant Railroad Companies, have refused and failed to
comply with the Chicago Slavery Era Disclosure Act as mandated by the City Council of
Chicago. Through their recent statements and acts, which are fraudulent, deceptive and
misleading, as set forth herein, and as disclosure will further reveal, Defendant Railroad
Companies have violated Illinois consumer protection and fair business practice laws.

46) Defendant Railroad Industry and Companies are charged, by and through this private
attorney general class action, with conspiracy; gross violations of human rights; crimes against
humanity; conversion; unjust enrichment; failure and refusal to account for, and disgorge their
ill-gotten and unjust gains; violation of the Chicago Slavery Era Disclosure Act; and consumer
fraud.

47) Several families, including the Brady, Fish, Forbes, Garret, Gould, Green, Harriman, Hill,
Hopkins, Huntington, James, Kenan, Law, Livingston, Morgan, Parker, Pitcaim, Perkins,
Rockefeller, Ryan, Scott, Stanford, Stevens, Stone, Thaw, Thomson, Tilden, Twombly,
Vanderbilt, Widener, Winans, Yerkes, and other families have made, and continue to
make, their fortunes from the Maafa, especially from the slave built and slave-like labor built
railroads; and/or from the slave and slave-like produced products which the railroads transport.
These, and other families, must be, and ultimately will be, held accountable for their crimes as
well.

THE BANKING INDUSTRY DEFENDANT

Bank of England

48) Founded in 1694, Defendant the Bank of England should have "been called the Bank of the
West Indies, because of its involvement in slavery. Humphrey Morice, the Bank's governor
between 1716 and 1729, owned six slave ships. ... He exported pewter, brass, swords, guns,
beads, and textiles from London and usually added a second cargo of goods in Rotterdam. He
liked to sell Dutch goods to Dutch traders in Africa, acquiring gold from them in return. Morice
preferred to sell the slaves he bought to the Portuguese in Africa rather than send his ships across
the Atlantic. If the slaves were not sold in Africa, he sent them to Virginia, Maryland, Jamaica,
and Barbados, where he usually exchanged them for rum. He instructed his captains not to stay
longer than 14 days waiting for a cargo of tobacco for the return journey."

49) Sir Richard Neave, a Bank of England director for 48 years, was chairman of The Society of
West Indian Merchants. Slaves were sold on the London Royal Exchange and "other places of
public resort" - many of them children."

Barclays Bank PLC

50) The British slave trade was based at Bristol and Liverpool, Bristol was largely built on the
commerce in slaves and sugar. "In the 1730s, there were up to 50 sailings a year, taking cheap
manufactured goods to West Africa to be bartered for slaves. As many as 17,000 slaves were
transported annually to the West Indies, yielding an average profit of around £7000, a massive
sum those days. In 1756, there were an estimated 84 Quaker slave traders in Bristol, among them
Alexander and David Barclay, who founded Defendant Barclays Bank in 1762."

51) Upon information and belief, "the Barclays Brothers made their first millions out of the slave
trade shipping millions of Africans from the west coast of Africa to the Caribbean and the
Americas - they were chained to the walls and floors of ships, the journey alone cost the lives of
a third of them, and [then forced to work] on plantations until they died of exhaustion."


ING Groep N.V.

52) Sir Francis Baring, the founder of Barings Bank, a subsidiary of Defendant ING Groep N.V.
"earned nearly £7 million from a business of dealing in slaves that went back 70 years. ... He was
said to have his first money trading in slaves when he was just 16, indicating his family's
immense wealth and business connections with the West Indies."

53) Upon information and belief, "London merchants were the main businessmen to profit from
the sugar trade, handling some 75% of the sugar imported. ... Slave trader Francis Baring is said
to have made his first money trading in slaves when he was just 16, indicating his family's
immense wealth and business connections with the West Indies. It was this family that was later
to develop their business into the present day Barings Bank ... At least 20 merchants who lived
around the edge of Blackheath in the 18th century were closely involved in the slave trade.
These include: John Angerstein, the founder of Lloyd's of London; Ambrose Crowley, an iron
merchant who made his fortune producing manacles, ankle irons and collars, essential for
securing the slaves from their journey from Africa in barbaric conditions; Samuel Fludyer, a
baronet and Lord Mayor of London 1761; and William Wilberforce who led the parliamentary
campaign to abolish slavery in Britain from 1789 to 1807."

54) Upon further information and belief, Barings Bank, Britain's oldest merchant bank, has been
the major financier of the colonization of, and slave-trade, slavery, segregation in the United
States for the past 225 years. Barings, the Queen's bank, financed the American Revolution, was
"the Financial Agents in Europe for the United States Government from 1803 until the
early-1870s, ... handled the financial arrangements for the United States's purchase of Louisiana
from France in 1803-04, financed the Napoleonic wars, and the building of the Erie Canal...
Barings was a leader in financing the Trans-Atlantic cotton trade, and the leader in raising
finance in Europe to build the United States railroads."

55) Barings was also one of the major financiers of colonialism, segregation, and apartheid in
Africa and the African Diaspora as well. Its private and institutional clients included
numerous United States Presidents, Harvard University, and the American Academy of Arts.

56) A spokesperson for ING Barings claims the original Barings Bros. went bust in 1891 and
that it acquired a successor firm with no liabilities from the defunct Barings.

Bank of New York

57) Founded on February 23, 1784, Defendant the Bank of New York stood alone as the
generator of virtually all of the city's commercial activity. Importers of cargoes entering the port
of New York turned to the Bank for financing. The Trans-Atlantic Slave Trade and
the Triangle Trade, in cotton, tobacco, sugar, rum and other slave produced and convict-lease
produced products was the City and Port of New York's commercial and import activity.

58) "Sugar and war ... transformed New York's economy. By about 1720 a fifth to a quarter of
the city's adult males worked as mariners, and half of the ships that used New York's port
traveled from or to the Caribbean. During King George's War (1744-1748) and the French and
Indian War (1754-1763) the city's economy boomed. Not surprisingly, African slavery grew with
it. By 1750 Africans made up more than 20 percent of the settlement's populace, and only
Charleston, South Carolina, surpassed New York in the number of slaves and slave owners in a
North American city. Legal slavery endured in New York until 1827.;"

59) "After the American Revolution the Napoleonic Wars and American neutrality enabled the
[Port of New York] to become the continental entrepot. From about 1790 to 1807 the value of
imports entering the city rose from $1.4 million to $7.6 million. By then New York's imports
were almost double those of its rival Philadelphia. More noteworthy were exports, whose value
increased tenfold, from $2.5 million to $26 million. By the 1820s customs duties collected in
New York were so abundant that they subsidized the entire operation of the federal Government,
excepting interest on the national debt. At mid-century the port of New York accounted for a
third of the nation's exports and half of its imports. Most significant, the flow of commodities
linked New York to the three economic engines of the century: the manufacturing Midlands of
Great Britain, the cotton-producing American South, and the agricultural Midwest, the
breadbasket of America. New York, according to the writer George Train in 1857, was ‘the
locomotive of these United States."

60) In 1792, the New York Stock Exchange was formed, and the first corporate stock traded was
The Bank of New York. Using profits made from the slave and convict-lease industries, the
Bank funded the construction of the Morris and Erie Canals, and invested in nearly every
railroad and utility project in New York City, including the subway system. By 1827, the
members of the New York Stock Exchange included 12 banks, 19 insurance companies, and
New York Light Company, the overwhelming majority of whom owed their existence and profits
to the slave, sugar, tobacco and cotton industries; and to the Trans-Atlantic Slave Trade, the
Triangle Trade, and the West Indies Trade.

61) "By 1900 New York was the national headquarters for the modern business structure -- the
corporation. Indeed, nine of the eleven major trusts that emerged shortly after 1882 (including oil
and sugar) were headquartered in New York. As the historian Kenneth T. Jackson has written,
‘In 1895, the metropolis contained 298 mercantile and manufacturing firms worth more than one
million dollars, more than Chicago, Philadelphia, Boston, San Francisco, Baltimore, and St.
Louis combined,' The deposits in New York banks were equal to the sum of all those in the rest
of the United States." The Bank of New York was one of, if not the most important
and richest of all, these New York banks.

62) In July 1922, the Bank of New York merged with the New York Life Insurance and Trust
Company merged, which profited from the sale of insurance policies on slaves.

Bank of America Corporation

63) Defendant Bank of America Corporation recently announced the acquisition of FleetBoston
Financial Group, in a deal valued at $47 billion. Bank of America, with assets valued at $930
billion, is now the United States's second-biggest banking company, behind Citigroup, which has
more than $1 trillion, and followed by J,P. Morgan Chase & CO., with assets valued at more
than $740 billion.

64) Upon information and belief, FleetBoston is the successor-in-interest to hundreds of banks,
including Bank of Boston, which was chartered bank in 1784, and Providence Bank, which was
chartered in 1791.

65) John Brown, the founder of Providence Bank, was a merchant, slave trader, West Indies
trader, and distiller of rum and gin. "On August 5, 1797, John Brown ... became the first
American to be tried under the U.S. Slave Trade Act of 1794 ... for fitting out his ship Hope for
the Africanslave trade. The voyage had concluded profitably a year earlier in Havana, Cuba with
the sale of 229 slaves." He was also "part owner of the schooner Delight, which
delivered 81 slaves to Savannah, Georgia."

66) John's brothers, James, Obadiah and Elisha, were also slave traders, and molasses and sugar
merchants; and his four sons, (Nicholas, Joseph, John, and Moses), were shippers,
merchants, manufacturers and bankers in Rhode Island. Moses, in partnership with Samuel
Slater, owned textile factories in Rhode Island and New England that used cotton grown by
slaves.

67) John Brown, and the two DeWolf Brothers, were the largest slave traders in the United
States, and their Families, and other co-conspirators, continued the slave trade for several
decades after it was pronounced illegal by the United States Government in 1808. "Three
generations of DeWolfs took advantage of those golden years, making 88 voyages and becoming
the nation's leading slave traders... James DeWolf became one of the richest men in Rhode
Island. ... By the time the slave trade ‘legally' ended in 1808, 402 Rhode Island men had become
ship owners or captains, and their ships carried 93,400 Africanslaves along the so-called Middle
Passage, according to Harvard University's DuBois Institute."

68) Upon information and belief, Providence Bank aided and abetted in these crime by loaning
money to, laundering and profiting from the Brown and DeWolf Families' illegal enterprises; by
"collecting custom duties and fees on over 41,369 enslavedAfricans;" and/or through
the illegal importation of between 250,000 to 1.5 million slaves after 1808 when the slave trade
was banned in Britain and the United States; thus financing and profiting from this illegal slave
trade and the slavery industry,

69) Through Nicholas Brown & Company, Brown & Bensen, Brown & Ives, and other family
controlled firms, the Brown Family surpassed in stature, wealth and power, other merchants and
slave traders such as Aaron Lopez, Joseph Wanton, and Christopher Champlin in Newport, and
James DeWolf of Bristol.

70) The Browns were the wealthiest and most powerful family in Rhode Island, and this wealth
and power was accumulated through, and rested on their participation in the Trans-Atlantic Slave
Trade, the Triangle Trade, the West Indies Trade; and in the shipping, sugar, molasses, rum,
cotton, textiles, machine and tool, and other industries in Rhode Island and New England.
By 1830, they had become the leading United States merchant bankers, and "ranked
second as financiers of American trade to the great Baring Brothers of London."

71) On May 31, 1770, John and Moses Brown, presented their grandfathers land to the College
of Rhode Island, now Brown University, and laid the cornerstone of University Hall, for many
years the Colleges only building. The dowel's were also instrumental in founding,
maintaining and funding Brown University.

72) A Fleet spokesman said it appears there is no connection to Brown's bank, though Fleet
doesn't have records going back 200 years. "And the connection between the original bank and
our bank is a very distant one," he said.

73) Fleet spokesman James Mahoney clarified their earlier statement. Providence Bank,
according to Mahoney was "one of hundreds that created Fleet, ... [and] the link between Fleet
and Brown is extremely remote."

N. M. Rothschild & Sons

74) Founded in 1799, as a textile trading firm in Manchester, England, Defendant N.M.
Rothschild & Sons was one of the "key financiers of the pre-Civil War cotton trade. They took
consignments of cotton from so-called commission merchants, insured them, shipped them to
Europe and sold them. They gave credit to cotton brokers and other middlemen. Rothschilds
were also heavily involved in financing both sides in the Civil War."

75) Rothschild's, through their agent August Belmont, who was Chairman of the Democratic
National Party in 1864, supported former confederate George McClellan's presidential campaign.
Belmont "purchased thousands of shares in Confederate state -Virginia and North Carolina
bonds- and Union securities, [[and he also] bought $6,000 of Confederate Government securities
for French clients (See: The Rothschild Archives book of American Stock, September 1864).


76) The House of Rothschild helped finance the slave-driven sugar industry in the Caribbean and
Louisiana; Napoleon's war against Toussaint L'Ouverture and Haiti's independence; Napoleon's
efforts to re-enslaveAfricans in the French colonies after the French National Assembly
abolished slavery in 1794; and Napoleon's fraudulent sale of Louisiana.

77) "European investors, worried about political instability after the French Revolution and the
1830 and 1848 uprisings, sought secure places of investment. As Latin America proved
increasingly unstable, investors such as Britain's House of Baring and Europe's House of
Rothschild increasingly looked to New York. When the city needed a new water supply, for
example, the House of Rothschild, among others, rounded up $12 million in investment to
construct the Croton reservoir system."

78) Between the end of the Civil War and 1914, Rothschild's main agents in the United States
were Kuhn, Loeb and Company and the J. P. Morgan Company. By the beginning of the
twentieth century, Rothschild, through Kuhn, Loeb and J.P. Morgan, provided the capital that
enabled John D. Rockefeller to greatly expand his Standard Oil empire; Edward Harriman to
finance his Union Pacific and Illinois Central Railroad empire, and Andrew Carnegie to build
U.S. Steel.

79) Rothschild archivist Victor Gray says his firm bought and sold "bills of exchange" used as
payment in various industries but was not active in the cotton trade itself."

J.P. Morgan Chase & Company

80) Tracing its corporate roots back to 1799, Defendant JP Morgan Chase & Company is the
parent company of JP Morgan Securities Inc. and JP Morgan Chase Bank, and the successor of
the Chase Manhattan Bank, Chemical Bank, Texas Bankshare and Manufacturers Hanover
Corporation.

81) Founded in 1832, the Leather Manufacturers' Bank, a predecessor of JP Morgan Chase, was
known as the "Slave Insurance Bank." ‘In the 1850s, the National Loan Fund Life Assurance
Company of London distributed a circular entitled ‘A Method by Which Slave Owners May Be
Protected From Loss' in which it named The Merchants Bank and the Leather Manufacturers
Bank as institutions able to pay and adjust claims. The circular also included the names of
medical examiners in Virginia, Washington DC, and North Carolina who were authorized to
examine slaves and offer insurance policies. Under a typical policy, a 3year-old slave could be
insured for $500 with an annual premium of about $11.25. The circular has exposed that Chase
Manhattan was connected with slave insurance policies based upon its merger with two of the
banks named in the circular. In 1920, The Merchants Bank merged with the Bank of the
Manhattan Company, and in 1955 it merged with Chase. In 1904, The Leather Manufacturers
Bank merged with the Mechanics National Bank, and then in 1926 merged with Chase,"


82) In 1854, Junius Spencer Morgan, J.P. Morgan's father, who was already wealthy in his own
right, became a partner of George Peabody's banking firm in England, which was a key financier
of the slave-produced cotton industry and trade, and a key provider of municipal bonds which
kept the slave-holding states, counties and municipalities with falling into bankruptcy. When
Peabody retired, J.S. Morgan took the house over and named it J.P. Morgan and Company. In
1862, it was renamed Drexel, Morgan and Company.

83) JP Morgan Chase also financed and profited from slave-like practices and conditions,
colonialism, segregation and apartheid, in the United States, Africa and the African
Diaspora.

84) Arsene Pujo, a U.S. Representative from Louisiana published a report on the banking
industry in the U.S. which found the J.P. Morgan and Company, the First National Bank,
National City Bank,, and Morgan Guaranty Trust Company controlled 118 directorships in 14
banks, 105 directorships in 12 transnational companies, 63 directorships in 24 producing and
trading companies, and 25 directorships in 12 public utility companies.

85) The Drexel Family had accumulated $116 million by 1925

86) "We have examined our archives and had them examined by an outside, independent
archival expert to look for any evidence to support these allegations," Chase spokesman Tom
Johnson said. "We found nothing to indicate that we were involved in any of the (slave)
transactions that are being quoted in articles about the lawsuit."

87) Thomas Johnson, J.P. Morgan spokesmen, said "the allegations are without merit," and they
have conducted a "thorough and extensive" search of internal and external archives.

Citigroup

88) Defendant Citigroup, also known as Citicorp and Citibank, is a New York corporation whose
principal place of business is located at Citigroup, 399 Park Avenue, New York, NY 10043. Its
Chicago office is located at Citigroup, 11 S. LaSalle Street, Chicago, IL 60603. Upon
information and belief, Citigroup dose business with and within the City of Chicago. Upon
further information and belief, Saloman Smith Barney, a division of Citigroup, "issues more
municipal bonds than anybody else in Chicago."

89) The City Bank of New York, Citigroup's oldest predecessor, was founded in 1812 By
Colonel Samuel Osgood, the first commissioner of the United States Treasury, to serve the
cotton, sugar, metal, coal and other merchants of New York, who owned and controlled the
slave-driven cotton, sugar, metal and coal industries in the United States,

90) In 1832, when Moses Taylor was twenty-six years old, "he started in the West India
business, for himself and became the chief figure in the great raw sugar trade. ... The rich Cuban
planters, [who were also slave masters], deposited their money with him and left in his care the
reams of United States Government bonds into which they had put their savings."

91) In 1855, Moses Taylor became president of the City Bank, the bank of the merchants of raw
materials. His father had been confidential agent for the old fur trader, John Jacob Astor. City
Bank was the bank of the sugar merchants, the cotton brokers, the metal merchants, the
anthracite coal interests, the leading New York gas companies, and some of the railway
companies of the South and West. It was the bank of Phelps, Dodge and Company, a firm that
imported metal from Britain in exchange for cotton. Moses Taylor was worth $500,000 in 1850.
He was worth fifty million when he died in 1882. By 1925, the Taylor Family was worth more
than $205 million.

92) Charles Stillman was a cotton merchant. Upon information and belief, between 1862 and
1865 Charles Stillman, Richard King, and Mifflin Kenedy "transported Confederate cotton to
Matamoros, [Mexico] under contract for payment in gold. Stillman bought much of the cotton
and sent it to his textile complex at Monterrey, but he sold even more of it in New York through
his mercantile firm, Smith and Dunning. The United States Government was a major purchaser.
On one sale at Manhattan Stillman netted $18,851 on a gross of $21,504. One contract for a
sixmonth period was worth $300,000 in gold. Stillman's cotton buyers in Texas included George
W. Brackenridge, and one of his major suppliers was Thomas William House.

93) By the end of the Civil War, Charles Stillman was one of the richest men in America. He
concentrated his investments in the National City Bank of New York, the successor to the City
Bank of New York, which his son James controlled. Charles supplied Brackenridge with
$200,000 in the 1870s in order to establish the San Antonio National Bank." Charles
Stillman was worth $7 million in 1875.

94) By 1872, 22-year old James Stillman, Charles' son, had made several millions as a member
of the firm of Smith, Woodward and Stillman, cotton commission merchants. He was the largest
stockholder in the National City Bank, and would later became its first chairman. James "took
over and greatly expanded his father's financial and mercantile empire in New York, Texas, and
Mexico, and turned it into the controlling interest in the National City Bank of New York, and
the most powerful force in the development of the Rio Grande valley."

95) James's "Texas holdings included the bonds of sixteen banks; control of land-development
companies in the lower Rio Grande valley, Corpus Christi, and Kerrville; an interest in the
Swenson Ranch; and, with the other three members of the ‘Big Four' - W. H. Harriman, Jacob
Henry Schiff, and William Rockefeller-control of most Texas railroads. The Big Four served as
directors under his chairmanship on the board, put together by Stillman, of the National City
Bank. They controlled the Texas and Pacific, the Southern Pacific, The International-Great
Northern, the Union Pacific Southern, the St. Louis, Brownsville and Mexico, and The Mexican
National, which ran from Corpus Christi to Mexico City and from the St. Louis, Brownsville &
Mexico terminus on the border at Brownsville to the Mexican capital."

96) By 1925, the Stillman Family was worth more than $215 million. Charles Stillman was
closely related, though family and business, to the Rockefellers and Morgans. The Rockefeller
Sisters, who had married into the Stillman Family, were worth $14.5 million each in 1925, and
Percy Avery Rockefeller, who was also affiliated with National City Bank, was worth $70
million.

97) Swante Magnus Swenson was an "entrepreneur, founder of the Sms Ranches, and first
Swedish immigrant to Texas. In 1854 he invested in the Buffalo Bayou, Brazos and Colorado
Railway, which gained him 100,000 acres of land in northwestern and western Texas, and made
him one of the largest landowners [and slave owners] in Texas. ... Acting as an agent for the
Swedish Government, he arranged for the exportation of Texas cotton abroad. ... By 1865
Swenson had gone to New Orleans and set up, a large mercantile business in partnership with
William Perkins; he also purchased a sugar plantation. Later that year he took his family to live
in New York City, where he established the financial house of Swenson Perkins Company. After
dissolving the Perkins partnership, Swenson established the banking house of S. M. Swenson
and Sons, When this business was discontinued, he became a large depositor in the National City
Bank, later the First National City Bank of New York.

98) Citicorp also financed and profited from slave-like practices and conditions, colonialism,
segregation and apartheid, in the United States, Africa and the African Diaspora.

Riggs National Bank

99) George Peabody, founder of the Peabody Institute, met Elisha Riggs of Baltimore. In 1814,
Riggs supplied financial backing to found the wholesale dry goods firm of Peabody, Riggs, and
Company. In 1816, Peabody moved to Baltimore and took offices in Old Congress Hall on
Baltimore and Sharp Streets. Baltimore would be his home for the next 20 years. The thriving
Baltimore business soon established branches in Philadelphia and New York.

100) Seeking still wider business opportunities, George Peabody traveled to England in 1827 to
purchase wares and to negotiate the sale of American cotton in Lancashire, in. 1837, the year
Queen Victoria ascended the throne, he took up residence in London. In 1838, Peabody played
an important role in the rescue of the financial fortunes of the state of Maryland and other states
by his support of their bonds, at a time when the market was flooded with such instruments.
Peabody was able to sell Maryland bonds to Baring Brothers by assuring the company of the
state's good -

101) 1845, Corcoran & Riggs finances the invention of the telegraph by Samuel Morse.
Corcoran & Riggs invests heavily in railroads and land, contributing to the nations push
westward. -

102) 1847, Corcoran & Riggs lends $16 million to the U.S. Government for the Mexican War
and subsequently covers the loan by selling bonds to London financial houses. As the first sale
of American securities in Europe since 1837, this transaction bolsters the credit of all American
bankers.

103) 1865, instead of accepting a charter under the new national bank act, Riggs & Co. remains a
private bank. This decision accounts for the bank's stability in the aftermath of the Civil War.

104) 1868, upon the request of Secretary of State Seward, Riggs & Co. supplies $7.2 million in
gold bullion to the U.S. Government to purchase Alaska from Russia.
http://www.riggsbank:com/Discover Riggs/timeline.html Brown Brothers Harriman & Company

105) Founded in 1818, Defendant Brown Brothers Harriman is the successor to Brown Brothers
& Company, John A. Brown & Company, Alexander Brown & Sons, and Brown, Shipley &
Company.

106) Upon information and belief, the bank founders, James and William Brown, built their
merchant bank by lending to Southern planters, brokering slave grown cotton, acting as a
clearinghouse for the South's complex financial system, arranging cotton shipments form
Southern ports to mills in New England and Britain, loaning millions to planters, merchants and
cotton brokers throughout the South; loaning money to slave masters to purchase slaves;
repossessing and managing slave plantations. Louisiana court records document the
firms ownership in 1840 of 4,614 acres of land and 346 slaves. The Brown Brothers, with offices
located in Boston, Philadelphia, New York, London, financed and exported to England 75% of
the slave-grown cotton. The Brown Family was worth more than $84.8 million in 1925.

107) Donald Murphy, a partner at Brown Brothers Harriman said, "Today's firm has no capital
or earnings connection with the Brown's of the nineteenth century." He further said
that the firm has no pre-Civil War records and sees no need to search for, or through them.


Deutsche Banc AG

108) Deutsche Banc bought the Baltimore firm of Alex. Brown & Sons in 1999 and changed its
name to Deutsche Banc Alex. Brown.

109) Upon information and belief, Alex. Brown took consignments of cotton from so-called
commission merchants, insured them, shipped them to Europe and sold them. They also gave
credit to cotton brokers and other middlemen. One of Brown's sons, John A. Brown, had created
a branch of their bank in Philadelphia in 1818, which a century later would merge with WA
Harriman & Company. George H. Walker, who helped the Harriman's set up their investment
bank, worked for his family, which owned Ely, Walker & Company Dry Goods and Walker.
Textiles, which owned numerous cotton mills, as well as a shirt factory in Post, Texas, later sold
To Burlington Industries. Harriman owned and controlled the Illinois Central Railroad, which
was built, maintained and expanded by slave, and slave-like labor.

110) Deutsche Banc also financed and profited from slave-like practices and conditions,
colonialism, segregation and apartheid, in the United States, Africa and the African Diaspora.


111) Deutsche Banc declined to comment on these allegations.

Lehman Brothers Holdings Inc.

112) Upon information and belief, defendant Lehman Brothers, was founded in 1844, and
quickly became "the largest cotton brokerage firm in Montgomery, Alabama, and as cotton
merchants in New Orleans before the Civil War, with connections to Liverpool and Germany.
King cotton was the cash crop, and the Lehmans accepted it from the local farmers, who were
also slave masters, as currency to settle accounts. The brothers traded the cotton for cash or
merchandise, becoming brokers for buyers and sellers. After Henry's death in 1856, Emanuel and
Mayer resettled in New York, which was the commodity trading center of the United States;
established their brokerage and investment banking firm; and continued trading in cotton, oil,
sugar and coffee. Lehman Brothers took a seat on The New York Stock Exchange in 1887. They
profited from slavery, and from slave-like practices and conditions, including peonage after the
Civil War, through their cotton trade; all of the founders owned slaves; and Emanuel and Mayer
sided with the Confederacy in the Civil War.

113) Lehman Brothers also specialized in Southern reconstruction, notably in the reorganization
of Southern railroads, especially the predecessor lines of the Illinois Central Railroad, which was
by slave labor, and rebuilt by convict-lease labor. Cotton and sugar, slavery and peonage; and
railroads and convict-lease, made Lehman Brothers very rich. They were among America's sixty
wealthiest Families, as compiled by Ferdinand Lundberg in 19 24."

114) For more than a decade, Lehman Brothers has been a pioneer in private prison finance,
brokering major deals between private prison operators, investors and lenders, and the $500
billion United States prison industry. The prison population today, like under slavery,
convict-lease, and the chain-gangs of yesterday, is overwhelmingly African, and poor people of
color. "No other bank is as grossly involved in the private prison industry as Lehman Brothers,"
said Kevin Pranis, co-coordinator of the Not With Our Money! campaign. "Whenever the
industry needs extra capital to finish construction on a prison or wants to repackage their debt,
Lehman Brothers is there."

115) After September 11th, Steve Logan, CEO of Cornell Corrections said, "It's clear that since
September 11 there's a heightened focus on detention... more people are gonna get caught. So I
would say that's positive... with the focus on people that are illegal and also from Middle Eastern
descent in the United States there are over 900,000 undocumented individuals from Middle
Eastern decent... that is a population, for lots of reasons that is being targeted... The Federal
business is the best business for us and... September 11 is increasing that business." The next
month, Lehman Brothers helped Cornell raise another $42 million from investors.

116) Prison Realty Trust, "the Nashville, Tenn.-baed real estate investment trust, which currently
owns 50 correctional facilities in 17 states and the District of Columbia, recently announced the
restructuring of its current $1 billion credit facility with a $1.2 billion new term loan and
revolving credit facility from an investment group that includes Credit Suisse First Boston and
Lehman Brothers. The additional $350 million would be generated from the sale of a new issue
of 12 percent cumulative convertible preferred stock and warrants, primarily to an investment
group led by Fortress Investment Group LLC, affiliates of the Blackstone Group and an Affiliate
of Bank of America Corp." In the past five years, Lehman Brothers was in loaning, or helping to
raise, more than $1.5 billion dollars to finance new prisons in Colorado, Mississippi and Idaho.

117) "Lehman Brothers is the number one financier of the private prison industry," said May Va
Lor, an organizer with Not With Our Money! "Investment banks fund predatory loans, they fund
globalization projects, they do horrible things--just pick one. But no other investment bank is as
involved in the private prison industry as Lehman Brothers is." ... The bank also issues higher
education bonds for many state universities and community colleges, and most of the larger state
pension funds have some fraction of their portfolio with Lehman Brothers Holdings Inc.


118) On Valentine's Day 2002, Not-With-Our-Money, an organizational member of the North
Carolina-based Grassroots Leadership's campaign which targets companies that aid the operating
of prisons for profit, kicked off its "Lehman Brothers Boycott Campaign" on 66 college
campuses last year.

119) In April 2003, Not-With-Our-Money, joined by representatives seven of groups including
the Communications Workers of America, Desis Rising Up and Moving, Fifth Avenue
Committee and the Prison Moratorium Project, asked New York City Comptroller William
Thompson to stop accepting Lehman's issuance of city bonds until the investment bank ceases
work with the private prison industry.

120) Lehman Brothers was also one of the major United States financiers of the racist apartheid
regime in South Africa, and the apartheid debt still strangles any and all progress that has been
made since Nelson Mandela assumed the Presidency in 1994.

121) Upon information and belief, as posted on Lehman's website, in March 1995, "an 18-person
s US and UK delegation from Lehman Brothers, one of the world's leading investment banks,
arrived in South Africa today. Led by Mr. Mel Shaftel, Managing Director and Head of
Investment Banking worldwide, the team plans to meet with its South African clients, including
a number of blue chip local companies, as well as with Government officials in Cape Town and
Johannesburg. The purpose of the visit is to explore opportunities to increase the flow of
investment capital into South Africa and other financial projects. ... Lehman Brothers recently
advised IBM Corporation on its reinvestment in SA, and is also an underwriter and market
maker of South African equities and Rand denominated debt, in addition, the Firm's
Commodities specialists are active in the bullion sector with South African counterparts."


122) Carole Brown, senior vice-president of Lehman Brothers, and chairwoman of the Chicago
Transit Authority, submitted an affidavit to the O-Hare Airport Authority certifying that the
Lehman Brothers "purchased a female slave in 1850, and that they ‘may have personally owned
other slaves.' But, their disclosure firm stresses, ‘There is not evidence that these slaves were
purchased or used by any predecessor entity of Lehman Brothers.' As for Martha, the company
states, ‘Historical records provide no evidence as to what role, if any, Martha played at H.
Lehman & Brothers,' the predecessor firm. ‘But the Lehman Brothers in the 1850s is not the
company that it is today. That's evidenced by my leadership and the fact that they don't condone
violations of fundamental human rights in any form,' Brown said."

123) Lehman Brothers is the only firm, out of the more than 2,000 firms that submitted affidavits
in compliance with the Chicago Slavery Era Disclosure Ordinance, to admit any ties to slavery.
"That means that other firms aren't taking the issue as seriously as we do," Ms. Brown said. "I
don't think it means that we're the only firm that has that part in our history. It just means that we
took it very seriously and we're quick to disclose what we know. What the city chooses to do
with the information is up to the city."

124) Lehman Brothers however, did not comply with the Ordinance in truth, or in full. It failed
to certify that it had "searched any and all records of the Undersigned and any and all
predecessor entities for records of investments or profits from slavery, the slave industry, or
slaveholder insurance policies." In the alternative; if Lehman claims that it did search
said records, including its own website, then it has perjured itself in said affidavit.

THE INSURANCE INDUSTRY DEFENDANT

Society of Lloyds

125) The Society of Lloyds, also known as Lloyd's of London, is a British corporation whose
principal place of business is located at Lime Street, London, EC3M 7HA, UK. It is represented
in the United States by Lloyd's America, Inc. whose principal office is located at 590 5th Ave.,
17th Floor, New York, NY 10036. LLOYDS is represented in Illinois by R. Dean Conlin whose
principal place of business is located at 115 South LaSalle Street Suite 2450, Chicago, IL 60603.
Upon information and belief, Lloyds conducts business with and with the City of Chicago, and
engages in business that affects interstate and foreign commerce.

126) With 71 syndicates underwriting insurance and 5 percent of the world's insurance, Lloyd's
is the world's second largest commercial insurer and sixth largest reinsurance group, providing
insurance services to business and Government s in over 120 countries. Lloyds was and
continues to be at. the center of the shipping and insurance industries.

127) For more than 200 years since its opening in February 1688, Edward Lloyd's Coffee House,
which later became the Society of Lloyds, insured, underwrote, and financed the overwhelming
majority of the documented 27,233 voyages that were involved in the Trans-Atlantic Slave
Trade, including their Outward, Middle and Return Passages.

128) More than any other insurance company, Lloyds was a co-conspirator in, co-responsible
for, and unjustly enriched by the enslavement and transporting of 12 to 15 million Africans to
the Americas, and the murder of more than 1.5 million Africans during the Middle Passage.

129) Agents and insurance companies affiliated with Lloyds also underwrote, insured, and
unjustly enriched by the slave-produced cargoes, especially sugar, tobacco, cotton, rice and rum,
during the Return Passage.

130) Lloyds failed to complete the Chicago Slavery Era Disclosure Ordinance, requiring it to
certify the search of all of its and its predecessor companies records and to disclose profits and
investments from the slavery industry, and the names of all slaves and slave holders associated
with it.

CAUSES OF ACTION

COUNT I -CONSPIRACY

131) Plaintiff on behalf of himself, his Ancestors, all other persons similarly situated, and on
behalf of the general public, re-alleges as if fully set forth, each and every allegation contained in
the preceding paragraphs.

132) As set forth above, Defendants, unlawfully, willfully and knowingly combined, conspired,
confederated, aided and abetted, tacitly and/or expressly agreed to participate in unlawful and
tortuous and terroristic acts pursuant to a common course of conduct, resulting in kidnapping and
dispersion, false imprisonment and enslavement, death and injury, of Plaintiffs and Class
members; Ancestors.

133) As set forth above, Defendants engaged in common, concerted and conspirational acts,
efforts, transactions, and activities designed and intended to wrongfully and unjustly enrich
themselves, their Families, companies, institutions, churches and nations, resulting in the harm to
Plaintiff, Class members, and their Ancestors,, which was done pursuant to and in furtherance of
this common scheme, the 568-year historical and continuing Maafa, which was and is a gross
violation of human rights, and which was and is a crime against humanity.

134) Defendants' concert of action and conspiracy to plan, organize, support and promote the
Maafa were and are a proximate cause of untold injured and damages, pain and suffering, that
Plaintiff, Class members, and their Ancestors, have endured for 568 years, and that continue to
endure today.

135) As a result of Defendants' concert of action and conspiracy to further the Maafa, Plaintiff,
Class members, and their Ancestors, have suffered, and continue to suffer, damages as set forth
herein.

136) WHEREFORE Plaintiff, and Class members, demand judgment in their favor against all
Defendants, jointly, severally, and/or individually, in an amount to be determined by jury trial,
plus interest, costs, and such other monetary, declaratory, injunctive, and equitable relief as this
Court deems appropriate to prevent Defendants from ever again committing these tortuous and
terroristic acts again, or be unjustly enriched by and through them.

COUNT II - FOREIGN SOVEREIGN IMMUNITIES ACT

137) Plaintiff on behalf of himself, his Ancestors and all other persons similarly situated, and on
behalf of the general public, re-alleges as if fully set forth, each and every allegation contained in
the preceding paragraphs,

138) The 568-year historical and continuing Maafa, was and is, at root, commercial activities,
and related set of tortuous and terroristic acts, which were are private activities and acts, not
sovereign, even when conducted under the color of law; and these commercial activities, and
related set of tortuous and terroristic acts, historical and continuing, were and are illegal; were
and are gross violations of the human rights of Plaintiff, Class members, and their Ancestors; and
were and are crimes of aggression and against peace, war crimes and crimes against humanity.

139) Foreign State Defendants, their Instrumentalities and Agencies, their Heads of States,
officials, employees and agents, and their predecessors, as stated herein, Have conducted, and
continue to conduct, in violation of 28 U.S.C. §§ 1605(a)(2), at all relevant times during the
568-year historical and continuing Maafa, the commercial activities, and related tortuous and
terroristic acts, set forth herein, within the United States, and/or tortious and terroristic acts in
connection with commercial activities elsewhere that have caused, and continues to cause, a
direct affect in the United States, and on Plaintiff, Class members, and their Ancestors.

Have taken and/or hold Plaintiff, Class members, and their Ancestors, property, in violation of
28 U.S.C. § 1605(a)(3), and in violation of international law.

Because rights in property in the United States, Africa, the African Diaspora, and the world,
wrongfully and unjustly acquired, in violation of 28 U.S.C. § 1605(a)(4), by succession or gift or
rights in immovable property situated in the United States, Africa, the African Diaspora, and the
world are at issue in this action.

1) Foreign State Defendants, their Instrumentalities and Agencies, their Heads of States,
officials, employees and agents, and their predecessors, as stated herein, by, through and during
their participation in, conspiracy to participate in, aiding and abetting the participation in the
622-year historical and continuing Maafa, and by, through and during the commission of the
commercial activities, tortuous and terroristic acts stated herein, have therefore forfeited their
right to claim immunity pursuant to the "commercial activities exception" of the Foreign
Sovereign Immunities Act 28 U.S.C. §§ 1605(a)(2), (a)(3) and (a)(4).

2) Foreign State Defendants, their Instrumentalities and Agencies, their Heads of States,
officials, employees and agents, and their predecessors, as stated herein, were, and continue to
be, wrongfully and unjustly enriched by and through their historical and continuing participation
in this 568-year Maafa, the African holocaust, which was and is a criminal commercial
enterprise, scheme and course of conduct.

3) The commercial, tortuous and terroristic acts of Foreign State Defendants, their
Instrumentalities and Agencies, their Heads of States, officials, employees and agents, and their
predecessors, were and are, historically and currently, violations of the laws of nature, cannon
law, the law of nations, customary international law, international treaties, agreements and
assurances, and/or the positive and municipal laws of the United States, Europe, the Americas,
and the world; they were and are gross violations of human rights; and they were and are crimes
against humanity, historical and continuing.

4) The actions, historical and continuing, of Foreign State Defendants, their Instrumentalities and
Agencies, their Heads of States, officials, employees and agents, acting individually and/or in
concert to carry out their unlawful and unjust objectives, were and are malicious, outrageous and
in willful, wanton, and reckless disregard of the rights of Plaintiff, Class members, and their
Ancestors. These Foreign State Defendants, their Instrumentalities and Agencies, their Heads of
States, officials, employees and agents, acting individually and jointly, specifically intended to
engage in or otherwise sponsor the commercial, tortuous and terroristic acts and terroristic
activities and acts set forth herein.

5) Foreign State Defendants, their Instrumentalities and Agencies, their Heads of States,
officials, employees and agents, have caused, and continue to cause, directly or indirectly,
contributed to and continue to contribute to, supported and continue to support, conspired to
cause and continue to conspire to cause, aided and abetted and continue to aid and abet, and have
been and are being wrongfully and unjustly enriched by the commission of the commercial,
tortuous and terroristic acts as described above.

6) Defendants, and their predecessors, knew or should have known that their conduct, which was
undertaken in an intentional manner, would lead to injuring, torturing, mutilating, branding,
maiming, raping, castrating, killing, lynching, kidnapping, enslaving, colonizing, segregating,
and discriminating against millions of innocent persons; and leaving untold villages, societies
and Peoples, and at least two continents plundered, pillaged and destroyed; and devastated
untold Families, villages, societies and generations grieving for their losses with extreme, severe,
and permanent physical, psychological and emotional injuries.

7) As a direct and proximate cause of Defendants', and their predecessors', extreme and
outrageous, wrongful and unjust, tortuous and terroristic acts and terroristic, unconscionable and
intentional, reckless and negligent, malicious and willful conduct and acts, and their wholesale
contempt and blatant disregard for human rights and customary international law, Plaintiff, Class
members, and millions of their Ancestors have suffered, continue to suffer, and will suffer
forever into the future extreme and severe, permanent, emotional, mental, psychological,
psychiatric and physical injuries, damages, disorders and traumas, pain and suffering, including,
but not limited to, group and individual anxiety; shock; helplessness; inadequacy; fear for self
and loved ones; fright; apprehension; anger; frustration; sadness; guilt; paranoia; emotional
distress and anxiety; permanent psychological distress; permanent mental injury and impairment,
causing continuing, long-term, and massive expenses for medical services, and counseling and
care; post-traumatic stress, loss of life and life's pleasures, companionship and consortium, loss
of family, career, earnings, and earning capacity; loss of accretion to their estates; and other
items of damages as set forth herein.

8) As a direct and proximate result of their individual and/or joint commercial, tortuous and
terroristic acts, Foreign State Defendants, their Instrumentalities and Agencies, their Heads of
States, officials, employees and agents, and their predecessors, have caused, and continue to
cause, substantial injuries and damages, including emotional distress, anxiety, fear,
apprehension, pain and suffering, as set forth herein; and Plaintiff, and Class members, and are
therefore entitled to the judgement and relief demanded by and through this action.

9) Foreign State Defendants, their Instrumentalities and Agencies, their Heads of States,
officials, employees and agents, are therefore individually, jointly and/or severally liable for
their acts, and for the acts of their predecessors and co-participants, historical and continuing;
and for the substantial injuries and damages, pain and suffering that they, their predecessors, and
co-participants, have caused, and continue to cause to Plaintiff, Class members and their
Ancestors, as set forth herein.

10) WHEREFORE, Plaintiff, and Class members, demand judgment in their favor against all
Defendants, jointly, severally, and/or individually, in an amount to be determined by jury trial,
plus interest, costs, and such other monetary, declaratory, injunctive, and equitable relief as this
Court deems appropriate to prevent Defendants from ever again committing these tortuous and
terroristic acts again, or be unjustly enriched by and through them.

COUNT III: GROSS VIOLATIONS OF HUMAN RIGHTS

11) Plaintiff on behalf of himself, his Ancestors and all other persons similarly situated, and on
behalf of the general public, re-alleges as if fully set forth, each and every allegation contained in
the preceding paragraphs.

12) Defendants, and their predecessors, by, through and during their historical and continuing
participation in the 568-year Maafa, the African holocaust, knowingly, intentionally and grossly
violated Plaintiffs, Class members', and their Ancestors' human rights, including but not limited
to their right to:

"Recognition everywhere as a person before the law."

"Be equal before the courts and tribunals."

"The equal protection of the law."

"Have an effective remedy, notwithstanding that the violation has been committed by persons
acting in an official capacity," and under the color of the law.

"Self-determination;" and our

"Right to return" to, and live in Africa, our ancestral home.

1) These most basic, fundamental and inalienable rights, have been recognized since at least the
Magna Charta, and have been raised to the status of customary international law through
codification Universal Declaration of Human rights, and in Articles 16, 14, 26, 2, 1, and 12
respectively, of the International Covenant on Civil and Political Rights. This Covenant was
ratified by the Senate Committee on Foreign Relations during the 102nd Congress, 2d Session
(1992).

2) Defendants, and their predecessors, knew or should have known that their conduct, which was
undertaken in an intentional manner, would lead to injuring, torturing, mutilating, branding,
maiming, raping, castrating, killing, lynching, kidnapping, enslaving, colonizing, segregating,
and discriminating against millions of innocent persons; and leaving untold villages, societies
and Peoples, and at least two continents plundered, pillaged and destroyed; and devastated
untold Families, villages, societies and generations grieving for their losses with extreme, severe,
and permanent physical, psychological and emotional injuries.

3) As a direct and proximate cause of Defendants', and their predecessors', extreme and
outrageous, wrongful and unjust, tortuous and terroristic acts and terroristic, unconscionable and
intentional, reckless and negligent, malicious and willful conduct and acts, and their wholesale
contempt and blatant disregard for human rights and customary international law, Plaintiff, Class
members, and millions of their Ancestors have suffered, continue to suffer, and will suffer
forever into the future extreme and severe, permanent, emotional, mental, psychological,
psychiatric and physical injuries, damages, disorders and traumas, pain and suffering, including,
but not limited to, group and individual anxiety; shock; helplessness; inadequacy; fear for self
and loved ones; fright; apprehension; anger; frustration; sadness; guilt; paranoia; emotional
distress and anxiety; permanent psychological distress; permanent mental injury and impairment,
causing continuing, long-term, and massive expenses for medical services, and counseling and
care; post-traumatic stress, loss of life and life's pleasures, companionship and consortium, loss
of family, career, earnings, and earning capacity; loss of accretion to their estates; and other
items of damages as set forth herein.

4) WHEREFORE, Plaintiff, and Class members, demand judgment in. their favor against all
Defendants, jointly, severally, and/or individually, in an amount to be determined by jury trial,
plus interest, costs, and such other monetary, declaratory, injunctive, and equitable relief as this
Court deems appropriate to prevent Defendants from everagain committing these tortuous and
terroristic acts again, or be unjustly enriched by and through them.

COUNT IV - CRIMES AGAINST HUMANITY

5) Plaintiff on behalf of himself, his Ancestors and all other persons similarly situated, and on
behalf of the general public, re-alleges as if fully set forth, each and every allegation contained in
the preceding paragraphs.

6) Upon information and belief, the Nurnberg Principles, which were adopted by the
International Law Commission, June-July 1950, declared that:

Principle I. Any person who commits an act which constitute a crime under international law is
responsible therefor and liable to punishment.

Principle II. The fact that international law does not impose a penalty for an act which
constitutes a crime under international law does not relieve the person who committed the act
from responsibility under international law.

Principle III. The fact that a person who committed the act which constitutes a crime under
international law acted as head of State or responsible Government official does not relieve him
from responsibility under international law.

Principle IV. The fact that a person acted pursuant to order of his Government or a superior does
not relieve him from responsibility under international law, provided a moral choice was in fact
possible to him.

Principle V. Any person charged with a crime under international law has the right to a fair trial
on the facts and law.

Principle VI. The crimes hereafter set out are punishable as crimes under international law.

1) These crimes under international law include, but are not limited to (a) the Crime of
Genocide, (b) Crimes against humanity, (c) the Crime of apartheid, (d) War Crimes, and (e) the
Crime of Aggression.

2) Defendants, their predecessors, and co-participants, during, by and through their participation
in the 568year historical and continuing Maafa, have committed and continue to commit, have
conspired and continue to conspire, have aided and abetted and continue to aid and abet, in the
commission of the following and other Crimes against humanity:

Murder - intentional and systematic killing of groups of People.

Extermination - intentional killing of on a large scale directed at members of groups; it includes
depriving People of food or medicine, with the intention of bringing about the destruction of part
of the population.

Enslavement - exercise of the power of ownership over a person; it includes trafficking in
persons, in particular, women and children.

Deportation or Forcible Transfer of Population - forcing People to leave an area in which they
are lawfully present, without grounds permitted under international law; deportation involves
crossing national frontiers and forcible transfers take place within national borders.

Imprisonment or Other Severe Deprivation of Physical Liberty - in violation of fundamental
rules of international law.

Torture and Mutilation - intentionally causing severe physical or mental pain or suffering to a
person in custody or under the control of the accused.

Rape, Sexual Slavery, Enforced Prostitution, Forced Pregnancy, Enforced Sterilization, or any
other form of sexual violence of comparable gravity - rape and other forms of sexual violence
may also constitute other crimes within the ICC's jurisdiction such as torture as a crime against
humanity or a war crime.

Persecution - against any identifiable group or collectivity on political, racial, national, ethnic,
cultural, religious, gender, or other grounds that are universally recognized as impermissible
under international law, in connection with any crime under the Statute - intentional and severe
deprivation of fundamental rights contrary to international law because of the identity of the
group or collectivity and linked to some other act which constitutes a crime against humanity,
war crime or genocide.

Enforced Disappearances - arrest, detention or abduction of persons, by or with the
authorization, consent or acquiescence of a state or political organization, followed by either (1)
a refusal to acknowledge the deprivation of freedom or (2) a refusal to give information on the
fate of "disappeared" persons, with the intention of removing them from the protection of the
law for a prolonged period of time.

Crime of Apartheid - inhumane acts committed in the context of an institutionalized regime of
systematic oppression and domination by one racial group over any other racial group committed
with the intention of maintaining that regime.

Other Inhumane Acts - of similar character intentionally causing great suffering, or serious
injury to body or to mental or physical health - inhumane acts of a similar gravity to other crimes
against humanity.

1) Murder; extennination; deportation or forcible
transfer of population; imprisonment or other severe deprivation of physical liberty;
torture or mutilation; rape, sexual slavery, enforced prostitution, forced
pregnancy, or enforced sterilization; persecution; enforced disappearances;
and other inhumane acts, even though not labeled crimes against humanity prior to the
1940's, were and are illegal, under the laws of nature, the law of nations, customary international
law, and the positive, municipal laws of the United States, the United Kingdom of Great Britain
and Ireland, the Republic of France, the Kingdom of Spain; and under the cannon law of the
Vatican; during and at all times relevant to the Maafa, from 1441 to the present.

2) As set forth herein, the concept of, and acknowledgement that the slave trade and slaver were
and are "crimes against humanity" can be traced to at least the middle of the nineteenth century.
The prohibition of the slave trade and slavery, and its rise to the jus cogen status of customary
international law can be traced to the 12th and 13th centuries.

3) Although the first list of such crimes was made at the end of the First World War, they were
not codified in an international instrument until the Charter of the Nuremberg Tribunal in 1945.
Crimes against humanity as identified in the Nuremberg Charter were recognized as part of
international law by the United Nations General Assembly the following year and were included
in subsequent international instruments, including the Statutes of the International Criminal
Tribunals for the former Yugoslavia and Rwanda. They have now been defined for the first time
in an international treaty when the Rome Statute of the International Criminal Court (Statute)
was adopted on 17 July 1998."

The Trans-Atlantic Slave Trade, slavery, and slave-like practices and conditions was and is
prohibited by a number of international agreements and treaties, including:

The Slavery Convention, 60 L.N.T.S. 253, entered into force March 9, 1927.

The Protocol amending the Slavery Convention, 182 U.N.T.S. 51, entered into force December
7, 1953.

The Supplementary Convention on the Abolition of Slavery, the Slave Trade, and Institutions
and Practices Similar to Slavery, 226 U.N.T.S. 3, entered into force April 30, 1957; The
Convention for the Suppression of the Traffic in Persons and of the Exploitation of the
Prostitution of Others, 96 U.N.T.S. 271, entered into force July 25, 1951.

The United Nations Convention Against Transnational Organized Crime.

The Protocol to Prevent, Suppress and Punish Trafficking in Persons, Especially Women and
Children, Supplementing the United Nations Convention Against Transnational Organized
Crime.

The Protocol Against the Smuggling of Migrants by Land, Sea and Air, Supplementing the
United Nations Convention Against Transnational Crime.

The Convention concerning Forced or Compulsory Labour (ILO No. 29), 39 U.N.T.S. 55,
entered into force May 1, 1932.

The Migration for Employment (Revised) (ILO No. 97), U.N.T.S., entered into force January 22,
1952.

The Equal Renumeration Convention (ILO No. 100), 165 U.N.T.S. 303, entered into force May
23, 1953.

The Abolition of Forced Labour Convention (ILO No. 105), 320 U.N.T.S. 291, entered into
force Jan. 17, 1959.

The Discrimination (Employment and Occupation) Convention (ILO No. 111), 362 U.N.T.S. 31,
entered into force June 15, 1960.

The Employment Policy Convention (ILO No. 122), 569 U.N.T.S. 65, entered into force July 9,
1965.

The Convention concerning the Promotion of Collective Bargaining (ILO No. 154), 1331
U.N.T.S. 267, entered into force Aug. 11, 1983.

The Convention concerning Occupational Safety and Health and the Working Environment (ILO
No. 155), 1331 U.N.T.S. 279, entered into force Aug. 11, 1983.

The International Convention on the Protection of the Rights of All Migrant Workers and
Members of Their Families, G.A. res. 45/158, annex, 45 U.N. GAOR Supp. (No. 49A) at 262,
U.N. Doc. A/45/49, 1990), entered into force 1 July 2003.

The Convention concerning Employment Promotion and Protection against Unemployment (ILO
No. 168), 71 ILO official Bull. 80, entered into force Oct. 17, 1991.

The Convention concerning the Prohibition and Immediate Action for the Elimination of the
Worst Forms of Child Labour (ILO No. 182), 38 I.L.M. 1207, 1999), entered into-force Nov. 19,
2000.

The United Nations High Commissioner For Human Rights Principles and Guidelines on Human
Rights and Trafficking, E/2002/68/Add.l, 2002).

1) Crimes against humanity have evolved to the status of a jus cogens norm which is "accepted
and recognized by the international community of States as a whole as a norm from which no
derogation is permitted and which can be modified only by a subsequent norm of general
international law having the same character."

2) The Restatement (Third) of the Foreign Relations Law asserts "that the norm is established
where there is acceptance and recognition by a ‘large majority' of states, even if over dissent by
‘a very small number of states' (Restatement (Third) of Foreign Relations Law, § 102, and
reporter's note 6, 1986), citing Report of the Proceedings of the Committee of the Whole, May
21, 1968, UN Doc. A/Conf. 39/11 at 471-72)."

3) ___The immoral and criminal refusal of the Defendants, especially the State Defendants
named herein, to acknowledge, ratify, and implement these principals of international law, and
ratify all of the international treaties, declarations, agreements and statutes that recognizes and
protects these inalienable rights and norms, constitutes another gross and continuing violation of
the human rights of Plaintiff, and Class members; another crime against humanity.

4)___The Nurnberg Principles further state, in Article 27, that: (1) "This statute shall apply
equally to all persons without distinction based on official capacity. In particular, official
capacity as a head of State of Government, a member of Government or parliament, an elected
representative or a Government official shall in no case exempt a person from criminal
responsibility under this statute, nor shall it, in and of itself, constitute a ground for reduction of
a sentence. (2) Immunities or special procedural rules which may attach to the official capacity
of a person, whether under national or international law, shall not bar the Court from exercising
its jurisdiction over such a person."

5) Defendants, their predecessors and co-participants, knew, or should have known, that their
conduct, which was undertaken in an intentional manner, would lead to injuring, torturing,
mutilating, branding, maiming, raping, castrating, killing, lynching, kidnapping, enslaving,
colonizing, segregating, and discriminating against millions of innocent persons; and leaving
untold villages, societies and Peoples, and at least two continents plundered, pillaged and
destroyed; and devastated untold Families, villages, societies and generations grieving for their
losses with extreme, severe, and permanent physical, psychological and emotional injuries.

6) As a direct and proximate cause of Defendants', and their predecessors', extreme and
outrageous, wrongful and unjust, tortuous and terroristic acts and terroristic, unconscionable and
intentional, reckless and negligent, malicious and willful conduct and acts, and their wholesale
contempt and blatant disregard for human rights and customary international law, Plaintiff, Class
members, and millions of their Ancestors have suffered, continue to suffer, and will suffer
forever into the future extreme and severe, permanent, emotional, mental, psychological,
psychiatric and physical injuries, damages, disorders and traumas, pain and suffering, including,
but not limited to, gronp and individual anxiety; shock; helplessness; inadequacy; fear for self
and loved ones; fright; apprehension; anger; frustration; sadness; guilt; paranoia; emotional
distress and anxiety; permanent psychological distress; permanent mental injury and impairment,
causing continuing, long-term, and massive expenses for medical services, and counseling and
care; post-traumatic stress, loss of life and life's pleasures, companionship and consortium, loss
of family, career, earnings, and earning capacity; loss of accretion to their estates; and other
items of damages as set forth herein.

7) WHEREFORE, Plaintiff, and Class members, demand judgment in their favor against all
Defendants, jointly, severally, and/or individually, in an amount to be determined by jury trial,
plus interest, costs, and such other monetary, declaratory, injunctive, and equitable relief as this
Court deems appropriate to prevent Defendants from ever again committing these tortuous and
terroristic acts again, or be unjustly enriched by and through them.

COUNT V: CONVERSION

8) Plaintiff on behalf of himself, his Ancestors and all other persons similarly situated, and on
behalf of the general public, re-alleges as if fully set forth, each and every allegation contained in
the preceding paragraphs.

9) Defendants knowingly, wrongfully and unjustly stole, received, converted and continue to
hold property, money, and wealth, tangible and intangible, belonging to Plaintiff, Class
Members, and their Ancestors, including the proceeds from the illicit, immoral and unjust
conduct set forth herein.

10) Defendants, and their predecessors, benefited from, and continue to benefit from the receipt
of said money and riches, tangible and intangible, the benefit of which remains with Defendants.
A trust or equitable lien is impressed upon such money and riches, tangible and intangible, and
the proceeds thereof.

11) Defendants, their predecessors and co-participants, wrongfully and unjustly assumed and
exercised, and continue to assume and exercise, ownership, management and inheritance over;
and who have been, and continue to be wrongfully and unjustly the constructive trustees.

12) Defendants, their predecessors and co-participants, refused to return, and continue to refuse
to return, these illicit and unjust gains to Plaintiff, class members; and have rejected all demand,
and continue to reject, our demand for remedy, restitution, reparations, and repatriation.

13) As a direct and proximate cause of Defendants', and their predecessors', extreme and
outrageous, wrongful and unjust, tortuous and terroristic acts and terroristic, unconscionable and
intentional, reckless and negligent, malicious and willful conduct and acts, and their
wholesale-contempt and blatant disregard for human rights and customary international law,
Plaintiff, Class members, and millions of their Ancestors have suffered, continue to suffer, and
will suffer forever into the future extreme and severe, permanent, emotional, mental,
psychological, psychiatric and physical injuries, damages, disorders and traumas, pain and
suffering, including, but not limited to, group and individual anxiety; shock; helplessness;
inadequacy; fear for self and loved ones; fright; apprehension; anger; frustration; sadness; guilt;
paranoia; emotional distress and anxiety; permanent psychological distress; permanent mental
injury and impairment, causing continuing, long-term, and massive expenses for medical
services, and counseling and care; post-traumatic stress, loss of life and life's pleasures,
companionship and consortium, loss of family, career, earnings, and earning capacity; loss of
accretion to their estates; and other items of damages as set forth herein.

14) WHEREFORE, Plaintiff, and Class members, demand judgment in their favor against all
Defendants, jointly, severally, and/or individually, in an amount to be determined by jury trial,
plus interest, costs, and such other monetary, declaratory, injunctive, and equitable relief as this
Court deems appropriate to prevent Defendants from ever again committing these tortuous and
terroristic acts again, or be unjustly enriched by and through them.

COUNT VI: UNJUST ENRICHMENT

15) Plaintiff on behalf of himself, his Ancestors, all other persons similarly situated, and on
behalf of the general public, re-alleges as if fully set forth, each and every allegation contained in
the preceding paragraphs.

16) Defendants, and their predecessors, have wrongfully and unjustly benefited, and continue to
wrongfully and unjustly benefit from the immoral, inhumane and illegal, 568-year historical and
continuing Maafa.

17) Defendants have failed to account for and/or return to Plaintiff, and Class members, the
value and riches, tangible and intangible, of Plaintiffs, Class members' and their Ancestors',
bodies and lives, labor, products and services; the values and riches wrongfully and unjustly
extorted from their tribes, societies and nations; and/or the profits and benefits derived there
from, during, by and through the 568-year historical and continuing Maafa.

18) Defendants, and their predecessors, have concealed and misrepresented the nature, scale,
scope, magnitude and duration of the participation, and their predecessors' participation in and
wrongful and unjust enrichment from the 568-year historical and continuing Maafa, and its
illegality and immorality.

19) The actions of Defendants, and their predecessors, in relationship to, during, by and through
the Maafa, have resulted in the oppression, exploitation, impoverishment, and disempowerment
of Africa, the African Diaspora, Plaintiff, Class members, and their Ancestors, to the wrongful
and unjust empowerment and enrichment of Defendants, Europe and the Americas.

20) Defendants', and their predecessors', historical and continuing refusal and failure to
acknowledge, apologize for, account and disgorge their odious, illicit and unjust riches and
gains, ahs allowed Defendants, and their Ancestors, to accumulate and retain a immoral, illegal
and unjust gain at the expense of Plaintiff, Class members, and their Ancestors.

21) There is a historical and continuing absence of legal and moral justification for, and a
conspiracy of silence about the oppression, exploitation, impoverishment, and disempowerment
of Africa and African People, Plaintiff, Class members, and their Ancestors, and about the
wrongful and unjust enrichment of Defendants, their predecessors and co-participants, at Africa's
and African Peoples' expense.

22) As a direct and proximate cause of Defendants', and their predecessors', extreme and
outrageous, wrongful and unjust, tortuous and terroristic acts and terroristic, unconscionable and
intentional, reckless and negligent, malicious and willful conduct and acts, and their wholesale
contempt and blatant disregard for human rights and customary international law, Plaintiff, Class
members, and millions of their Ancestors have suffered, continue to suffer, and will suffer
forever into the future extreme and severe, permanent, emotional, mental, psychological,
psychiatric and physical injuries, damages, disorders and traumas, pain and suffering, including,
but not limited to, group and individual anxiety; shock; helplessness; inadequacy; fear for self
and loved ones; fright; apprehension; anger; frustration; sadness; guilt; paranoia; emotional
distress and anxiety; permanent psychological distress; permanent mental injury and impairment,
causing continuing, long-term, and massive expenses for medical services, and counseling and
care; post-traumatic stress, loss of life and life's pleasures, companionship and consortium, loss
of family, career, earnings, and earning capacity; loss of accretion to their estates; and other
items of damages as set forth herein.

23) WHEREFORE, Plaintiff, and Class members, demand judgment in their favor against all
Defendants, jointly, severally, and/or individually, in an amount to be determined by jury trial,
plus interest, costs, and such other monetary, declaratory, injunctive, and equitable relief as this
Court deems appropriate to prevent Defendants from ever again committing these tortuous and
terroristic acts again, or be unjustly enriched by and through them.

COUNT VII: DEMAND FOR AN ACCOUNTING

24) Plaintiff on behalf of himself, his Ancestors, all other persons similarly situated, and on
behalf of the general public, re-alleges as if fully set forth, each and every allegation contained in
the preceding paragraphs.

25) Defendants know or should know, that they, their predecessors and co-participants, created,
were required by law to create, archived and preserved voluminous amounts of corporate,
institutional, church, family and other records, papers, documents and materials, the
overwhelming majority of which still exist today.

26) Numerous catalogues, inventories and/or guides, are now available on the Internet,
especially those materials which have been donated to, or housed by libraries, archives,
museums, and other repositories, some of which are funded by donations from Defendants, their
predecessors and co-participants, and/or numerous Government al agencies and programs.
Plaintiff has examined literally hundreds of these catalogues, inventories and guides, and avers
that they document and will prove, in abundant detail, the legal and factual allegations, and
causes of action set forth herein.

27) Additionally, a wealth of data and information, scholarly research, Government al reports,
media articles, corporate websites, family genealogies are now available to the general public via
the Internet and/or CD-ROMs. Plaintiff has downloaded and scanned tens of thousands of
webpages of material, some of which is summarized herein, which also prove our claims.

28) The United Nations, and other international agencies and programs, especially UNESCO,
have also launched and funded a number of projects to assist states in Africa and the Caribbean
in their efforts to preserve and protect their slave-trade and slavery archives and national
treasures, including slave forts, slave markets, slave ships, etc. Much of this material is also now
accessible through the Internet.

29) Defendants however, continue to lie to, and deceive the public into believing that these
records, this evidence, does not exist, in order to justify their historical and continuing failure
and refusal to acknowledge and accept liability for their crimes; and to justify their historical and
continuing failure and refusal to account for, and disgorge their illicit and unjust gains.

30) Defendants willfully and intentionally refuse to disclose, truthfully and completely, their
participation in, and unjust enrichment by and through the Maafa, even when mandated to do so
by law, as the Chicago Slavery Era Disclosure Ordinance requires them to do.

31) Full disclosure of all corporate, institutional, church and family records and materials
relating to the Maafa, and Defendants, their predecessors and co-participants role in, and
wrongful and unjust enrichment by and through is need, and legally required. These records,
when compared to the other materials as set forth above that are now available, will document
and prove in detail how, when, to where, from where, and by whom Plaintiffs, and Class
members' Ancestors were stolen and enslaved; who was wrongfully and unjustly enriched by and
through this crime, when, how and how much; and how, when, where, and why this illicit and
unjust gains were converted; and who owns and controls this wealth today.

32) Moreover, due to the unique, extraordinary, and horrific nature of the Maafa; the historic and
continuing denial of Our ancestors, and our, most basic and fundamental rights, including, but
not limited to the right to be recognized and treated as equals before the courts of the nation; and
due to the exceptional, blatant and corrupt influence and role of the United States Government,
at all levels and branches, in the commission and cover-up of this crime, Plaintiff "urges the
Court to consider intentional profiting from the Maafa, which was and is a crime against
humanity, especially the slave-trade, slavery, and slave-like practices and conditions, as a ground
for establishing mutuality."

33) WHEREFORE, Plaintiff, and Class members, demand that the Court order, all Defendants to
disclose, truthfully, completely and immediately, a copy, electronic and/or print, of all corporate,
institutional, church, family, Government al or other records, documents and materials that relate
to the causes of action as set forth herein, free of charge; with the understanding that said
materials will deposited with an independent, non-Government al, historical commission, as set
forth herein, which will be based on the historical and majority African colleges and universities
throughout the United States.

COUNT VIII: FREEDOM OF INFORMATION ACT

34) Plaintiff on behalf of himself, his Ancestors and all other persons similarly situated, and on
behalf of the general public, re-alleges as if fully set forth, each and every allegation contained in
the preceding paragraphs.

35) The Maafa, the 568-year historical and continuing African holocaust, was and is a
commercial enterprise, and like all enterprises, legal or illegal, the Maafa was and is highly
regulated, policed and controlled by every branch and level of the United States Government.

36) Voluminous amounts of Government al record were created at all times relevant to this
complaint, archived, and preserved, documenting:

Every aspect of this gross and continuing violation of human rights, this crime under
international law, and detailing its magnitude, scope, scale, and duration, and impact, historical
and continuing.

The complex relationships, legal, human, property, fiduciary, and other, and the full range and
forms of contact between Plaintiff, class members, and their Ancestors, and Defendants, and
their predecessors, during, at each stage in the Maafa's evolution, and at all periods relevant to
this complaint.

The roles that Defendants, their predecessors and co-participants, played, and continue to play, at
every level of the enterprise, scheme and course of conduct; the multiplicity of ways and means
by and through which they were, and continue to be unjustly enriched by it; the amount or value
of that wrongful and unjust enrichment; and when and how it was converted.

1) WHEREFORE, Plaintiff, and Class members, demand that the Court order, pursuant to the
Freedom of Information Act, the United States Government, and the State Governments as set
forth herein, to search all relevant Government archives, repositories and databases; and provide
to Plaintiff, and Class members, a copy, electronic and/or print, of all records, documents and
materials found, free of charge; with the understanding that said materials will deposited with an
independent, non-Government al, historical commission,. as set forth herein, which will be based
on the historical and majority African colleges and universities throughout the United States.

COUNT IX: CHICAGO SLAVERY ERA DISCLOSURE ACT

2) Plaintiff on behalf of himself, his Ancestors and all other persons similarly situated, and on
behalf of the general public, re-alleges as if fully set forth, each and every allegation contained in
the preceding paragraphs.

3) Upon information and belief, the Chicago City Council passed the "Slavery Era Disclosure
Ordinance" -- unanimously -- requiring any and all "companies" under contract to Chicago's
Government to

4) Sign, under penalty of perjury, "A Certification Regarding Slavery Era Business," affirming
that "The Undersigned has searched any and all records of the Undersigned and any and all
predecessor entities for records of investments or profits from slavery, the slave industry, or,
slaveholder insurance policies from the slavery era* (including insurance policies issued to
slaveholders that provided coverage for damage to or injury or death of their slaves) and has
disclosed in this EDS any and all such records to the City. In addition, the Undersigned must
disclose the names of any and all slaves or slaveholders described in those records. Failure to
comply with these disclosure requirements may make the Matter to which this EDS pertains
voidable by the City."

5) Defendants, set forth herein, do business within and with the City of Chicago, and/or its
instrumentalities and agencies, within the meaning of the "Slavery Era Disclosure Ordinance."
Upon information and belief, Defendants have failed to comply, and/or failed to comply
truthfully and fully, with the disclosure requirements of this Ordinance.

6) WHEREFORE, Plaintiff, and Class members, demand, a declaration that Defendants have not
complied in full or in part with the "Slavery Era Disclosure Ordinance;" full disclosure of all
Certifications and the attached information that have been submitted by all companies and/or
business that have complied; an order voiding all existing contracts and business with the City of
Chicago, and putting on hold all future contracts or business, for those companies and/or
businesses, especially the Defendants named in this action, who have failed to comply; and an
order directing the City of Chicago to suspend all business with them until they comply,
truthfully, and in full.

COUNT X: ILLINOIS UDAP

7) Plaintiff on behalf of himself, his Ancestors and all other persons similarly situated, and on
behalf of the general public, re-alleges as if fully set forth, each and every allegation contained in
the preceding paragraphs.

8) in the regular course of the 568-year historical and continuing enterprise, as described herein,
and especially beginning in December 1997, the date the United Nations General Assembly
voted to convene the 3rd World Conference Against Racism in Durban, and March 26, 2002,
that date the Farmer-Paellman vs. Aetna, et al civil action was filed, but at all time relevant to
this complaint, Defendants, and their predecessors, have engaged in, and continue to engage in,
deception, fraud, false pretense, false promise, misrepresentation, and/or the concealment,
suppression and/or material omission of facts, including but not limited to: Covering-up and
concealing their participation in, and wrongful and unjust enrichment by, through and during
568year historical and continuing Maafa, which was and is a criminal enterprise.

Issuing false and misleading reports, releases and statements to the public, the media, and to
domestic and international tribunals, forums and meetings.

Making false statements, misrepresentations, and/or material omissions of facts on their official
Websites.

Conducting false, misleading, deceptive and unfair advertising, marketing, promotional and
public relations campaigns, and other such acts.

1) This conduct, which is set forth herein, constitutes unfair and deceptive acts in violation of
815 ILCS 505/1 and 2.

2) Defendants acted with the intent that others, especially Plaintiff, Class members, and the
general public, rely upon the concealment, suppression and omissions of information set forth
above.

3) Defendants' unfair and deceptive practices occurred in the course of conduct that involves
intrastate and foreign trade and commerce.

4) Defendants' violation of 815 ILCS 505/1 and 2 was done with intent to deceive and to
defraud, and to create a likelihood of confusion and misunderstanding.

5) in making these misrepresentations of fact, with knowledge or reckless disregard of the laws
prohibiting false and misleading statements, Defendants have failed to fulfill their duty to not
omit or misrepresent material facts; have engaged in unlawful business practices; and have
committed acts of untrue and misleading advertising, including but not limited to the
promotional, website, and other public statements set forth in this Complaint.

6) Plaintiff, Class members, and the general public, are consumers within the meaning of Illinois
UDAP § 505/1.

7) Defendants have engaged, and continue to engage, in trade or commerce in Illinois, within the
meaning of Illinois UDAP § 505/1, both in general and by making these continued intentional
misrepresentations.

8) Illegal practices in the conduct or trade or commerce are prohibited the Illinois Consumer
Fraud Act, Illinois UDAP § 505/2, regardless whether any person has in fact been misled,
deceived or damaged.

9) Pursuant to Illinois UDAP § 505/10a, any person who suffers actual damage as a result of a
violation of the Illinois consumer fraud Act committed by any person other person, or any
private attorney general acting in the public interest, may bring an action against such person.
The court may award actual economic damages or any other equitable relief which the court
deems proper, including declaratory and injunctive relief and reasonable attorney fees.

10) Pursuant to Illinois UDAP § 505/2, Plaintiff, Class members, and/or private attorney
generals, need not prove competition between the parties or actual confusion or
misunderstanding.

11) The Continued Misrepresentations and/or concealment, suppression and omission of material
facts were and are a direct, foreseeable, producing, and proximate cause of monetary, economic,
and other damages, including emotional distress, to Plaintiff, Class members, and the general
public, in amounts yet to be determined and, unless enjoined, will continue to cause such damage
to plaintiff, class members, and the general public.

12) WHEREFORE, Plaintiff, and Class members, seek, pursuant to the provisions of Illinois
UDAP, and all applicable laws in all 50 states and the District of Columbia, a decree that
Defendants have engaged in the conduct alleged herein and that such conduct is unlawful and in
violation of 815 ILCS505/2; all actual economic damages and civil penalties for each act, the
amount to be determined at trial; full disclosure of all relevant facts and information which has
been misrepresented, suppressed, concealed or omitted; and injunctive relief prohibiting
Defendants from making the continued intentional misrepresentations, and from continuing to
lie, misrepresent, deceive, conceal, suppress, and omit material facts.

DEMAND FOR JUDGEMENT and RELIEF

13) WHEREFORE, Plaintiff, and Class Members, demand judgement, damages, declaratory and
injunctive relief against Defendants, and their co-participants, jointly, severally and/or in the
alternative as follows: Certify this private attorney general action as a class action pursuant to
Federal Rule of Civil Procedure 23, and designating Plaintiff as the class representative and as a
private attorney general, and counsel for Plaintiff as Class counsel.

Facilitating discovery in this matter, determine and try the common legal and factual issues, and
award Plaintiff damages on each of the causes stated above plus interest, costs, expenses and
such other monetary and equitable relief as this Court deems appropriate.

Declaring that Defendants, and their predecessors, by participating in, conspiring to participate
in, aiding and abetting in the commission of, and/or by being wrongfully and unjustly enriched
by, through and during the 568-year historical and continuing Maafa, the African holocaust,
violated, and continue to violate, the laws of nature, cannon law, the laws of nations and
international law, and international agreements and treaties enforceable in this Court as federal
common law.

Directing Defendants, and their co-participants, to acknowledge and apologize for the role that
they and their predecessors played, and continue to play, in the 568-year historical and
continuing Maafa, the African holocaust; and that they have been and are being wrongfully and
unjustly enriched, at the expense of Africa, Plaintiff, Class members and their Ancestors.

Enjoining Defendants, their co-participants and successors, from ever participating in this or
similar criminal "enterprise's," schemes and courses of conduct again, and from ever causing
similar and other injuries and damages, pain and suffering, to Plaintiff, Class members and their
Heirs again.

Directing Defendants to make truthful, full and timely disclosure of all of their Government al,
church, corporate, institutional, family and other records that reveal any evidence of the
trafficking in and sale of Plaintiffs and Class members' Ancestors, and/or the use of their slave,
convict-lease, slave-like, involuntary, forced and compulsory labor.

Appointing an independent historic commission to serve as an independent, non-Government al,
depository based on historical and majority African universities and colleges, for the aforesaid
records. Imposing a constructive trust in the value of said monies, profits and/or benefits derived
by Defendants, and their predecessors', sale of the Ancestors of Plaintiffs, and Class members,
and for the use of their slave, convict-lease, slave-like, involuntary, forced and compulsory labor.

Declaring all slave markets, auction blocs, slave forts, Plantations, Underground Railroad sites,
cemeteries, etc., national and international treasures and monuments, and deeding the sites to the
independent historic commission for preservation and maintenance.

Direct Defendants to give an accounting of the monies, profits and/or benefits derived by
Defendants', and their predecessors', sale of the Ancestors of Plaintiffs, and Class members, and
for the use of their slave, convict-lease, slave-like, involuntary, forced and compulsory labor.

Order Defendants to make full restitution in the value of all monies, profits and/or benefits
derived by Defendants, and their predecessors', sale of the Ancestors of Plaintiffs, and Class
members, and for the use of their slave, convict-lease, slave-like, involuntary, forced and
compulsory labor,

Order Defendants to equitably disgorge of all said monies, profits, and/or benefits derived by
Defendants', and their predecessors', by, through and during the 568-year historical and
continuing Maafa, the African holocaust,; by and through the sale of human beings, and the use
of their slave, convict-lease, slave-like, involuntary, forced and compulsory labor.

Grant Plaintiff, and Class members a jury trial on all issues so triable.

Award damages at the trial herein, together with interest, exemplary, punitive and/or treble
damages, attorneys fees and costs of this action.

Grant such other and further equity and relief as shall seem just to this Court.

DEMAND FOR JURY TRIAL

1) Plaintiff, and Class members, hereby demand a trial by jury of any and all issues triable of
right by a jury.

Footnotes

1

The term Maafa is taken from Dr. Marimba Ani's book, Yurugu: An African-Centered Critique
of European Cultural Thought and Behavior (1994), Africa World Press. According to Dr. Ani,
"Maafa is a Kiswahili word for ‘disaster' that African People are now using to reclaim our right
to tell our own story. Maafa refers to the enslavement of our people and to the sustained attempt
to dehumanize us." See: To Be Afrikan by Dr. Ani, http:// www.africawithin.com/ani/ani
afrikan.htm.

2

Lawrence Landry, et. al, v. Mayor Richard J. Daley (which declared the City of Chicago's mass
arrest of African students in 1967, illegal); and the Campaign to Cash the Check v. the 1966
Democratic National Convention (which declared the city of Chicago's moratorium on
demonstrations at and during the Democratic National Convention illegal).

3

O'Hare Airport Website. Chicago Slavery Era Disclosure Act.

4

Id.

5

Mark Brown. Daley's tight-lipped on family business. Sun Times. March 18, 2003.

6

Rome Statute of The International Criminal Court. Article 7: Crimes Against Humanity. U.N.
Doc. A/CONF. 183/9 (1998), entered into force July 1,2002. University of Minnesota. Human
Rights Library. http:// wwwl.umn.edu/humanrts/instree/Rome Statute ICC/Rome ICC toc.html.
See also Article 6 of the Nuremberg Charter.

7

Rome Statute.

8

Id.

9

Id.

10

Id.

11

Spitzer, Ryan Michael. Should Europe Pay Reparations to Africa for Colonialism and Slavery?
35 Vandcrbilt Journal of Transnational Law 1313-1346, 1340-1347. October 2002. http://
udayton.edu/race/06hrights/GeoRegions/Africa/Africa04 htm

12

Id.

13

Id.

14

The International Covenant of Political and Civil Rights, Article 16, U.N. Doc. A/810, at
U.N.T.S. (1992).

15

Id. Article 14.

16

Id. Article 2(3)(a).

17

Dred Scott Decision.

18

Keith T. Poole. Dimensions of the Civil War: Largest Land Armies Assembled in History.
American Economic History class at the University of Hawaii.

19

Republican National Convention. Proceedings of the National Republican National Convention,
1860. Page 82. Illinois Historical Digitization Projects. Northern Illinois University Libraries.
2001 The University of Chicago http://lincoln.lib.niu. edu/cgi-bin/getobject ?p.2036:80./
lib35/artfll/databases/sources/IMAGE/

20

Id.

21

Thompson, 149 F. Supp.2d at 60, (quoting Cerbone v. Int'l Ladies Garment Worker's Union, 768
F.2d 45, 48 (2d Cir. 1985).

22

Id.

23

Harris v. Hutchinson, 209 f.3d 325, 330 (4th Cir. 2000) (citing to Alvarez-Machain v. U.S., 107
F.3d 696, 701 (1996), vacated on other grounds, 321 F.3d 604 (9th Cir. 2002), petition for cert.
Filed, 72 USLW 3170 (Sept 2, 2003).

24

Harris, 209 F,3d at 330.

25

Thompson v. Metropolitan Life Ins. Co., 149 F. Supp.2d 38, 54 (S.D.N.Y. 2001) (citing
Connecticut Light & Power Co. v. Secretary of U.S. Dept. of Labor, 85 F.3d 89, 96 (2d Cir.
1996).

26

See Roberts v. Gadsen Memorial Hospital, 835 F.2d 793, 800 (11th Cir. 1988), opinion amended
on rehearing, 850 F.2d 1549 (11th Cir. 1988); Dunn v. Air Line Pilots Ass'n., 836 F. Supp. 1574
(S.D. Fla. 1993).

27

National Railroad Passenger Corporation, Petitioner v. Abner Morgan, Jr. 232 F. 3d 1008,
affirmed in part, reversed in part, and remanded. June 10, 2002.

28

Id.

29

Id.

30

Id.

31

John DOE I, et al., vs. UNOCAL CORP., Union Oil Company of California. Brief of Amici
Curiac International Human Rights Organizations and International Law and Human Rights Law
Scholars in Support of Plaintiffs-Appellants. United States Court of Appeals for the Ninth
Circuit. Page 14. http:/www.cia.ore/proiects/UnocalÄnicisBrmcIFINAL pdf

32

Id. Footnote 11.

33

Id. Page 14.

34

Id. Page 14-15.

35

John DOE I, et al., vs. UNOCAL CORP. Page 17.

36

Id. at pages 17-18.

37

Id. at pages 23-24.

38

Id. at page 27.

39

Id. at page 30.

40

Natalie Wagner. The development of the grave breaches regime and of individual criminal
responsibility by the International Criminal Tribunal for the former Yugoslavia. RICR Juin
IRRC June 2003. Vol. 85 No 850. Page 351.
http://www.icrc.org/Web/eng/siteeng0.nsf/htmall/5PYB3G/$File/irrc 850 Waner.pdf. See also
Kvocka Judgement, op. cit. (note 116), para. 310.

41

Id. "For example, ‘even a lowly guard who pulls the switch to release poisonous gas into the gas
chamber holding hundreds of victims would be more culpable than a supervising guard stationed
at the perimeter of the camp who shoots a prisoner attempting to escape.' Id., para. 311."

42

Id. "Liability is imposed on all persons who had: the intention to take part in a joint criminal
enterprise and to further-individually and jointly- the criminal purposes of that enterprise and
where it is foreseeable that crimes will be committed by other members of the enterprise. Id."

43

Id., para 311-12.

44

Id., para 3.

45

Roger, Edward C. Slavery Illegality in All Ages and Nations. 1855. Page 22.

46

Id.

47

Id.

48

Evidence That Pre-Civil War U.S. Slavery Was Illegal and Unconstitutional. Quoted from
William Godell, Slavery and AntiSlavery, New York. William Harmed, 1852. Page 576.

49

Page 70. Rev. Fee was a leading member of the Abolitionist Movement. See
http://medicolegal.tripod.com/fecasm 1851.htm

50

Id.

51

Id.

52

Vol. I, page 89.

53

Compiled from: Papal Documents; Encyclical and Papal Letters by Pope; Celia Easton. A Brief
History of Slavery; Pat Bartos. Popes and Slavery; Slavery a la Mexicana; Nelissa Snell. Chains:
Slavery in the Middle Ages; Dr. Kwame Nantambu. "question of Apology for Slavery: Global
View; Paul Allard. Slavery and Christianity. The Catholic Encyclopedia, Volume XIV. 1912.
Robert Appleton Company; Rodney Stark. The Truth About the Catholic Church and Slavery.
Christianity Today Magazine. Week of July 14, 2003. This article is an excerpt from his book,
For the Glory of God: How Monotheism Led to Reformations, Science, Witch-hunts, and the
End of Slavery; Slavery in Iberian America. Catholicism and Slavery. 1999 Catholic League for
Religious and Civil Rights; The Catholic Community Forum; and Slavery and the Catholic
Church. A Catholic Response Inc. See also Fr. Joel S, Panzer. The Popes and Slavery. 1996.
Alba House.

54

Timeline Compiled from Numerous Websites.

55

Id.

56

Id.

57

Id.

58

Celia Easton. Brief History of Slavery, note organizer for Humanities 221. Geneseo University.

59

Id.

60

Walter George Smith. Transcribed by Douglas J. Potter. International Law. The Catholic
Encyclopedia, Volume IX. Online Edition Copyright 2003. K. Knight New Advent.
http://www.newadvent.org/cathen/09073a.htm.

61

Slavery in Iberian America. Catholicism and Slavery. 1999 Catholic League for Religious and
Civil Rights.

62

63

Edward C. Roger. Slavery Illegality For All Ages and Nations. 1855.. Page 36.

64

Id.

65

Timeline compiled from a number of Websites..

66

Compiled From Numerous Websites.

67

Karl Heintz Jr. 1802: The Caribbean Sea, Napoleon Restores Slavery. 2003.
http://www.Sakpasse.com.

68

Id.

69

Ann Geracimos. A Mystery in Miniature: Anenigmnatic button once decorated the uniform of
Haitian liberator Toussaint L'Ouverture. Smithsonian Magazine. January 2000.

70

Roger, Edward C. Slavery Illegality in All Ages and Nations. 1855. http://www.xxxxx.xx. Page
38.

71

Id.

72

Id. Page 39.

73

Id.

74

Roger, Edward C. Slavery Illegality in All Ages and Nations. 1855. http://www.xxxxx.xx. Page
40.

75

Id.

76

Id.

77

Id.

78

Black

Experience in America: Chapter 2: The Human Market.
http://www.rit.edu/-nrcgsh/bx/bx02a.htnl.

79

Helen Honor Tuncliff Catteral. Judicial Cases Concerning American Slavery and the Negro. Vol.
1. Cases for the Courts of England, Virginia, West Virginia and Kentucky.

80

English Parliamentary History. XV!, 172. Page 465.

81

Davis. Page 11.

82

Somerset v Stewart Lofft 1-18; 20 Howell's State Trials I, 79-82; 98 Eng Rep 499-510 (King's
Bench, 22 June 1772).

83

Lindsay, Arnett G. "Diplomatic Relations between the United States and Great Britain Bearing
on the Return of NegroSlaves, 1783-1828." Journal of Negro History 5 (October 1920): 391-419.
Dinsmore Documentation. Added April 10, 2003. http://www.dinsdoc.com/lindsay-lhtm

84

Hon. John P. Hand. Negro Slavery In Illinois. Illinois Trails History and Genealogy.
http://www.iltrails.org/.

85

Hon. John P. Hand. Negro Slavery In Illinois. Illinois Trails History and Genealogy. http://www.
iltrails.org/.

86

Id.

87

Leigh Kimmel. Slavery as Practiced by the French in Illinois. The Illinois Trails State Data Page

88

Id.

89

Hon. John P. Hand.

90

Leigh Kimmel. Slavery as Practiced by the French in Illinois. The Illinois Trails State Data Page

91

Hon. John P. Hand.

92

Joe R. Feagin. Documenting the Costs of Slavery, Segregation, and Contemporary
Discrimination: Are Reparations in Order for African Americans?" Working Paper 00-10. Which
was delivered at the Inclusion in Asset Building: Research and Policy Symposium. Center for
social Development. Washington university in St. Louis.

93

Id.

94

Id.

95

Cooper, Thomas. Manchester. 1788.

96

Feagin.

97

Feagin.

98

Feagin.

99

Larsen.

100

Eltis,

101

Id.

102

Miller, Joseph. The Way Of Death: Merchant Capitalism and the Angolan Slave Trade
1730-1830.

103

Larsen.

104

Cooper.

105

Miller. Page 440.

106

Eltis.

107

Id.

108

Curtin, Philip. The AfricanSlave Trade, A Census.

109

Joseph E. Inikori. Forced Migation.

110

Eltis.

111

Francis, Anika. The Economics Of The AfricanSlave Trade.

112

Eltis.

113

Joe R. Feagin. Documenting the Costs of Slavery, Segregation, and Contemporary
Discrimination: Are Reparations in Order for African Americans?" Working Paper 00-10. Which
was delivered at the Inclusion in Asset Building: Research and Policy Symposium. Center for
social Development. Washington university in St. Louis.

114

Id.

115

Id.

116

Feagin.

117

Id.

118

Trans-Atlantic Slave Trade Database and Lloyd's Register Website. http://www.lr.org/corporatc
in formalion/brief hislory.htm.

119

Merseyside Maritime Museum Website.

120

Spain vs. England: The Early History of the Slave Trade.

121

Trans-Atlantic Slave Trade Database.

122

Gerrit Smith. English Involvement in the Slave Trade. http:/ www.britishempire.co.uk

123

Trans-Atlantic Slave Trade Database.

124

Id.

125

American Wealth

126

Sam Nitze. Calif. Film maker focuses on her family's prominence in the slave trade in Bristol.
Journal newspaper. http:// www.tracesoflhetrade.org/library/pro files/02963.html.

127

Id.

128

Id.

129

Id.

130

The Trans-Atlantic Slave Trade Database.

131

American Wealth.

132

The Trans-Atlantic Slave Trade Database.

133

The Cabildo. Antebellum Louisiana: Urban Life. http:// lsm.crt.state.la.us/cabildo/cab9a.htm.

134

135

National Archives.

136

Meyer Weinberg.

137

American Wealth.

138

Id.

139

The United States Supreme Court declared the tobacco industry a monopoly in 1911 and 1946,

140

Slavery Was Illegal and Unconstitutional. Page 39. http://
medicolegal.tripod.com/slaveryillegal.htm

141

Id.

142

Id.

143

Slavery Was Illegal and Unconstitutional. Page 39. http://
medicolegal.tripod.com/slaveryillegal.htm

144

Id.

145

Id.

146

Id.

147

Id.

148

Id.

149

Id.

150

Id.

151

Id.

152

Id.

153

Id.

154

Slavery Was Illegal and Unconstitutional. Page 40. http://
medicolegal.triood.com/slavervillegal.htm

155

Id.

156

Id.

157

Id.

158

The Shirley Plantation Website. 2003. http:// www.shirleyplantation.com/FamilyHistory.html.

159

Andreas, Andrea. "The Untold GU History Professor Explores Racial Issues." Georgetown
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160

Id.

161

Id.

162

National Catholic Reporter.

163

Id.

164

Andreas.

165

Id.

166

Hoovers Online.

167

Id.

168

Dimon Inc. Website.

169

Id.

170

Standard Commercial Website.

171

Washington Post.

172

Moyer, David. MD. The Tobacco Reference Guide. Chapter 29: The tobacco Industry. UICC
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173

Ligget & Meyers Website.

174

Nannie M. Tilley. The RJ Reynolds Tobacco Company. Page 8-12.

175

David Vorcacos. RJ Reynolds, J.P. Morgan Among 12 Sued in AfricanSlave Cases. Bloomberg.
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176

U.S. Smokeless Tobacco Company Website.

177

Snuff" in the U.S.A. http://www.snuffbox.org.uk/abr.htm# us

178

See: Taylor #10. Page 60.

179

Robert F. Datzell Jr. Enterprising Elite: The Boston Associates and the World They Made.
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180

American Economic History: Topic 6. Voteview.uh.edu/topic6.htm

181

Economist, 21 September 1850.

182

The Handbook of Texas Online. Richard King. The Texas State Historical Association.
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183

Murphy Givens. Radio Column for July 19, 2002: King Ranch and King Cotton.
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184

Staple Cotton Association Website.

185

London Economist quoted in Cotton Is King: or, The Culture of Cotton, 1855

186

Dunavant Enterprise Inc. Website. About Us. http:// www.dunavant.com/aboutus.html

187

Cargill Cotton UK Website. http:// www.cargillcottonuk.com/ralli.html.

188

Hohenberg Rites Set. Birmingham News Obituaries. Submitted by Beverly Giles
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189

Avondale Mills Website.

190

Braxton Bragg Coiner Papers Inventory. Manuscript Department. Library of the University of
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191

E. T. Waldron. Prattville Factory Timeline. Revised by Willie Redden & Tommy Brown.

192

Norris Taylor. Notable Carters: Bostwick, Jabez Abel Early Oil Pioneer, Oil Magnate, Joined
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193

Black. Page 3.

194

Black. Page 3 and 4.

195

196

Theodore Kornweibel,

197

198

CN Website. History

199

East St. Louis Action Project. The New Era of Transportation. University of Illinois at
Urbana-Champaign.

200

Cahokia.

201

See Jesse White's Website.

202

Quote Canadian National's Website.

203

Jan McCoy and Donald W. Johnson. The St. Francisville Area, West Feliciana Parish, Louisiana.
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204

Alana A. Carmon. East Feliciana Parish. Center for Cultural and Eco-Tourism. University of
Louisiana at Lafayette.

205

Jim Cox, USA TODAY, Feb 21, 2002.

206

History of Scott County. Information gleaned from Official Website of Forest, Mississippi.
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South: Southern Railroad Management, 1840-1860" Steven G. Collins, St. Louis Community
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207

Id.

208

Ron Collins. Vaiden Mississippi: Back Home Again. 2002. http://
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209

Republican National Convention. Proceedings of the National Republican National Convention,
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210

Guide to the Papers of the Illinois Central Railroad. Newbury Library. Chicago, Illinois.

211

212

See Footnote #40.

213

See Footnote #106.

214

Professor Ted Korweibel of San Diego State University

215

USA Today and CNN. See Footnote #40.

216

CSX Transportation Statement In Response to Lawsuit Filed Seeking Financial Reparations.
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217

218

See Footnote #40.

219

220

Dunavant Enterprises Website.

221

World Business Chicago Website.

222

American Wealth Website.

223

The Mariners' Museum. Captive.Passage: The Trans-Atlantic Slave Trade and the Making of
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224

Britain & the Slave Trade. hutt://www.goacom.com/overseas-digest/History/4slavetrade.html.

225

Id.

226

Barclays Bank - The Sons of robbers & mass murderers still reap the rewards. Justice. May 8,
2003

227

Id.

228

Joan Anim-Addo. Longest Journey: A History of Black Lewisham.

229

Id.

230

South African Press Association. NGO Launches US apartheid. Reparations Law Suit. 12 Nov
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231

Bank of New York Company Inc. Website. The Bank of New York: A History of Distinction.
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232

Timothy J. Gilfoyle. America's Heart. The Atlantic Monthly. Volume 283, No. 2. February 1999.
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233

Id.

234

Id.

235

Bank Of America Buys FleetBoston. Boston, Oct. 27, 2003 and Providence Journal. October 28,
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236

Biographical Directory of the American Congress, 1774-1949, page 900

237

Id.

238

Id

239

Dana Ayoub. New booklet examines R.I. slave trade. Brown Daily Herald. September 4, 2003
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240

Tatsha Robertson and Ross Kerber. History unchained: Delving beyond celebrated abolitionists,
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241

Jay Coughtry. The Notorious Triangle: Rhode Island and the Slave Trade 1700 to 1807. Pages
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242

Biographical Directory of the American Congress, 1774-1949, page 900

243

Id.

244

American Wealth Website. Bankers I: Brown Brothers Bankers.

245

246

Kenneth R. Gosselin. Profits Made at the Cost of Freedom: Beyond Aetna, Others Reaped
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247

James. Cox. FleetBoston: Traced to slave-trading merchant. USA TODAY. February 21, 2002.
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248

Id.

249

Marc D. Weidenmier. Comrades in Bonds: The Subsidized Sale of Confederate War Debt to
British Leaders. Claremont McKenna College and NBER. February 2003.
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250

Timothy J. Gilfoyle. America's Heart, The Atlantic Monthly. Volume 283, No. 2. February 1999.
Pages 95-98. A Review of Edwin G. Burrows and Mike Wallace. GOTHAM: A History of New
York City to 1898

251

James. Cox. FleetBoston: Traced to slave-trading merchant. USA TODAY. February 21, 2002.
http:// www.usatoday.com/money/general/2002/02/21/slave-financiers.htmJames Cox.
FleetBoston: Traced to slave-trading merchant. February 21, 2002.

252

Scripophily.com. http://www.scripoplhily.nel/hecfromleatl.html.

253

South African Press Association. NGO Launches US Apartheid. Law Suit. November 12, 2002.

254

Kevin Moran. Chase Denies Slave-Trade Link. Houston Chronicle, January 21,2003.

255

James Cox. Insurance Firms Issued Slave Policies. USA today. February 21, 2002.

256

Mark Brown. Daley's tight-lipped on family business. Sun times. March 18, 2003.

257

258

American Wealth.

259

Thomas House had become a millionaire by growing cotton, owning ships, and trading in cotton
and slaves. During the war his cotton ships ran the naval blockade from Galveston to Havana
and Belize (fonner British Honduras).

260

The Handbook of Texas Online. Charles Stillman. http:/
www.tsha.utexas.edu/handbook/online/articles/view/SS/fst57.html

261

American Wealth.

262

The Handbook of Texas Online.

263

Id.

264

American Wealth. RAKEN.com

265

Red River Authority of Texas. 2003. http://www.rra.dsLtx.us/c t/people/smSWENSON.cfm.

266

South African Press Association. NGO Launches US apartheid. Reparations Law Suit. 12 Nov
2002

267

James Cox. Brown Bros., Loans Gave Planters Cash To Buy Slaves. USA TODAY. February 21,
2002.

268

Myra. A. Thomas. Reparations Lawsaits: The Target Companies and Why They Were Chosen:
Aetna, CSX, and FleetBoston Named in Lawsuits. NorthStar network. September 30, 2002.

269

James Cox. Brown Bros., Loans Gave Planters Cash To Buy Slaves. USA TODAY. February 21,
2002.

270

Id.

271

Taken from Lehman Brothers Website at http:// www.lehman.com/who/history/indcx.htm, and
from the American Wealth Website at http://www.raken.com/american wealth/bankers gilded
age/Bankers index3.asp.

272

Jews for Racial & Economic Justice. A Passover Picket at Lehman Brothers on March 21 st,
2002.

273

Id.

274

Karen Juanita Carrillo. Locking away profits: Capitalizing on immigrant detentions has turned
into a booming business for Lehman Brothers. Color Lines Magazine September 2002. See also:
Lehman Brothers' For-Profit Prison Deals. Color Lines Magazine. 2002.

275

Id.

276

Karen Juanita Carrillo. Locking away profits:

277

Lehman Brothers Website. Press Release: Leading Investment Bank Visits SA. Johannesburg.
March 6, 1995.

278

Fran Spiclman. Company admits its ties to slavery. Chicago Sun Times. November 24, 2003.

279

Id.

280

City of Chicago. Department of Procurement and Services Website. Economic Disclosure
Statement and Affidavit. Section VI Certification Regarding Slavery Era Business.

281

As codified by the Rome Statute of the International Criminal Court.

282

283

284

285

286

287

288

289

290

291

Amnesty International. The International Criminal Court. Fact Sheet 4: Prosecuting crimes
against humanity. http:// web.amnesty.org/library/index/engior400052000.

292

293

294

295

296

City of Chicago. Economic Disclosure Statement and Affidavit.
http://www.ohare.com/doa/bussin/AttA-EDS.pdf

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