Sunday, July 12, 2020


Article Index


239. Plaintiffs on behalf of themselves, their ancestors and all other descendants who are similarly situated, re-allege as if fully set forth, each and every allegation contained in the preceding paragraphs.

240. As a result of defendants' failure and refusal to account for, acknowledge and return to plaintiffs and the plaintiff class, the value of their ancestors' slave labor, defendants have willfully and wrongfully misappropriated and converted the value of that labor and its derivative profits into defendants' own property.

241. Defendants have never accounted for or returned the value of plaintiffs' ancestors' slave labor and the profits defendants derived from said slave labor.

242. As a result of defendants' wrongful acts and omissions, plaintiffs and the plaintiff class have been injured and demand judgment against the defendants jointly, severally and/or in the alternative on this cause of action for, amongst other things: (a) an accounting of the slave labor monies, profits and/or benefits derived by defendants; (b) a constructive trust in the value of said monies, profits and/or benefits derived by defendants use of slave labor; (c) full restitution in the value of all monies, profits, and/or benefits derived by defendants' use of slave labor; (d) equitable disgorgement of all said monies, profits, and/or benefits derived by defendants' exploitation of slave labor; and (e) other damages in an amount in excess of the jurisdictional limits of this Court and to be determined at the trial herein, together with interest, exemplary or punitive damages, attorneys' fees and costs of this action.


Vernellia R. Randall
Founder and Editor
Professor Emerita of Law
The University of Dayton School of Law