PRAYER FOR RELIEF

WHEREFORE, plaintiffs and the plaintiff class demand judgment against the Defendants, jointly and severally, in an amount to satisfy the jurisdictional limitation of this Court. Plaintiffs request the Court to award punitive sufficient to punish these defendants and deter others from committing similar acts in the future. Additionally, Plaintiffs request the Court to grant the following equitable relief:(1)For an accounting;

(2)For the imposition of a constructive trust;

(3)For restitution of the value of their ancestors' slave labor;

(4)For restitution of the value of Defendants' unjust enrichment based upon slave labor; and

(5)For the cost of this action; and