257. 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.

258. Each of the defendants acted individually and in concert with their industry group and with each other, either expressly or tacitly, to participate in a plan that was designed in part to commit the tortious acts referred to herein.

259. For instance, each industry group was co-dependent on the others and operated as a joint enterprise, designed in part, to maintain and continue a system of inhumane servitude.

260. The shipping and railroad industry benefited and profited from the transportation of the slaves. The railroad industry utilized slave labor in the construction of rail lines.

261. These transportation industries were dependent upon the manufacturing and raw materials industries to utilize the slaves they shipped and provide them further profits from shipping the produced raw and manufactured items to the various markets.

262. The cotton, tobacco, rice and sugar industries thrived on profits generated from their use of slave labor, and relied upon financial and insurance industries to finance and insure the slaves that they utilized and owned.

263. All the industries: raw market, retail, financial, insurance, and transportation, benefited from the reduced costs of slave-produced goods.

264. Each of the defendants, acting individually and in concert with their industry group and with each other, agreed, expressly or tacitly, to participate in a plan to establish and maintain the illegal institution of slavery for their own individual and mutual profit and benefit.

265. Each of the defendants agreed, either expressly or tacitly, to participate in the above-cited plan knowing that it would include the following illegal means - kidnapping, forcible transfer of population, torture, murder, rape, imprisonment or other severe deprivation of physical liberty in violation of fundamental rules of international law, enforced pregnancy, intentional infliction of emotional distress, assault and battery.

266. Each of the defendants committed one or more of the following overt acts in furtherance of the plan: Direct and indirect management of plantations; issuing policies insuring the enslaved Africans for the benefit of their owners; direct use of enslaved Africans; leasing of enslaved Africans; providing the necessary financing agreements, which were used to further the scheme; providing the necessities, e.g. clothing, required to maintain enslaved Africans.

267. Plaintiff class and their ancestors were injured by the overt acts as cited above.