Her Majesty’s High Court of Justice (Plaintiffs) collective realleges and incorporates fully set forth all fact’s defendant Judge Charles R. Norgle “knowing and willing” took the Constitutional oath of office On September 10, 1984, defendant Norgle was nominated by President Ronald Reagan to a new seat on the United States District Court for the Northern District of Illinois created by 98 Stat. 333. defendant Judge Charles R. Norgle confirmed by the United States Senate on
October 3, 1984, and
defendant Judge Charles R. Norgle received his commission on October 4, 1984
(Defendants) Confederate State of Mississippi was not in the (Plaintiffs)
United States of America Union Government on or about the dates of September
10, 1984, October 3, 1984, and October 4, 1984
Her Majesty’s High Court
of Justice (Plaintiffs) collective realleges and incorporates fully set forth
all facts Further factual (Defendants) Confederate State of Mississippi was not
in the (Plaintiffs) United States of America Union Government on or about the
dates of March 6th of 1937 defendant Judge Charles R. Norgle “actual vital
birth records defendant Judge Charles R. Norgle born cultivated by white
supremacy under direct international false slavery data scheme in Chicago,
Illinois on or about March 6th of 1937 defendant Judge Charles R. Norgle false
slavery data scheme within (Defendants) U.S. Army from 1955 to 1957,
(Defendants) Confederate State of Mississippi was not in the (Plaintiffs)
United States of America Un`ion Government on or about the dates of 1955 to
1957,
Further factual defendant
Judge Charles R. Norgle cultivated by white supremacy false slavery data scheme
within (Defendants) Northwestern University, where he received a Bachelor of
Business Administration in 1964 Further factual defendant Judge Charles R.
Norgle continue cultivated by white supremacy false slavery data scheme within
(Defendants)John Marshall Law School, where he received his Juris Doctor in
1969, (Defendants) Confederate State of Mississippi was not in the (Plaintiffs)
United States of America Union Government on or about the dates of 1969
including but not limited to
defendant Judge Charles
R. Norglean cultivated by white supremacy while under oath of office assistant
state's attorney of DuPage County, Illinois from 1969 to 1971, and continue the
same defendant Judge Charles R. Norglean cultivated by white supremacy deputy
public defender for DuPage County from 1971 to 1973 defendant Judge Charles R.
Norglean became an associate judge for DuPage County in 1973, and then a
circuit judge from 1977 to 1978, again serving as an associate judge from 1978
to 1981, and as a circuit judge from 1981 to 1984 (Defendants) Confederate
State of Mississippi was not in the (Plaintiffs) United States of America Union
Government on or about the dates of 1971 throughout 1984
Her Majesty’s High Court
of Justice Notwithstanding defendant Judge Charles R. Norgle being accused of
(Conspiracy to Commit an offense against Plaintiffs United States of America
Union government) judicial decrees international mail, wire fraud, submitting
false slavery data against all (Plaintiffs) negro slave’s freedom, ensuring
abuse of power to committing fraud of court judicial decrees records
On or about the dates of
July 14th of 2003 OPINION AND ORDER In re African-American Slave Descendants'
Litigation MDL No. 1491, Lead Case No. 02 C 7764 OPINION AND ORDER CHARLES
NORGLE, United States District Judge
Before the court is
Plaintiffs' Motion to Preserve Evidence. For the following reasons, Plaintiffs'
motion is denied.
I. BACKGROUND
In Plaintiffs'
Consolidated Amended Complaint, Plaintiffs identify themselves as formerly
enslaved African-Americans or descendants of formerly enslaved
African-Americans and seek monetary and injunctive relief against various
corporate institutions, Defendants, for present and past wrongs in connection
with the institution of slavery. Plaintiffs' Consolidated Amended Complaint
tracks the course of early legislation and the passage of the Thirteenth
Amendment to the United States Constitution following the Civil War, at the
conclusion of which, in 1865, half a million people including substantial
numbers of African-Americans had died. Plaintiffs concede that the actual
institution of slavery has formally ended (Pls.' Consolidated Am. Compl. ¶ 46.),
and no party disputes the evils of slavery. One specific remedy Plaintiffs seek
is that Defendants be "compelled to produce documents that reveal crucial
information surrounding the institution of slavery and the economic benefits
that flowed therefrom." (Pls.' Mot. to Preserve Evidence, at 1.)
Plaintiffs have now filed
their Motion to Preserve Evidence. In their motion, Plaintiffs' fail to
specifically identify what documents they are seeking to preserve or what time
frame the document preservation order should encompass. Plaintiffs merely
present an overly broad and vague statement as to the documents that they are
seeking and assert that document preservation is needed.
Plaintiffs primarily base
their need for a document preservation order on two public statements. First, a
Professor at Emory University, William J. Carney, stated that "[a]ny
company that's retaining records that are 100 years old is absolutely insane.
Every company needs to have a regular document retention policy that call [sic]
for regular destruction of documents that are not required any more for
business reasons." William J. Carney, Will American Companies be Forced to
Repay Profits of Slavery. (http://www.knowledge.emory.edu/ss_100902c.html).
Plaintiffs contend that
this statement is in essence telling the Defendants to destroy all of their
documents that might relate to this case. Second, an executive at J.P. Morgan
made a comment on January 21, 2003, which indicated that after searching its
business archives, J.P. Morgan could find no evidence to support the
allegations that it is linked to any slave transactions.
Defendants object to the
entry of any preservation order. Defendants contend that Plaintiffs has failed
to make a sufficient showing that there is a need for a preservation order, and
that the "entry of such an order would suggest that Defendants are guilty
of something that Plaintiffs have shown absolutely no evidence or basis for
suggesting." (Defs.' Resp. Br., at 9.) Defendants have not filed a
counter-motion for document preservation in this instance.
II. DISCUSSION
The court has broad
discretion in determining whether to enter a preservation order. "A motion
to preserve evidence is an injunctive remedy and should issue only upon an
adequate showing that equitable relief is warranted." Madden v. Wyeth,
2003 U.S.Dist. LEXIS 6427 at *2 (N.D. Texas 2003), (citingPepsi-Cola Bottling
Co. of Olean v. Cargill Inc., 1995 U.S.Dist. LEXIS 19735, at *3 (D. Minn. Oct.
20, 1995); Humble Oil Refining Co. v. Harang, 262 F. Supp. 39, 42 (E.D. La.
1996)). The court will look at three factors in determining whether a
preservation order is warranted in this instance: 1) whether Plaintiffs can
demonstrate that Defendants will destroy necessary documentation without a
preservation order; 2) whether Plaintiffs will suffer irreparable harm if a
preservation order is not entered; and 3) the burden imposed upon the parties
by granting a preservation order.
1. Whether Plaintiffs can
demonstrate that Defendants will destroy documentation without a preservation
order.
Plaintiffs fail to
demonstrate that Defendants will destroy any necessary materials related to
this action without a preservation order. Plaintiffs rely on two statements
made by individuals not directly related to the litigation to support their
contention that a preservation order is needed. First, the statement made by
Professor William J. Carney has no bearing on this action whatsoever. Carney's
statements are those of an uninterested third-party and will be given little
weight. Furthermore, Carney's statements merely relate to his opinions on
whether companies should be forced to repay profits for slavery.
Carney further discusses
what a company's normal document preservation policies should entail. Carney in
no way implies that Defendants should destroy documents related to this
litigation, nor can Plaintiffs impute Carney's statements to actions by
Defendants. The mere presence of an article by an uninterested third-party does
not warrant a document preservation order.
Second, Plaintiffs assert
that a statement made by a J.P. Morgan executive warrants a document
preservation order. Again, the court is not persuaded by Plaintiffs' argument.
Although J.P. Morgan is a named defendant in the suit, the statement which
Plaintiffs rely on merely states that upon J.P. Morgan's review of its records,
it has found no evidence connecting it with the slave trade. The statement in
no way connotes that J.P. Morgan or any other Defendant has destroyed or
intends to destroy documents. The statement made by a J.P. Morgan executive
does not warrant a preservation order. Therefore, Plaintiffs have failed to
show that Defendants will destroy documentation without the issuance of a
protective order.
2. Whether Plaintiffs
will suffer irreparable harm if a preservation order is not ordered.
Plaintiffs fail to
demonstrate that they will suffer irreparable harm if a preservation order is
not issued. Defendants have a duty, which they fully acknowledge, not to
destroy documentation relevant to the pending litigation. (Defs.' Resp. Br., at
5.)
Generally, Rules 26
through 37 of the Federal Rules of Civil Procedure govern matters pertaining to
discovery in the federal courts. Rule 26(b), which outlines the scope and
limits of discovery, provides in part:
Unless otherwise limited
by order of the court in accordance with these rules, the scope of discovery is
as follows:
(1) In General. Parties
may obtain discovery regarding any matter, not privileged, that is relevant to
the claim or defense of any party, including the existence, description,
nature, custody, condition, and location of any books, documents, or other
tangible things and the identity and location of persons having knowledge of
any discoverable matter. For good cause, the court may order discovery of any matter
relevant to the subject matter involved in the action. Relevant information
need not be admissible at the trial if the discovery appears reasonably
calculated to lead to the discovery of admissible evidence.
Fed.R.Civ.P. 26(b)(1).
Where there is abuse of
the discovery process, the Federal Rules of Civil Procedure provide for
sanctions. See Fed.R.Civ.P. 37. In cases where a party fails to disclose
information or amend prior discovery responses as required by the rules, the
court may impose appropriate sanctions, including, among other things,
informing the jury of the failure to make such a disclosure. Fed.R.Civ.P.
37(c)(1).
Defendants and Plaintiffs
have a duty to preserve evidence once a lawsuit has commenced. The Seventh
Circuit has stated that parties have an affirmative duty to preserve evidence
which may be relevant to the litigation. Smith Barney. Inc. v. Schell, 53 F.3d
804, 807 (7th Cir. 1995). When a party breaches this duty, sanctions are the
appropriate remedy. See Shepherd v. Am. Broadcasting Co., Inc., 62 F.3d 1469,
1481 (D.C. Cir. 1995) (upholding the district court's order of sanctions where
a party consciously disregarded its obligation to preserve evidence).
Furthermore, by Defendants' attorneys
responding to this motion, all attorneys in this case have acknowledged their
obligation under the rules regarding the preservation of evidence. Defendants
have stated that "[e]ach Defendant herein acknowledges its obligations and
agrees to continue to comply with such obligations under the Federal Rules of
Civil Procedure and the common law." (Defs.' Resp. Br., at 5.) Any
improper conduct by an attorney in this case may be subject to control by Rule
11, and any request for sanctions under Rule 11 will be analyzed in great
detail by this court. See Nisenbaum v. Milwaukee County, No. 02-4296, ___ F.3d
___, 2003 WL 21464590 (7th Cir. June 25, 2003).
3. The burden imposed
upon the parties by granting a preservation order.
Finally, the court finds
that the issuance of a preservation order would impose too immense a burden on
the parties. A review of Plaintiffs' proposed preservation order depicts the
various problems and burdens that would befall the discovery process if placed
on the parties. Plaintiffs are requesting in essence, that Defendants preserve any
and all documents that may relate to the establishment of the company, in past
or present form, and any and all documents that "touch on economic
benefit. . . ." (Pls.' Proposed Order, at 1-2.) To order Defendants, some
of whose business structures have been analogized in size an diversity with
that of the New York Stock Exchange, to retain any and all such documents would
be too burdensome at this stage. (See Bonny v. The Society of Lloyd's. et al.,
3 F.3d 156, 158 n. 2 (7th Cir. 1992).
The Court is well aware
that the entry of a preservation order may interfere with the operations of a
business entity and its enforceability might be difficult without placing heavy
burdens on the parties given the broad allegations against numerous Defendants.
Retention and preservation of records not specifically identified would be
difficult to carry out. The costs of preservation may substantially outweigh
the probability of the relevance of the material sought in the lawsuit. Manual
for Complex Litigation. Third, § 21.442 at 75.
Plaintiffs' overly broad
and vague requests would place a great burden on the Defendants before they can
even test the legal sufficiency of Plaintiffs' Consolidated Amended Complaint.
The Seventh Circuit has noted that "[b]efore the defendant may be put to
the burden of producing evidence, the plaintiff has to show that there is some
ground for suspecting that the defendant has indeed violated the plaintiffs’
rights. Otherwise we would have a regime of precomplaint discovery."
Latimore v. Citibank Fed. Sav. Bank, 151 F.3d 712, 714 (7th Cir. 1998).
Plaintiffs fail to demonstrate that their desire for a preservation order
outweighs the burdens it would impose on Defendants at this stage of the
litigation.
By prior order,
Defendants will answer or otherwise plead to the Consolidated Amended Complaint
on July 18, 2003.
III. CONCLUSION
Given Plaintiffs'
interest in court-compelled preservation and Defendants' acknowledgment of
their obligation to preserve relevant documents, the court concludes that a
document preservation order is unnecessary at this time. The Federal Rules of
Civil Procedure provide sufficient immediate protection for the interest of all
parties. The court is convinced that all of the parties are fully aware of the
consequences that may befall a litigant who destroys relevant documents and
information. "To further embellish the grave importance of document
preservation, through an administratively demanding mechanism, seems
inordinate, at best." In Re Potash Antitrust Litigation, MDL No. 981, 1994
WL 1108312, at *8 (Minn. 1994). Accordingly, Plaintiffs' Motion for
Preservation of Evidence is denied.
IT IS SO ORDERED.
(Plaintiffs) direct cause
of action of criminal fraud acting under color of law overt acts of mail and
wire fraud usage in all judicial ruling propounding to depict correct
“international slavery data” being absolute false statement (RICO) judicial
decrees obstruction of justice of
defendant Judge Charles
R. Norgle committed to the same on (Appeals records) mention herein (Defendant)
EASTERBROOK, Chief Judge, and (Defendant) POSNER and (Defendant) MANION,
Circuit Judges United States Court of Appeals Seventh Circuit further
conspirers to the same false slavery data acting under color of law did so
concealing on or about the dates of (a) throughout (e)
(a) Madden v. Wyeth, 2003 U.S.Dist. LEXIS
6427 at *2 (N.D. Texas 2003), (citingPepsi-Cola Bottling Co. of Olean v.
Cargill Inc., 1995 U.S.Dist. LEXIS 19735, at *3 (D. Minn. Oct. 20, 1995);
Humble Oil Refining Co. v. Harang, 262 F. Supp. 39, 42 (E.D. La. 1996)).
(b) Smith Barney. Inc. v. Schell, 53 F.3d
804, 807 (7th Cir. 1995). When a party breaches this duty, sanctions are the
appropriate remedy.
(c) Shepherd v. Am. Broadcasting Co., Inc.,
62 F.3d 1469, 1481 (D.C. Cir. 1995) (upholding the district court's order of
sanctions where a party consciously disregarded its obligation to preserve
evidence).
(d) Nisenbaum v. Milwaukee County, No.
02-4296, ___ F.3d ___, 2003 WL 21464590 (7th Cir. June 25, 2003).
(e) (See Bonny v. The Society of Lloyd's. et
al., 3 F.3d 156, 158 n. 2 (7th Cir. 1992).
(f) " Latimore v. Citibank Fed. Sav.
Bank, 151 F.3d 712, 714 (7th Cir. 1998).
(g) In Re Potash Antitrust Litigation, MDL
No. 981, 1994 WL 1108312, at *8 (Minn. 1994).
Her Majesty’s High Court
of Justice Accordingly (Defendants) Confederate State of Mississippi was not in
the (Plaintiffs) United States of America Union Government on or about the
dates of said case law (a) throughout (g) submitted by defendant Judge Charles
R. Norgle
Her Majesty’s High Court
of Justice Accordingly Defendant Judge Charles R. Norgle concealing under usage
of judicial decree (Defendants) Confederate State of Mississippi with
(Defendants) the 13th Confederate States of America illegal existences” against
the civil rights of (Plaintiffs) Negro slaves and others similarly the same
Her Majesty’s High Court
of Justice Accordingly Defendant Judge Charles R. Norgle concealing with usage
of “fraudulent judicial decree” committed to “wire fraud scheme” overt acts obstruction
of justice “international false slavery data” (“Defendants”) The Confederate
States of Mississippi America” never ratified 13th amendment not freeing one
single Negro slave’s entire population within their Jurisdiction on or about
the dates of (1861 – Feb. 6th 2013). Citing undersigned council proceeding “Pro
Se” (Hamilton) own federal case *See Case 3:16-mc-00016
13th Amendment being
ratified 2013 7th day February
Her Majesty’s High Court
of Justice On or about the dates of July 14th of 2003 OPINION AND
ORDER In re African-American Slave Descendants' Litigation MDL No. 1491, Lead
Case No. 02 C 7764 OPINION AND ORDER CHARLES NORGLE, United States District
Judge
Defendant Judge Charles
R. Norgle knowing and willing concealing false slavery data mail and wire fraud
scheme under overt acts RICO acting under color of law usage of government
judicial decree, federal employee falsifying material facts (Defendants)
Confederate State of Mississippi international wire fraud scheme including to
continue to occurred On or about the dates of July 14th of 2003
throughout 2013 February 6th within (Plaintiffs) United States of
America Union government since (1865) federal employee falsifying material
facts (Defendants) Confederate State of Mississippi
Her Majesty’s High Court
of Justice On or about the dates of July 14th of 2003 OPINION AND ORDER In re
African-American Slave Descendants' Litigation MDL No. 1491, Lead Case No. 02 C
7764 OPINION AND ORDER CHARLES NORGLE, United States District Judge Defendant
Judge Charles R. Norgle knowing and willing represented false slavery data
against the 13th amendment being ratified and (Plaintiffs) Negro slaves are
being wrongfully classifications as ancestor and descendants have no standing
and forever not entitled to reparation under the falsifying material facts
(Defendants) Confederate State of Mississippi
ratified the 13th amendment of colonial America in the past (1865) which this
legally never physically occurred until in the future year 2013 7th day
Defendant Judge Charles R. Norgle knowing and willing RICO criminal party to
(Defendants) Confederate State of Mississippi joins (Plaintiffs) United States
of America Union government February 7th 2013
Her Majesty’s High Court
of Justice Defendant Judge Charles R. Norgle On or about the dates of July 14th
of 2003 acting under color of law overt acts RICO concealing with usage of
judicial decree (Defendants) Confederate State of Mississippi was not in the
(Plaintiffs) United States of America Union OPINION AND ORDER In re African-American
Slave Descendants' Litigation MDL No. 1491, Lead Case No. 02 C 7764 OPINION AND
ORDER CHARLES NORGLE, United States District Judge
(Conspiracy to Commit an offense against
Plaintiffs the Trans-Atlantic Slave Trade Database) Accordingly, (a)(Defendants)
Confederate State of Mississippi government et al simultaneously white
supremacy agents over the age of (18) he/she was not in the (Plaintiffs) United
States of America Union Government on or about the dates of July 14th
of 2003
Her Majesty’s High Court
of Justice Accordingly On or about the dates of May 22nd 2007 “Chief Defendant”
John Glover Roberts Jr. Chief Justice of the Supreme Court of (Plaintiffs)
United States of America Union government acting under color of law accused of
being white supremacy persons criminal intent producing fraudulent judicial
decrees containing “international false slavery data” (among others herein)
denied “Petition filed by
(Plaintiffs) Deadria
Farmer-Paellman on the material facts presented at issue is whether statues of
limitations should be tolled to permit slave descendants to bring actions for
“Restitution against the
(Defendants) Corporations “that illegally denied that they earned profits
enslaving (Plaintiffs) Negro Slaves “entire populations” in violations of
northern antislavery laws, with the “criminal fraudulent RICO obstruction of
justice hostile dismissal of this actions by
“Chief Defendant” Judge
Charles Ronald Norgle Sr. of the United States District Court for the Northern
District of Illinois of (Plaintiffs) United States of America Union government
acting under color of law accused of being white supremacy persons criminal
intent producing fraudulent judicial decrees containing “international false
slavery data” on the filed March 26th of 2002
18 U.S. Code § 1349 -
Attempt and conspiracy to commit international wire fraud, submitting false
slavery data against all (Plaintiffs) negro slaves’ international freedom
rights as fraudulent claimed by “Chief Defendant United Nations” General
Assembly as Resolution 217 during its third session on 10 December 1948 at the
Palais de Chaillot in Paris, France
Her Majesty’s High Court
of Justice (PLAINTIFFS) collective continue cause of actions for overt acts
(Conspiracy to Commit an offense against Plaintiffs United States of America
Union government) set forth in Count One 18 U.S. Code § 1028A - Aggravated
identity theft of (Plaintiffs) United States of America Union government on the
exact dates of April 15th of 1865 throughout on or about the 6th
day of February 2013 upon all Attempt and conspiracy described herein
(Conspiracy to Commit an offense against Plaintiffs United States of America
Union government) continue their after the dates of 6th of day of February 2013
throughout (December 25th of 2021) attempted to continue cover up these ungodly
epic international crimes against
(Plaintiffs) negro
slave’s international freedom rights as fraudulent claimed by The Universal
Declaration of Human Rights international document adopted by the (Defendant)
United Nations General Assembly that enshrines the rights and freedoms of all
human beings (Exbibit A) mention herein paragraph below
Her Majesty’s High Court of Justice
(Plaintiffs) collective realleges and incorporates fully set forth all facts
(Defendant) United Nations General Assembly enshrines The Universal Declaration
of Human Rights international document was never accepted by the (Defendants)
Confederate State of Mississippi on or about the dates of 10th of December 1948, May 7th of 1999, May 3rd 2001, July 30th of
2010, December 15th of 2010, January 5th 2001, March 26th of 2002, May 22nd of
2007, March 9th of 2011, May 13th of 2011, September 13th of 201, December 2nd
of 2011, March 30th of 2012, April 4th of 2012, involving (Plaintiffs)
collectively and undersigned council of record (Hamilton) Federal Court Case
within said dates mention herein
(Defendants) Confederate
State of Mississippi acting under color of laws (agents) he/she did so Attempt
and conspiracy to commit international wire fraud, scheme including illegally
joining (Plaintiffs) United States of America Union government on or about the
7th day of February 2013 not in past colonial America records of 1865 civil war
aftermath.
CIVIL ACTION # CV 02
1862, CLASS ACTION filed March 26, 2002 Farmer-Paellmann v. Fleetboston
Financial Corp
COMPLAINT AND JURY TRIAL
DEMAND
GARALJHS, Judge
Plaintiffs, on behalf of
themselves and all other persons similarly situated, state, upon information
and belief, as follows:
INTRODUCTION,
JURISDICTION AND VENUE Introduction
1. Over 8,000,000
Africans and their descendants were enslaved in the United States from 1619 to
1865. The practice of slavery constituted an "immoral and inhumane
deprivation of Africans' life, liberty, African citizenship rights, cultural
heritage" and it further deprived them of the fruits of their own labor.
2. The first slave ship
that sailed into Jamestown Harbor in Virginia in 1619 contained a handful of
captive Africans, but by the end of the Atlantic slave trade, more than two
centuries later, somewhere between 8 million and 12 million Africans had
arrived in the New World in chains.
Brent Staples, African
Holocaust, The Lessons of a Graveyard.
3. Historians estimate
that one slave perished for everyone who survived capture in the African
interior and made it alive to the New World, meaning as many as 12 million
perished along the way.
Ira Berlin, "Many
Thousands Gone".
4. Although, it is a common
perception that the South alone received the enslaved Africans, many of them
arrived in the Dutch colonial city of New Amsterdam that later became New York
City. Integral to the colony from the start. slaves helped build Trinity
Church, the streets of the city and the wall, from which Wall Street takes its
name, that protected the colony from military strikes.
Brent Staples, African
Holocaust, The Lessons of a Graveyard.
5. These slaves in New
York lived in attics, hallways and beneath porches, cheek to jowl with their
master and mistresses. In death, these same slaves were banished to the Negro
Burial Ground, which lay a mile outside the city limits and contained between
10,000 and 20,000 bodies by the time it was closed in 1794. Id..
6. Further research conducted by Howard University of 400 skeletons of these buried slaves revealed that 40 percent were children under the age of 15 and the most common cause of death was malnutrition. Most of the children had rickets, scurvy, anemia or related diseases. The adult skeletons show that many people died of unrelenting hard labor. Strain on the muscles and ligaments was so extreme that muscle attachments were commonly ripped away from the skeleton taking chunks of bone with them — leaving the body in perpetual pain.
The highest mortality rate is
found among women ages 15 to 20. Investigators have concluded that some died of
illnesses acquired in the holds of slave ships or from a first exposure to the
cold or from the trauma of being torn from their families and shipped in chains
halfway around the globe. Moreover, the research has concluded that these women
were worked to death by owners who could simply go out and buy a new slave.
Brent Staples, African
Holocaust, Lessons from a Graveyard, quoting in part form Dr. Michael Blakey,
Howard University.
7. But New Yorkers were
not alone in the utilization of slaves, in fact, more recent research has
revealed that many of our esteemed and celebrated institutions of learning had
their origins in the profits derived from the slave trade. For instance, money
from the slave trade financed Yale University's first endowed professorship,
its first endowed scholarships and its first endowed library fund. Moreover, in
the 1830's, Yale officials led the opposition that prevented the building of
the first African American college, on the grounds that such an institution
would have been "incompatible with the existence of Yale". Nicholas
and John Brown, two of the founders of what became Brown University were slave
traders. Likewise. Harvard Law School was endowed by money its founder earned
selling slaves in Antigua's cane fields.
Kate Zernike, "Slave
Trader's in Yale's Past Fuel Debate on Restitution", New York Times
(August 13, 2001).
8. Many early American
industries were based on the cotton, sugar, rice, tobacco, and other products
African labor produced. Railroads and shipping companies, the banking industry
and many other businesses made huge profits from the commerce generated by the
output of enslaved labor.
9. Slaves built the U.S.
Capitol, cast and hoisted the statue of freedom on top of its dome, and cleared
the forest between the Capitol and the White House.
Randall Robinson,
Compensate the Forgotten Victims of America's Slavery Holocaust.
10. Slavery fueled the
prosperity of the young nation. From 1790 to 1860 alone, the U.S. economy
reaped the benefits of as much as $40 million in unpaid labor. Some estimate
the current value of this unpaid labor at 1.4 trillion dollars.
Tim Wise, "Breaking
the Cycle of White Dependency" (5/22/02).
Tamara Audi,
"Payback for Slavery; Growing Push for Reparations Tries to Fulfill Broken
Promise", quoting Randall Robinson (9/18/00).
11. Not only did the
institution of slavery result in the extinguishment of millions of Africans, it
eviscerated whole cultures: languages, religions, mores, and customs, it
psychologically destroyed its victims. It wrenched from them their history,
their memories, and their families on a scale never previously witnessed.
12. When the institution
finally ended, the vestiges, racial inequalities and cultural psychic scars
left a disproportionate number of American slave descendants injured and
heretofore without remedy.
13. Although the
institution of slavery in the United States was officially outlawed in 1865, it
continued, de facto, until as recently as the 1950's. National archive records
reveal that in the 1920's and 1930's, the NAACP still received letters from
African-Americans claiming to still be on plantations and forced to work
without pay. Several claims were investigated and were found to be legitimate.
Moreover, as late as 1954, the Justice Department prosecuted the Dial brothers
in Sumpter County, Alabama because they held blacks in involuntary servitude.
Alistair Highet,
"Will America Pay for the Sins of the Past, Slavery's Past".
(February 14, 2002). The Hartford Adovate, quoting. Dr. Ronald Waters.
14. Even for those who
were "freed", their lives remained locked in quasi-servitude, due to
legal, economic and psychic restraints that effectively blocked their economic,
political and social advancement.Id..
15. Hence, new measures
called "Black Codes" guaranteed control of Blacks by white employers.
As John Hope Franklin noted in From Slavery to Freedom:
the control of blacks by
white employers was about as great as that which slaveholder had exercised.
Blacks who quit their job could be arrested and imprisoned for breach of
contract. They were not allowed to testify in court except in cases involving
members of their own race; numerous fines were imposed for seditious speeches,
insulting gestures or acts, absence from work, violating curfews and the
possession of firearms. There was of course no enfranchisement of blacks and no
indication that in the future they' could look forward to full citizenship and
participation in democracy.
Franklin, John Hope. From
Slavery to Freedom, New York; Knof(1947).
16. The
post-Reconstruction Southern practices of peonage and sharecropping which
continued well into the twentieth century were direct outgrowths of slavery
that continued a system of complete control by the dominant culture. Peonage
was a complex system where a black man would be arrested for
"vagrancy", ordered to pay a fine that he could not afford, and then
incarcerated. A plantation owner would then pay the fine and then hire him
until he could afford to pay off the fine. The peon was forced to work, locked
up at night and if he escaped, was chased by bloodhounds until recaptured.
Yuval Taylor, I was Born
a Slave.
17. Likewise, during the
1920's, fortunate African-Americans became sharecroppers on land leased from
whites whose grandparents had owned their forebearers. These African Americans
were not allowed to vote, and were socially and economically relegated to the
leftovers in education, earnings, and freedoms.
18. More recently, a 1998
census report shows that 26 percent of African American people in the United
States live in poverty compared to 8 percent of whites. It also showed that
14.7 percent of African Americans have four-year college degrees, compared with
25 percent of whites. The same year, African American infant-mortality rates
were more than twice as high as those among whites. Federal figures also show
that a Black person born in 1996 can expect to live, on average, 6.6 fewer
years than a white person born the same year.
19. African-Americans are
more likely to go to jail. to be there longer, and if their crime is eligible,
to receive the death penalty. They lag behind whites according to every social
yardstick: literacy, life expectancy, income and education. They are more
likely to be murdered and less likely to have a father at home.
20. Defendants,
including, but not limited to FLEETBOSTON FINANCIAL CORPORATION, AETNA INC.,
CSX, through their predecessors-in-interest, conspired with slave traders, with
each other and other entities and institutions (whose identities are not yet
specifically identified, but which are described herein as CORPORATE DOES #
1-100) and other un-named entities and/or financial institutions to commit
and/or knowingly facilitate crimes against humanity, and to further illicitly
profit from slave labor.
21. Plaintiffs and the
plaintiff class are slave descendents whose ancestors were forced into slavery
from which the defendants unjustly profited. Plaintiffs seek an accounting,
constructive trust, restitution, disgorgement and compensatory and punitive
damages arising out of Defendants' past and continued wrongful conduct.
JURISDICTION AND VENUE
22. This Court has
jurisdiction over this matter pursuant to 28 U.S.C. § 1332 (a) since the amount
in controversy exceeds $75,000 per plaintiff exclusive of interests and costs
and there is diversity of citizenship.
23. The Court has
personal jurisdiction over the parties in that the defendants conduct
systematic and continuous business within the State of New York.
24. Venue is proper in
this Court since the Defendants do business and may be found in the District
within the meaning of 28 U.S.C. § 1391 (a).
25. Plaintiffs and the plaintiff
class are African-American slave descendents.
26. Plaintiff is a New
York resident whose ancestors were enslaved in the agricultural industry.
DEFENDANTS
27. Defendants and the
other known and unknown defendants used and/or profited from slave labor and
have retained the benefits and use of those profits and products derived from
that slave labor. Defendants knew that the plaintiff class was subject to
physical and mental abuse and inhuman treatment.
28. Defendants conspired
with each other with intentions to violate Plaintiffs' ancestors' basic human
rights from slavery in that and by so doing to profit from these violations.
29. Defendant FLEETBOSTON
is a Delaware corporation with its principal place of business located at 100
Federal Street, Boston, Massachusetts 02110. It does continuous and systematic
business in New York. FLEETBOSTON is the successor in interest to Providence
Bank who was founded by Rhode Island businessman John Brown. Brown owned ships
that embarked on several slaving voyages and Brown was prosecuted in federal
court for participating in the international slave trade after it had become
illegal under federal law. Upon information and belief, Providence Bank lent
substantial sums to Brown, thus financing and profiting from the founder's
illegal slave trading. Upon information and belief, FLEETBOSTON also collected
custom fees due from ships transporting slaves, thus, further profiting from
the slave trade.
30. Defendant CSX is a
Virginia corporation with its principal place of business located at 901 E.
Cary Street, Richmond, VA 23219. It is a successor-in-interest to numerous
predecessor railroad lines that were constructed or run, at least in part, by
slave labor.
Jim Cox, "Rail
Networks Own Lines Bult with Slave Labor" USA TODAY (02/21/02)
31. Defendant AETNA INC.
("AETNA") is a corporation with its principal place of business
located at 151 Farmington Avenue, Hartford, Connecticut 06156. Upon information
and belief, AETNA's predecessor in interest, actually insured slave owners against
the loss of their human chattel. AETNA knew the horrors of slave life as is
evident in a rider through which the company declined to pay the premiums for
slaves who were lynched or worked to death or who committed suicide.
Additionally, AETNA insured enslaved Africans who worked in the agricultural
industry of which Plaintiff's enslaved. AETNA, therefore, unjustly profited
from the institution of slavery.
32. Defendants CORPORATE
DOES NOS. 1-100 are other companies, industrial, manufacturing, financial and
other enterprises that, like the named Defendants, its/their predecessors,
affiliates and/or assigns unjustly profited from slave labor. The designation
CORPORATE DOES NOS. # 1-100 is used until such time as the specific identity of
such additional companies, as they relate to this action, is ascertained
through discovery and/or other means.
CLASS ALLEGATIONS
33. This action is
brought and may properly be maintained as a class action pursuant to the
provision of the Federal Rules of Civil Procedure 23(a), 23(b)(2) and 23(b)(3).
Plaintiffs seek certification of the following class: all African-American
slave descendants.
34. The exact number of
Plaintiff class members is not known. Plaintiffs estimate that the class
includes millions of African-American slave descendants and the Plaintiffs
estimate that the class is so numerous that joinders of individual members is
impracticable. The number and identities of the class members can only be
ascertained through appropriate investigation and discovery.
35. Questions of fact and
law are common with respect to each class member. Common questions of fact and
law include:
a. Whether Defendants
knowingly, intentionally and systematically benefited from the use of enslaved
laborers;
b. Whether Defendants
wrongly converted to their own use and for their own benefit, the slave labor
and services of the Plaintiffs' forebearers. as well as, the products and
profits from such slave labor;
c. Whether the Defendants
knew or should have known that they were assisting and acting as accomplices in
immoral and inhuman deprivation of life and liberty;
d. Whether Defendants
have been unjustly enriched by their wrongful conduct; and
e. Whether, as a result
of this horrific and wrongful conduct by the Defendants, the Plaintiff class is
entitled to restitution or other equitable relief, or to compensatory or
punitive damages.
36. The claims of the
individually named Plaintiffs are typical of the claims of the Plaintiff Class
Members. Plaintiffs and all members of the Plaintiff Class have been similarly
affected by the Defendants common course of conduct and the members of each
class have similar claims against the Defendants. The claims of all class
members depend on a showing of the Defendants' common course of conduct. as described
herein, which gives Plaintiffs, individually and as class representative, the
right to the relief sought herein.
37. There is no conflict
as between Plaintiffs and the other members of the class with respect to this
action or the claims for relief. Plaintiffs know and understand their asserted
rights and their roles as class representatives.
38. Plaintiffs and their
attorneys are able to and will fairly, and adequately, protect the interest of
the Class. Several of Plaintiffs' attorneys are experienced class action
litigators who are or will be able to conduct the proposed litigation.
Plaintiffs' attorneys can vigorously prosecute the rights of the proposed class
members.
39. Prosecution of
separate actions by individual Plaintiffs will create the risk of inconsistent
and varying adjudications and will establish incompatible standards of conduct
for Defendants in that different Courts may order Defendants to provide
different types of accounting or take other inconsistent actions.
40. Prosecutions of separate
actions by individual plaintiffs of other proposed class members not party to
the adjudications will substantially impair or impede their ability to protect
their interest in that, for example, Defendants may exhaust their available
funds in satisfying the claims of earlier plaintiffs to the detriment of later
plaintiffs.
41. Defendants have acted
and/or 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 have been unjustly
enriched by participation in acts that were known to be immoral and inhumane,
and Defendants: (a) prevented and or refused restitution to the proposed class
members, (b) prevented and/or refused to disgorge wrongfully gained and/or
earned profits and benefits, or (c) refused to provide a full and complete
accounting and disclosure of the extent of their aforesaid actions.
42. Common questions of
law and fact predominate in the claims of all class members, including the
named Plaintiff. These claims depend on proving Defendants are liable for their
acts and/or omissions based, in part, on evidence of a common scheme.
Plaintiffs' and the plaintiff class members; proposed evidentiary showings
would be based on the same documents and testimony concerning the Defendants'
actions.
43. A class action is
superior to the other available methods for the fair, just and efficient
adjudication of the controversy. Plaintiffs and the Plaintiff 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/or 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 plaintiffs; 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 nearby
states. The management of the litigation as a class would pose few problems for
this Court.
44. Certification of the
Plaintiff class is appropriate under Fed.R.Civ.P. 23(a) and also under
23(b)(2), 23(b)(3).
EQUITABLE TOLLING
45. The plaintiffs have
been unable to secure records with regards to their ancestors due to the
failure of most to be able to reliably access ship manifestos, or human cargo
lists that directly connect them to their descendants. Moreover, family names
were changed once the Africans arrived in America making it nearly impossible
to accurately trace records. Recent advances in Internet and computer databases
have made these records more accessible to the average African-American.
46. Likewise, corporate
histories and records have also been extremely difficult and inaccessible to
most people. Hence, research tracing the monetary benefit derived by American
corporations from the slave trade has only been accessible and discussed by
prominent researches within the last year.
47. Moreover, efforts to
attempt to raise the issue of reparations for African-Americans in an attempt
to secure easier access to information have stalled in Congress. Representative
John Conyers from Michigan has for the last 11 years attempted to propose a
resolution, No. 40, seeking to set aside $8 million dollars to study the
effects of slavery and come up with a formula for reparations. His resolution
has died in committee for each of these past eleven years.
48. Moreover, with the
advent of litigation related to reparations for holocaust victims from
government entities and corporations, more emphasis has been placed on the
viability of lawsuits for reparations for human rights violations.
49. Finally, the action
of each of the Defendants by their failure to provide an accounting to the
plaintiff constitutes a continuing tort that tolls the statute.
COUNT I — CONSPIRACY
50. 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.
51. For instance, each
industry group was co-dependent on each other and operated as joint enterprise,
designed in part, to maintain and continue a system of inhumane servitude. 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. These transportation industries were dependent upon the
manufacturing and raw materials industry to utilize the slaves they shipped.
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. All
industries: raw market, retail, financial, insurance, and transportation,
benefited from the reduced costs of slave-produced goods.
COUNT II — DEMAND FOR AN
ACCOUNTING
52. Plaintiffs on behalf
of themselves and all other descendants who are similarly situated, re-allege
as if fully set forth, each and every allegation contained into the preceding
paragraphs.
53. The Defendants knew
or should have know of the existence of corporate records that indicate their
profiting from slave labor. Plaintiffs and the public have demanded that the
Defendants reveal their complete corporate records regarding same and that a
just and fair accounting be made for profits derived from the slave trade.
54. Defendants have
failed to provide said records and have failed to comply with plaintiffs'
demand.
WHEREFORE, Plaintiffs
demand judgment: (a) requiring defendants make a full disclosure of all of
their corporate records that reveal any evidence of slave labor or their
profiting from same; (2) seeking the appointment of an independent historic
commission to serve as a depository for corporate records related to slavery
and; (3) directing defendants to account to plaintiffs for any profits they
derived from slavery.
COUNT III — HUMAN RIGHTS
VIOLATIONS
57. Plaintiffs on behalf
of themselves and all other descendants who are similarly situated, re-allege
as if fully set forth, each and every allegation contained into the preceding
paragraphs.
58. The Defendants
participated into the activities of the institution of slavery and in so doing
furthered the commission of crimes against humanity, crimes against peace,
slavery and forced labor, torture, rape, starvation, physical and mental abuse,
summary execution. Specifically, the defendants profited from these wrongs.
59. Defendants knowingly
benefited from a system that enslaved, tortured, starved and exploited human
beings, so as to personally benefit them. In the process, the Defendants
directly or indirectly subjected the plaintiffs' ancestors to inhumane
treatment, physical abuse, torture, starvation, execution and subjected the
plaintiffs to the continued effects of the original acts, including but not
limited to: race discrimination, unequal opportunity, poverty, substandard
health care, substandard treatment, substandard housing, substandard education,
unjust incarceration, racial profiling, and inequitable pay.
60. The above referenced
actions by the Defendants were in violation of international law.
61. As a result of the
above referenced violations of international law, Plaintiffs and members of the
Plaintiff class have suffered injury and are entitled to compensatory damages
in an amount to be determined at trial.
COUNT IV — CONVERSION
62. Plaintiffs on behalf
of themselves and all other slave ancestors who are similarly situated,
re-allege as if fully set forth, each and every allegation contained in the
preceding paragraphs.
63. As a result of
Defendants' failure and refusal to account for, acknowledge and return to
Plaintiffs and the members of the Plaintiff class, the value of their slave
labor, Defendants have willfully and wrongfully misappropriated and converted
the value of that labor and its derivative profits into Defendants' own
property.
64. Defendants have never
accounted for or returned the value of Plaintiffs ancestors' slave labor and
the profits Defendants derived from said slave labor.
65. As a result of
Defendants' wrongful acts and omissions, Plaintiffs and members of the
Plaintiffs' 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, attorney's fees and costs of this
action.
COUNT V — UNJUST
ENRICHMENT
66. Plaintiffs on behalf
of themselves and all other slave descendants who are similarly situated,
re-allege as if fully set forth, each and every allegation contained into the
preceding paragraphs.
67. Defendants have
improperly benefited from the immoral and inhumane institution of Slavery in
the United States.
68. Defendants have
failed to account for and or return to Plaintiffs and the Plaintiff class the
value of their ancestors' slave labor and or the profits and benefits the
Defendants derived therefrom and Defendants have concealed the nature and scope
of their participation in the Institution.
69. As a result of the
Defendants' wrongful acts and omissions as described above, Defendants have
been unjustly enriched.
70. Defendants have been
unjustly enriched at the expense of Plaintiffs and the Plaintiffs' class.
Plaintiffs and the Plaintiffs' class therefore demand restitution and judgment
against the Defendants jointly, severally and/or in the alternative, 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, attorney's fees and the costs of this action.
PRAYER FOR RELIEF
WHEREFORE Plaintiffs and
the Plaintiffs' class demand a jury trial and judgment and damages against the
Defendants, jointly, severally and/or in the alternative, as follows:
(1) For an order
certifying the Plaintiff class alleged herein;
(2) For an accounting;
(3) For the appointment
of an independent historic commission;
(4) For the imposition of
a constructive trust;
(5) For restitution of
the value of their descendants' slave labor;
(6) For restitution of
the value of their unjust enrichment based upon slave labor;
(7) For disgorgement of
illicit profits;
(8) For compensatory damages
in an amount to be determined by trial together with interest;
(9) For exemplary or
punitive damages in an amount to be determined at trial;
(10) For attorneys' fees;
and
(11) For the cost of this
action.
Edward D. Fagan
By:___________________________ EDWARD D. FAGAN, ESQ. (EF-4125) FAGAN ASSOCIATES
301 South Livingston Avenue Livingston, New Jersey 07039 (973) 994-2908
Roger S. Wareham
By:_________________________ ROGER S. WAREHAM, ESQ. (RW 4751) JOMO SANGA
THOMAS, ESQ. (JT 7544) THOMAS WAREHAM RICHARDS 572 Flatbush Avenue, Suite 2
Brooklyn, New York 11225 (718) 941-6407
Subscribed and sworn before Public Notary Public on this _____ day of __________ 2022
_________________________
Public Notary
Respectfully ________________________________________
Estate of Louis Charles Hamilton II Cmdr. US Navy MSS (Pro Se Plaintiff) 2724 61st Street, Suite 1-B17, Galveston, TX 77551
CC: Queen Elizabeth II, Princess Elizabeth Alexandra Mary, Prince William, Duke of Cambridge, KG, KT, PC, ADC (William Arthur Philip Louis) Prince Henry of Wales, KCVO, (Henry Charles Albert David), Prime Minister Boris Johnson The British Embassy, Washington D.C 3100 Massachusetts Ave NW, Washington, DC 20008 forward to files of United Kingdom
CC: International Criminal Court “Honorable Mrs. Fatou Bensouda
#ICC #Honorable #Ms #Fatou #Bensouda #pursuant #to #Nuremberg #Nazi #Criminals #Trials #™Cmdr. #Bluefin
Tina Fey
Prince Harry Windsor
Will Smith
Bill and Hillary Clinton
Megyn Kelly
Cara Delevingne
Samuel L Jackson
Jerry Springer show
Jerry Seinfeld
China Turkey
Israel
North Dakota
British Royal Family
President Barack Obama
United States Navy Seals
Will Ferrell
Derek Zoolander
The View
Jimmy Fallon
Bill Muhar
Fox News Live
BBC World News
Dixie Chicks bitches
Sen. Ted Cruz
NATO
Nobel Prize
ABC NBC CBS
India
Tiwain
Texas
Supreme Court
Sarah Palin
Bristol Palin
Track Palin
Star Trek
Star Wars
It always sunny in Philadelphia
As the world turns
Days of our lives
LA Clippers
British Parliament
Inspector Callahan
David and Charles Koch
Africa
Thailand
Bill Gates Bill Cosby
Cheers
Big Bang Theory
30 Rock
Alec Baldwin
Clint Eastwood
Tom Cruise
Tom Jones
Jimmy Kimmel
Jimmy Carr
Jimmy Hendrix
Japan
Soviet Union
Madonna
Cher
Chris Isaac
Oscar
Conan Congress
Washington DC
Texas
Alaska Air
The Beetles
Johnny Depp
Johnny Cash
Pirates of the Caribbean
Super Mario Bros
Victoria Secret
NASA Space Station
Hogwarts
Kim Kardashian
Jim Carrey
Jim Morrison
Courtney Love
The Who
James Brown
Black Lives Matters
Michael Jackson
Michael Jordan
Cobey Bryant
Olivia Newton John
Track Morgan
United States Marshal
UPS FedEx
PTSD
US Marines
US Army
US Coast Guard
British Royal Navy
Harvard University
Jesus Christ LDS
Pope
Vatican City
Middle East
Hong Kong
Tabitha
Black History
Martin Luther King Jr
Malcolm X
Barnie Sanders
Sen. Ted Cruz
Penelope Cruz
Mission impossible
Days of our lives
Married with children
I Love Lucky
MASH
Dred Scott
Catholics
Jew
Syria
Iran
CBS News
NBC News
ABC News
CNN
Hot News
The Daily Beast
Jebb Bush
Sheldon Cooper
Rushi Barot
Geeta International Inc.
Harry Potter
Harry C. Arthur Esq.
Jesus Christ
Holy Bible
Allah
Samsung Galaxy S3
BBC Radio
BBC Technology
Samsung Galaxy A5
Rick Santorum
Mobile Gallery
Germany
Portugal
France
Italy
Mitsubishi
Toyota
Ford Trucks
Jeep Eagles
Pearl harbor Hawaii
Lady Gaga
Libya
Apple
Bill Gates
Cher
Verizon
At&T
Sprint
Ben Carson dumped
Deep Sea Horizon
Enron
Hezbollah ISIS
Military
British Columbia University
British Columbia
British Vogue
Bill Murray
Stephen Colbert
Stephen Hawking
Boris Johnson
Beijing
Solar panels
Pegasus
Native Americans
Mexico
United States
Apple iPad
Maia Shibutani
California
New York City
New Jersey Shore
Abraham Lincoln
National Geographic
David Beckham
David Cameron
Cameron Diaz
Drew Barrymore
Justin Bieber
Marco Rubio
Eva Longoria
London
King Kong
David Spade
Ben Stiller
Adel
Dallas Cowboys
John Mayer
John Saseen
Iowa
Angela Mcglowan
Rajinder Singh Dhiman
Dr Seuss
Dr Pepper
Dr Piper
Europe
Locheed Martin
Martin Lawrence
Jack Black
Jaguar
BMW
Mariah Carey
Chiang Rai
Baltimore
British India
Jarad Leto
Tom Hanks
Tom Hardy
The Hollywood Reporter
John Lennon
John Kerry
Ash Carter
Republican Party
Russia
Chicago
Kristen Stewart Samuel L Jackson
Kevin Hart
Kevin Durant
Jay Z
Kareem Abdul Jabar
Lakers
NBA
Republican party
Selena Gomez
Will Smith
Thailand
Fox Sports
Charles Barkley
Jerry Springer
Jerry Seinfeld
North Dakota
Hollywood
Oscar
Nobel Prize
British Parliament
Switzerland
Geniva
Paris Hilton
Paris
Donald Trump
Sen Ted Cruz
It's always sunny in Philadelphia
Derek Zoolander
Ben Stiler
Owen Wilson
Jackie Chan
Chris Tucker
Canada
Mexico
Russia
Egypt
Africa
Will Ferrell
Isreal
Saudi Arabia
Morgan Freeman
Spike Lee
AL Sharpton
Tonya Lewis Lee
Donald John Trump Jr.
Rex Marsav
Melissa Whitley
Joe Czyzyk
Linda Adewole
Mitt Romney
United States Veterans Initative
Sen. Orrin Hatch
Sen. Jeff Sessions
Sen. Lindsey Graham
Sen. John Cornyn
Sen. Mike Lee
Sen. Ted Cruz
Sen. Jeff Flake
Sen. David Vitter
Sen. David Perdue
Sen. Thom Tillis
David Duke
Jessie Jackson
NAACP
ACLU
NSA
William McCants
Sigmar Gabriel
Professor Roger Griffin
Ivana Trump
Marla Maples
Ben Carson
Candy Carson
Chris Rock
Vanessa D Gilmore
Willie M Zanders
Karen Wells Roby
Danny Devito
Ray Romano
Amy Poehler
Ashton Kutcher
President Donald Trump
Ellen DeGeneres
Pinky Rose De Chavez
Prince Harry Windsor
Lalisa Manoban
No comments:
Post a Comment