"Second Amended Complaint for Injunctive Relief and Damages", 14 Jul 2016

The Former Child Slave Plaintiffs bring this action on behalf of themselves and all other similarly situated former child slaves of Malian origin against Defendants: Nestlé...Cargill...and Archer Daniels Midland...for the forced labor and torture they suffered as a result of the wrongful conduct either caused and/or aided and abetted by these corporate entities. Specifically, the Former Child Slave Plaintiffs assert claims for child slavery/forced labor, cruel, inhumane or degrading treatment, and torture under the Alien Tort Statute (“ATS”)...Plaintiffs demand a trial by jury on all issues so triable. [Also]...respectfully request the Court to: (a) enter judgment in favor of the Plaintiffs on all counts of the Complaint;  (b) award the Plaintiffs compensatory and punitive damages; (c) grant the Plaintiffs equitable relief including, but not limited to, an injunction prohibiting further damage to their persons, remedying past damage, and protecting their rights under customary international law; (d) award Plaintiffs the costs of suit including reasonable attorneys’ fees;...award Plaintiffs such other and further relief as the Court deems just under the circumstances.