COMPLAINT

(Jury Trial Requested)

Plaintiffs JOHN MELVIN ALEXANDER et al. allege as follows:

STATEMENT OF JURISDICTION

1. This action arises under the Fourteenth Amendment to the Constitution of the United States; the Civil Rights Act of April 9, 1866, 14 Stat. 27, currently codified at 42 U.S.C. 1981; the Civil Rights Act of April 20, 1871, 17 Stat. 13, currently codified at 42 U.S.C. 1983, 1985(3). Jurisdiction is based on 28 U.S.C. 1331, 1343, and 1367.

HISTORICAL OVERVIEW OF THE CIRCUMSTANCES

THAT PRECIPITATED THIS SUIT

A. Plaintiffs And Defendants

2. Plaintiffs, United States citizens, are the African American survivors of the Riot of May 31, 1921 to June 1, 1921, and/or their descendants who were African American residents of the Greenwood section of the City of Tulsa ( Greenwood ). They bring this suit for restitution and repair of the injuries sustained by them or their relatives from the actions and inaction of the agents of the State Of Oklahoma and the CITY OF TULSA for acts they committed during and in the aftermath of the Riot. Defendants the GOVERNOR OF THE STATE OF OKLAHOMA and the CITY OF TULSA conspired together and acted in concert with one another throughout and after the Riot. The Defendants called out local units of the State National Guard and deputized white citizens of Tulsa, Oklahoma ( Tulsa ), who, acting under color of state law, participated as members of a white mob in a race Riot that was designed to, and did in fact, brutalize and terrorize the African American residents of the Greenwood District. Almost every building in the Greenwood District was razed to the ground.

3. One group of Plaintiffs was forcibly removed from their homes by the white mob that included Defendants lawful agents. That group includes: FRANCES BLACKWELL; NELL HAMILTON HAMPTON; ISHMAEL S. MORAN; JUANITA MAXINE SCOTT PARRY; and JAMES L. STEWARD, who was forced out of his home after the rioting white mob set fire to the building while he and his family were still inside.

4. Other Plaintiffs escaped from the mob only to be captured later by the members of Defendant the City of Tulsa s police force or by the National Guard. They include Plaintiffs JOHN ALEXANDER, JUANITA SMITH BOOKER, KINNEY BOOKER, DOROTHY BOOKER BOULDING, JOHNNIE L. GRAYSON BROWN, JOE R. BURNS, ROSA L. GREEN BYNUM, BEATRICE CAMPBELL-WEBSTER, NAOMI HOOKER CHAMBERLAIN, MILDRED MITCHELL CHRISTOPHER, CARRIE HUMPHREY CUDJOE, LUCILLE BUCHANAN FIGURES, ERNESTINE GIBBS, HAROLD GIBBS, HAZEL FRANKLIN HACKETT, MADELEINE HAYNES, JOYCE WALKER HILL, VERA INGRAM, EUNICE CLOMAN JACKSON, DR. HOBART JARRETT, HAZEL DELORES SMITH JONES, MARY TACOMA MAUPIN, ALICE HIGGS LOLLIS, ISHMAEL S. MORAN, SIMON R. RICHARDSON, BEULAH LOREE KEENAN SMITH, GOLDEN WILLIAMS SMITH, DOROTHY WILSON STRICKLAND, LOIS WHITE TAYLOR, BERTRAM C. WILLIAMS, LOUIE BARTON WILLIAMS, and WESS YOUNG.

5. Other Plaintiffs were forced to flee town completely. They include J.B. BATES, LULA BELLE LACY BULLOCK, JAMES DALE CARTER, who was carried forty miles by his mother, ROSELLA CARTER, OTIS GRANVILLE CLARK, LEROY LEON HATCHER, who walked nine miles to escape the rioting white mob, JOYCE WALKER HILL, EDWARD EARVEN JONES, ELDORIS MAE ECTOR McCONDICHIE, SIMEON L. NEAL, RUTH DEAN NASH, JUANITA MAXINE SCOTT PARRY, IDA BURNS PATTERSO, ALICE PRESLEY, TULETA S. DUNCAN SHAWNEE, BEULAH LOREE KEENAN SMITH, LOLA SNEED SNOWDEN, LOIS WHITE TAYLOR, WILLIE MAE SHELBURN THOMPSON, QUEEN ESTHER LOVE WALKER, who was shot at as she attempted to flee, and MARIE WHITEHORN

6. These and other Plaintiffs had their property looted and burned by the white mob acting under color of state law. They include J.B. BATES, ESSIE LEE JOHNSON BECK, J.D. BELL, PHINES BELL, JUANITA SMITH BOOKER, KINNEY BOOKER, DOROTHY BOOKER BOULDING, JEANETTE McNEAL BRADSHAW, TERESA EARLEE BRIDGES DYSART, JOHNNIE L. GRAYSON BROWN, ROSA L. GREEN BYNUM, MURIEL MIGNON LILLY CABELL, MILDRED MITCHELL CHRISTOPHER, MILDRED LUCAS CLARK, OTIS GRANVILLE CLARK, BLANCHE CHATMAN COLE, CARRIE HUMPHREY CUDJOE, HATTIE LILLY DUNN, JAMES DURANT, LUCILLE BUCHANAN FIGURES, ARCHIE JACKSON FRANKLIN, JIMMIE LILLY FRANKLIN, ERNESTINE GIBBS, HAROLD GIBBS, MARGARET TILLEY GIBBS, THERESSA CORNELLA McNEAL GILLIAM, MILDRED JOHNSON HALL HAZEL FRANKLIN HACKETT, LEROY LEON HATCHER, MADELEINE HAYNES, JOYCE WALKER HILL, DR. OLIVIA J. HOOKER, SAMUEL L. HOOKER, JR., WILHELMINA GUESS HOWELL, VERA INGRAM, GENEVIEVE ELIZABETH TILLMAN JACKSON, DR. HOBART JARRETT, WILMA MITCHELL JOHNSON, HAZEL DELORES SMITH JONES, JULIA BONTON JONES, THELMA KNIGHT, CAROL SMITHERMAN MARTIN, MARY TACOMA MAUPIN, RUTH DEAN NASH, SIMEON L. NEAL, ALMADGE J. NEWKIRK, JUANITA MAXINE SCOTT PARRY, IDA BURNS PATTERSON, DELOIS VADEN RAMSEY, JEWEL SMITHERMAN ROGERS, GERLINE HELEN WRIGHT SAYLES, JULIUS WARREN SCOTT, VENEICE DUNN SIMS, BEULAH LOREE KEENAN SMITH, GOLDEN WILLIAMS SMITH, LOLA SNEED SNOWDEN, JAMES L. STEWARD, DOROTHY WILSON STRICKLAND, LOIS WHITE TAYLOR, WILLIE MAE SHELBURN THOMPSON, EFFIE LEE SPEARS TODD, MELVIN C. TODD, QUEEN ESTHER LOVE WALKER, SAMUEL WALKER, TROY SIDNEY WALKER, and MARY LEON BROWN WATSON.

7. Other Plaintiffs were physically injured. They include CARRIE HUMPHREY CUDJOE, JAMES DURANT, and BEULAH LOREE KEENAN SMITH.

8. Other Plaintiffs had family members who were killed by the rioting white mob. They include J.B. BATES, LEROY LEON HATCHER, and CECIL WHITE.

9. The rioting white mob so terrorized many of the Plaintiffs families, including those of ELDORIS MAE ECTOR McCONDICHIE, ALICE PRESLEY, and WILLIE MAE SHELBURN THOMPSON that they left Tulsa or the State of Oklahoma for good in the wake of the Riot.

10. Many of the Plaintiffs families were denied the opportunity to rebuild their homes and businesses in Greenwood subsequent to the Riot.

11. THE GOVERNOR OF THE STATE OF OKLAHOMA and the TULSA CHIEF OF POLICE are sued in their official capacity because their predecessors in office acted in a manner consistent with the powers accruing to that office. In civil rights lawsuits, it is not the historical person, but the state or municipal institution that is held responsible for the acts of government officials. Because both the individuals occupying the position of Governor of the State of Oklahoma and Chief of Police of Tulsa in 1921 used the official power of their positions to propagate the Riot and empower the rioting white mob, the incumbents of these positions remain responsible for the official acts carried out in the name of the Governor of the State of Oklahoma and the Chief of Police. THE CITY OF TULSA and THE CITY OF TULSA POLICE DEPARTMENT are also sued.

B. Background of the Suit

12. Before the Civil War, Oklahoma was a territory in which African Americans were held in slavery. After the war, African Americans and others migrated to "the territory," seeking economic opportunity. Oklahoma was, in the words of Ralph Ellison, a magnet for many individuals who had found disappointment in the older area of the country, white as well as black, but for Negroes it has a traditional association with freedom which had entered their folklore. Thus the uneducated and educated alike saw Oklahoma as a land of opportunity. ^{^[1]}

13. Yet after Oklahoma gained statehood in 1907, African Americans faced increasing discrimination at the hands of white settlers. The legislature s first bill called for segregation on railroads. The state enacted restrictions on African Americans voting rights and service on juries, and starting in the 1910 s in Oklahoma, but continuing throughout the Jim Crow era,^{^[2]} municipalities promoted gross differentials in funding of white and separate, segregated schools. Twice during the decade of the 1910 s the United States Supreme Court struck down Oklahoma legislation that discriminated on the basis of race: the first was the railroad segregation statute; the second was the grandfather clause in voting registration. The State Of Oklahoma and defendant the CITY OF TULSA, however, persisted in their racial discrimination.^{^[3]}

14. African Americans who violated the etiquette of segregation were subjected to violence at the hands of the white citizenry, on many occasions through the action or inaction of the state. Sometimes that violence took the form of riots, such as an incident in Norman, Oklahoma, a small town that is now the home of the University of Oklahoma. In 1898, a white man employed an African American construction worker. A portion of the white community, including Norman city officials, incensed by the interracial workplace, severely injured the white man for employing an African American.^{^[4]}

15. Also common at the time were what was known as "nigger drives," to remove African Americans from cities. After African Americans were driven out, cities established informal "sun down" laws. They placed notices in prominent places notifying African Americans that they could not remain in the city after dark. For example, in the early 1920s the signs in Norman, Oklahoma, read, "Nigger, don't let the sun go down on you in this town."^{^[5]} At other times, the racial violence led to death by lynching: the Oklahoma State Legislature found that of the 24 individuals lynched in Oklahoma between 1911 and 1921, before 1921, 23 were African Americans.^{^[6]} Months before the Riot, in August 1920, it was clear that the rule of law had broken down in the state. Two men were lynched on the same weekend in Oklahoma: one the only white man lynched during that period was taken from the Tulsa jail and lynched in front of a crowd that included Tulsa police officers;^{^[7]} and the next day an African American man was taken from the Oklahoma City jail and lynched.^{^[8]}

16. The African American community grew increasingly concerned over lynchings. The August 1920 lynchings drove home a particularly important lesson: that no one was safe in the Tulsa jail and that the African American community was likely to be a continuing target of white mob violence. The Tulsa Star, Greenwood s leading newspaper, editorialized about the Oklahoma City lynching that While the boy was in jail . . . there was danger of mob violence. ^{^[9]} The possibility of another lynching was very real to African Americans in the Greenwood District of Tulsa. The Riot, which began on May 31, 1921, and lasted through the night into June 1, 1921, was precipitated by the rumor of just such a lynching.

C. Basis of the Suit

17. On the evening of May 31, 1921, a white mob, many of whom were drunk, gathered in front of the Tulsa jail, and was rumored to be preparing to lynch an African American man accused of attempting to assault a white woman. Some African American men, including World War I veterans, came to the jail to prevent the lynching. During a m l e between some of the white and African American men, shots were fired and all hell broke loose. ^{^[10]} The Mayor of the CITY OF TULSA, acting under color of law, called out local units of the State National Guard and, with the assistance of the police chief of Tulsa, deputized and armed some of the white citizens of Tulsa, many of whom were part of the drunken mob. The deputies were instructed to go get . . . a nigger. ^{^[11]} The deputized white citizens, acting under color of law, terrorized and brutalized the African American residents of Greenwood.

18. In the early hours of the morning of June 1, 1921, local units of the National Guard, along with the white Chief of Police and his deputies, removed the African American residents of Greenwood from their homes. The deputies and the white mob then looted the empty buildings before burning Greenwood to the ground. Defendants harnessed the latest techniques of modern warfare to put down what they considered a Negro Uprising. Defendants or their agents deployed a machine gun to fire on African American residents of Greenwood. Defendants or their agents also used airplanes for reconnaissance of Greenwood. In addition, some eyewitnesses recall that one or more of the airplanes engaged in the attack by shooting at the African American Greenwood residents and dropping one or more incendiary devices. These acts resulted in the mass destruction of property located in Greenwood, as well as the unlawful killing of hundreds of African American residents of Greenwood. In the course of the Riot, Defendants unlawfully detained African American residents of Greenwood, forcing many of them to work in captivity.

19. The Riot, which occurred only sixty years after the end of de jure slavery in 1865, was part of a much larger culture of discrimination against African Americans, which was itself a legacy of slavery. Many of the Riot victims themselves had been slaves. Many whites explained the Riot as the result of increasingly aggressive attitudes of African Americans, who sought social equality following their service in World War I. One African American property-owner was characterized as a man who had come back from the war in France with exaggerated ideas about equality and thinking he can whip the world. ^{^[12]} The role of the Riot in reducing the status of Tulsa s African American community was told by one white newspaper: The white citizens of Tulsa have forgotten the bitter hatred and their desperation that caused them to meet the negroes in battle to the death Tuesday. ^{^[13]} Only once African Americans had been reduced to the status of helpless refugees, could they be seen as objects of charity.^{^[14]}

20. The claim that the Riot was an attempt to restore segregation and hark back to the antebellum past was supported by statements within the African American press as well. The Oklahoma City Black Dispatch observed after the Riot, that:

The old order changeth; no longer is the Negro satisfied or clothed with the placidity of spirit of his slave parents. We black men in Oklahoma know that the legislature of this state tried to deprive us of our franchise when it enacted the 1916 Registration act; we know that such a statute is in conflict with the Constitution of the United States and its interpretation by the Supreme Court. NO LONGER WILL WE BE SATISFIED WITH THE PIG TAILS OF CITIZENSHIP; we want to eat farther up on the body of the hog. ^{^[15]}

21. Other whites linked the Riot to demands for equal treatment by people only recently removed from slavery. One white man wrote in the aftermath of the Riot, that White adventurers trapped him in his native jungle only a few years ago; shipped him in chains to serve the white man in other lands; a stroke of political fortune makes him free and equal to the white man in our country, and he has the consummate gall and impudence to want a place at the council board of the white man s civilization. A white Tulsa paper editorialized after the Riot about the consequences of slavery. If those who invaded the shores of the Dark Continent for the purpose of securing slaves for the southern plantations of America could have foreseen the consequence of their acts it is certain the black man would never have been introduced to the United States.

22. In 1997, in an effort to end the conspiracy of silence ^{^[16]} and to promote a discussion involving the whole community of the CITY OF TULSA and the State Of Oklahoma, The State Of Oklahoma itself commissioned a study to determine liability for the Riot and make recommendations for restitution for the Riot s victims. The resulting body, The Oklahoma Commission to Study the Riot of 1921 ( Commission ), ascertained the causes and consequences of the Riot. The Oklahoma State Legislature accepted those findings,^{^[17]} which linked the Riot to racial violence throughout Oklahoma. The Commission s findings determined that:

The root causes of the Riot reside deep in the history of race relations in Oklahoma and Tulsa which included the enactment of Jim Crow laws, acts of racial violence (not the least of which was the 23 lynchings of African-Americans versus only one white from 1911) against African-Americans in Oklahoma, and other actions that had the effect of putting African-Americans in Oklahoma in their place and to prove to African-Americans that the forces supportive of segregation possessed the power to push down, push out, and push under African-Americans in Oklahoma. ^{^[18]}

23. In the aftermath of the Riot, Defendants the GOVERNOR OF THE STATE OF OKLAHOMA and the CITY OF TULSA impeded the Plaintiffs attempts to rebuild their lives. Defendant the CITY OF TULSA acted quickly to apply zoning restrictions to Greenwood that rendered reconstruction of the destroyed dwellings prohibitively expensive. When the zoning regulations were declared unlawful, Defendant the CITY OF TULSA refused to provide economic compensation or to help the victims, many of whom remained housed in tents through the fall and into the winter of 1921.

24. The State Of Oklahoma and Defendant the CITY OF TULSA acted quickly to suppress talk of the Riot and the survivors attempts to seek legal redress. Efforts to seek relief from the court system were unsuccessful and futile.

25. Because of the Klan s influence throughout the legal system, African American victims of the Riot quickly learned that they could not count on the legal system for restitution.^{^[19]} The Klan, already a feature of Oklahoma life before the Riot, became entrenched at all levels of the Oklahoma establishment in the months and years following the Riot. Despite their best efforts to use the court system, African Americans were subjected to discriminatory decision making rather than justice. For example, a grand jury called to determine the causes of the Riot issued indictments against a large number of African Americans. Fearing this many of them fled town. Defendant the CITY OF TULSA also refused to pay any restitution to the African American survivors of the Riot: the only restitution paid was to white gun-shop owners whose business had been looted. While some African Americans filed lawsuits at the time, over 100 of them were dismissed before even receiving a hearing in the State Of Oklahoma s courts.^{^[20]} Of the two cases that were heard by the Court, one, filed by Mabel Allen, was dismissed before the jury deliberated,^{^[21]} and the Oklahoma Supreme Court dismissed the other on appeal.^{^[22]}

26. Legal redress was also stymied by Oklahoma common law doctrine which unconstitutionally limited municipal liability.^{^[23]} Precedent applied from Oklahoma s Territorial Court made it difficult, if not impossible, for Riot victims to sustain a claim against the CITY OF TULSA or its actors absent ratification by the City Council.^{^[24]}

27. The legislature of the State Of Oklahoma adopted many of the Commission s findings by statute in 2001 and made specific reference to the conspiracy of silence surrounding the events in Tulsa of May 31-June 1, 1921, and their aftermath. ^{^[25]} According to the legislature:

Perhaps the most repugnant fact regarding the history of the 1921 Riot is that it was virtually forgotten, with the notable exception of those who witnessed it on both sides, for seventy-five (75) years. This conspiracy of silence served the dominant interests of the state during that period which found the riot a public relations nightmare that was best to be forgotten, something to be swept well beneath history s carpet for a community which attempted to attract new businesses and settlers. ^{^[26]}

28. In 1997, in an effort to end the conspiracy of silence ^{^[27]} and to promote a discussion involving the whole community of the CITY OF TULSA and the State Of Oklahoma, the State Of Oklahoma created the Oklahoma Commission to Study the Riot of 1921. The Commission was designed to make whole a fractured community still suffering from the legacy of silence surrounding the Riots. Specifically, the Commission was charged with:

undertak[ing] a study to develop a historical record of the 1921 Riot including the identification of [any] person[ ] who:

1. was an actual resident of the Greenwood area or community of the City of Tulsa on or about May 31, 1921, or June 1, 1921; or

2. sustained an identifiable loss to their person, personal relations, real property, personal property or other loss as a result of . . . the 1921 Riot. ^{^[28]}

29. The Commission was empowered to produce a written report of its findings and recommendations [for the Oklahoma legislature] . . . contain[ing] specific recommendations regarding whether or not reparations can or should be made and the appropriate methods to achieve the recommendations made in the final report, by February 28, 2001.

30. The Commission found that, to this day, Oklahoma, and in particular, Tulsa, remains racially divided. The legislature, in adopting the Commission s findings recognized that reconciliation begins through knowledge of the past, followed by acceptance of the past, and finally atonement through compensation to the survivors and their heirs. The Commission drew upon testimony of a large number of Oklahomans, both African American and white, in compiling its record. The Defendants refuse to make restitution for their actions prior to and during the Riot, and in perpetuating a conspiracy of silence ^{^[29]} after the Riot until the creation of the Commission itself.

31. In the wake of its findings, The Commission . . . turned the responsibility for how the State Of Oklahoma will respond to the historical record to the 48th Oklahoma Legislature. 74 Okl. St. Ann. 8000.1.5 (West 2002). The legislature found that:

The documentation assembled by The 1921 Riot Commission provides strong evidence that some local municipal and county officials failed to take actions to calm or contain the situation once violence erupted and, in some cases, became participants in the subsequent violence which took place on May 31 and June 1, 1921, and even deputized and armed many whites who were part of a mob that killed, looted, and burned down the Greenwood area. ^{^[30]}

The staggering cost of the Riot included the deaths of an estimated 100 to 300 persons, the vast majority of whom were African-Americans, the destruction of 1,256 homes, virtually every school, church and business, and a library and hospital in the Greenwood area, and the loss of personal property caused by rampant looting by white rioters. The Riot Commission estimates that the property costs in the Greenwood district was approximately $2 million in 1921 dollars or $16,752,600 in 1999 dollars. Nevertheless, there were no convictions for any of the violent acts against African-Americans or any insurance payments to African-American property owners who lost their homes or personal property as a result of the Riot. Moreover, local officials attempted to block the rebuilding of the Greenwood community by amending the Tulsa building code to require the use of fire-proof material in rebuilding the area thereby making the costs prohibitively expensive. ^{^[31]}

The 48th Oklahoma Legislature in enacting the 1921 Riot Reconciliation Act of 2001 concurs with the conclusion of The 1921 Riot Commission . . . . [T]his response recognizes that there were moral responsibilities at the time of the riot which were ignored and has been ignored ever since rather than confront the realities of an Oklahoma history of race relations that allowed one race to put down another race. Therefore, it is the intention of the Oklahoma Legislature in enacting the 1921 Riot Reconciliation Act of 2001 to freely acknowledge its moral responsibility on behalf of the state of Oklahoma and its citizens that no race of citizens in Oklahoma has the right or power to subordinate another race today or ever again. ^{^[32]}

32. The State Of Oklahoma and the CITY OF TULSA empowered, encouraged, and furthered the illegal brutalization of African Americans by whites during and after the race Riot. From Defendants acceptance of their moral responsibility to atone for these acts logically flows the obligation that they accept their legal responsibility as well.

33. The conspiracy of silence fell particularly hard on the African American citizens of Oklahoma. African Americans were not allowed to speak of their experiences,^{^[33]} and were not believed when they did. Many of the survivors and their families suffered a deep psychological scarring, as one of the purposes of the Riot and its aftermath which lingers to this day throughout the African American community in Tulsa was to diminish the sense of security of Greenwood African Americans, to place them in a subservient condition, and to enforce a racial caste system that privileged whites and disadvantaged and demeaned African Americans. Many of the Riot survivors are still hesitant to talk about the events surrounding the Riot and its aftermath. Many of them still believe that the state and municipal government will punish them for discussing openly what happened during the Riot.

34. According to the Report of the Oklahoma Commission to Study the Riot of 1921 ( Commission Report ), The 1921 riot is, at once, a representative historical example and a unique historical event. It has many parallels in the pattern of past events, but it has no equal for its violence and its completeness. ^{^[34]}

35. The Commission was formed with the intent of determining the causes of and liabilities for the 1921 Tulsa Riot. The survivors were led to expect that Defendants THE GOVERNOR OF THE STATE OF OKLAHOMA and CITY OF TULSA would abide by the findings of the Commission. Instead, it appears that despite the concurrence in and acknowledgment of the facts establishing their complicity in the Riot and its consequences, the state and municipality have decided to wait for the survivors, all of them in excess of eighty-years-old, to die off so that the problem will silently pass away.

36. Defendants continue to fail to abide by the recommendation of the Commission, and refuse to provide redress to the Plaintiffs who are direct victims of a Riot that killed between 100-300 African American men, women, and children, and resulted in the looting and destruction of their property.

37. Plaintiffs also seek to establish an educational fund^{^[35]} for the Greenwood District of Tulsa to ensure that the State Of Oklahoma and the CITY OF TULSA can come together as a community united, with the common goal of promoting racial reconciliation and understanding. For too long, Defendants have silenced Plaintiffs and discounted their testimony. In so doing, Defendants have only perpetuated the divisions that were solidified during and after the Riot. Education about the past must be coupled with restitution or reparations to enable the community to move forward, together, in the common purpose of bettering the lives of all the citizens of Oklahoma.

THE PARTIES

A. Plaintiffs

i Survivors

38. Plaintiffs file this action against THE GOVERNOR OF THE STATE OF OKLAHOMA (in his official capacity); THE CITY OF TULSA; THE CHIEF OF POLICE OF THE CITY OF TULSA; and THE CITY OF TULSA POLICE DEPARTMENT.

39. Plaintiff JOHN MELVIN ALEXANDER is an individual residing in the State of Oklahoma. Plaintiff was born on December 22, 1919. At the time of the Riot, Plaintiff lived at 1621 North Norfolk Street in the Greenwood District of Tulsa. During the Riot, the rioting white mob took Plaintiff s father to the Ball Park holding camp; Plaintiff was unlawfully detained against his will in Brady Theater detention center. Plaintiff went on to fight for the United States in WWII & Korea. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

40. Plaintiff JUANITA DELORES BURNETT ARNOLD is an individual residing in the State of Oklahoma. Plaintiff was born on July 27, 1909. At the time of the Riot, Plaintiff lived at 1000 N. Lansing Street in the Greenwood District of Tulsa. During the Riot, Plaintiff fled from the rioting white mob with her mother and father. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

41. Plaintiff J.B. BATES is an individual residing in the State of Oklahoma. Plaintiff was born on June 13, 1916. At the time of the Riot, Plaintiff lived between Greenwood and Marshall Street in the Greenwood District of Tulsa. Plaintiff s grandfather died during the Riot. Plaintiff s property was destroyed during the Riot, although the rioting white mob did not burn down his family home. Plaintiff and his parents had to leave their house and stay with relatives in Tulsa and were unable to return to their home until at least two week after the Riot. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

42. Plaintiff ESSIE LEE JOHNSON BECK is an individual residing in the State of Oklahoma. Plaintiff was born on April 29, 1915. Plaintiffs property was destroyed during the Riot. At the time of the Riot, Plaintiff lived in the Greenwood District of Tulsa. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

43. Plaintiff JAMES D. BELL is an individual residing in the State of Oklahoma. Plaintiff was born on June 12, 1921. At the time of the Riot, Plaintiff lived at 418 N. Cincinnati Avenue in the Greenwood District of Tulsa. Plaintiff was born prematurely as a result of the shock his mother suffered during the Riot. Plaintiff s property was destroyed during the Riot, including his family home. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

44. Plaintiff PHINES BELL is an individual residing in the State of Washington. Plaintiff was born on August 16, 1918. At the time of the Riot, Plaintiff lived in the Greenwood District of Tulsa. Plaintiff suffered property damage during the Riot. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

45. Plaintiff FRANCES BLACKWELL is an individual residing in the State of Oklahoma. Plaintiff was born on February 12, 1913. At the time of the Riot, Plaintiff lived in the Greenwood District of Tulsa. The rioting white mob forced Plaintiff to flee her home for several days to avoid capture by Defendant s agents. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

46. Plaintiff JUANITA WILLIAMS BLAKELY is an individual residing in the State of Oklahoma. Plaintiff was born on August 5, 1914. Plaintiff resided at Frankfort Place, one block from Greenwood. Plaintiff s family property was destroyed during the Riot. Plaintiff hid under the bed when members of the rioting white mob entered her house and sent fire to the curtains. Plaintiffs and family fled from the burning house and saw airplanes over Greenwood and Archer dropping incendiary devices. Plaintiff s mother found a relative to take Plaintiff to Gerard, Kansas while Plaintiff s mother remained in Tulsa and was detained at the Fairgrounds. Plaintiff s home was destroyed in the fire. Plaintiff s uncle, Osborne Monroe, owned a skating rink and a boarding house, both of which were destroyed in the Riot.

47. Plaintiff JUANITA SMITH BOOKER is an individual residing in the State of Oklahoma. Plaintiff was born on January 15, 1914. At the time of the Riot, Plaintiff lived on Archer Street in the Greenwood District of Tulsa. Plaintiff s property was destroyed during the Riot. The rioting white mob burned her family home to the ground and destroyed it completely with the exception of an upright victrola, which was the only item of personal property the family managed to salvage after the Riot. Plaintiff and her family were temporarily housed at the former Booker T. Washington School after the Riot. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

48. Plaintiff KINNEY BOOKER is an individual residing in the State of Oklahoma. Plaintiff was born on March 21, 1913. At the time of the Riot, Plaintiff lived at 320 North Hartford Street in the Greenwood District of Tulsa. During the Riot, he hid in an attic while the white rioters set fire to his home. Plaintiff s family property was destroyed during the Riot. Plaintiff was forced to flee her house by the rioting white mob. He was lucky to escape before it burned to the ground. Plaintiff was unlawfully detained against his will at the Convention Hall detention center. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

49. Plaintiff DOROTHY BOOKER BOULDING is an individual residing in the State of Missouri. Plaintiff was born on December 2, 1915. At the time of the Riot, Plaintiff lived in the Greenwood District of Tulsa. Plaintiff is the sister of Plaintiff KINNEY BOOKER. Plaintiff suffered property damage during the Riot. Plaintiff was forced to flee her house by the rioting white mob. Plaintiff was unlawfully detained against her will in one of the detention centers. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

50. Plaintiff JEANETTE McNEAL BRADSHAW is an individual residing in the State of Illinois. Plaintiff was born on June 28, 1918. At the time of the Riot, Plaintiff lived at 911 Fairview Street in the Greenwood District of Tulsa. Plaintiff is the sister of Plaintiff Plaintiff THERESSA CORNELLA McNEAL GILLIAM. Plaintiffs mother was a prominent business woman, owning a boarding house and working as a dressmaker with a large inventory of fabric and dresses. Plaintiff s family property was destroyed during the Riot. The business and its stock was completely lost during the Riot. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

51. Plaintiff TERESA EARLEE BRIDGES DYSART is an individual residing in the State of Texas. Plaintiff was born on December 11, 1917. At the time of the Riot, Plaintiff lived at 514 N. Hartford in the Greenwood District of Tulsa. Plaintiff s family property was destroyed during the Riot, including two pianos and an organ, some hand-made Indian jewelry, and a Rooflee model car. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

52. Plaintiff JOHNNIE L. GRAYSON BROWN is an individual residing in the State of Oklahoma. Plaintiff was born on July 5, 1914. At the time of the Riot, Plaintiff lived at 31 N. Kenosha Street in the Greenwood District of Tulsa with her family. Plaintiff's family property was destroyed during the Riot. The rioting white mob ransacked her home. Plaintiff, along with her aunt, Corene Grayson Edwards, was unlawfully detained against her will at the Fairground detention center for several days. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

53. Plaintiff LEE ELLA STROZIER BROWN is an individual residing in the State of California. Plaintiff was born on January 29, 1919. At the time of the Riot, Plaintiff lived in the Greenwood District of Tulsa. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

54. Plaintiff CLARENCE BRUNER is an individual residing in the State of Oklahoma. Plaintiff was born on July 28, 1904. At the time of the Riot, Plaintiff lived in the Greenwood District of Tulsa. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

55. Plaintiff LULA BELLE LACY BULLOCK is an individual residing in the State of Missouri. Plaintiff was born on April 22, 1920. At the time of the Riot, Plaintiff lived in Bullette Street in the Greenwood District of Tulsa. Plaintiff is sister of Plaintiff ARTIE LACY JOHNSON. Plaintiffs fled the Rioting white mob. Plaintiffs property was destroyed during the Riot: their family store and home were burned down. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

56. Plaintiff JOE R. BURNS is an individual residing in the State of Oklahoma. Plaintiff was born on February 5, 1915. At the time of the Riot, Plaintiff lived at 517 Latimer Court in the Greenwood District of Tulsa. Plaintiff fled with his father and mother to Mohawk Park, hiding in the shrubs and trees in the creek. His family was later captured and placed in detention centers. Plaintiff was unlawfully detained against his will in the Convention Center detention center. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

57. Plaintiff ROSA L. GREEN BYNUM is an individual residing in the state of Maryland. Plaintiff was born on August 14, 1920. At the time of the Riot, Plaintiff lived on N. Detroit Street. Plaintiff's family property was destroyed. Plaintiff and her family where held in detention with other families for several days. Plaintiff was unlawfully detained against her will in one of the detention centers.

58. Plaintiff MURIEL MIGNON LILLY CABELL is an individual residing in the State of California. Plaintiff was born on December 29, 1913. At the time of the Riot, Plaintiff lived on Elgin Street in the Greenwood District of Tulsa. Plaintiff is the sister of Plaintiffs HATTIE LILLY DUNN and JIMMIE LILLY FRANKLIN. Plaintiffs parents owned a home with four bedrooms, one bathroom, a living room, a dining room, and an office used by their father, who was a photographer. Their father had a photographic studio, a dark room, and several large cameras, and also owned a Ford Sedan. Plaintiffs uncle, Fred Wells, was a prominent Tulsa physician and surgeon, who owned a Ford Coupe and medical equipment. Plaintiff s family property was destroyed during the Riot. Their home was the third house burned during the Riot. The rioting white mob destroyed their home and all their family s possessions. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

59. Plaintiff BEATRICE CAMPBELL-WEBSTER is an individual residing in the State of California. Plaintiff was born on March 5, 1914. At the time of the Riot, Plaintiff lived with her family at 906 N. Latimer Street in the Greenwood District of Tulsa. Plaintiff s family property was destroyed during the Riot. Plaintiff lost her home and furnishings, including a piano and a victrola, leather couches and chairs, and miscellaneous other possessions. Plaintiff fled her home to avoid the rioting white mob. Plaintiff was unlawfully detained against her will in one of the detention centers. Plaintiff escaped with her family to Alsuma, a nearby town, where the National Guard captured them. Her father was sent to the Ball Park detention center, and the rest of the family was sent to the Convention Hall detention center. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

60. Plaintiff JAMES DALE CARTER is an individual residing in the State of Missouri. Plaintiff was born on November 26, 1920. Plaintiff is the son of Plaintiff ROSELLA CARTER. Plaintiff resided on Greenwood at the time of the Riot. Plaintiff s property was destroyed during the course of the Riot and Plaintiff s fled from the rioting white mob, his mother carrying him forty miles on her back to safety.

61. Plaintiff ROSELLA CARTER is an individual residing in the State of Missouri. Plaintiff was born on June 20, 1900. Plaintiff is the mother of Plaintiff JAMES DALE CARTER. Plaintiff resided on Greenwood at the time of the Riot. Plaintiff s property was destroyed during the course of the Riot and Plaintiff s fled from the rioting white mob, carrying her son on her back forty miles to escape to safety.

62. Plaintiff SAMUEL CASSIUS is an individual residing in the State of New Jersey. Plaintiff was born on May 2, 1921. At the time of the Riot, Plaintiff lived in the Greenwood District of Tulsa. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

63. Plaintiff NAOMI HOOKER CHAMBERLAIN is an individual residing in the State of New York. Plaintiff was born on January 26, 1918. At the time of the Riot, Plaintiff lived on Independence Street in a house valued at $10,000 in 1921 dollars. Her parents also owned a large store at 123 N. Greenwood Avenue in the Greenwood District of Tulsa. Plaintiff is the sister of Plaintiffs DR. OLIVIA J. HOOKER and SAMUEL L. HOOKER. Plaintiff s family property was destroyed during the Riot. White rioters damaged Plaintiffs home during the Riot, and the rioting white mob completely destroyed Plaintiffs parents business, which was described as a total loss. The estimated value of the goods destroyed amounted to $100,000 in 1921 dollars. Plaintiffs father filed a lawsuit against the insurance company for the value of the destroyed property, but the case was thrown out in 1926 or 1927. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

64. Plaintiff MILDRED MITCHELL CHRISTOPHER is an individual residing in the State of Florida. Plaintiff was born on October 19, 1913. At the time of the Riot, Plaintiff lived on King Street in the Greenwood District of Tulsa. Plaintiff's property was destroyed during the Riot: her home was burned and property was taken from the house including a piano and silver flatware. Plaintiff fled to Broken Arrow, Oklahoma with plaintiff's mother and sisters. Plaintiff stayed in an abandoned stone house in Broken Arrow with other families fleeing the Riot for several days until the National Guard and the Red Cross located them. Plaintiff and her family were unlawfully detained against their will in the Fairground detention center until her mother's employer claimed them. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

65. Plaintiff MILDRED LUCAS CLARK is an individual residing in the State of Arkansas. Plaintiff was born October 15, 1921, four months after the Riot. Plaintiff s mother resided at 1012 N. Elgin at the time of the Riot. Plaintiff s mother fled to the home of white neighbors to escape the Riot and later was held at the Convention Center for several days. Plaintiff s family property was destroyed during the Riot. Plaintiff s mother died shortly after the birth of Plaintiff due to the poor living conditions for Greenwood residents after the Riot.

66. Plaintiff OTIS GRANVILLE CLARK is an individual residing in the State of Oklahoma. Plaintiff was born on February 13, 1903. At the time of the Riot, Plaintiff lived at 805 E. Archer Street in the Greenwood District of Tulsa. During the Riot, Plaintiff was caught in the middle of a gun battle. He was sprayed with blood when his friend was shot through the hand by a white sniper, and both of them fled for their lives. His cousin s caf was burned to the ground. His stepfather disappeared during the Riot and was never seen again. Plaintiff s family property was destroyed during the Riot. His home was burned to the ground. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

67. Plaintiff SANDY CLARK is an individual residing in the State of Oklahoma. Plaintiff was born in 1907. At the time of the Riot, Plaintiff lived in the Greenwood District of Tulsa. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

68. Plaintiff BLANCHE CHATMAN COLE is an individual residing in the State of Oklahoma. Plaintiff was born on April 21, 1904. At the time of the Riot, Plaintiff lived in a rented home in the Greenwood District of Tulsa. During the Riot, her family fled to Clarksville, Oklahoma. Plaintiff s family property was destroyed during the Riot. All the family s belongings were burned or stolen during the Riot. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

69. Plaintiff WORDIE "PEACHES" MILLER COOPER is an individual residing in the State of Oklahoma. Plaintiff was born on February 4, 1911. At the time of the Riot, Plaintiff lived in the Greenwood District of Tulsa. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

70. Plaintiff CARRIE HUMPHREY CUDJOE is an individual residing in the State of Oklahoma. Plaintiff was born on April 6, 1921. At the time of the Riot, Plaintiff lived at 1211 N. Lansing Street in the Greenwood District of Tulsa. Plaintiff s parents owned their own home, a horse, a cow, some chickens, and miscellaneous furnishings and other items. Plaintiff s family property was destroyed during the Riot. Their home was burned down during the Riot, and all of Plaintiff s family s possessions were destroyed or stolen. Plaintiff and her family were unlawfully detained against their will in one of the detention centers. Plaintiff, her mother and brother fled to Mohawk Park on foot where the National Guard picked them up and took them to a church at Seventh Avenue and Boston Street. State and municipal officials held Plaintiff, her mother, and her brother at the Church for three days. Plaintiff and suffered physical injury during the Riot. Both of them injured their feet while fleeing the white mob. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

71. Plaintiff LaVERNE COOKSEY DAVIS is an individual residing in the State of Oklahoma. Plaintiff was born on May 24, 1904. At the time of the Riot, Plaintiff lived in South Tulsa, which was a white district of Tulsa. Plaintiff witnessed the burning of Greenwood. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

72. Plaintiff DOLLY MAE DOUFITT is an individual residing in the State of California. Plaintiff was born on January 11, 1920. At the time of the Riot, Plaintiff lived in the Greenwood District of Tulsa.

73. Plaintiff HATTIE LILLY DUNN is an individual residing in the State of California. Plaintiff was born on March 16, 1918. At the time of the Riot, Plaintiff lived on Elgin Street in the Greenwood District of Tulsa. Plaintiff is the sister of Plaintiffs MURIEL MIGNON LILLY CABELL and JIMMIE LILLY FRANKLIN. Plaintiff s family property was destroyed during the Riot. The rioting white mob destroyed their home. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

74. Plaintiff JAMES DURANT is an individual residing in the State of Michigan. Plaintiff was born on January 27, 1915. At the time of the Riot, Plaintiff lived in the Greenwood District of Tulsa. Plaintiff suffered property damage during the Riot: his family home was burned to the ground. Plaintiff was forced to flee his house by the rioting white mob. Plaintiff was physically injured during the Riot. Members of the rioting white mob attacked him. Plaintiff fled from the rioting white mob and hid in a bus with other Greenwood residents. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

75. Plaintiff LUCILLE B. BUCHANAN FIGURES is an individual residing in the State of Oklahoma. Plaintiff was born on January 9, 1909. At the time of the Riot, Plaintiff lived at 521 N. Elgin Street in the Greenwood District of Tulsa. Plaintiff s family property was destroyed during the Riot. Plaintiff s property was destroyed during the Riot, including her family home. Plaintiff and her mother were unlawfully detained against their will in one of the detention centers until her mother s white employer claimed them from the detention center. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

76. Plaintiff ARCHIE JACKSON FRANKLIN is an individual residing in the State of California. Plaintiff was born on November 11, 1915. At the time of the Riot, Plaintiff lived in the Greenwood District of Tulsa. Plaintiff is the brother of Plaintiff HAZEL FRANKLIN HACKETT. Plaintiff s property was destroyed during the Riot, including her family home. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

77. Plaintiff JIMMIE LILLY FRANKLIN is an individual residing in the State of California. Plaintiff was born on June 12, 1916. At the time of the Riot, Plaintiff lived on Elgin Street in the Greenwood District of Tulsa. Plaintiff is the sister of Plaintiffs MURIEL MIGNON LILLY CABELL and HATTIE LILLY DUNN. Plaintiff s family property was destroyed during the Riot. The rioting white mob destroyed their home. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

78. Plaintiff JOAN HILL GAMBREL is an individual residing in the State of New Jersey. At the time of the Riot, Plaintiff lived in the Greenwood District of Tulsa. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

79. Plaintiff ERNESTINE GIBBS is an individual residing in the State of Oklahoma. Plaintiff was born on December 15, 1902. At the time of the Riot, Plaintiff lived on King Street, in the middle of a train track area. Plaintiff fled from her home to avoid the rioting white mob. Her home was destroyed, along with all the family s possessions, during the Riot. Plaintiff was unlawfully detained against her will at the Fairground detention center. Plaintiff s family property was destroyed during the Riot. Plaintiff s brother, along with many other African American men, only evaded the rioting white mob by jumping into a river and swimming to freedom. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

80. Plaintiff HAROLD GIBBS is an individual residing in the State of Oklahoma. Plaintiff was born on January 16, 1920. At the time of the Riot, Plaintiff lived on Jasper Street in the Greenwood District of Tulsa. Plaintiff s family property was destroyed during the Riot, including his father s wagon and two horses. Plaintiff and his mother were unlawfully detained against their will in a detention center. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

81. Plaintiff MARGARET TILLEY GIBBS is an individual residing in the State of Oklahoma. Plaintiff was born on January 16, 1920. At the time of the Riot, Plaintiff lived near Jasper Street in the Greenwood District of Tulsa. Plaintiff s family property was destroyed during the Riot.

82. Plaintiff THERESSA CORNELLA McNEAL GILLIAM is an individual residing in the State of Illinois. Plaintiff was born on October 11, 1911. At the time of the Riot, Plaintiff lived in the Greenwood District of Tulsa with her family. Plaintiff is the sister of Plaintiff JEANEATTE MCNEAL BRADSHAW. Plaintiff s family property was destroyed during the Riot. Their mother s boarding house and dressmaking business were completely destroyed during the Riot. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

83. Plaintiff EDWARD L. GIVENS is an individual residing in the State of North Carolina. At the time of the Riot, Plaintiff lived in the Greenwood District of Tulsa.

84. Plaintiff BERTHA GUYTON is an individual residing in Tulsa, Oklahoma. Plaintiff s was born on 1914. Plaintiff was a resident in the Greenwood district at the time of the riot.

85. Plaintiff HAZEL FRANKLIN HACKETT is an individual residing in the State of Alabama. Plaintiff was born on October 11, 1918. At the time of the Riot, Plaintiff lived at 604 E. Independence Place in the Greenwood District of Tulsa. Plaintiff is the sister of Plaintiff ARCHIE JACKSON FRANKLIN. Plaintiff s family property was destroyed during the Riot. During the Riot, rioting white mob burned down Plaintiff s family s home and destroyed all the family s possessions. Plaintiff was unlawfully detained against her will for three days at the Fairground detention center. Plaintiff was father s employer claimed Plaintiff s father from the detention center. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

86. Plaintiff MILDRED JOHNSON HALL is an individual residing in the State of California. Plaintiff was born on October 17, 1919. At the time of the Riot, Plaintiff lived in the Greenwood District of Tulsa. Plaintiff s family property was destroyed during the Riot. Plaintiff s family was buying a home in Greenwood that was destroyed by the white mob during the Riot. Plaintiff s mother died months after the Riot from tuberculosis and pneumonia resulting from her stay, during the fall and winter of 1921, in the municipal tents erected after the Riot. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

87. Plaintiff NELL HAMILTON HAMPTON is an individual residing in the State of Oklahoma. Plaintiff was born on March 4, 1911. At the time of the Riot, Plaintiff lived in the Greenwood District of Tulsa. Plaintiff was forced to flee her home by the rioting white mob. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

88. Plaintiff LEROY LEON HATCHER is an individual residing in the State of Oklahoma. Plaintiff was born on May 23, 1921. At the time of the Riot, Plaintiff lived near Brady Street in the Greenwood District of Tulsa. Plaintiff s family property was destroyed during the Riot. The rioting white mob killed Plaintiff s father and burned down their home. Plaintiff s mother carried him nine miles in an effort to avoid the rioting white mob. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

89. Plaintiff MADELEINE HAYNES is an individual residing in the State of California. Plaintiff was born on June 7, 1912. At the time of the Riot, Plaintiff lived at 544 E. Pine Street in the Greenwood District of Tulsa. Plaintiff s family property was destroyed during the Riot. The rioting white mob burned down Plaintiff s family s home. Plaintiff was detained against her will in one of the detention centers. National Guardsmen took Plaintiff and her family into custody and transported Plaintiff, her sister, and her mother to the Ball Park detention center. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

90. Plaintiff JOYCE WALKER HILL is an individual residing in the State of Kansas. Plaintiff was born on December 18, 1908. At the time of the Riot, Plaintiff lived at 322 N. Frankfort in the Greenwood District of Tulsa. Plaintiff is the sister of Plaintiffs SAMUEL WALKER and TROY SIDNEY WALKER. Plaintiff s family property was destroyed during the Riot. The rioting white mob destroyed Plaintiff s family home, which was a two-story, eight-room house. Plaintiff s family also ran a restaurant business. By the time Plaintiff escaped from the rioting white mob, both her feet were bloody from running barefoot along the gravel railroad tracks. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

91. Plaintiff DR. OLIVIA J. HOOKER is an individual residing in the State of New York. Plaintiff was born on February 12, 1915. At the time of the Riot, Plaintiff lived on Independence Street in the Greenwood District of Tulsa. Plaintiff is the sister of Plaintiffs NAOMI HOOKER CHAMBERLAIN and SAMUEL L. HOOKER. Plaintiff s family property was destroyed during the Riot, including their home and business. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

92. Plaintiff SAMUEL L. HOOKER, JR. is an individual residing in the State of Illinois. Plaintiff was born on January 6, 1918. At the time of the Riot, Plaintiff lived on Independence Street in the Greenwood District of Tulsa. Plaintiff is the brother of Plaintiffs NAOMI HOOKER CHAMBERLAIN and DR. OLIVIA J. HOOKER. Plaintiff s family property was destroyed during the Riot, including their home and business. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

93. Plaintiff WILHELMINA GUESS HOWELL is an individual residing in the State of Oklahoma. Plaintiff was born on April 25, 1907. At the time of the Riot, Plaintiff lived in the Greenwood District of Tulsa. Plaintiff s family property was destroyed during the Riot. The rioting white mob killed Plaintiff s uncle. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

94. Plaintiff MILDRED HUDSPETH is an individual residing in the State of California. At the time of the Riot, Plaintiff lived in the Greenwood District of Tulsa.

95. Plaintiff CHARLES HUGHES is an individual residing in the State of Michigan. At the time of the Riot, Plaintiff lived in the Greenwood District of Tulsa. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

96. Plaintiff MYRTLE WELLS HURD is an individual residing in the State of Oklahoma. At the time of the Riot, Plaintiff lived in the Greenwood District of Tulsa. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

97. Plaintiff VERA INGRAM is an individual residing in the State of Oklahoma. Plaintiff was born on March 4, 1914. At the time of the Riot, Plaintiff lived at 1342 N. Lansing Avenue in the Greenwood District of Tulsa. Plaintiff s family property was destroyed during the Riot. Plaintiff s family fled to Mowhawk Park, where the rioting white mob shot at Plaintiff s family. Plaintiff was unlawfully detained against her will in the Fairground detention center. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

98. Plaintiff EUNICE CLOMAN JACKSON is an individual residing in the State of Oklahoma. Plaintiff was born on August 17, 1903. At the time of the Riot, Plaintiff lived at 401 E. Marshall Street in the Greenwood District of Tulsa. Plaintiff was unlawfully detained against her will in one of the detention centers. During the Riot the Tulsa police captured Plaintiff and took her, along with her mother and brother, to the Convention Center detention center. Plaintiff s mother s white employer claimed the family from the Convention Center. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

99. Plaintiff GENEVIEVE ELIZABETH TILLMAN JACKSON is an individual residing in the State of Oklahoma. Plaintiff was born on June 29, 1915. At the time of the Riot, Plaintiff lived on Brickyard (now Frankfort) Hill in the Greenwood District of Tulsa. Plaintiff s family property was destroyed during the Riot. Plaintiff saw airplanes drop incendiary devices on Greenwood. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

100. Plaintiff WILLIE BELL WHITE JACKSON is an individual residing in the State of Ohio. Plaintiff was born on June 4, 1910. At the time of the Riot, Plaintiff lived in the Greenwood District of Tulsa. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

101. Plaintiff DR. HOBART JARRETT is an individual residing in the State of New York. Plaintiff was born on June 4, 1910. At the time of the Riot, plaintiff lived at 1213 N. Greenwood Street in the Greenwood District of Tulsa. Plaintiff s parents owned a store on Easton Street, in Greenwood. Plaintiff s family property was destroyed during the Riot. During the Riot, the rioting white mob burned down the store and looted, defecated, and urinated in their home. Plaintiff was unlawfully detained against his will in one of the detention centers. The National Guard took plaintiff and his family into custody and transported them to the Fairground detention center. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

102. Plaintiff ARTIE LACY JOHNSON is an individual residing in the State of Missouri. Plaintiff was born on July 29, 1915. At the time of the Riot, plaintiff lived on Bullette Street in the Greenwood District of Tulsa. Plaintiff is the sister of Plaintiff LULA BELLE LACY BULLOCK. Plaintiffs fled the Rioting white mob. Plaintiffs property was destroyed during the Riot: their family store and home were burned down. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

103. Plaintiff WILMA MITCHELL JOHNSON is an individual residing in the State of New Mexico. Plaintiff was born on August 14, 1919. At the time of the Riot, Plaintiff lived at 1421 N. Kenosha Street in the Greenwood District of Tulsa. During the Riot, the rioting white mob shot Plaintiff s father three times, but Plaintiff s father survived. Plaintiff s family property was destroyed during the Riot. The rioting white mob burned down Plaintiff s parents restaurant. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

104. Plaintiff EDWARD EARVEN JONES is an individual residing in the State of Oklahoma. Plaintiff was born on March 24, 1920. At the time of the Riot, Plaintiff lived on East Davenport Avenue in the Greenwood District of Tulsa. Plaintiff s mother saw airplanes piloted by white rioters drop incendiary devices during the Riot. Plaintiff escaped from the Riot with his family to Catoosa, Oklahoma, and then to Red Bird, Oklahoma. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

105. Plaintiff HAZEL DOLORES SMITH JONES is an individual residing in Tulsa, Oklahoma. Plaintiff was born on January 8, 1919. At the time of the Riot, Plaintiff lived with her thirteen brothers and sisters at 1205 N. Madison Street in the Greenwood District of Tulsa. Plaintiff s family property was destroyed during the Riot. The rioting white mob burned Plaintiff s family home to the ground. Plaintiff was unlawfully detained against her will in one of the detention centers. Plaintiff, along with her mother and her siblings, were taken to the Fairground and were held for three or four days until Plaintiff s father came for them.

106. Plaintiff JULIA BONTON JONES is an individual residing in the State of Oklahoma. Plaintiff was born on June 7, 1917. At the time of the Riot, Plaintiff lived in the Greenwood District of Tulsa. Plaintiff suffered property damage during the Riot: her family home was burned down and all the property within was destroyed or stolen. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

107. Plaintiff PERCY JONES is an individual residing in the State of Missouri. Plaintiff was born on January May 2, 1921. At the time of the Riot, Plaintiff lived in the Greenwood District of Tulsa.

108. Plaintiff THELMA THURMAN KNIGHT is an individual residing in the State of Oklahoma. Plaintiff was born on May 30. 1915. At the time of the Riot, Plaintiff lived at 619 E. Cameron Street in the Greenwood District of Tulsa. Plaintiff s family property was destroyed during the Riot. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

109. Plaintiff LEANNA JOHNSON LEWIS is an individual residing in the State of Oklahoma. Plaintiff was born on August 24, 1919. At the time of the Riot, Plaintiff lived in the Greenwood District of Tulsa. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

110. Plaintiff KATIE MAE JOHNSON LIVINGSTON is an individual residing in the State of Oklahoma. Plaintiff was born on May 6, 1921. At the time of the Riot, Plaintiff lived in the Greenwood District of Tulsa. Plaintiff s family property was destroyed during the Riot: Plaintiff s house was burned down. Plaintiff fled from the rioting white mob with her mother and sister. They went to stay with relatives in Clarksville, Oklahoma, and never returned to live in Tulsa. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

111. Plaintiff ALICE HIGGS LOLLIS is an individual residing in the State of Oklahoma. Plaintiff was born on June 21, 1906. At the time of the Riot, Plaintiff lived on Pine Place in the Greenwood District of Tulsa. Plaintiff was unlawfully detained against her will in a segregated hospital hastily created for African American Riot victims. Plaintiff, who suffered from rheumatism, was forced to sleep on a mattress on the ground in the hospital. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

112. Plaintiff ROANNA HENRY McCLURE is an individual residing in the State of Oklahoma. Plaintiff was born on February 21, 1914. At the time of the Riot, Plaintiff lived on Pine Place in the Greenwood District of Tulsa. The rioting white mob shot at Plaintiff and Plaintiff s grandmother from Resevoir Hill. Plaintiff was unlawfully detained against her will. After the Riot, Plaintiff was housed in a segregated makeshift hospital on 15^th Street without sufficient beds, forcing her to lie on mattresses placed on the floor of the building. Plaintiff and Plaintiff s grandmother were later taken to the Fairgrounds where they slept on mattresses on the floor. Plaintiff s family property was destroyed: their house was set on fire and partially burned. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

113. Plaintiff ELDORIS MAE ECTOR McCONDICHIE is an individual residing in the State of Oklahoma. Plaintiff was born on September 8, 1911. At the time of the Riot, Plaintiff lived at 1341 N. Iroquois Street in the Greenwood District of Tulsa. During the Riot, Plaintiff witnessed whites piloting airplanes from which they shot at fleeing African American men, women, and children. Plaintiff fled with her family to Pawhuska, Oklahoma. Plaintiff still has nightmares about the Riot. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

114. Plaintiff CAROL SMITHERMAN MARTIN is an individual residing in the State of North Carolina. Plaintiff was born on December 22, 1912. At the time of the Riot, Plaintiff lived in the Greenwood District of Tulsa. Plaintiff suffered property damage during the Riot: her father, Andrew Jackson Smitherman, owned a newspaper and his business and family home was burned to the ground. Plaintiff was forced to flee Tulsa by the rioting white mob. One year after the Riot, Klansmen cut off Plaintiff s uncle s ear in an act of racial intimidation and violence. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

115. Plaintiff MARY TACOMA MAUPIN is an individual residing in the State of Kentucky. Plaintiff was born on November 9, 1905. At the time of the Riot, Plaintiff lived at 507 N. Detroit Avenue in the Greenwood District of Tulsa. Plaintiff resided with her uncle. Plaintiff s family property was destroyed during the Riot. The rioting white mob burned and looted the family home. Plaintiff heard the rioting whites exclaim: These niggers have better things than we do! What the rioting white mob could not take it destroyed. Plaintiff was unlawfully detained against her will in one of the detention centers. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

116. Plaintiff WILLIE MUSGROVE MEANS is an individual residing in the State of California. Plaintiff was born on August 24, 1916. At the time of the Riot, Plaintiff lived in the Greenwood District of Tulsa. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

117. Plaintiff ISHMAEL S. MORAN is an individual residing in the State of California. Plaintiff was born on January 1, 1920. At the time of the Riot, Plaintiff lived at 313 N. Elgin in the Greenwood District of Tulsa. Plaintiff's father worked at the National Bank of Tulsa on Boston Street. Plaintiff was forced to flee his house and hide from the rioting white mob. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

118. Plaintiff RUTH DEAN NASH is an individual residing in the State of Oklahoma. Plaintiff was born on September 9, 1915. At the time of the Riot, Plaintiff lived on Latimer Street in the Greenwood District of Tulsa. Plaintiff s property was destroyed during the Riot. The rioting white mob burned Plaintiff s home to the ground. To escape the Riot, Plaintiff and her mother fled in a car for Muskogee, Oklahoma. Plaintiff and her mother were taken to the Dunbar School and later joined by her father. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

119. Plaintiff SIMEON L. NEAL is an individual residing in the State of Illinois. Plaintiff was born on August 31, 1920. At the time of the Riot, Plaintiff lived in the Greenwood District of Tulsa. Plaintiff s family property was destroyed during the Riot: his father s tailor shop and three rented homes were burned. Plaintiff was forced to flee from the rioting white mob. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

120. Plaintiff ALMADGE J. NEWKIRK is an individual residing in the State of California. Plaintiff was born on October 13, 1913. At the time of the Riot, Plaintiff lived at 119 N. Greenwood Avenue in the Greenwood District of Tulsa. Plaintiff s parents ran a business consisting of a bakery and a confectionary shop, and a photography studio. Plaintiff s family property was destroyed during the Riot. The rioting white mob destroyed the buildings and the business in the course of the Riot. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

121. Plaintiff MYRTLE NAPIER OLIVER is an individual residing in the State of Georgia. Plaintiff was born in 1911. At the time of the Riot, Plaintiff lived at 526 N. Elgin Street in the Greenwood District of Tulsa with her family. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

122. Plaintiff JUANITA MAXINE SCOTT PARRY is an individual residing in the State of Oklahoma. Plaintiff was born on June 21, 1919. At the time of the Riot, Plaintiff lived at 341 or 404 N. Elgin Street in the Greenwood District of Tulsa. Plaintiff is the sister of Plaintiff JULIUS WARREN SCOTT. Plaintiff s family home was destroyed during the Riot. Plaintiff fled with her family to the home of an attorney named I.H. Spears and saw people burning houses at Hartford near Archer. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

123. Plaintiff IDA BURNS PATTERSON is an individual residing in the State of Florida. Plaintiff was born on January 25, 1919. Plaintiff is the sister of Plaintiff JOE R. BURNS. At the time of the Riot, Plaintiff lived at 517 Latimer Court in the Greenwood District of Tulsa. During the Riot Plaintiff fled with her family from the rioting white mob and hid in a ravine on Apache Street. Plaintiff suffered property damage during the Riot. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

124. Plaintiff FREDDIE SCOTT PAYNE is an individual residing in the State of California. Plaintiff was born on November 8, 1914. Plaintiff resided in Greenwood, across from Booker T. Washington High School on a steep hill behind the school at the time of the riot. Plaintiff s grandfather and uncle were killed during the riot. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

125. Plaintiff JOAN ALEXANDER POWDRILL is an individual residing in the State of California. Plaintiff was born on March 27, 1917. Plaintiff lived at 1621 North Norfolk Street in the Greenwood District of Tulsa. Plaintiff is the sister of Plaintiff JOHN MELVIN ALEXANDER. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

126. Plaintiff ALICE PRESLEY is an individual residing in the State of California. Plaintiff was born on March 8, 1921. At the time of the Riot, Plaintiff lived in the Greenwood District of Tulsa. The Riot so traumatized Plaintiff s parents that they left Tulsa for good after the Riot. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

127. Plaintiff DeLOIS VADEN RAMSEY is an individual residing in the State of Oklahoma. Plaintiff was born on March 5, 1919. At the time of the Riot, Plaintiff lived on Elgin Street in the Greenwood District of Tulsa. Plaintiff s father owned a Vaden s Pool Hall, a popular recreation spot frequented by many notable African Americans. Plaintiff s family property was destroyed during the Riot by the rioting white mob: they even shot her dog. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

128. Plaintiff CORA HAWKINS RENFRO is an individual residing in the State of Illinois. Plaintiff was born on April 28, 1920. At the time of the Riot, Plaintiff lived in the Greenwood District of Tulsa. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

129. Plaintiff SIMON R. RICHARDSON is an individual residing in the State of Oklahoma. Plaintiff was born on February 12, 1914. At the time of the Riot, Plaintiff lived on Greenwood Avenue in the Greenwood District of Tulsa. Plaintiff was unlawfully detained against his will in the Convention Center detention center. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

130. Plaintiff JEWEL SMITHERMAN ROGERS is an individual residing in the State of California. Plaintiff was born on June 12, 1917. At the time of the Riot, Plaintiff lived on Elgin Street in the Greenwood District of Tulsa. Plaintiff suffered property damage during the Riot: her family home was burned to the ground. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

131. Plaintiff GERLINE HELEN WRIGHT SAYLES is an individual residing in the State of Illinois. Plaintiff was born on October 26, 1916. At the time of the Riot, Plaintiff lived on 435 E. Booker Street in the Greenwood District of Tulsa. Plaintiff suffered property damage during the Riot. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

132. Plaintiff JULIUS WARREN SCOTT is an individual residing in the State of Oklahoma. Plaintiff was born on September 23, 1921. Plaintiff was born in a tent in the Greenwood District of Tulsa in the immediate aftermath of the Riot. Plaintiff is the brother of Plaintiff JUANITA MAXINE SCOTT PERRY. Plaintiff s family home was destroyed during the Riot. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

133. Plaintiff WILLIAM A. SCOTT is an individual residing in Chicago, Illinois. Plaintiff s date of birth is March 15, 1913. Plaintiff resided at 620 N. Elgin Place at the time of the Riot. Plaintiff s home burned to the ground and Plaintiff and Plaintiff s parents moved to Plaintiff s grandmother s house until the home could be rebuilt.

134. Plaintiff TULETA S. DUNCAN SHAWNEE is an individual residing in the State of California. Plaintiff was born on September 7, 1903. At the time of the Riot, Plaintiff lived at 1062 N. Lansing Street in the Greenwood District of Tulsa. Plaintiff fled from the rioting white mob. Plaintiff left Tulsa after the Riot, never to return. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

135. Plaintiff VENEICE DUNN SIMMS is an individual residing in the State of Oklahoma. Plaintiff was born on January 21, 1905. At the time of the Riot, Plaintiff lived at 1027 N. Kenosha Street in the Greenwood District of Tulsa. Plaintiff s family home was destroyed during the Riot. Plaintiff s family fled from Tulsa, never to return. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

136. Plaintiff HAL "CORNBREAD" SINGER is an individual residing in Nanterre, France. Plaintiff was born on October 8, 1919. At the time of the Riot, Plaintiff lived on Frankfort Avenue in the Greenwood District of Tulsa. Plaintiff suffered property damage during the Riot. The rioting white mob destroyed Plaintiff s family s home and property. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

137. Plaintiff NAOMI SIPLIN is an individual residing in the State of California. At the time of the Riot, Plaintiff lived in the Greenwood District of Tulsa.

138. Plaintiff BEULAH LOREE KEENAN SMITH is an individual residing in the State of Oklahoma. Plaintiff was born on May 20, 1908. At the time of the Riot, Plaintiff lived at 1411 N. Lansing Street in the Greenwood District of Tulsa. Plaintiff s property was destroyed during the Riot. Plaintiff suffered physical injury during the Riot, as her back was injured fleeing from the mob. Her family attempted to evade capture by hiding in a hog pen, but her father was captured and placed in a detention center. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

139. Plaintiff GOLDEN WILLIAMS SMITH is an individual residing in the State of Oklahoma. Plaintiff was born on May 20, 1916. At the time of the Riot, Plaintiff lived on Greenwood Avenue in the Greenwood District of Tulsa. Plaintiff s family property was destroyed during the Riot. The rioting white mob burned down Plaintiff s parents home and the state or municipal authorities removed Plaintiff s family to the Fairground detention center. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

140. Plaintiff LOLA SNEED SNOWDEN is an individual residing in the State of Indiana. Plaintiff was born on January 21, 1915. At the time of the Riot, Plaintiff resided on Cruse Street in the Greenwood District of Tulsa. Plaintiff's property was destroyed in the riot, including her family home. Plaintiff and her family fled to the woods and stayed with several Native American families before returning to Tulsa. Plaintiff still suffers from phobias and nightmares. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

141. Plaintiff JAMES L. STEWARD is an individual residing in the State of Oklahoma. Plaintiff was born on July 12, 1917. At the time of the Riot, Plaintiff lived at 444 E. Marshall Place in the Greenwood District of Tulsa. Plaintiff s family property was destroyed during the Riot. The rioting white mob set fire to his home while Plaintiff and his family were still inside. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

142. Plaintiff DOROTHY WILSON STRICKLAND is an individual residing in the State of Illinois. Plaintiff was born on November 6, 1912. At the time of the Riot, Plaintiff lived at 419 E. Latimer Court in the Greenwood District of Tulsa. Plaintiff s family suffered property damage during the Riot: her father s store was one of the first buildings burned by the rioting white mob. Plaintiffs were forced to flee from the rioting white mob. Plaintiff was unlawfully detained against his will in one of the detention centers. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

143. Plaintiff SARAH TATUM is an individual residing in the State of Connecticut. Plaintiff was born on April 20, 1912. At the time of the Riot, Plaintiff lived in the Greenwood District of Tulsa. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

144. Plaintiff LOIS WHITE TAYLOR is an individual residing in the State of California. Plaintiff was born on September 27, 1919. At the time of the Riot, Plaintiff resided at 1273 N. Lansing Street in the Greenwood District of Tulsa. Plaintiff fled from the rioting white mob with her brother and mother to Turley, Oklahoma, a town north of Tulsa. Plaintiff s family property was destroyed during the Riot: all their personnel possessions were destroyed or looted, and the family home was damaged in the fire.

145. Plaintiff WILLIE MAE SHELBURN THOMPSON is an individual residing in the State of Oklahoma. Plaintiff was born on December 4, 1912. At the time of the Riot, Plaintiff lived at on Lansing Avenue in the Greenwood District of Tulsa. Plaintiff s family property was destroyed during the Riot. After the Riot, Plaintiff s family was so concerned for her safety that they sent her to live with her father in Austin, Texas. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

146. Plaintiff EFFIE LEE SPEARS TODD is an individual residing in the State of Oklahoma. Plaintiff was born on November 5, 1908. At the time of the Riot, Plaintiff lived in the Greenwood District of Tulsa. Plaintiff fled from the rioting white mob. Plaintiff s property was destroyed during the Riot. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

147. Plaintiff MELVIN C. TODD is an individual residing in the State of Oklahoma. Plaintiff was born on April 12, 1910. At the time of the Riot, Plaintiff lived on Elgin Street in the Greenwood District of Tulsa. Plaintiff suffered property damage during the Riot: his house was burned down. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

148. Plaintiff KATHRYN MAE TAYLOR TOLIN is an individual residing in the State of California. Plaintiff was born on August 27, 1910. At the time of the Riot, Plaintiff lived in the Greenwood District of Tulsa. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

149. Plaintiff BESSIE MAE AUSTIN VESTER is an individual residing in the State of Oklahoma. Plaintiff was born on September 28, 1919. At the time of the Riot, Plaintiff lived in the Greenwood District of Tulsa. Plaintiff s sister was badly burned during the Riot. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

150. Plaintiff QUEEN ESTHER LOVE WALKER is an individual residing in the State of Oklahoma. Plaintiff was born on May 4, 1921. At the time of the Riot, Plaintiff lived in the Greenwood District of Tulsa. Plaintiff s family property was destroyed during the Riot, including a house on Greenwood Avenue and a prosperous restaurant. The rioting white mob shot at Plaintiff and her family while they attempted to flee. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

151. Plaintiff SAMUEL WALKER is an individual residing in the State of Missouri. Plaintiff was born on September 28, 1921. At the time of the Riot, Plaintiff s mother, who lived on Frankfort Avenue in the Greenwood District of Tulsa, was pregnant with Plaintiff. Plaintiff was born prematurely in a Red Cross tent put up for the Riot survivors. Plaintiff is the brother of Plaintiffs TROY SIDNEY WALKER and JOYCE WALKER HILL. Plaintiff s family property was destroyed during the Riot. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

152. Plaintiff TROY SIDNEY WALKER is an individual residing in the State of Washington. Plaintiff was born on August 16, 1918. At the time of the Riot, Plaintiff lived on Frankfort Avenue in the Greenwood District of Tulsa. Plaintiff is brother of JOYCE WALKER HILL and SAMUEL WALKER. Plaintiff s family property was destroyed during the Riot. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

153. Plaintiff OSCAR DOUGLAS WASHINGTON is an individual residing in the State of Missouri. Plaintiff was born on February 18, 1912. At the time of the Riot, Plaintiff lived on the 900 Block of Queen Street in the Greenwood District of Tulsa. Plaintiff saw airplanes flying low over Greenwood. Plaintiff fled with his family from the rioting white mob. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

154. Plaintiff MARY LEON BROWN WATSON is an individual residing in the State of Oklahoma. Plaintiff was born on October 9, 1909. At the time of the Riot, Plaintiff lived in the Webb Hotel on the corner of Greenwood Avenue and Archer Street in the Greenwood District of Tulsa. Plaintiff s family property was destroyed during the Riot. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

155. Plaintiff ALLEN MATTHEW WHITE is an individual residing in the State of Ohio. Plaintiff was born on February 4, 1917. At the time of the Riot, Plaintiff lived at 1431 N. Lansing Street in the Greenwood District of Tulsa with his family. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

156. Plaintiff CECIL WHITE is an individual residing in the State of California. Plaintiff was born on April 15, 1919. At the time of the Riot, Plaintiff lived at 427 E. Latimer Street in the Greenwood District of Tulsa. During the Riot, the rioting white mob shot and killed Plaintiff s uncle. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

157. Plaintiff MARIE WHITEHORN is an individual residing in the State of California. Plaintiff was born on April 24, 1910. At the time of the Riot, Plaintiff lived on Greenwood Avenue in the Greenwood District of Tulsa. Plaintiff fled from the rioting white mob during the course of the Riot. Plaintiff suffered emotional trauma as a result of the Riot. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

158. Plaintiff MILDRED EVITT WILBURN is an individual residing in the State of Oklahoma. Plaintiff was born on January 17, 1921. At the time of the Riot, Plaintiff lived in the Greenwood District of Tulsa with her family. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

159. Plaintiff BERTRAM C. WILLIAMS is an individual residing in the State of Washington. Plaintiff was born on September 22, 1920. At the time of the Riot, Plaintiff lived at 543 E. Latimer Court in the Greenwood District of Tulsa. Plaintiff was unlawfully detained against his will in one of the detention centers. During the Riot, Plaintiff fled from the rioting white mob with his family to Mowhawk Park, where the National Guard captured him and took him to a detention center. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

160. Plaintiff LOUIE BARTON WILLIAMS is an individual residing in the State of Illinois. Plaintiff was born on September 21, 1912. At the time of the Riot, Plaintiff lived in the Greenwood District of Tulsa. Plaintiff was order from her house by the rioting white mob, and fled until she was caught. Plaintiff was unlawfully detained against her will in one of the detention centers. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

161. Plaintiff WILLIAM HAROLD WOOD is an individual residing in the State of Oklahoma. At the time of the Riot, Plaintiff lived in the Greenwood District of Tulsa.

162. Plaintiff CLOTIE LEWIS WRIGHT is an individual residing in the State of California. At the time of the Riot, Plaintiff lived in the Greenwood District of Tulsa. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

163. Plaintiff WESS YOUNG is an individual residing in the State of Oklahoma. Plaintiff was born on February 20, 1917. At the time of the Riot, Plaintiff lived on the 300 block of N. Hartford Avenue in the Greenwood District of Tulsa. Plaintiff was captured by the National Guard and unlawfully detained against his will at the Booker T. Washington High School. As required by the Oklahoma State Legislature (74 Okl. Stat. Ann. 8205 (West 2000)), the Executive Director of the Oklahoma Historical Society has certified that Plaintiff is a Riot Survivor.

164. Each of the Plaintiffs described above suffered and was directly injured in some way by the unlawful conduct of the Defendants.

ii Descendants

165. Plaintiff JOHN HOPE FRANKLIN is the son of B.C. Franklin. At the time of the Riot, Plaintiff s father was an attorney in the Greenwood District of Tulsa during the Riot. Plaintiff s home and office burned to the ground and he worked out of a tent for several months. Plaintiff s father was also detained and taken to the Convention Hall detention center during the Riot.

166. Plaintiff REV. BRADFORD BISHOP is an individual residing in Tulsa, Oklahoma. Plaintiff is the brother of Plaintiffs LISA LATIMER, PATRICE LATIMER, JAYPHEE LATIMER, CAESAR LATIMER, JAMES HAROLD LATIMER, CHARLE SYLVESTER LATIMER, JULIUS PEGUES. Plaintiffs are the children of James Harold and Julia Latimer, who resided in the Greenwood District of Tulsa at the time of the Riot.

167. Plaintiff LISA LATIMER, is an individual residing in Tulsa, Oklahoma. Plaintiff is the brother of Plaintiffs REV. BRADFORD BISHOP, PATRICE LATIMER, JAYPHEE LATIMER, CAESAR LATIMER, JAMES HAROLD LATIMER, CHARLE SYLVESTER LATIMER JULIUS PEGUES. Plaintiffs are the children of James Harold and Julia Latimer, who resided in the Greenwood District of Tulsa at the time of the Riot.

168. Plaintiff PATRICE LATIMER, is an individual residing in Tulsa, Oklahoma. Plaintiff is the brother of Plaintiffs REV. BRADFORD BISHOP, LISA LATIMER, JAYPHEE LATIMER, CAESAR LATIMER, JAMES HAROLD LATIMER, CHARLE SYLVESTER LATIMER, JULIUS PEGUES. Plaintiffs are the children of James Harold and Julia Latimer, who resided in the Greenwood District of Tulsa at the time of the Riot.

169. Plaintiff JAYPHEE LATIMER is an individual residing in Tulsa, Oklahoma. Plaintiff is the brother of Plaintiffs REV. BRADFORD BISHOP, LISA LATIMER, PATRICE LATIMER, CAESAR LATIMER, JAMES HAROLD LATIMER, CHARLE SYLVESTER LATIMER, JULIUS PEGUES. Plaintiffs are the children of James Harold and Julia Latimer, who resided in the Greenwood District of Tulsa at the time of the Riot.

170. Plaintiff CAESAR LATIMER is an individual residing in Tulsa, Oklahoma. Plaintiff is the brother of Plaintiffs REV. BRADFORD BISHOP, LISA LATIMER, PATRICE LATIMER, JAYPHEE LATIMER, JAMES HAROLD LATIMER, CHARLE SYLVESTER LATIMER, JULIUS PEGUES. Plaintiffs are the children of James Harold and Julia Latimer, who resided in the Greenwood District of Tulsa at the time of the Riot.

171. Plaintiff JAMES HAROLD LATIMER is an individual residing in Tulsa, Oklahoma. Plaintiff is the brother of Plaintiffs REV. BRADFORD BISHOP, LISA LATIMER, PATRICE LATIMER, JAYPHEE LATIMER, CAESAR LATIMER,, CHARLE SYLVESTER LATIMER, JULIUS PEGUES. Plaintiffs are the children of James Harold and Julia Latimer, who resided in the Greenwood District of Tulsa at the time of the Riot.

172. Plaintiff CHARLE SYLVESTER LATIMER, is an individual residing in Tulsa, Oklahoma. Plaintiff is the brother of Plaintiffs REV. BRADFORD BISHOP, LISA LATIMER, PATRICE LATIMER, JAYPHEE LATIMER, CAESAR LATIMER, JAMES HAROLD LATIMER, JULIUS PEGUES. Plaintiffs are the children of James Harold and Julia Latimer, who resided in the Greenwood District of Tulsa at the time of the Riot.

173. Plaintiff JULIUS PEGUES is an individual residing in Tulsa, Oklahoma. Plaintiff is the brother of Plaintiffs REV. BRADFORD BISHOP, LISA LATIMER, PATRICE LATIMER, JAYPHEE LATIMER, CAESAR LATIMER, JAMES HAROLD LATIMER, CHARLE SYLVESTER LATIMER. Plaintiffs are the children of James Harold and Julia Latimer, who resided in the Greenwood District of Tulsa at the time of the Riot.

174. Plaintiff REV. BRADFORD BISHOP is an individual residing in Tulsa, Oklahoma. Plaintiff is the brother of Plaintiffs LISA LATIMER, PATRICE LATIMER, JAYPHEE LATIMER, CAESAR LATIMER, JAMES HAROLD LATIMER, CHARLE SYLVESTER LATIMER, JULIUS PEGUES. Plaintiffs are the children of James Harold and Julia Latimer, who resided in the Greenwood District of Tulsa at the time of the Riot.

175. Plaintiff ANITA WILLIAMS CHRISTOPHER is the daughter of William D. and Lula Williams and granddaughter of John Wesley Williams. At the time of the Riot, William D. Williams, Lula Williams, and John Wesley Williams all resided at Greenwood and Archer in the Greenwood District of Tulsa. They owned the Dreamland Theatre that was burned down and their home was burned down.

176. Plaintiff ARTHUR JEFRERSON is the grandchild of Johnny Adams, children of Eliza Adams and nephew and niece of Saucer Grayson. At the time of the Riot, Plaintiffs and Plaintiffs mother lived on Jasper Street. Plaintiff s family also owned six or seven rent houses on Jasper Street just off Greenwood Avenue. Everything they owned was burned down by the white mob. The family hid in an old shed behind their homes near an alley and watched through cracks as the white mob set fire to their property. The white mob was heavily armed, shooting everywhere and their uncle, Saucer Grayson was shot and killed.

177. Plaintiff JESSIE THOMAS is the grandchild of Johnny Adams, children of Eliza Adams and nephew and niece of Saucer Grayson. At the time of the Riot, Plaintiffs and Plaintiffs mother lived on Jasper Street. Plaintiff s family also owned six or seven rent houses on Jasper Street just off Greenwood Avenue. Everything they owned was burned down by the white mob. The family hid in an old shed behind their homes near an alley and watched through cracks as the white mob set fire to their property. The white mob was heavily armed, shooting everywhere and their uncle, Saucer Grayson was shot and killed.

178. Plaintiff JUANITA ALEXANDER HOPKINS is the daughter of C.J. Alexander, Sr. Plaintiff is the sister of Plaintiffs C. J. ALEXANDER, III and LILLIAN ALEXANDER. They are the children of C. J. Alexander, Jr. and the grandchildren of C. J. Alexander, Sr. At the time of the Riot, C.J. Alexander, Sr. and his family lived on Williams Street in the Greenwood District of Tulsa.

179. Plaintiff C.J. ALEXANDER is the son of C.J. Alexander, Sr. Plaintiff is the brother of Plaintiffs JUANITA ALEXANDER HOPKINS and Lillian Alexander. They are the children of C. J. Alexander, Jr. and the grandchildren of C. J. Alexander, Sr. At the time of the Riot, C.J. Alexander, Sr. and his family lived on Williams Street in the Greenwood District of Tulsa.

180. Plaintiff LILLIAN ALEXANDER is the daughter of C.J. Alexander, Sr. Plaintiff is the sister of Plaintiffs C. J. ALEXANDER, III and JUANITA ALEXANDER HOPKINS. They are the children of C. J. Alexander, Jr. and the grandchildren of C. J. Alexander, Sr. At the time of the Riot, C.J. Alexander, Sr. and his family lived on Williams Street in the Greenwood District of Tulsa.

181. Plaintiff JOHNETTA ADAMS is the niece of Roy Alsup. At the time of the Riot, Roy Aslup lived on Madison Street off Lansing in the Greenwood District do of Tulsa with his mother and father and several sisters. When the riot broke out his father left the house with his gun. Roy, his mother and sister fled because of the burning that was happening. They went north along the railroad tracks toward Owasso. As they were fleeing a white woman called them over to her barn, gave them sandwiches and allowed them to stay in the barn until they were rounded up by the National Guard and taken to Carver Stadium. Mr. Alsup reported to his family many times that he saw planes flying over Greenwood dropping bombs.

182. Plaintiff RHONDA ANDERSON is the child of Mary Franklin Anderson. Plaintiff is the sister of Plaintiffs ROBERT EARL ANDERSON, DIANE ANDERSON STEELE and MARIETTA ANDERSON WAITERS. At the time of the Riot, Ms. Anderson lived in the Greenwood District of Tulsa.

183. Plaintiff ROBERT EARL ANDERSON is the child of Mary Franklin Anderson. Plaintiff is the brother of Plaintiffs RHONDA ANDERSON, DIANE ANDERSON STEELE and MARIETTA ANDERSON WAITERS. At the time of the Riot, Ms. Anderson lived in the Greenwood District of Tulsa.

184. Plaintiff DIANE ANDERSON STEELE is the child of Mary Franklin Anderson. Plaintiff is the sister of RHONDA ANDERSON, ROBERT EARL ANDERSON, and MARIETTA ANDERSON WAITERS. At the time of the Riot, Ms. Anderson lived in the Greenwood District of Tulsa.

185. Plaintiff MARIETTA ANDERSON WAITERS is the child of Mary Franklin Anderson. Plaintiff is the sister of Plaintiffs RHONDA ANDERSON, ROBERT EARL ANDERSON, DIANE ANDERSON STEELE. At the time of the Riot, Ms. Anderson lived in the Greenwood District of Tulsa.

186. Plaintiff RUTH ELLA AUTRY is the child of Rev. James and Laura Jeffries Autry. Plaintiff is the sister of Plaintiffs JAMES AUTRY, and ELMER AUTRY. At the time of the Riot, Rev. James Autry was the pastor of Holsey Chapel C.M.E. Church on N. Peoria Avenue in the Greenwood District of Tulsa. Plaintiff s father saw bombs falling from planes over Greenwood. Rev. Autrey found it difficult to return to Tulsa and was deeply emotionally scarred.

187. Plaintiff JAMES AUTRY is the child of Rev. James and Laura Jeffries Autry. Plaintiff is the brother of Plaintiffs RUTH ELLA AUTRY, and ELMER AUTRY. At the time of the Riot, Rev. James Autry was the pastor of Holsey Chapel C.M.E. Church on N. Peoria Avenue in the Greenwood District of Tulsa. Plaintiff s father saw bombs falling from planes over Greenwood. Rev. Autrey found it difficult to return to Tulsa and was deeply emotionally scarred.

188. Plaintiff ELMER AUTRY is the child of Rev. James and Laura Jeffries Autry. Plaintiff is the brother RUTH ELLA AUTRY, and JAMES AUTRY. At the time of the Riot, Rev. James Autry was the pastor of Holsey Chapel C.M.E. Church on N. Peoria Avenue in the Greenwood District of Tulsa. Plaintiff s father saw bombs falling from planes over Greenwood. Rev. Autrey found it difficult to return to Tulsa and was deeply emotionally scarred.

189. Plaintiff AILEEN JOANNE AUSTIN COBURN is the daughter of Simon and Senora Austin. Plaintiff is the sister of LEONA AUSTIN McCAIN. At the time of the Riot, Simon and Senora Austin lived in the Greenwood district of Tulsa.

190. Plaintiff LEONA AUSTIN McCAIN is the daughters of Simon and Senora Austin. Plaintiff is the sister of AILEEN JOANNE AUSTIN COBURN. At the time of the Riot, Simon and Senora Austin lived in the Greenwood district of Tulsa.

191. Plaintiff RAMONA DINKINS WIMBERLY is the daughter of Grace Russell Ayers Wimberly. At the time of the Riot, Grace Wimberly lived in the Greenwood district of Tulsa Ms. Wimberly s mother worked for a white woman and hid at her place of work during the riot. Plaintiff s home was burned and the family had to find another place to live.

192. Plaintiff ERLINE CROSSLIN is the child of Fannie Mae Bagby. Plaintiff is the sister of BILLIE WAYNE RUCKER, J. C. RUCKER, ROBERT C. RUCKER and ROSEZELLA TURNER. At the time of the Riot, Fannie Mae Bagby lived in Greenwood District of Tulsa.

193. Plaintiff BILLIE WAYNE RUCKER is the child of Fannie Mae Bagby. Plaintiff is the sister of ERLINE CROSSLIN, J. C. RUCKER, ROBERT C. RUCKER and ROSEZELLA TURNER. At the time of the Riot, Fannie Mae Bagby lived in Greenwood District of Tulsa.

194. Plaintiff J. C. RUCKER, is the child of Fannie Mae Bagby. Plaintiff is the brother of ERLINE CROSSLIN, BILLIE WAYNE RUCKER, ROBERT C. RUCKER and ROSEZELLA TURNER. At the time of the Riot, Fannie Mae Bagby lived in Greenwood District of Tulsa.

195. Plaintiff ROBERT C. RUCKER is the child of Fannie Mae Bagby. Plaintiff is the brother of Plaintiffs ERLINE CROSSLIN, BILLIE WAYNE RUCKER, J. C. RUCKER, and ROSEZELLA TURNER. At the time of the Riot, Fannie Mae Bagby lived in Greenwood District of Tulsa.

196. Plaintiff ROSEZELLA TURNER is the child of Fannie Mae Bagby. Plaintiff is the sister of ERLINE CROSSLIN, BILLIE WAYNE RUCKER, J. C. RUCKER, and ROBERT C. RUCKER. At the time of the Riot, Fannie Mae Bagby lived in Greenwood District of Tulsa.

197. Plaintiff JOHN BAILEY is the great nephew of David Bailey. At the time of the Riot, David Baily lived in the Greenwood District of Tulsa.

198. Plaintiff ROY DAVIS is the son of Peter Bailey. At the time of the Riot, Peter Baily owned a business in Greenwood, located at Pine and Greenwood.

199. Plaintiff A. BANKS, is the child of Nick Banks. Plaintiff is the brother of Plantiffs BERNICE BANKS DAVIS and AUDREY BANKS PARSON. At the time of the Riot, Nick Banks owned a pool hall and was a chef at the Ketchum Hotel in the Greenwood District of Tulsa.

200. Plaintiff BERNICE BANKS DAVIS is the child of Nick Banks. Plaintiff is the sister of Plaintiffs A. BANKS and AUDREY BANKS PARSON. At the time of the Riot, Nick Banks owned a pool hall and was a chef at the Ketchum Hotel in the Greenwood District of Tulsa.

201. Plaintiff AUDREY BANKS PARSON is the child of Nick Banks. Plaintiff is the sister of Plaintiffs A. BANKS, BERNICE BANKS DAVIS. At the time of the Riot, Nick Banks owned a pool hall and was a chef at the Ketchum Hotel in the Greenwood District of Tulsa.

202. Plaintiff MARY BELL ARRINGTON is the child of J.D. and Ida Mae Bell and the grandchild of Isaac (Ike) and Mollie Bell. Plaintiff is the sister of Plaintiffs R.G. BELL and CATHRYN BELL SNODDY. At the time of the Riot, J.D. Bell, Ida Mae Bell, Issac Bell and Mollie Bell lived in the Greenwood District of Tulsa. Their mother, Ida Mae Bell, was 9 months pregnant at the time of the Tulsa Race Riot. She told them that she had to walk for a long time on June 1, 1921 along the railroad tracks. She saw bodies thrown on the church and trucks carrying bodies to the 15^th Street area where she believed they were buried in mass graves. The mother gave birth ten days after the Tulsa Race Riot and had female trouble ever since the Tulsa Race Riot. The Bell s owned a family business, Bells Barbershop on the corner of Greenwood and Archer. Their home was burned down during the riot and the family rebuilt it.

203. Plaintiff R.G. BELL is the child of J.D. and Ida Mae Bell and the grandchild of Isaac (Ike) and Mollie Bell. Plaintiff is the brother of Plaintiffs MARY BELL ARRINGTON, and CATHRYN BELL SNODDY. At the time of the Riot, J.D. Bell, Ida Mae Bell, Issac Bell and Mollie Bell lived in the Greenwood District of Tulsa. Their mother, Ida Mae Bell, was 9 months pregnant at the time of the Tulsa Race Riot. She told them that she had to walk for a long time on June 1, 1921 along the railroad tracks. She saw bodies thrown on the church and trucks carrying bodies to the 15^th Street area where she believed they were buried in mass graves. The mother gave birth ten days after the Tulsa Race Riot and had female trouble ever since the Tulsa Race Riot. The Bell s owned a family business, Bells Barbershop on the corner of Greenwood and Archer. Their home was burned down during the riot and the family rebuilt it.

204. Plaintiff CATHRYN BELL SNODDY is the child of J.D. and Ida Mae Bell and the grandchild of Isaac (Ike) and Mollie Bell. Plaintiff is the sister of Plaintiffs MARY BELL ARRINGTON and R.G. BELL. At the time of the Riot, J.D. Bell, Ida Mae Bell, Issac Bell and Mollie Bell lived in the Greenwood District of Tulsa. Their mother, Ida Mae Bell, was 9 months pregnant at the time of the Tulsa Race Riot. She told them that she had to walk for a long time on June 1, 1921 along the railroad tracks. She saw bodies thrown on the church and trucks carrying bodies to the 15^th Street area where she believed they were buried in mass graves. The mother gave birth ten days after the Tulsa Race Riot and had female trouble ever since the Tulsa Race Riot. The Bell s owned a family business, Bells Barbershop on the corner of Greenwood and Archer. Their home was burned down during the riot and the family rebuilt it.

205. Plaintiff LISA PRESLEY is the great grandchild of Lucinda Pittman Davis, granddaughter of Lucinda Davis Pittman and daughter of Doris Patricia Presley. At the time of the Riot, Lucinda Pittman Davis, Lucinda Davis Pittman lived in the Greenwood District of Tulsa. The Davis s family home was burned to the ground during the Tulsa Race Riot and all the family s property was lost.

206. Plaintiffs JILL ELIZABETH PRESLEY is the great grandchild of Lucinda Pittman Davis, granddaughter of Lucinda Davis Pittman and daughter of Doris Patricia Presley. At the time of the Riot, Lucinda Pittman Davis, Lucinda Davis Pittman lived in the Greenwood District of Tulsa. The Davis s family home was burned to the ground during the Tulsa Race Riot and all the family s property was lost.

207. Plaintiff JEAN WILLIAMS MCGILL is the niece of Judge Amos T. Hall. At the time of the Riot, Judge Amos T. Hall lived in the Greenwood District of Tulsa. Plaintiff s uncle was seriously injured during the Tulsa Race Riot.

208. Plaintiff MATTIE DAVIS OLIVER is the daughter of Mary Ella Green. At the time of the Riot, Mary Ella Green lived in the Greenwood District of Tulsa with her sister. Ms. Ella Green and her sister fled when the riot began to an all-African American town, Wybark, OK. They met other African Americans on the Muskogee Bridge attempting to cross the bridge to come to Tulsa to assist the Greenwood residents. White policemen prevented them from entering Tulsa.

209. Plaintiff ALLENE KNIGHTEN RAYFORD is the child of James and Julia Knighten. Plaintiff is the sister of Plaintiff JAMES BERNARD KNIGHTEN. At the time of the Riot, James and Julia Knighten lived in the Greenwood District of Tulsa. Plaintiff s parents lost everything in the Tulsa Race Riot including the family home, a small rental house, service station, small shop and a tow story store front building. They also lost a car and a truck. The approximate value of the property lost is $100,000 including furnishings.

210. Plaintiff JAMES BERNARD KNIGHTEN is the child of James and Julia Knighten. Plaintiff is the brother of Plaintiff ALLENE KNIGHTEN RAYFORD. At the time of the Riot, James and Julia Knighten lived in the Greenwood District of Tulsa. Plaintiff s parents lost everything in the Tulsa Race Riot including the family home, a small rental house, service station, small shop and a tow story store front building. They also lost a car and a truck. The approximate value of the property lost is $100,000 including furnishings.

211. Plaintiff BERNICE LAWLER is the daughter of Wilma Kirkwood. Plaintiff is the sister of Plaintiff LORRAINE MCFARLAND. At the time of the Riot, Wilma Kirkwood lived in the Greenwood District of Tulsa. Plaintiffs mother witnessed the white mob lynch an African American during the Tulsa Race Riot.

212. Plaintiff LORRAINE MCFARLAND is the daughter of Wilma Kirkwood. Plaintiff is the sister of Plaintiff BERNICE LAWLER. At the time of the Riot, Wilma Kirkwood lived in the Greenwood District of Tulsa. Plaintiffs mother witnessed the white mob lynch an African American during the Tulsa Race Riot.

213. Plaintiff THELMA KINLAW GERMANY is the daughter of Evans and Caldonia Collins Kinlaw. At the time of the Riot, Evans and Caldonia Collins Kinlaw rented a home in Greenwood District of Tulsa. During the Riot the home was burned and they lost all their personal property.

214. Plaintiff DOROTHY JONES is the child of Ruth Fowler Martin and the grandchild of Richard and Viola Fowler (Huggins). Plaintiff is the sister of , NANCY MARTIN, CATHERINE MARTIN, JAMES PRESTON MARTIN, FELTON MARTIN, LESLIE BEARD. At the time of the Riot, Ruth Fowler Martin, Richard Fowler, and Viola Fowler lived in the Greenwood District of Tulsa. Plaintiff s mother fled with her husband, Richard Fowler, with her child, Ruth Fowler, from the rioting white mob. The rioting white mob burned down their home and destroyed all their property.

215. Plaintiff NANCY MARTIN is the child of Ruth Fowler Martin and the grandchild of Richard and Viola Fowler (Huggins). Plaintiff is the sister of Plaintiff DOROTHY JONES, CATHERINE MARTIN, JAMES PRESTON MARTIN, FELTON MARTIN, LESLIE BEARD. At the time of the Riot, Ruth Fowler Martin, Richard Fowler, and Viola Fowler lived in the Greenwood District of Tulsa. Plaintiff s mother fled with her husband, Richard Fowler, with her child, Ruth Fowler, from the rioting white mob. The rioting white mob burned down their home and destroyed all their property.

216. Plaintiff CATHERINE MARTIN is the child of Ruth Fowler Martin and the grandchild of Richard and Viola Fowler (Huggins). Plaintiff is the sister of Plaintiffs DOROTHY JONES, NANCY MARTIN, JAMES PRESTON MARTIN, FELTON MARTIN, LESLIE BEARD. At the time of the Riot, Ruth Fowler Martin, Richard Fowler, and Viola Fowler lived in the Greenwood District of Tulsa. Plaintiff s mother fled with her husband, Richard Fowler, with her child, Ruth Fowler, from the rioting white mob. The rioting white mob burned down their home and destroyed all their property.

217. Plaintiff JAMES PRESTON MARTIN is the child of Ruth Fowler Martin and the grandchild of Richard and Viola Fowler (Huggins). Plaintiff is the brother of Plaintiffs DOROTHY JONES, NANCY MARTIN, CATHERINE MARTIN, FELTON MARTIN, LESLIE BEARD. At the time of the Riot, Ruth Fowler Martin, Richard Fowler, and Viola Fowler lived in the Greenwood District of Tulsa. Plaintiff s mother fled with her husband, Richard Fowler, with her child, Ruth Fowler, from the rioting white mob. The rioting white mob burned down their home and destroyed all their property.

218. Plaintiff FELTON MARTIN is the child of Ruth Fowler Martin and the grandchild of Richard and Viola Fowler (Huggins). Plaintiff is the brother of DOROTHY JONES, NANCY MARTIN, CATHERINE MARTIN, JAMES PRESTON MARTIN, LESLIE BEARD. At the time of the Riot, Ruth Fowler Martin, Richard Fowler, and Viola Fowler lived in the Greenwood District of Tulsa. Plaintiff s mother fled with her husband, Richard Fowler, with her child, Ruth Fowler, from the rioting white mob. The rioting white mob burned down their home and destroyed all their property.

219. Plaintiff LESLIE BEARD is the child of Ruth Fowler Martin and the grandchild of Richard and Viola Fowler (Huggins). Plaintiff is the sister of Plaintiffs DOROTHY JONES, NANCY MARTIN, CATHERINE MARTIN, JAMES PRESTON MARTIN, FELTON MARTIN. At the time of the Riot, Ruth Fowler Martin, Richard Fowler, and Viola Fowler lived in the Greenwood District of Tulsa. Plaintiff s mother fled with her husband, Richard Fowler, with her child, Ruth Fowler, from the rioting white mob. The rioting white mob burned down their home and destroyed all their property.

220. Plaintiff MARY PRISCILLA PARKER HARRISON is the daughter of Ellen Ursuline Richards Tillman. Plaintiff is the sister of and GENIEIVE JACKSON. At the time of the Riot, Ellen Ursuline Richards Tillman lived in the Greenwood District of Tulsa.

221. Plaintiff GENIEIVE JACKSON is the daughter of Ellen Ursuline Richards Tillman. Plaintiff is the sister of Plaintiff MARY PRISCILLA PARKER HARRISON. At the time of the Riot, Ellen Ursuline Richards Tillman lived in the Greenwood District of Tulsa.

222. Plaintiff DIANA LYNN SHELTON is the daughter of Billy Shelton and granddaughter of Ollie Steele. Plaintiff is the sister of Plaintiff and SHIRLEY SHELTON. At the time of the Riot, Ollie Steele was a hairdresser and beauty shop owner in the Greenwood District of Tulsa. Ollie Steele was crippled in the riot. She was shot in the legs and her legs were burned. She kept her legs wrapped with surgical wrap and walked with a cane the rest of her life.

223. Plaintiff SHIRLEY SHELTON is the daughter of Billy Shelton and granddaughter of Ollie Steele. Plaintiff is the sister of Plaintiff DIANA LYNN SHELTON. At the time of the Riot, Ollie Steele was a hairdresser and beauty shop owner in the Greenwood District of Tulsa. Ollie Steele was crippled in the riot. She was shot in the legs and her legs were burned. She kept her legs wrapped with surgical wrap and walked with a cane the rest of her life.

224. Plaintiff OSCAR BOYD is the grandchild of Mr. and Mrs. Willie Staples and the children of Gertrude Staples. At the time of the Tulsa Race Riot, their mother was 19 years old and lived with their grandparents in the Greenwood District of Tulsa. The rioting white mob burned their home to the ground.

225. Plaintiff ALICE BOYD VAUGHN is the grandchild of Mr. and Mrs. Willie Staples and the children of Gertrude Staples. At the time of the Tulsa Race Riot, their mother was 19 years old and lived with their grandparents in the Greenwood District of Tulsa. The rioting white mob burned their home to the ground.

226. Plaintiff HELEN SIPUELHUGGINS is the daughter of Rev. Travis B. and Martha Bell Smith Sipuel. At the time of the Riot, Rev. Travis B. and Martha Bell Smith Sipuel lived in the Greenwood District of Tulsa. The rioting white mob burned Plaintiff s parent s home to the ground and all their personal property lost. Her father, who was a dark skinned African American, was taken by the militia to McNulty Park. Her mother was very light in complexion and was standing in front of the home watching it burn. A militia officer saw her mother standing their and asked: Lady, what are you doing her? and the mother could not respond so he said Well, you d better get yourself back to the white part of town before the niggers get ahold of you. Shortly thereafter her parents moved to Chicksaw, Oklahoma.

227. Plaintiff LAVADA LOUISE PARKER OSBOURNE is the daughter of Steve and Mary Lue Hicks Parker. At the time of the Riot, Steve and Mary Lue Hicks Parker owned a home and Parker s Grocery and Restaurant which was located at 1439 Iroquois Street in the Greenwood District of Tulsa. Plaintiff s parents were unlawfully detained against their will in one of the detention centers.

228. Plaintiff LAWRENCE HERMAN DENNIE is the grandchild of Howard and Ida Rodgers. At the time of the Riot, Howard and Ida Rodgers lived in the 100 or 200 block of Hartford Street in the Greenwood District of Tulsa. Plaintiff s parents home was seriously damaged during the Tulsa Race Riot. Their uncle, George Dennie, Jr. was injured during the Tulsa Race Riot and hospitalized.

229. Plaintiff ALFREDA O. DENNIE FRANKLIN is the grandchild of Howard and Ida Rodgers. At the time of the Riot, Howard and Ida Rodgers lived in the 100 or 200 block of Hartford Street in the Greenwood District of Tulsa. Plaintiff s parents home was seriously damaged during the Tulsa Race Riot. Their uncle, George Dennie, Jr. was injured during the Tulsa Race Riot and hospitalized.

230. Plaintiff NORMAN JEAN DENNIE LESHIE is the grandchild of Howard and Ida Rodgers. At the time of the Riot, Howard and Ida Rodgers lived in the 100 or 200 block of Hartford Street in the Greenwood District of Tulsa. Plaintiff s parents home was seriously damaged during the Tulsa Race Riot. Their uncle, George Dennie, Jr. was injured during the Tulsa Race Riot and hospitalized.

231. Plaintiff FRANK EUGENE RODGERS is the grandchild of Howard and Ida Rodgers. At the time of the Riot, Howard and Ida Rodgers lived in the 100 or 200 block of Hartford Street in the Greenwood District of Tulsa. Plaintiff s parents home was seriously damaged during the Tulsa Race Riot. Their uncle, George Dennie, Jr. was injured during the Tulsa Race Riot and hospitalized.

232. Plaintiff IDA LOUISE DENNIE WILLIS is the grandchild of Howard and Ida Rodgers. At the time of the Riot, Howard and Ida Rodgers lived in the 100 or 200 block of Hartford Street in the Greenwood District of Tulsa. Plaintiff s parents home was seriously damaged during the Tulsa Race Riot. Their uncle, George Dennie, Jr. was injured during the Tulsa Race Riot and hospitalized.

233. Plaintiff EDNA EARLY WORKS is the grandchild of Howard and Ida Rodgers. At the time of the Riot, Howard and Ida Rodgers lived in the 100 or 200 block of Hartford Street in the Greenwood District of Tulsa. Plaintiff s parents home was seriously damaged during the Tulsa Race Riot. Their uncle, George Dennie, Jr. was injured during the Tulsa Race Riot and hospitalized.

234. Plaintiff LEONA JERRYE BRUNER ANTHONY is an individual residing residing in Marshall, Texas. Plaintiff is the sister of Plaintiff CLIFTON JOE TIPTON. Plaintiff is the daughter of Corinne Lillian Lucas Tipton Bruner. At the time of the Riot, Corinne Lillian Lucas Tipton Bruner lived at 634 E. Jasper in the Greenwood District of Tulsa. Her home was damaged when part of it was burned in the Riot.

235. Plaintiff CLIFTON JOE TIPTON is an individual residing in Tulsa, Oklahoma. Plaintiff is the brother of Plaintiff LEONA JERRYE BRUNER ANTHONY. Plaintiff is the son of Corinne Lillian Lucas Tipton Bruner. At the time of the Riot, Corinne Lillian Lucas Tipton Bruner lived at 634 E. Jasper in the Greenwood District of Tulsa. Her home was damaged when part of it was burned in the Riot.

236. Plaintiff NAOMI LAWSON BROWN is an individual residing in Colorado Springs, Colorado. Plaintiff is the sister of Plaintiffs EDWARD LAWSON, WILBUR FOSTER, and RONALD EARL MOORE. Plaintiffs are the sons and daughters of Naomi Foster Moore and the grandson of Mattie Pearl Calhoun. At the time of the Riot, Naomi Foster Moore and Mattie Pearl Calhoun lived in the Greenwood District of Tulsa.

237. Plaintiff EDWARD LAWSON is an individual residing in Beverly Hills, California. Plaintiff is the brother of Plaintiffs NAOMI LAWSON BROWN, WILBUR FOSTER, and RONALD EARL MOORE. Plaintiffs are the sons and daughters of Naomi Foster Moore and the grandson of Mattie Pearl Calhoun. At the time of the Riot, Naomi Foster Moore and Mattie Pearl Calhoun lived in the Greenwood District of Tulsa.

238. Plaintiff WILBUR FOSTER is an individual residing in Los Angeles, California. Plaintiff is the brother of Plaintiffs NAOMI LAWSON BROWN, EDWARD LAWSON, and RONALD EARL MOORE. Plaintiffs are the sons and daughters of Naomi Foster Moore and the grandson of Mattie Pearl Calhoun. At the time of the Riot, Naomi Foster Moore and Mattie Pearl Calhoun lived in the Greenwood District of Tulsa.

239. Plaintiff RONALD EARL MOORE is an individual residing in Springfield, Missouri. Plaintiff is the brother of Plaintiffs NAOMI LAWSON BROWN, EDWARD LAWSON, and WILBUR FOSTER is an individual residing in Los Angeles, California. Plaintiffs are the sons and daughters of Naomi Foster Moore and the grandson of Mattie Pearl Calhoun. At the time of the Riot, Naomi Foster Moore and Mattie Pearl Calhoun lived in the Greenwood District of Tulsa.

240. Plaintiff MARCUS LAWSON is an individual residing in Colorado Springs, Colorado. Plaintiff is the brother of Plaintiffs NAOMI LAWSON BROWN, EDWARD LAWSON, WILBUR FOSTER, and RONALD EARL MOORE. Plaintiffs are the sons and daughters of Naomi Foster Moore and the grandson of Mattie Pearl Calhoun. At the time of the Riot, Naomi Foster Moore and Mattie Pearl Calhoun lived in the Greenwood District of Tulsa.

241. Plaintiff MARGARET ANN LAWSON is an individual residing in Colorado Springs, Colorado. Plaintiff is the sister of Plaintiffs NAOMI LAWSON BROWN, EDWARD LAWSON, WILBUR FOSTER, and RONALD EARL MOORE. Plaintiffs are the sons and daughters of Naomi Foster Moore and the grandson of Mattie Pearl Calhoun. At the time of the Riot, Naomi Foster Moore and Mattie Pearl Calhoun lived in the Greenwood District of Tulsa.

242. Plaintiff BERNARD CARTER is an individual residing in Compton, California. Plaintiff EDDIE HUE CARTER is an individual residing in Compton, California. Plaintiff ROBERT CARTER, JR. is in individual residing in Bakersfield, California. Plaintiff SAMUEL LEE CARTER is in individual residing in Bakersfield, California. Plaintiff BOBBIE JEAN CARTER TENNYSON is an individual residing in Tulsa, Oklahoma. Plaintiffs are the sons of Robert and Juanita Carter. At the time of the Riot, Robert and Juanita Carter lived in the Greenwood District of Tulsa.

243. Plaintiff JOHNYE CANNON LAWSON is an individual residing in Houston, Texas. Plaintiff is the sister of Plaintiffs NATHANIEL CANNON, HENRY CANNON, and MILDRED CANNON WALLACE. Plaintiffs are the sons and daughters Johnnye M. Mitchell Cannon and grandchildren of Charles and Jessie Mitchell. At the time of the Riot, Johnnye M. Mitchell Cannon, Charles Cannon, and Jessie Mitchell lived in the Greenwood District of Tulsa. Plaintiffs mother and grandparents were forced to flee Greenwood in order save their lives. Plaintiffs parents and grandparent s home was burned to the ground.

244. Plaintiff NATHANIEL CANNON is an individual residing in Muskogee, Oklahoma. Plaintiff is the brother of Plaintiffs JOHNYE CANNON LAWSON, HENRY CANNON, and CANNON WALLACE. Plaintiffs are the sons and daughters Johnnye M. Mitchell Cannon and grandchildren of Charles and Jessie Mitchell. At the time of the Riot, Johnnye M. Mitchell Cannon, Charles Cannon, and Jessie Mitchell lived in the Greenwood District of Tulsa. Plaintiffs mother and grandparents were forced to flee Greenwood in order save their lives. Plaintiffs parents and grandparent s home was burned to the ground.

245. Plaintiff HENRY CANNON is an individual residing in Tulsa, Oklahoma. Plaintiff is the brother of Plaintiffs JOHNYE CANNON LAWSON, NATHANIEL CANNON, and MILDRED CANNON WALLACE. Plaintiffs are the sons and daughters Johnnye M. Mitchell Cannon and grandchildren of Charles and Jessie Mitchell. At the time of the Riot, Johnnye M. Mitchell Cannon, Charles Cannon, and Jessie Mitchell lived in the Greenwood District of Tulsa. Plaintiffs mother and grandparents were forced to flee Greenwood in order save their lives. Plaintiffs parents and grandparent s home was burned to the ground.

246. Plaintiff MILDRED CANNON WALLACE is an individual residing in Houston, Texas. Plaintiff is the sister of Plaintiffs JOHNYE CANNON LAWSON, NATHANIEL CANNON, and HENRY CANNON. Plaintiffs are the sons and daughters Johnnye M. Mitchell Cannon and grandchildren of Charles and Jessie Mitchell. At the time of the Riot, Johnnye M. Mitchell Cannon, Charles Cannon, and Jessie Mitchell lived in the Greenwood District of Tulsa. Plaintiffs mother and grandparents were forced to flee Greenwood in order save their lives. Plaintiffs parents and grandparent s home was burned to the ground.

247. Plaintiff SARAH CURVAY MAYSHAW is an individual residing in Tulsa, Oklahoma. Plaintiff was born on June 13, 1923. Plaintiff is the daughter of Arthur Chester Curvay and Mattie Owens Curvay. At the time of the Riot, Arthur Chester Curvay and Mattie Owens Curvay resided at 1411 N. Owasso in the Greenwood District of Tulsa. The house was ransacked and damaged by the white mob. The only personal property remaining at the house was a pair of rubber boots with $300.00 hidden inside.

248. Plaintiff LINDA EDMONDSON GRAVES is an individual residing in Tulsa, Oklahoma. Plaintiff is the daughter of Luther Edmondson. At the time of the Riot, Luther Edmondson lived in the Greenwood District of Tulsa. Plaintiff s father damaged his knees while swimming across the Arkansas River to escape the white mob and fled to Sapulpa, west of Tulsa.

249. Plaintiff NAOMI NASH WILLIAMS WIMBERLY is an individual residing in Tulsa, Oklahoma. Plaintiff is the daughter of Mable Carter and granddaughter of Emma Hervey. At the time of the Riot, Mable Carter Emma Hervey lived in the Greenwood District of Tulsa. During the Riot, the Rioting white mob burned Plaintiff s home to the ground.

250. Plaintiff PATRICIA WILLIAMS is an individual residing in Tulsa, Oklahoma. Plaintiff was born on July 10, 1915. Plaintiff is the daughter of Delteresa Starr and the granddaughter of Beatrice Hughes and great-grandaughter of Mary Hughes Simmons. At the time of the Riot, Delteresa Starr, Beatrice Hughes, Mary Hughes Simmons were residents of the Greenwood District of Tulsa. Plaintiff and her mother left Tulsa after the Riot for economic reasons.

251. Plaintiff PEGGY ANN MCRUFFIN MITCHELL is an individual residing in Dallas, Texas. Plaintiff is the daughter of John B.and Hattie Johnson McRuffin. At the time of the Riot, John B. Ruffin and Hattie Johnson McRuffin resided in the Greenwood District of Tulsa. Plaintiff s family home was destroyed as well as all the famlily s personal possessions including jewelry, a fur coat and clothing. Plaintiff s parents escaped to St. Louis and later moved to Detroit Michigan.

252. Plaintiff AUDELE MCLEOD BEEKS is an individual residing in St. Louis, Missouri. Plaintiff is the sister of Plaintiffs FELICIA MCLEOD JOHNSON and WALLACE MCLEOD. Plaintiffs are the sons and daughters of Wallace McLeod, Sr. and Bessie Audele Beatty McLeod. At the time of the Riot, Wallace McLeod, Sr. and Bessie Audele Beatty McLeod lived at 301 N. Elgin in the Greenwood District of Tulsa. The rioting white mob burned their home to the ground. Plaintiff s father was unlawfully detained against his will at the Convention Center detention center.

253. Plaintiff FELICIA MCLEOD JOHNSON is an individual residing in Los Angeles, California. Plaintiff is the sister of Plaintiffs AUDELE MCLEOD BEEKS and WALLACE MCLEOD, JR. is in individual residing in Tulsa. Plaintiffs are the sons and daughters of Wallace McLeod, Sr. and Bessie Audele Beatty McLeod. At the time of the Riot, Wallace McLeod, Sr. and Bessie Audele Beatty McLeod lived at 301 N. Elgin in the Greenwood District of Tulsa. The rioting white mob burned their home to the ground. Plaintiff s father was unlawfully detained against his will at the Convention Center detention center.

254. Plaintiff WALLACE MCLEOD, JR. is in individual residing in Tulsa. Plaintiff is the brother of Plaintiffs AUDELE MCLEOD BEEKS and FELICIA MCLEOD JOHNSON. Plaintiffs are the sons and daughters of Wallace McLeod, Sr. and Bessie Audele Beatty McLeod. At the time of the Riot, Wallace McLeod, Sr. and Bessie Audele Beatty McLeod lived at 301 N. Elgin in the Greenwood District of Tulsa. The rioting white mob burned their home to the ground. Plaintiff s father was unlawfully detained against his will at the Convention Center detention center.

255. Plaintiff DELLA SHELTON JACKSON an individual residing in Oklahoma City, Oklahoma. Plaintiff is the grandchild of Trishie Wright. At the time of the Riot, Trishie Wright lived in the Greenwood District of Tulsa.

256. Plaintiff JOHNNY SHELTON an individual residing in Los Angeles, California. Plaintiff FAYE MAY is an individual residing in Oklahoma. Plaintiff is the grandchild of Trishie Wright. At the time of the Riot, Trishie Wright lived in the Greenwood District of Tulsa.

257. Plaintiff FAYE MAY is an individual residing in Oklahoma. Plaintiff is the grandchild of Trishie Wright. At the time of the Riot, Trishie Wright lived in the Greenwood District of Tulsa.

258. Plaintiff BETTY ANDERSON is an individual residing in Edmond, Oklahoma. Plaintiff is the grandchild of Trishie Wright. At the time of the Riot, Trishie Wright lived in the Greenwood District of Tulsa.

259. Plaintiff MAIME SHELTON is an individual residing in Los Angeles, California. Plaintiff is the grandchild of Trishie Wright. At the time of the Riot, Trishie Wright lived in the Greenwood District of Tulsa.

260. Plaintiff BILLY SHELTON is an individual residing in Oklahoma City, Oklahoma. Plaintiff is the grandchild of Trishie Wright. At the time of the Riot, Trishie Wright lived in the Greenwood District of Tulsa.

261. Plaintiff MARGARET LEE is an individual residing in Oklahoma. Plaintiff is the grandchild of Trishie Wright. At the time of the Riot, Trishie Wright lived in the Greenwood District of Tulsa.

262. Plaintiff EUNA VANN SMITH is an individual residing in Tulsa, Oklahoma. Plaintiff is the daughter of Guy Vann and Ida Whitmore Vann. At the time of the Riot, Guy Vann and Ida Whitmore Vann lived in the Greenwood District of Tulsa.

263. Plaintiff MARIETTA ANDERSON WAITERS is an individual residing in Valley Springs, California. Plaintiff is the sister of Plaintiffs DIANNE ANDERSON STEELE, ROBERT EARL ANDERSON, and RHONDA ANDERSON. Plaintiffs are the children of Mary Franklin Anderson. At the time of the Riot, Mary Franklin Anderson lived in the Greenwood District of Tulsa.

264. Plaintiff DIANNE ANDERSON STEELE is an individual residing in Compton California. Plaintiff is the sister of Plaintiffs MARIETTA ANDERSON WAITERS, ROBERT EARL ANDERSON, and RHONDA ANDERSON. Plaintiffs are the children of Mary Franklin Anderson. At the time of the Riot, Mary Franklin Anderson lived in the Greenwood District of Tulsa.

265. Plaintiff ROBERT EARL ANDERSON is an individual residing in Compton, California. Plaintiff is the brother of Plaintiffs MARIETTA ANDERSON WAITERS, DIANNE ANDERSON STEELE, and RHONDA ANDERSON. Plaintiffs are the children of Mary Franklin Anderson. At the time of the Riot, Mary Franklin Anderson lived in the Greenwood District of Tulsa.

266. Plaintiff RHONDA ANDERSON is an individual residing in Tulsa, Oklahoma. Plaintiff is the sister of Plaintiffs MARIETTA ANDERSON WAITERS, DIANNE ANDERSON STEELE, and ROBERT EARL ANDERSON. Plaintiffs are the children of Mary Franklin Anderson. At the time of the Riot, Mary Franklin Anderson lived in the Greenwood District of Tulsa.

267. Plaintiff IRMA THOMAS ANTHONY is an individual residing in Tulsa, Oklahoma. Plaintiff is the sister of Plaintiffs LEONTYNE THOMAS HARRELL and JERRY FIELDS THOMAS. At the time of the Riot, Myrtle Fields Parker lived in the Greenwood District of Tulsa.

268. Plaintiff LEONTYNE THOMAS HARRELL is an individual residing in Oakland California. Plaintiff is the sister of Plaintiffs IRMA THOMAS ANTHONY and JERRY FIELDS THOMAS. Plaintiffs are the children of Myrtle Fields Parker. At the time of the Riot, Myrtle Fields Parker lived in the Greenwood District of Tulsa.

269. Plaintiff JERRY FIELDS THOMAS is an individual residing in Oklahoma City, Oklahoma. Plaintiff is the brother of Plaintiffs IRMA THOMAS ANTHONY and LEONTYNE THOMAS HARRELL. Plaintiffs are the children of Myrtle Fields Parker. At the time of the Riot, Myrtle Fields Parker lived in the Greenwood District of Tulsa.

270. Plaintiff OVEID LACY III is the brother of Plaintiff ROBERT LACY. Plaintiffs are the sons of Oveid Lacy Jr. At the time of the Riot, Oveid Lacy Jr. lived in the Greenwood District of Tulsa.

271. Plaintiff ROBERT LACY is the brother of Plaintiff OVEID LACY III. Plaintiffs are the sons of Oveid Lacy Jr. At the time of the Riot, Oveid Lacy Jr. lived in the Greenwood District of Tulsa.

272. Plaintiff NICKOLAS A. BANKS is an individual residing in Vancouver, Washington. Plaintiff is the brother of Plaintiffs BERNICE E. DAVIS and AUDREY PARSONS. Plaintiffs are the children of Nick Banks. At the time of the Riot, Nick Banks owned a pool hall, and worked as a chef at the Ketchum Hotel in the Greenwood District of Tulsa.

273. Plaintiff BERNICE E. DAVIS is an individual residing in Milwaukie, Oregon. Plaintiff is the sister of Plaintiffs NICKOLAS A. BANKS and AUDREY PARSONS. Plaintiffs are the children of Nick Banks. At the time of the Riot, Nick Banks owned a pool hall, and worked as a chef at the Ketchum Hotel in the Greenwood District of Tulsa.

274. Plaintiff AUDREY PARSONS is an individual residing in Milwaukie, Oregon. Plaintiff is the sister of Plaintiffs NICKOLAS A. BANKS and BERNICE E. DAVIS. Plaintiffs are the children of Nick Banks. At the time of the Riot, Nick Banks owned a pool hall, and worked as a chef at the Ketchum Hotel in the Greenwood District of Tulsa.

275. Plaintiff MAE ETTA REYNOLDS is an individual residing in Tulsa, Oklahoma. Plaintiff is the sister of Plaintiff LEROY KIRK, JR. Plaintiffs are the children of Mary Payne. At the time of the Riot, Mary Payne lived in the Greenwood District of Tulsa.

276. Plaintiff JOHN W. PATTON is an individual residing in Edmond, Oklahoma. Plaintiff is the son of Calvin Patton. At the time of the Riot, Calvin Patton lived in the Greenwood District of Tulsa.

277. Plaintiff JO ANN EWING is an individual residing in Aurora, Colorado. Plaintiff is the sister of Plaintiffs WANDA EWING POPE, ROBERT EWING, and BILL EWING Plaintiffs are the children of Eva Small. At the time of the Riot, Eva Small lived in the Greenwood District of Tulsa.

278. Plaintiff WANDA EWING POPE is an individual residing in Accra, Ghana, West Africa. Plaintiff is the sister of Plaintiffs JO ANN EWING, ROBERT EWING, and BILL EWING. Plaintiffs are the children of Eva Small. At the time of the Riot, Eva Small lived in the Greenwood District of Tulsa.

279. Plaintiff ROBERT EWING is an individual residing in Oakland, California. Plaintiff is the brother of Plaintiffs JO ANN EWING, WANDA EWING POPE, and BILL EWING is an individual residing in Louisville, Colorado. Plaintiffs are the children of Eva Small. At the time of the Riot, Eva Small lived in the Greenwood District of Tulsa.

280. Plaintiff BILL EWING is an individual residing in Louisville, Colorado. Plaintiff is the brother of Plaintiffs JO ANN EWING, WANDA EWING POPE, and ROBERT EWING. Plaintiffs are the children of Eva Small. At the time of the Riot, Eva Small lived in the Greenwood District of Tulsa.

281. Plaintiff BOBBYE LOUISE GILBERT is an individual residing in Midland, Texas. Plaintiff is the sister of Plaintiff FANNIE WILLIAMS. Plaintiffs are children of Joseph and Mamie Henderson. At the time of the Riot, Joseph Henderson and Mamie Henderson lived in the Greenwood District of Tulsa.

282. Plaintiff FANNIE WILLIAMS is an individual residing in Arlington, Texas. Plaintiff is the sister of Plaintiff BOBBYE LOUISE GILBERT. Plaintiffs are children of Joseph and Mamie Henderson. At the time of the Riot, Joseph Henderson and Mamie Henderson lived in the Greenwood District of Tulsa.

283. Plaintiff SIMON BERRY JR. is an individual residing in Los Angeles, California. Plaintiff is the son of Simon Berry Sr. At the time of the Riot, Simon Berry Sr., lived in the Greenwood District of Tulsa.

284. Plaintiff MARGUERITE BAGBY is an individual residing in Tulsa, Oklahoma. Plaintiff is the daughter of Anna Tolbert. At the time of the Riot, Anna Tolbert lived in the Greenwood District of Tulsa.

285. Plaintiff Maxine JESSIE VADEN is an individual residing in Tulsa, Oklahoma. Plaintiff is the sister of Plaintiff JOYCE RAMSEY. Plaintiffs are the daughters of Hosea Vaden and Linda Agnetta Vaden. At the time of the Riot, Hosea Vaden and Linda Agnetta Vaden lived in the Greenwood District of Tulsa.

286. Plaintiff JOYCE RAMSEY is an individual residing in Tulsa, Oklahoma. Plaintiff is the sister of Plaintiff Maxine JESSIE VADEN. Plaintiffs are the daughters of Hosea Vaden and Linda Agnetta Vaden. At the time of the Riot, Hosea Vaden and Linda Agnetta Vaden lived in the Greenwood District of Tulsa.

287. Plaintiff RAYMOND BEARD,SR. is an individual residing in Tulsa, Oklahoma. At the time of the Riot, Plaintiff s sister, Mary Beard, lived in the Greenwood District of Tulsa.

288. Plaintiff FLOYD PRICE is an individual residing in Tulsa, Oklahoma. Plaintiff is the brother of Plaintiff CAROLYN PRICE JOHNSON. Plaintiffs are the children of Ruth Fairchild Price. At the time of the Riot, Ruth Fairchild Price lived in the Greenwood District of Tulsa.

289. Plaintiff CAROLYN PRICE JOHNSON is an individual residing in Plano, Texas. Plaintiff is the sister of Plaintiff FLOYD PRICE. Plaintiffs are the children of Ruth Fairchild Price. At the time of the Riot, Ruth Fairchild Price lived in the Greenwood District of Tulsa.

290. Plaintiff MILDRED LOUISE DAVIS SCOTT is an individual residing in Detroit, Michigan. Plaintiff is the sister of Plaintiffs THERESA DAVIS SCOTT, FRED DAVIS, and SANDRA JEAN DAVIS LANDRUM. Plaintiffs are the surviving children of Thomas R. Davis and Rosa Davis. At the time of the Riot, Thomas R. Davis and Rosa Davis lived in the Greenwood District of Tulsa.

291. Plaintiff THERESA DAVIS SCOTT is an individual residing in Tulsa, Oklahoma. Plaintiff is the sister of Plaintiffs MILDRED LOUISE DAVIS SCOTT, FRED DAVIS, and SANDRA JEAN DAVIS LANDRUM. Plaintiffs are the surviving children of Thomas R. Davis and Rosa Davis. At the time of the Riot, Thomas R. Davis and Rosa Davis lived in the Greenwood District of Tulsa.

292. Plaintiff FRED DAVIS is an individual residing in Tulsa, Oklahoma. Plaintiff is the brother of Plaintiffs MILDRED LOUISE DAVIS SCOTT, THERESA DAVIS SCOTT, and SANDRA JEAN DAVIS LANDRUM is an individual residing in Tulsa, Oklahoma. Plaintiffs are the surviving children of Thomas R. Davis and Rosa Davis. At the time of the Riot, Thomas R. Davis and Rosa Davis lived in the Greenwood District of Tulsa.

293. Plaintiff SANDRA JEAN DAVIS LANDRUM is an individual residing in Tulsa, Oklahoma. Plaintiff is the sister of Plaintiffs MILDRED LOUISE DAVIS SCOTT, THERESA DAVIS SCOTT, and FRED DAVIS. Plaintiffs are the surviving children of Thomas R. Davis and Rosa Davis. At the time of the Riot, Thomas R. Davis and Rosa Davis lived in the Greenwood District of Tulsa.

294. Plaintiff ROSIE LEE JACKSON is an individual residing in Tulsa, Oklahoma. Plaintiff is the sister of Plaintiffs FRED SMITH, FANIIE SMITH VERNER, and ERMA SMITH THOMPSON. Plaintiffs are the children of Willis and Maggie Smith. At the time of the Riot, Willis and Maggie Smith lived in the Greenwood District of Tulsa.

295. Plaintiff FRED SMITH is an individual residing in Tulsa, Oklahoma. Plaintiff is the brother of Plaintiffs ROSIE LEE JACKSON, FANIIE SMITH VERNER, and ERMA SMITH THOMPSON. Plaintiffs are the children of Willis and Maggie Smith. At the time of the Riot, Willis and Maggie Smith lived in the Greenwood District of Tulsa.

296. Plaintiff FANIIE SMITH VERNER is an individual residing in Tulsa, Oklahoma. Plaintiff is the sister of Plaintiffs ROSIE LEE JACKSON, FRED SMITH, and ERMA SMITH THOMPSON. Plaintiffs are the children of Willis and Maggie Smith. At the time of the Riot, Willis and Maggie Smith lived in the Greenwood District of Tulsa.

297. Plaintiff ERMA SMITH THOMPSON is an individual residing in Montclair, California. Plaintiff is the sister of Plaintiffs ROSIE LEE JACKSON, FRED SMITH, and FANIIE SMITH VERNER. Plaintiffs are the children of Willis and Maggie Smith. At the time of the Riot, Willis and Maggie Smith lived in the Greenwood District of Tulsa.

298. Plaintiff DELORES HARRINGTON is an individual residing in St. Louis, Missouri. Plaintiff is the sister of Plaintiff SHIRLEY RIDLEY. Plaintiffs are the daughters of Marion Spears. At the time of the Riot, Marion Spears lived in the Greenwood District of Tulsa.

299. Plaintiff SHIRLEY RIDLEY is an individual residing in Chicago, Illinois. Plaintiff is the sister of Plaintiff Plaintiff DELORES HARRINGTON. Plaintiffs are the daughters of Marion Spears. At the time of the Riot, Marion Spears lived in the Greenwood District of Tulsa.

300. Plaintiff PAT MOORE is an individual residing in Tulsa, Oklahoma. Plaintiff is the granddaughter of Mattie King Mitchell. At the time of the Riot, Mattie King Mitchell lived in the Greenwood District of Tulsa.

301. Plaintiff SHIRLEY TYUS is an individual residing in Conway, Arkansas. Plaintiff is the granddaughter of Isaac Johnson. At the time of the Riot, Isaac Johnson lived in the Greenwood District of Tulsa.

302. Plaintiff SELMA LOCKARD is an individual residing in Tulsa, Oklahoma. Plaintiff is the sister of Plaintiffs FRANK LOCKARD, JESSIE MAE LOCKARD, EDWARD LOCKWARD, ERNEST LOCKARD, OSCAR LOCKARD, CORTEZ LOCKARD, and EMMA LOCKARD HORN. Plaintiffs are children of Joe Lockard and Rina Hawkins-Lockard. At the time of the Riot, Joe Lockard and Rina Hawkins-Lockard lived in the Greenwood District of Tulsa.

303. Plaintiff FRANK LOCKARD is an individual residing in Tulsa, Oklahoma. Plaintiff is the brother of Plaintiffs SELMA LOCKARD, JESSIE MAE LOCKARD, EDWARD LOCKWARD, ERNEST LOCKARD, OSCAR LOCKARD, CORTEZ LOCKARD, and EMMA LOCKARD HORN. Plaintiffs are children of Joe Lockard and Rina Hawkins-Lockard. At the time of the Riot, Joe Lockard and Rina Hawkins-Lockard lived in the Greenwood District of Tulsa.

304. Plaintiff JESSIE MAE LOCKARD is an individual residing in Detroit, Michigan. Plaintiff is the sister of Plaintiffs SELMA LOCKARD, FRANK LOCKARD, EDWARD LOCKWARD, ERNEST LOCKARD, OSCAR LOCKARD, CORTEZ LOCKARD, and EMMA LOCKARD HORN. Plaintiffs are children of Joe Lockard and Rina Hawkins-Lockard. At the time of the Riot, Joe Lockard and Rina Hawkins-Lockard lived in the Greenwood District of Tulsa.

305. Plaintiff EDWARD LOCKWARD is an individual residing in Chicago, Illinois. Plaintiff is the brother of Plaintiffs SELMA LOCKARD, FRANK LOCKARD, JESSIE MAE LOCKARD, ERNEST LOCKARD, OSCAR LOCKARD, CORTEZ LOCKARD, and EMMA LOCKARD HORN. Plaintiffs are children of Joe Lockard and Rina Hawkins-Lockard. At the time of the Riot, Joe Lockard and Rina Hawkins-Lockard lived in the Greenwood District of Tulsa.

306. Plaintiff ERNEST LOCKARD is an individual residing in Detroit, Michigan. Plaintiff is the brother of Plaintiffs SELMA LOCKARD, FRANK LOCKARD JESSIE MAE LOCKARD, EDWARD LOCKARD, OSCAR LOCKARD, CORTEZ LOCKARD, and EMMA LOCKARD HORN. Plaintiffs are children of Joe Lockard and Rina Hawkins-Lockard. At the time of the Riot, Joe Lockard and Rina Hawkins-Lockard lived in the Greenwood District of Tulsa.

307. Plaintiff OSCAR LOCKARD is an individual residing in Detroit, Michigan. Plaintiff is the brother of Plaintiffs SELMA LOCKARD, FRANK LOCKARD, JESSIE MAE LOCKARD, EDWARD LOCKWARD, ERNEST LOCKARD, CORTEZ LOCKARD, and EMMA LOCKARD HORN. Plaintiffs are children of Joe Lockard and Rina Hawkins-Lockard. At the time of the Riot, Joe Lockard and Rina Hawkins-Lockard lived in the Greenwood District of Tulsa.

308. Plaintiff CORTEZ LOCKARD is an individual serving in the United States Army and is stationed in Japan. Plaintiff is the brother of Plaintiffs SELMA LOCKARD, FRANK LOCKARD, JESSIE MAE LOCKARD, EDWARD LOCKWARD, ERNEST LOCKARD, OSCAR LOCKARD, and EMMA LOCKARD HORN. Plaintiffs are children of Joe Lockard and Rina Hawkins-Lockard. At the time of the Riot, Joe Lockard and Rina Hawkins-Lockard lived in the Greenwood District of Tulsa.

309. Plaintiff EMMA LOCKARD HORN is an individual residing in Muskogee, Oklahoma. Plaintiff is the sister of Plaintiffs SELMA LOCKARD, FRANK LOCKARD, JESSIE MAE LOCKARD, EDWARD LOCKWARD, ERNEST LOCKARD, OSCAR LOCKARD, and CORTEZ LOCKARD. Plaintiffs are children of Joe Lockard and Rina Hawkins-Lockard. At the time of the Riot, Joe Lockard and Rina Hawkins-Lockard lived in the Greenwood District of Tulsa.

310. Plaintiff PATRICIA WILLIAMS is an individual residing in Madison, Wisconsin. Plaintiff is the the grandchild of Deltessa Starr Williams. At the time of the Riot, Deltessa Starr Williams lived in the Greenwood District of Tulsa.

311. Plaintiff LORENZO CARLOS VANN is an individual residing in Tulsa, Oklahoma. Plaintiff is a descendant of Vera C. Marshall McGowen. At the time of the Riot, Vera C. Marshall owned Poro Beauty College in the Greenwood District of Tulsa. This property was destroyed by the rioting white mob.

312. Plaintiff CARRIE M. MCDONALD STROTHER an individual residing at Kansas City, Missouri. Plaintiff is a descendant of Carrie B. McDonald. At the time of the Riot, Carrie B. McDonald owned a boarding house/hotel, a restaurant, and a grocery store in the Greenwood District of Tulsa. The rioting white mob looted or burned Carrie B. McDonald s leather sofas and chairs and marble topped mahogany library tables during the Riot.

313. Plaintiff MARY A. WILSON is an individual residing at Englewood, Colorado. Plaintiff is a descendant of Dan Wilson, Violet Dixon Wilson, and Richard E. Wilson. At the time of the Riot, Dan Wilson, Violet Dixon Wilson, and Richard E. Wilson lived in the Greenwood District of Tulsa. Dan Wilson, who came to Tulsa from Kingfisher, Oklahoma, was captured during the Riot and disappeared.

314. Plaintiff JIMMIE WICKAM is an individual residing in McAlister, Oklahoma. Plaintiff is a descendant of Dr. Charles Wickham. At the time of the Riot, Dr. Charles Wickham lived across the street from Mount Zion Baptist Church in the Greenwood District of Tulsa.

315. Plaintiff FRANK WALKER, SR, an individual residing in Inglewood, California. Plaintiff is a descendant of Riley Walker, Sr., and Essie Walker. At the time of the Riot, Riley Walker, Sr., and Essie Walker resided at 423 E. Latimer Ct, in the Greenwood District of Tulsa.

316. Plaintiff DENNETTE MARIA WALKER is an individual residing in Tulsa, Oklahoma. Plaintiff is a descendant of Riley Walker, Sr., and Essie Walker. At the time of the Riot, Riley Walker, Sr., and Essie Walker resided at 423 E. Latimer Ct, in the Greenwood District of Tulsa.

317. Plaintiff RILEY WALKER, JR residing in Oakland, California. Plaintiff is a descendant of Riley Walker, Sr., and Essie Walker. At the time of the Riot, Riley Walker, Sr., and Essie Walker resided at 423 E. Latimer Ct, in the Greenwood District of Tulsa.

318. Plaintiff FRANK WALKER, JR, an individual residing in Inglewood, California. Plaintiff is a descendant of Riley Walker, Sr., and Essie Walker. At the time of the Riot, Riley Walker, Sr., and Essie Walker resided at 423 E. Latimer Ct, in the Greenwood District of Tulsa.

319. Plaintiff HARRY LEON WALKER is an individual residing in Richmond, California. Plaintiff is a descendant of Riley Walker, Sr., and Essie Walker. At the time of the Riot, Riley Walker, Sr., and Essie Walker resided at 423 E. Latimer Ct, in the Greenwood District of Tulsa.

320. Plaintiff HARRY DANIEL WALKER is an individual residing in Fullerton California. Plaintiff is a descendant of Riley Walker, Sr., and Essie Walker. At the time of the Riot, Riley Walker, Sr., and Essie Walker resided at 423 E. Latimer Ct, in the Greenwood District of Tulsa.

321. Plaintiff EDWINA WALKER CARR is an individual residing in Las Angeles, California. Plaintiff is a descendant of Raphael Walker. At the time of the Riot, Raphael Walker lived in the Greenwood District of Tulsa.

322. Plaintiff MARCIA WALKER PUCKETT is an individual residing in Chicago, Illinois. Plaintiff is a descendant of Raphael Walker. At the time of the Riot, Raphael Walker lived in the Greenwood District of Tulsa.

323. Plaintiff WILLIAM D. WALKER is an individual residing in Tulsa, Oklahoma. Plaintiff is a descendant of Raphael Walker. At the time of the Riot, Raphael Walker lived in the Greenwood District of Tulsa.

324. Plaintiff OLENE WALKER WASHINGTON is an individual residing in Tulsa, Oklahoma. Plaintiff is a descendant of Raphael Walker. At the time of the Riot, Raphael Walker lived in the Greenwood District of Tulsa.

325. Plaintiff JEANETTE HAWKINS is an individual residing in Chicago, Illinois. Plaintiff is a descendant of Clarence Hawkins, Jr. At the time of the Riot, Clarence Hawkins, Jr., lived in the Greenwood District of Tulsa.

326. Plaintiff OLANDER HAWKINS is an individual residing in Chicago, Illinois. PLAINTIFF is a descendant of Lula Hawkins. At the time of the Riot, Lula Hawkins lived in the Greenwood District of Tulsa.

327. Plaintiff STARLA HAWKINS is an individual residing in Denver, Colorado. Plaintiff is a descendant of Berzell Williams Hawkins. At the time of the Riot, Berzell Williams Hawkins lived in the Greenwood District of Tulsa.

328. Plaintiff CHARLOTTE WILLIAMS is an individual residing in Washington, D.C. Plaintiff is a descendant of Orlando Williams, Sr. At the time of the Riot Orlando Willard Williams, Sr, lived in the Greenwood District of Tulsa. His home was burned down during the Riot. In his home was a hidden trunk containing $1000.00, which was also lost.

329. Plaintiff NAOMI LAWSON BROWN is an individual residing in Colorado Springs, Colorado. Plaintiff is a descendant of Londy Bohannon and Travelene Bohannon Lawson. At the time of the Riot, Londy Bohannon and Travelene Bohannon Lawson lived the Greenwood District of Tulsa.

330. Plaintiff EDWARD LAWSON an individual residing in Beverly Hills, California. Plaintiff is a descendant of Londy Bohannon and Travelene Bohannon Lawson. At the time of the Riot, Londy Bohannon and Travelene Bohannon Lawson lived the Greenwood District of Tulsa.

331. Plaintiff MARCUS LAWSON is an individual residing in Buffalo, New York. Plaintiff is a descendant of Londy Bohannon and Travelene Bohannon Lawson. At the time of the Riot, Londy Bohannon and Travelene Bohannon Lawson lived the Greenwood District of Tulsa.

332. Plaintiff MARGARET ANN LAWSON is an individual residing in Buffalo, Oklahoma. Plaintiff is a descendant of Londy Bohannon and Travelene Bohannon Lawson. At the time of the Riot, Londy Bohannon and Travelene Bohannon Lawson lived the Greenwood District of Tulsa.

333. Plaintiff PALMER LAWSON, JR. is an individual residing in Buffalo, New York. Plaintiff is a descendant of Londy Bohannon and Travelene Bohannon Lawson. At the time of the Riot, Londy Bohannon and Travelene Bohannon Lawson lived the Greenwood District of Tulsa.

334. Plaintiff WILBUR FOSTER is a descendant of Mattie Pearl Calhoon. At the time of the Riot, Mattie Pearl Calhoon lived in the Greenwood District of Tulsa.

335. Plaintiff RONALD MOORE is a descendant of Mattie Pearl Calhoon. At the time of the Riot, Mattie Pearl Calhoon lived in the Greenwood District of Tulsa.

336. Plaintiff BERNARD CARTER is an individual residing in Compton, California. Plaintiff is a descendant of Robert Carter. At the time of the Riot, Robert Carter lived in the Greenwood District of Tulsa.

337. Plaintiff EDDIE CARTER is an individual residing in Compton, California. Plaintiff is a descendant of Robert Carter. At the time of the Riot, Robert Carter lived in the Greenwood District of Tulsa.

338. Plaintiff ROBERT CARTER, JR, is an individual residing in Bakersfield, California. Plaintiff is a descendant of Robert Carter. At the time of the Riot, Robert Carter lived in the Greenwood District of Tulsa.

339. Plaintiff SAMUEL LEE CARTER is an individual residing in Bakersfield, California. Plaintiff is a descendant of Robert Carter. At the time of the Riot, Robert Carter lived in the Greenwood District of Tulsa.

340. Plaintiff BOBBIE JEAN CARTER TENNYSON is an individual residing in Tulsa, Oklahoma. Plaintiff is a descendant of Robert Carter. At the time of the Riot, Robert Carter lived in the Greenwood District of Tulsa.

341. Plaintiff DOROTHY WILLIAMS BRANLETT is an individual residing in Tulsa, Oklahoma. Plaintiff is the grandchild of Fisher James Williams and Dinah Freeman Williams. At the time of the Riot, Fisher James Williams lived in the Greenwood District of Tulsa, and was injured during the Riot. Plaintiff s father died as a result of his injuries at St. John s Hospital on June 21, 1921.

342. Plaintiff GRANT WILLIAMS is an individual residing in University City, Missouri. Plaintiff is the grandchild of Fisher James Williams and Dinah Freeman Williams. At the time of the Riot, Fisher James Williams lived in the Greenwood District of Tulsa, and was injured during the Riot. Plaintiff s father died as a result of his injuries at St. John s Hospital on June 21, 1921.

343. Plaintiff TERRY NASH is the son of Oscar and Mollie Nash. At the time of the Riot, Plaintiff s parents lived on North Owasso Street in the Greenwood District of Tulsa at the time of the Riot. All of their property was destroyed during the Riot.

344. Plaintiff AUDREY TAYLOR is an individual residing in Tulsa, Oklahoma. Plaintiff is the descendant of Osborne Monroe, Lottie Monroe, and Ester Tyree. At the time of the Riot, Osborne Monroe, Lottie Monroe, and Ester Tyree lived in the Greenwood District of Tulsa.

345. Plaintiff BYRON TAYLOR is an individual residing in Tulsa, Oklahoma. Plaintiff is the descendant of Osborne Monroe, Lottie Monroe, and Ester Tyree. At the time of the Riot, Osborne Monroe, Lottie Monroe, and Ester Tyree lived in the Greenwood District of Tulsa.

346. Plaintiff GERALDINE PERRYMAN-TEASE is an individual residing in Tulsa, Oklahoma. The plaintiff is the daughter of Addie Perryman-Tease and the niece of Bob Perryman. At the time of the Riot, Addie Perryman-Tease and Bob Perryman lived in the Greenwood District of Tulsa. Bob Perryman was killed during the Riot.

347. Plaintiff MILDRED MARIAN HAMEL MILLER is an individual residing in Austin, Texas. Plaintiff is the descendant of Tom Swift Hamel and Luvenia Williams. At the time of the Riot, Tom Swift Hamel and Luvenia Williams lived in the Greenwood District of Tulsa.

348. Plaintiff LADAWNA MILLER is an individual residing in Austin, Texas. Plaintiff is the descendant of Tom Swift Hamel and Luvenia Williams. At the time of the Riot, Tom Swift Hamel and Luvenia Williams lived in the Greenwood District of Tulsa.

349. Plaintiff PATSY ROBINSON is the granddaughter of Pearl Oliver, the daughter of Montana Wright and the niece of Paris Oliver. At the time of the Riot, Pearl Oliver and Paris Oliver lived in the Greenwood District of Tulsa. Plaintiff and her family lived on Greenwood at the time of the Riot. Plaintiff s grandmother suffered an emotional and mental breakdown as a result of the Riot and was never the same. Plaintiff s uncle was harmed in the Riot. Plaintiff s family home was destroyed in the Riot.

350. Plaintiff MARGARET THARPE is the daughter of Geraldine Smith Marks, the granddaughter of Omega Smith and the great-granddaughter of Abigail Goodson. At the time of the Riot, Geraldine Smith Marks, Omega Smith and Abigail Goodson lived in the Greenwood District of Tulsa. Plaintiff s uncle disappeared during the Riot and was never heard from again.

351. Plaintiff MAXINE JACKSON LACY is the daughter of Ed and Cory Jackson and the granddaughter of Ella Johnson. At the time of the Riot, Ed Jackson, Cory Jackson, and Ella Johnson owned two homes, one on N. Owasso and the other on Easton near Mt. Zion Baptist Church. The house on Easton was completely destroyed in the Riot. Plaintiff s father attempted to escape with his family. Plaintiff s pregnant mother fell down during her escape. Plaintiff s family fled to Claremore, Oklahoma, where they were rescued by their employer, Miller Hamett. Plaintiff s grandmother, Ella Johnson disappeared and was never heard from again.

352. Plaintiff RAYMOND PRESLEY is the son of John Smith Presley and Josephine Davis Presley, and the grandson of Lucinda Davis. At the time of the Riot, Plaintiff s family owned a home on N. Greenwood in the Greenwood District of Tulsa. Plaintiff s grandmother, Lucinda Davis, who was a member of the Creek Nation, owned a home near Kyle s Drugstore. Her home and all of its contents were destroyed.

353. Plaintiff WILMA PRESLEY BELL is the descendant of John Smith Presley and Josephine Davis Presley, and the grandson of Lucinda Davis. At the time of the Riot, Plaintiff s family owned a home on N. Greenwood in the Greenwood District of Tulsa. Plaintiff s grandmother, Lucinda Davis, who was a member of the Creek Nation, owned a home near Kyle s Drugstore. Her home and all of its contents were destroyed.

354. Plaintiff MAYBELLINE PRESLEY HOOKS is the descendant of John Smith Presley and Josephine Davis Presley, and the grandson of Lucinda Davis. At the time of the Riot, Plaintiff s family owned a home on N. Greenwood in the Greenwood District of Tulsa. Plaintiff s grandmother, Lucinda Davis, who was a member of the Creek Nation, owned a home near Kyle s Drugstore. Her home and all of its contents were destroyed.

355. Plaintiff MILDREN PRELSEY KAVANAUGH is the descendant of John Smith Presley and Josephine Davis Presley, and the grandson of Lucinda Davis. At the time of the Riot, Plaintiff s family owned a home on N. Greenwood in the Greenwood District of Tulsa. Plaintiff s grandmother, Lucinda Davis, who was a member of the Creek Nation, owned a home near Kyle s Drugstore. Her home and all of its contents were destroyed.

356. Plaintiff BETTY PRESLEY MCMILLAN is the descendant of John Smith Presley and Josephine Davis Presley, and the grandson of Lucinda Davis. At the time of the Riot, Plaintiff s family owned a home on N. Greenwood in the Greenwood District of Tulsa. Plaintiff s grandmother, Lucinda Davis, who was a member of the Creek Nation, owned a home near Kyle s Drugstore. Her home and all of its contents were destroyed.

357. Plaintiff ELIZABETH PRESLEY MONDAY is the descendant of John Smith Presley and Josephine Davis Presley, and the grandson of Lucinda Davis. At the time of the Riot, Plaintiff s family owned a home on N. Greenwood in the Greenwood District of Tulsa. Plaintiff s grandmother, Lucinda Davis, who was a member of the Creek Nation, owned a home near Kyle s Drugstore. Her home and all of its contents were destroyed.

358. Plaintiff JOYCE MARIE PRESLEY is the descendant of John Smith Presley and Josephine Davis Presley, and the grandson of Lucinda Davis. At the time of the Riot, Plaintiff s family owned a home on N. Greenwood in the Greenwood District of Tulsa. Plaintiff s grandmother, Lucinda Davis, who was a member of the Creek Nation, owned a home near Kyle s Drugstore. Her home and all of its contents were destroyed.

359. Plaintiff RONALD DEAN PRESLEY is the descendant of John Smith Presley and Josephine Davis Presley, and the grandson of Lucinda Davis. At the time of the Riot, Plaintiff s family owned a home on N. Greenwood in the Greenwood District of Tulsa. Plaintiff s grandmother, Lucinda Davis, who was a member of the Creek Nation, owned a home near Kyle s Drugstore. Her home and all of its contents were destroyed.

360. Plaintiff LEON ROLLERSON is an individual residing in Tulsa, Oklahoma. He is the brother of plaintiffs ERIC ROLLERSON, YVONNNE ROLLERSON, and WILA ROLLERSON. Plaintiffs are the children of Lloyd and Myrtle Rollerson, who resided in the Greenwood District of Tulsa at the time of the Riot.

361. Plaintiff ERIC ROLLERSON is an individual residing in Tulsa, Oklahoma. He is the brother of LEON ROLLERSON, YVONNE ROLLERSON, and WILA ROLLERSON. Plaintiffs are the children of Lloyd and Myrtle Rollerson, who resided in the Greenwood District of Tulsa at the time of the Riot.

362. Plaintiff YVONNE WILLERSON is an individual residing in Tulsa, Oklahoma. She is the sister of ERIC ROLLERSON, LEON ROLLERSON, and WILA ROLLERSON. Plaintiffs are the children of Lloyd and Myrtle Rollerson, who resided in the Greenwood District of Tulsa at the time of the Riot.

363. Plaintiff WILA ROLLERSON is an individual residing in Tulsa, Oklahoma. She is the sister of LEON ROLLERSON, ERIC ROLLERSON, and YVONNE ROLLERSON. Plaintiffs are the children of Lloyd and Myrtle Rollerson, who resided in the Greenwood District of Tulsa at the time of the Riot.

364. Plaintiff STANLEY FAIR, JR. is an individual residing in Tulsa, Oklahoma. He is the brother of JANE FAIR PRUETT, BRENDA FAIR CAMPBELL, GERALDINE FAIR JESSIE, and YVONNE FAIR SHAW. Plaintiffs are the children of Stanley Fair, Sr., who resided in the Greenwood District of Tulsa at the time of the Riot.

365. Plaintiff JANE FAIR PRUETT is an individual residing in Tulsa, Oklahoma. She is the sister of STANLEY FAIR, JR., BRENDA FAIR CAMPBELL, GERALDINE FAIR JESSIE, and YVONNE FAIR SHAW. Plaintiffs are the children of Stanley Fair, Sr., who resided in the Greenwood District of Tulsa at the time of the Riot.

366. BRENDA FAIR CAMPBELL is an individual residing in Tulsa, Oklahoma. She is the sister of STANLEY FAIR, JR., JANE FAIR PRUETT, GERALDINE FAIR JESSIE, and YVONNE FAIR SHAW. Plaintiffs are the children of Stanley Fair, Sr., who resided in the Greenwood District of Tulsa at the time of the Riot.

367. Plaintiff GERALDINE FAIR JESSIE is an individual residing in Tulsa, Oklahoma. She is the sister of STANLEY FAIR, JR., JANE FAIR PRUETT, BRENDA FAIR CAMPBELL, and YVONNE FAIR SHAW. Plaintiffs are the children of Stanley Fair, Sr., who resided in the Greenwood District of Tulsa at the time of the Riot.

368. Plaintiff YVONE FAIR SHAW is an individual residing in Tulsa, Oklahoma. She is the sister of JANE FAIR PRUETT, BRENDA FAIR CAMPBELL, and GERALDINE FAIR JESSIE. Plaintiffs are the children of Stanley Fair, Sr., who resided in the Greenwood District of Tulsa at the time of the Riot.

369. Plaintiff AMY GAMBLE EIDSON is an individual residing in Tulsa, Oklahoma. She is the sister of EVA GAMBLE MORRIS. Plaintiffs are the children of Harry Gamble, Jr., who resided in the Greenwood District of Tulsa at the time of the Riot.

370. Plaintiff EVA GAMBLE MORRIS is an individual residing in Tulsa, Oklahoma. She is the sister of AMY GAMBLE EIDSON. Plaintiffs are the children of Harry Gamble, Jr., who resided in the Greenwood District of Tulsa at the time of the Riot.

371. Plaintiff BOBBIE JEAN SAULET is an individual residing in Kansas City, Missouri. She is the daughter of Willie James and Dorothy Grayson, who resided in the Greenwood District of Tulsa at the time of the Riot.

372. Plaintiff MAXIMILLIAN HOWELL is an individual residing in Topeka, Kansas. He is the son of Johnson Howell, who resided in the Greenwood District of Tulsa at the time of the Riot.

373. Plaintiff MAXINE JOHNSON LACY is an individual residing in Tulsa, Oklahoma. She is the daughter of Ed and Cora Jackson, who resided in Greenwood District of Tulsa at the time of the Riot.

374. Plaintiff SHIRLEY A. JOHNSON TYUS is an individual residing in Conway, Arkansas. She is the sister of JANICE LOU JOHNSON ROSS, MARILYN KAY JOHNSON COLEY, LENA MAE JOHNSON PAYNE, and RONALD WAYNE JOHNSON. Plaintiffs are the children of Bennie Lee Johnson, who resided in the Greenwood District of Tulsa at the time of the Riot.

375. Plaintiff JANICE LOU JOHNSON ROSS is an individual residing in Plumerville, Arkansas. She is the sister of SHIRLEY A. JOHNSON TYUS, MARILYN KAY JOHNSON COLEY, LENA MAE JOHNSON PAYNE, and RONALD WAYNE JOHNSON. Plaintiffs are the children of Bennie Lee Johnson, who resided in the Greenwood District of Tulsa at the time of the Riot.

376. Plaintiff MARILYN KAY JOHNSON COLEY is an individual residing in Plumerville, Arkansas. She is the sister of SHIRLEY A. JOHNSON TYUS, JANICE LOU JOHNSON ROSS, LENA MAE JOHNSON PAYNE, and RONALD WAYNE JOHNSON. Plaintiffs are the children of Bennie Lee Johnson, who resided in the Greenwood District of Tulsa at the time of the Riot.

377. Plaintiff LENA MAE JOHNSON PAYNE is an individual residing in Plumerville, Arkansas. She is the sister of SHIRLEY A. JOHNSON TYUS, JANICE LOU JOHNSON ROSS, MARILYN KAY JOHNSON COLEY, and RONALD WAYNE JOHNSON. Plaintiffs are the children of Bennie Lee Johnson, who resided in the Greenwood District of Tulsa at the time of the Riot.

378. Plaintiff RONALYD WAYNE JOHNSON is an individual residing in Plumerville, Arkansas. He is the brother of SHIRLEY A. JOHNSON TYUS, JANICE LOU JOHNSON ROSS, MARILYN KAY JOHNSON COLEY, and LENA MAE JOHNSON PAYNE. Plaintiffs are the children of Bennie Lee Johnson, who resided in the Greenwood District of Tulsa at the time of the Riot.

379. Plaintiff VAL GENE JOHNSON, SR. is an individual residing in Tulsa, Oklahoma. He is the brother of MARY L. EMERSON, BOBBIE WILSON, and VASSIE CLARK. Plaintiffs are the children of Robert Franklin Johnson, who resided in the Greenwood District of Tulsa at the time of the Riot.

380. Plaintiff MARY L. EMERSON is an individual residing in Tulsa, Oklahoma. She is the sister of VAL GENE JOHNSON, SR., BOBBIE WILSON, and VASSIE CLARK. Plaintiffs are the children of Robert Franklin Johnson, who resided in the Greenwood District of Tulsa at the time of the Riot.

381. Plaintiff BOBBIE WILSON is an individual residing in Tulsa, Oklahoma. She is the sister of VAL GENE JOHNSON, SR., MARY L. EMERSON, and VASSIE CLARK. Plaintiffs are the children of Robert Franklin Johnson, who resided in the Greenwood District of Tulsa at the time of the Riot.

382. Plaintiff VASSIE CLARK is an individual residing in Tulsa, Oklahoma. He is the brother of VAL GENE JOHNSON, SR., MARY L. EMERSON, and BOBBIE WILSON. Plaintiffs are the children of Robert Franklin Johnson, who resided in the Greenwood District of Tulsa at the time of the Riot.

383. Plaintiff MELVIN TIP JONES is an individual residing in Beggs, Oklahoma. He is the son of plaintiffs LEE AND STELLA JONES, who resided in the Greenwood District of Tulsa at the time of the Riot.

384. Plaintiff LORRAINE LEWIS is an individual residing in Tulsa, Oklahoma. She is the sister JIMMIE LEWIS and JOE LEWIS. Plaintiffs are the children of Willie Lewis, who resided in the Greenwood District of Tulsa at the time of the Riot.

385. Plaintiff JIMMIE LEWIS is an individual residing in Tulsa, Oklahoma. He is the brother of LORRAINE LEWIS and JOE LEWIS. Plaintiffs are the children of Willie Lewis, who resided in the Greenwood District of Tulsa at the time of the Riot.

386. Plaintiff JOE LEWIS is an individual residing in Tulsa, Oklahoma. He is the brother of LORRAINE LEWIS and JIMMIE LEWIS. Plaintiffs are the children of Willie Lewis, who resided in the Greenwood District of Tulsa at the time of the Riot.

387. Plaintiff MARTHA MCGLORIE SWINDALL is an individual residing in Tulsa, Oklahoma. She is the daughter of Reverend A.L. and Lucinda McGlorie, who resided in the Greenwood District of Tulsa at the time of the Riot.

388. Plaintiff DONALD JOHN MCGOWAN is an individual residing in Tulsa, Oklahoma. He is the son of Clyde William McGowan, who resided in the Greenwood District of Tulsa at the time of the Riot.

389. Plaintiff PAT GALBRAITH MOORE is an individual residing in Tulsa, Oklahoma. She is the daughter of Mattie King Mitchell, who resided in the Greenwood District of Tulsa at the time of the Riot.

390. Plaintiff ELIZABETH COOLEY CHAPPELLE is the widow of Rev. T. Oscar Chappelle. At the time of the Riot, Rev. T. Oscar Chappelle lived in Greenwood District of Tulsa.

391. Plaintiff JEANNE OSBY GOODWIN is the widow of E. L. Goodwin. At the time of the Riot, E. L. Goodwin lived in Greenwood District of Tulsa.

392. Plaintiff JOBIE ELIZABETH HOLDERNESS is the widow of Lynn Holderness. At the time of the Riot, Lynn Holderness lived in Greenwood District of Tulsa.

393. Plaintiff HAZEL LATIMER is the widow of Fred Latimer, Sr. At the time of the Riot, Fred Latimer, Sr. lived in Greenwood District of Tulsa.

394. Plaintiff LORELL KIRK is the widow of Thomas Kirk. At the time of the Riot, Thomas Kirk lived in Greenwood District of Tulsa.

395. Plaintiff MARY LOUPE is the widow of Richard Wesley Loupe. At the time of the Riot, Richard Wesley Loupe lived in Greenwood District of Tulsa.

396. Plaintiff CLAUDIA MAUDE SMITHERMAN is the widow of Theodore Smitherman. At the time of the Riot, Theodore Smitherman lived in Greenwood District of Tulsa.

397. Plaintiff BETTY SPEARS is the widow of Marvin Spears. At the time of the Riot, Marvin Spears lived in Greenwood District of Tulsa.

398. Plaintiff ROSE STRIPLIN is the widow of Sylvester Striplin, Sr. At the time of the Riot, Sylvester Striplin, Sr. lived in Greenwood District of Tulsa.

399. Plaintiff PANSY TILLEY is the widow of Delmar Tilley. At the time of the Riot, Delmar Tilley lived in Greenwood District of Tulsa.

400. Plaintiff HARRIET ADAMS SMITH is an individual residing in Tulsa, Oklahoma. Plaintiff is a descendant of Thomas and Tacora Adams. At the time of the Riot, Thomas and Tacora Adams lived in Greenwood District of Tulsa.

401. Plaintiff DONNA ADAMS is an individual residing in Tulsa, Oklahoma. Plaintiff is a descendant of Thomas and Tacora Adams. At the time of the Riot, Thomas and Tacora Adams lived in Greenwood District of Tulsa.

402. Plaintiff THOMAS ADAMS, JR. is a descendant of Thomas and Tacora Adams. At the time of the Riot, Thomas and Tacora Adams lived in Greenwood District of Tulsa.

403. Plaintiff EUGENE BOLTON is an individual residing in Tulsa, Oklahoma. Plaintiff is a descendant of Fletcher Daniels. At the time of the Riot, Fletcher Daniels lived in Greenwood District of Tulsa.

404. Plaintiff JAMES BOLTON is an individual residing in Altadena, California. Plaintiff is a descendant of Fletcher Daniels. At the time of the Riot, Fletcher Daniels lived in Greenwood District of Tulsa.

405. Plaintiff ROGER DUNCAN is an individual residing in San Diego, California. Plaintiff is a descendant of James L. and Carrie Duncan. At the time of the Riot, James L. and Carrie Duncan lived in Greenwood District of Tulsa.

406. Plaintiff RITA DUNCAN is an individual residing in Tulsa, Oklahoma. Plaintiff is a descendant of James L. and Carrie Duncan. At the time of the Riot, James L. and Carrie Duncan lived in Greenwood District of Tulsa.

407. Plaintiff SYLVESTER TERRY, JR. is a descendant of Fannie Rose Frazier Jackson. At the time of the Riot, Fannie Rose Frazier Jackson lived in Greenwood District of Tulsa.

408. Plaintiff ANNIE ALEXANDER WILSON is an individual residing in Tulsa, Oklahoma. Plaintiff is a descendant of Henry and Ora Tilley. At the time of the Riot, Henry and Ora Tilley lived in Greenwood District of Tulsa.

409. Plaintiff DOROTHY JACKSON BREWER is a descendant of Henry and Ora Tilley. At the time of the Riot, Henry and Ora Tilley lived in Greenwood District of Tulsa.

410. Plaintiff CLARENCE JACKSON is an individual residing in Tulsa, Oklahoma. Plaintiff is a descendant of Henry and Ora Tilley. At the time of the Riot, Henry and Ora Tilley lived in Greenwood District of Tulsa.

411. Plaintiff GEORGE ALEXANDER is an individual residing in Tulsa, Oklahoma. Plaintiff is a descendant of Henry and Ora Tilley. At the time of the Riot, Henry and Ora Tilley lived in Greenwood District of Tulsa.

412. Plaintiff EVA MAE TILLEY JONES is an individual residing in Tulsa, Oklahoma. Plaintiff is a descendant of Henry and Ora Tilley. At the time of the Riot, Henry and Ora Tilley lived in Greenwood District of Tulsa.

413. Plaintiff MAYBELLE WALLACE is an individual residing in Tulsa, Oklahoma. Plaintiff is a descendant of Ed and Viola Wallace. At the time of the Riot, Ed and Viola Wallace lived in Greenwood District of Tulsa.

414. Plaintiff DENISE MCCRAY is an individual residing in Tulsa, Oklahoma. Plaintiff is a descendant of Ed and Viola Wallace. At the time of the Riot, Ed and Viola Wallace lived in Greenwood District of Tulsa.

415. Plaintiff OTIS MCCRAY III is a descendant of Ed and Viola Wallace. At the time of the Riot, Ed and Viola Wallace lived in Greenwood District of Tulsa.

416. Plaintiff ARVEN AUTRY is an individual residing in Tulsa, Oklahoma. Plaintiff is a descendant of Rev. James P. and Laura Jeffries Autry. At the time of the Riot, Rev. James Autry was the pastor of Holsey Chapel C.M.E. Church on N. Peoria Avenue in the Greenwood District of Tulsa. Plaintiff s father saw bombs falling from planes over Greenwood. Rev. Autrey found it difficult to return to Tulsa and was deeply emotionally scarred.

B. Defendants

417. Defendant THE GOVERNOR OF THE STATE OF OKLAHOMA is an individual living in the State of Oklahoma, and is sued in his official capacity.

418. Defendant THE CITY OF TULSA is a municipality located in the State of Oklahoma.

419. Defendant THE CHIEF OF POLICE OF THE CITY OF TULSA is an individual living in the State of Oklahoma, and is sued in his official capacity.

420. Defendant THE CITY OF TULSA POLICE DEPARTMENT is an entity located in the State of Oklahoma.

421. Plaintiffs are unaware of the true names and capacities of Defendants DOES 1 through 100, inclusive, and accordingly sue said Defendants by such fictitious names. As soon as Plaintiffs learn the true names and capacities of Defendants DOES 1 through 100, inclusive, it will amend this Complaint accordingly. Plaintiffs are informed and believe and therefore allege that Defendants DOES 1 through 100, inclusive, are in some way responsible for the acts and obligations sued upon herein. "THE GOVERNOR OF THE STATE OF OKLAHOMA," "THE CITY OF TULSA," "THE CHIEF OF POLICE," THE CITY OF TULSA POLICE DEPARTMENT, and DOES 1 through 100, inclusive, shall be referred to collectively herein as "Defendants."

FACTUAL BACKGROUND^{^[36]}

A. Greenwood, 1921

422. Plaintiffs incorporate by reference paragraphs 1-170.

423. The widespread atmosphere of racial hostility in Oklahoma in the years preceding the Riot was exacerbated by Tulsa whites anger at the prosperity of the Greenwood District.^{^[37]}

424. In the spring of 1921, Greenwood, the African American section of Tulsa, was one of the most vibrant African American communities in America. About 8,000 people lived in the largely self-sufficient community.^{^[38]}

425. Greenwood s professional class had become so prosperous by 1921, that the streets on which it conducted its business were collectively known nationally as the Negro Wall Street. ^{^[39]}

426. Running north out of the downtown commercial district and shaped, more or less, like an elongated jigsaw puzzle piece Greenwood was bordered by the Frisco railroad yards to the south, by Lansing Street and the Midland Valley tracks to the east, and by Stand Pipe and Sunset Hills to the west.^{^[40]}

427. The southern end of Greenwood Avenue, including the adjacent side streets, was the home of the African American commercial district. This several block stretch of handsome one, two, and three-story red brick buildings housed dozens of African American-owned and -operated businesses, including grocery stores and meat markets, clothing and dry good stores, billiard halls, beauty parlors and barber shops, as well as a drug store, a jewelry store, an upholstery shop, and a photography studio.

428. Greenwood s economy was diverse, consisting of business persons and professionals as well as skilled and semi-skilled workers. Because of racial segregation, these businesses served primarily African Americans. It is estimated that Greenwood had 33 professionals, including 2 dentists, 4 druggists, 1 jeweler, 3 lawyers, 2 photographers, 10 physicians, and 6 real estate/insurance agents. It is estimated that by 1921 Greenwood boasted 108 business establishments, which included 9 billiard halls, 2 retail stores, 4 confectioneries, 1 feed and grain store, 11 boarding houses, 2 garages, 41 groceries, 5 hotels, 30 restaurants, 2 movie theaters, and 1 undertaker s parlor. Greenwood s economy also consisted of an estimated 24 skilled crafts persons, including 5 builders, 2 dressmakers, 1 plumber, 1 printer, 4 shoemakers, 10 tailors, and 1 upholsterer, plus an estimated 26 low-skilled workers, with 12 barbers, 5 cleaners, 3 hairdressers, and 6 shoeshiners.

429. There were two African American newspapers: the Tulsa Star and the Oklahoma Sun. Moreover, Greenwood was also home to a local business league, various fraternal orders, a Y.M.C.A. branch, and a number of women s clubs.^{^[41]}

430. On a per capita basis, there were more churches in Greenwood than there were in the city s white community as well as a number of Bible study groups, Christian youth organizations, and chapters of national religious societies. All told, there were more than a dozen African American churches in Tulsa at the time of the Riot, including First Baptist, Vernon A.M.E., Brown s Chapel, Morning Star, Bethel Seventh Day Adventist, and Paradise Baptist, as well as Church of God, Nazarene, and Church of God in Christ congregations. Mount Zion Baptist Church was dedicated on April 10, 1921 less than eight weeks before the Riot.

431. Greenwood was also home to other highly successful business entrepreneurs, including two hotels: the Gurley Hotel and the Stradford Hotel. The Stradford was a modern fifty-four room structure, one of the largest African American-owned businesses in Oklahoma.

432. Most of the African American-owned businesses in Tulsa were much more modest. Scattered about the district were numerous small stores, from two-seater barbershops to family-run grocery stores, that helped to make pre-Riot Greenwood, on a per capita basis, one of the most business-laden African American communities in the country.

B. Prelude to the Riot

433. In the early evening of May 31, 1921, a crowd of whites began gathering at the Tulsa County Courthouse, drawn there in part because of a newspaper story suggesting that a nineteen year-old African American youth, Dick Rowland, had assaulted a white elevator operator, seventeen-year-old Sarah Page.

434. Sometime around 4:00 to 5:00 p.m., and certainly by 6:30 p.m., rumors circulated in the Greenwood community that Dick Rowland would be lynched that evening.

435. The previous August, a mob had taken a man out of the cell where Rowland was being held, and lynched him. Twenty-three African Americans had been lynched in the previous decade.

436. Two prominent African Americans came to the Courthouse to investigate the rumored lynching.

437. Sometime after 6:30 p.m., other African Americans began to gather at the Courthouse. By about 7:00 p.m. there were perhaps about 800 people of both races at the Courthouse and tensions were running high. Some white people were yelling to Get these niggers away from here.

438. About this time, a number of whites went to the National Guard armory seeking arms. At the same time, several carloads of armed African Americans headed towards the Courthouse to protect Dick Rowland from the gathering white mob.

439. According to J.B. Stradford, an African American businessman, Sheriff McCulloch stated that he could handle the crowd and that he did not require assistance from the African American residents of the town. He did not turn away, however, a growing number of white men who continued to mob the Courthouse, many of them having returned drunk from the armory.

440. A white man then made a speech in front of the Courthouse and advised the crowd to go home, stating that African Americans were riding around with high-powered revolvers and guns downtown. The speech had some effect and the crowd started to disperse.

441. At the Courthouse, a white man confronted some of the African American men and began disarming them. One man refused to give up his gun to the white man. The white man asked, Nigger, where you goin with that gun? A struggle resulted, the gun went off, police officers and white men started firing on the African Americans, an African American man was killed, and the Riot started.^{^[42]} Sheriff McCullough testified that when the shot was fired, that was just like throwing a match in the powder can. ^{^[43]} The street cleared quickly.

C. The Riot Starts: All Hell Breaks Loose

442. According to O.W. Gurley, a prominent African American businessman, at that point "all hell broke loose."

443. As the streets cleared, the African American victim of the shooting lay in front of the Courthouse. Walter White, associate secretary of the NAACP, who came to Tulsa immediately after the Riot to investigate it, reported that the African American victim lay dying, under a billboard with a picture of Mary Pickford, America s sweetheart, smiling winsomely.^{^[44]}

444. Almost immediately, members of the white mob opened fire on the African American men, who defended themselves by firing back. Outnumbered more than twenty to one, the African American men fought in retreat towards the Greenwood District.

445. With armed whites in close pursuit, the African American men came under heavy gunfire along Fourth Street, two blocks north of the Courthouse.

446. A short while later, a second, deadlier, skirmish broke out at the corner of Second and Cincinnati Streets. A second contingent of African American men came under fire from the rioting white mob and had to fight for their lives.

447. Heavily outnumbered by the whites, and suffering casualties, most of the African Americans were able, however, to make it safely across the Frisco railroad tracks and into Greenwood.

448. By 10:00 p.m. the police station was filled with a mob of armed whites. Groups of these white men left the police station in squads and returned sometime later.

449. The white Police Chief John A. Gustafson, deputized between 250 and 500 white men. The police issued guns to the newly deputized white citizens of Tulsa to put down what they referred to as a Negro uprising. But the police failed to even record the names of the people to whom they gave the guns. After the Riot, Police Chief Gustafson pleaded in the pages of a white Tulsa newspaper for the return of guns, stating they were issued with the understanding that they would be returned when the need for them passed.

450. The police department ordered commandeered the gun shops and the pawnshops and issued guns to the newly deputized white mob that then made its way towards Greenwood. The police department also ordered deputies and non-deputies alike to go home, get a gun, and get a nigger. ^{^[45]}

451. Local officials sought the assistance of the State National Guard.

452. A State National Guard commander arrived with two officers and sixteen men at approximately 10:30 p.m. They went to the police station, where they began working in conjunction with the police.

453. Binkley Wright, who was seventeen at the time of the Riot, was an eyewitness to the events.

454. According to one Survivor, Binkley Wright, African Americans formed a protective brigade at Mt. Zion Baptist Church, helping to fight off the rioting white mob, which included newly deputized members of the police department, entering Greenwood.

455. Binkley Wright saw many African Americans killed when the white mob, including newly deputized members of the police department and men in military uniform, broke through and heavily attacked the Church.

456. Throughout the night of May 31, 1921 to June 1, 1921, the white mob, including men newly deputized by the police department, came across the Frisco railroad into Greenwood. Although outnumbered, the African American residents fought to keep them out, but the whites forced their way into Greenwood, shooting, wounding, and killing many African Americans, and burning down everything in their path.

457. State National Guardsmen fired upon a number of African American Greenwood residents in the process of responding to the Negro uprising. Some time after 11:00 p.m., twenty Guardsmen arrived at the police station, where they had set up headquarters. They guarded the border between white Tulsa and the African American Greenwood District for several hours.

458. Some African Americans attempted to organize an effort to defend themselves against the oncoming mob, which included newly deputized members of the police department, on Brickyard Hill between Haskell and Jasper Streets.

459. Between the hours of 1:00 a.m. and 2:00 a.m., J.B.A. Robertson, the Governor of Oklahoma, declared martial law throughout Tulsa County, and ordered the troops to suppress the Negro Uprising. ^{^[46]}

460. The Guard, which had been instructed by the State to restore order, on some occasions joined the rioters instead, acting like wild men. ^{^[47]}

461. At 1:15 a.m. some white Guardsmen placed a machine gun on a truck, along with three experienced white machine gunners and six other white enlisted men. They traveled around the city putting down African American efforts to defend themselves from the white mob. At 3:00 a.m., Guardsmen were ordered to Stand Pipe Hill. Their commander deployed the Guardsmen along Detroit Avenue, from Stand Pipe Hill to Archer Street, on the west side of Greenwood. They began a bridgehead into Greenwood, using a truck with a machine gun mounted upon it, and entered the town, disarming and placing African American men in protective custody and sending them to the Convention Hall by police cars and trucks.

462. African Americans at Paradise Baptist Church told one survivor, Binkley Wright, that the mayor of the CITY OF TULSA had opened the Armory and given two machine guns to whites and that whites were using those machine guns to mow down our people. ^{^[48]}

463. Binkley Wright was then asked by some of the African American men to aid in the defense of Greenwood, loading and reloading guns behind the steps of Paradise Baptist Church for the human chain of African American defenders.

464. Later, these African Americans moved on to Stand Pipe Hill to defend the people of North Tulsa who were under attack. Led by "Peg‑Leg" Taylor, these African Americans met and "conferenced" behind the steps of Paradise Baptist Church. Then they made a human chain and went up the hill to defend African Americans from the white mob.

465. The white mob, including recently deputized members of the police department and uniformed members of the National Guard, were firing machine guns.

466. This white mob, containing newly deputized members of the police department, and Guardsmen outnumbered and shot the African American men stationed at Paradise Baptist Church.

467. Plaintiff KINNY BOOKER witnessed bullets raining down upon him, either from an airplane or Stand Pipe Hill, while he hid in the upper floors of his home.

468. On June 1, 1921, there were only two planes in Tulsa. One was a government‑owned plane. The government may have commandeered other planes.^{^[49]}

469. At Sunset Hill, located on the northwest side of Greenwood, the Guardsmen advanced on the African Americans living there and fired at will for nearly half an hour. Before advancing on Greenwood, they shot the African American men, women, and children who hid behind barricades to defend their homes. The guardsmen also attacked African Americans barricaded in a concrete store in the northeast corner of Greenwood. The Guardsmen fought along side white civilians, including those who had been newly deputized by the police department, killing African Americans.

470. At some point during the Riot, the Chief of Police informed a prominent African American businessman that if the African American residents ceased their resistance to the white mob, they would be treated fairly the next day.

471. At 5:00 a.m., in the morning of June 1, 1921, a whistle blew as a signal to the white mob, containing individuals newly deputized by the police department, and the National Guard, to enter Greenwood.

472. As soon as the African American residents stopped defending themselves, however, the Chief of Police contacted nearby cities and towns for reinforcements. By 9:00 a.m. the next day, Guardsmen had arrived from Muskogee, Oklahoma City, and Wagoner.^{^[50]}

473. The Guardsmen worked in close conjunction with the Tulsa police. The police and Guardsmen placed a large number of Greenwood residents in protective custody , a euphemism for illegal imprisonment, and turned them over to the police cars that stood close by.

474. Defendants instructed the Guard to take the African American residents of Greenwood into protective custody. ^{^[51]} The majority of the city s African American men, women, and children had either fled to the countryside or were held allegedly for their own protection against their will in one of a handful of hastily set-up internment centers, including Convention Hall, the Fairgrounds, and McNulty Baseball Park.

475. Plaintiff KINNY BOOKER was removed from his home some time after martial law was declared. Even though Plaintiff KINNY BOOKER and his sister and three brothers hid in the attic, and despite the pleas of his father, the rioting white mob set his home on fire. His family was able to get out without injury despite coming under small arms fire.

476. Plaintiff KINNY BOOKER s family was transported by the National Guard to Convention Hall.

477. As the Guardsmen were advancing, the white mob accompanying them, and including individuals newly deputized by the white police department, set fires all over Greenwood. As the Guardsmen swept through Greenwood disarming and placing the residents in protective custody, the white mob followed closely after setting fire to the buildings.

478. Brigadier General Charles F. Barrett, who was in charge of the National Guard brigade, stated that, on the morning of June 1, 1921, he witnessed a rioting white mob of 15,000 to 20,000 in Greenwood, which was by now on fire. The National Guard marched through the crowded streets. Trucks loaded with scared and partially clothed African American men, women, and children were parading the streets under heavily armed guards.

479. Personal belongings and household goods had been removed from many homes and piled in the streets. On the steps of the few houses that remained sat feeble and gray Negro men and women and occasionally a small child. The look in their eyes was one of dejection and supplication. Judging from their attitude, it was not of material consequence to them whether they lived or died. Harmless themselves, they apparently could not conceive the brutality and fiendishness of men who would deliberately set fire to the homes of their friends and neighbors and just as deliberately shoot them down in their tracks. ^{^[52]}

480. Brigadier General Barrett wrote that In all my experience, I have never witnessed such scenes that prevailed in this city when I arrived at the height of the rioting 25,000 whites, armed to the teeth were ranging the city in utter and ruthless defiance of every concept of law and righteousness. Motorcars bristling with guns swept through your city, their occupants firing at will. ^{^[53]}

481. Maurice Willows, the Director of the local Red Cross, stated that all that fire, rifles, revolvers, machine guns, and inhuman bestiality could be done with 35 city blocks with its 10,000 Negro population, was done. ^{^[54]}

482. The Guardsmen facilitated the destruction of Greenwood. They removed African American residents against their will. Many of these residents believed that, if the Guardsmen would only help them, they were capable of defending themselves and their property from the depredations of the white mob, which included individuals newly deputized by the police department. Instead, the Guard worked at the Defendants direction to place African American Greenwood residents in protective custody instead of protecting Greenwood property.

483. All firing had ceased by 11:00 a.m., not because the Guard had succeeded in bringing the white rioters under control but rather because the African American Greenwood residents had been killed, placed in protective custody, or driven out.^{^[55]} Even after the Riot ceased, the newly deputized white citizens were told that they were to "go out and shoot any nigger you see and the law'll be behind you."^{^[56]}

484. As many as 300 African Americans were killed.^{^[57]}

485. Forty-two square blocks of property was laid waste in ashes and 8,000-10,000 African Americans were rendered homeless.^{^[58]}

486. Defendant the CITY OF TULSA held many of the African American men, women, and children in custody against their will for days after the Riot. The police and National Guard were used as guards in the various camps to ensure the African Americans remained in custody. The Defendants THE GOVERNOR OF STATE OF OKLAHOMA and the CITY OF TULSA forced African Americans to work their way out of custody by cleaning up the destruction caused by the white rioters. At some time on June 2, General Barrett issued Field Order Number 4, which decreed that "all able bodied [N]egro men remaining in detention camp at the Fairgrounds and other places in the City of Tulsa [would] be required to render such service and perform such labor as [was] required by the military commission."^{^[59]} The African American Greenwood residents were treated like chattel and, in treatment reminiscent of slavery, were often only released when their white employer vouched for them. Those released wore green tags to identify that they had been properly released from custody.

D. Defendants Policy and Custom

of Racial Discrimination

487. The Defendants engaged in a longstanding and official policy, practice, custom, habit and usage to deny African Americans their equal rights under the law. This was done in numerous ways, described below.

488. Defendants permitted Plaintiffs to be physically attacked even participating in some of the attacks resulting in bodily injury, death and destruction and theft of property. Defendants, with deliberate indifference and on the basis of race, failed to protect Plaintiffs from repeated criminal acts, failed to equally enforce the laws and branded Plaintiffs with the racial badges of inferiority and slavery in the form of racially motivated violence. Defendants failure to prevent or aid in preventing the commission of racial crimes exacerbated the Riot and led to further wrongs against Plaintiffs. Defendants failed to adequately train and supervise those persons it deputized and those persons to whom it issued ammunition during the Riot. Defendants failed to meaningfully investigate and act upon complaints filed by Plaintiffs on the basis of race. Defendants routinely under-investigated, under-responded, undercharged, mishandled and failed to protect Plaintiffs from a series of criminal acts or prosecute those responsible for such acts. Defendants abdicated their responsibility to investigate, develop and charge white citizens with crimes against Plaintiffs, thereby ratifying and jointly participating in racially motivated acts to deprive Plaintiffs of their constitutional and statutory rights. Defendants made decisions on a racially discriminatory basis. Defendants failed to make restitution and reparations it promised Plaintiffs.

489. All of Defendants actions and inaction, as alleged in the Complaint, were pursuant to Defendants policy, custom, habit, usage and pattern and practice of unequal enforcement of the law depriving Plaintiffs of their Fourteenth Amendment constitutional rights and statutory rights. Defendants did not treat white citizens in the same or similar manner as Plaintiffs.

490. As a direct and proximate result of Defendants unconstitutional and illegal racially motivated actions, Plaintiffs have suffered the loss of their property, physical injury, and emotional distress from witnessing the murder and injury of their family members.

E. Findings of The Oklahoma Commission to

Study the Riot of 1921

491. The 1921 Riot Commission was created pursuant to House Joint Resolution No. 1035. The statute, as amended, charged the commission to:

undertake a study to develop a historical record of the 1921 Riot including the identification of persons who:

1. Can provide adequate proof to the Commission that the person was an actual resident of the Greenwood area or community of the City of Tulsa on or about May 31, 1921, or June 1, 1921; or

2. Can demonstrate to the satisfaction of the members of the Commission that the person sustained an identifiable loss to their person, personal relations, real property, personal property or other loss as a result of tortious or criminal conduct, whether or not the conduct was ever adjudicated, occurring during the period beginning on or about May 31, 1921, and ending not later than June 30, 1921, resulting from the activity commonly described as the 1921 Riot. ^{^[60]}

492. The Statute also required that the Commission produce, by February 28, 2001, a final report of its findings and recommendations and to submit that report in writing to the Governor, the Speaker of the House of Representatives, the President Pro Tempore of the Senate, and the Mayor and each member of the City Council of the City of Tulsa, Oklahoma.

493. Most importantly, under the terms of the statute:

The Report may contain specific recommendations regarding whether or not reparations can or should be made and the appropriate methods to achieve the recommendations made in the final report. ^{^[61]}

494. After four years of intense study, the Commission generated a comprehensive study that examined more than 20,000 pages on the Riot.^{^[62]} The final Commission Report did contain a recommendation that reparations should be made and detailed the manner in which Defendants the GOVERNOR OF THE STATE OF OKLAHOMA and the CITY OF TULSA make reparations.^{^[63]}

495. A number of documents were attached to the Commission Report, providing support for each of the Commission s findings concerning the causes and consequences of the Riot, the Defendants participation in and responsibility for the Riot, and Defendants the GOVERNOR OF THE STATE OF OKLAHOMA s and the CITY OF TULSA s moral and legal liability to pay restitution to the African American survivors of the Riot and their descendants.

496. The findings were published in the Commission Report and incorporated by statute.^{^[64]}

497. The findings include determinations that: the root causes of the Riot stemmed from a history racism and violence in both Tulsa and Oklahoma;^{^[65]} the action or inaction of local municipal and county officials enabled a white mob, that included state and local officials, to kill 100-300 African Americans, loot and burn 1,256 African American residences and businesses in Greenwood;^{^[66]} and that the property lost should be valued at approximately $2 million in 1921 dollars or $16,752,600 in 1999 dollars. ^{^[67]} The Oklahoma State Legislature further concluded that there had been no convictions or payments of any kind to the African American victims of the Riot, and that local officials attempted to block the rebuilding of the Greenwood ;^{^[68]} and that the Defendants ignored their moral responsibilities at the time of the riot [and have continued to do so] ever since rather than confront the realities of an Oklahoma history of race relations that allowed one race to put down another race. ^{^[69]}

498. The Commission Report, which was endorsed by the State of Oklahoma s legislature, made the following additional findings and recommendations:

a. As hostile groups gathered and their confrontation worsened, municipal and county authorities failed to take actions to calm or contain the situation. ^{^[70]}

b. At the eruption of violence, civil officials selected many men, all of them white and some of them participants in that violence, and made those men their agents as deputies. ^{^[71]}

c. In that capacity, deputies did not stem the violence but added to it, often through overt acts themselves illegal. ^{^[72]}

d. Public officials provided firearms and ammunition to individuals, again all of them white. ^{^[73]}

e. Units of the Oklahoma National Guard participated in the mass arrests of all or nearly all of Greenwood s residents, removed them to other parts of the city, and detained them in holding centers. ^{^[74]}

f. Entering the Greenwood District, [White] people stole, damaged or destroyed personal property left behind in homes and businesses. ^{^[75]}

g. [White p]eople, some of them agents of government, also deliberately burned or otherwise destroyed homes credibly estimated to have numbered 1,256, along with virtually every other structure including churches, schools, businesses, even a hospital and library in the Greenwood district. ^{^[76]}

h. Despite duties to preserve order and to protect property, no government at any level offered adequate resistance, if any at all, to what amounted to the destruction of the neighborhood referred to commonly as Little Africa and politely as the Negro quarter. ^{^[77]}

i. [C]redible evidence makes it probable that many people, likely numbering between one and three hundred, were killed during the riot. ^{^[78]}

j. Not one of these criminal acts was then or ever has been prosecuted or punished by government at any level, municipal, county, state, or federal. ^{^[79]}

k. Even after the restoration of order it was official policy to release a African American detainee only upon the application of a white person, and then only if that white person agreed to accept responsibility for that detainee s subsequent behavior. ^{^[80]}

l. [N]either [city and county government] contributed substantially to Greenwood s rebuilding; in fact, municipal authorities acted initially to impede rebuilding. ^{^[81]}

m. In the end, the restoration of Greenwood after its systematic destruction was left to the victims of that destruction. ^{^[82]}

499. According to the Report of the Oklahoma Commission to Study the Riot of 1921, an accurate assessment of the value of the property destroyed by the rioters totals at least $16,752,600 in 1999 dollars.^{^[83]}

F. Statute of Limitations Should Be

Equitably Tolled and Waived

500. Because of the work of the Commission, there exists today a tremendous amount of information that was not available in 1921 about the Tulsa Riot, Defendants the GOVERNOR OF THE STATE OF OKLAHOMA s and the CITY OF TULSA s culpability, and the implications of such culpability on the legal redress available to the Plaintiffs. Defendants the GOVERNOR OF THE STATE OF OKLAHOMA and the CITY OF TULSA acted, both in 1921 and subsequently, to hide evidence of their culpability and to prevent African American victims of the Riot and their descendants from bringing suit against Defendants. Furthermore, the State of Oklahoma, in its statute creating the Commission, waived the statute of limitations as an affirmative defense. Thus, the applicable statute of limitations is subject to equitable tolling or, in the alternative, to waiver, implicitly or explicitly, by the State of Oklahoma.

501. The State of Oklahoma and its agents acting in their official capacities and the CITY OF TULSA have misrepresented and concealed information about their role in the Riot. Defendants have knowingly perpetuated confusion and misinformation or failed to provide information about the factual circumstances underlying the Riot. As a result of Defendants fraudulent concealment, Plaintiffs have been unable, even with reasonable diligence, to discover the underlying facts and evidence to successfully bring a cause of action. Consequently, Defendants are precluded by their own acts and ommissions from asserting the statute of limitations as a defense. Under the doctrine of unclean hands, Defendants are estopped from claiming this affirmative defense.

502. The State of Oklahoma created the Commission in large part precisely to discover hidden or suppressed facts surrounding the Riot that could not otherwise have been discovered by Plaintiffs. The Commission Report revealed information never before made available to the public. The Commission described the Commission Report as a tower of new knowledge that enabled visions never seen before. ^{^[84]} Specifically, the Commission stated that the Commission Report:

[i]ncluded . . . records and papers long presumed lost, if their existence had been known at all. Some were official documents, pulled together and packed away, years earlier. Uncovered and examined, they took the commission back in time, back to the years just before and just after 1921. Some were musty legal records saved from the shredders. Briefs filed, dockets set, lawsuits decided each opened an avenue into another corner of history. Pages after pages laid [sic] open the city commission s deliberations and decisions as they affected the Greenwood area. Overlooked records from the National Guard offered overlooked perspectives and illuminated them with misplaced correspondence, lost after-action reports, obscure field manuals, and self-typed accounts from men who were on duty at the riot. ^{^[85]}

503. A significant amount of previously unavailable evidence including long-forgotten documents and photographs has been discovered.

504. Not until now has the story of the Tulsa Riot been told fully and truthfully. The Report of the Oklahoma Commission to Study the Riot of 1921, stated that: Much of the evidence used in preparing the report was recently discovered. :

Before there was this commission, much was known about the Riot. More was unknown. It was buried somewhere, lost somewhere, or somewhere undiscovered. No longer. Old records have been reopened, missing files have been recovered, new sources have been found. ^{^[86]}

505. The Commission Report breaks the conspiracy of silence that has existed for over a half century and for the first time this past tragedy has been extensively aired. ^{^[87]}

Until recently, the Riot has been the most important least known event in the state s entire history. Even the most resourceful of scholars stumbled as they neared it for it was dimly lit by evidence and the evidentiary record faded more with every passing year. ^{^[88]}

506. However, the history of the Riot may now comprise the most thoroughly documented moments ever to have occurred in Oklahoma. ^{^[89]} The Commission itself acknowledged surprise over the amount of new evidence and that it contributed so much. ^{^[90]} Even the book Death in a Promised Land; the Riot of 1921, written by Scott Ellsworth (the acknowledged expert on the Riot) and published in 1982, did not have the evidence contained in the Commission Report.^{^[91]}

507. Only now do Plaintiffs have sufficient information to state the nature of the causes of action they can bring and against whom. Prior to the Commission s Report, the Defendants concluded that the Riot was something to be swept well beneath the history s carpet. ^{^[92]} Plaintiffs made repeated requests for information that was denied to them by Defendants the GOVERNOR OF THE STATE OF OKLAHOMA and CITY OF TULSA, which prevented them from being able to pursue legal action. Not until the Commission published its Commission Report were Plaintiffs provided with the information needed to bring suit.

508. Thus, Plaintiffs are excused from the time limits on filing, and the statute of limitations should be equitably tolled insofar as much of the information upon which this lawsuit rests was only discovered by the efforts of the Oklahoma Commission to Study the Riot of 1921.

509. Defendants also erected barriers making it extremely difficult, if not impossible, for Plaintiffs to seek legal redress for injuries resulting from the Riot. The atmosphere surrounding Tulsa in the wake of the Riot made conditions potentially deadly for individuals who wanted to seek restitution through the courts. Such barriers included:

a. The Grand Jury convened by the State of Oklahoma returned indictments against African Americans for inciting the Riot. Because of the discriminatory manner in which the indictments were returned, African American residents of Greenwood were prevented or inhibited from filing or continuing lawsuits on behalf of the African American residents of Greenwood. In an absurdly biased grand jury report, which was orchestrated by the Oklahoma attorney general, Tulsa blamed the African American community for the Riot, further prejudicing the claims of Riot victims in the courts. Tulsa prosecutors threatened to imprison key Greenwood leaders, like A.J. Smitherman, editor of the Tulsa Star, and J.B. Stradford, which caused them to flee Oklahoma. Stradford filed suit in Chicago, but could not adequately prosecute his claim, for fear of imprisonment and bodily harm. Stradford never set foot in Oklahoma again.

b. The court system was corrupted with the pernicious influence of the Ku Klux Klan, thereby resulting in a racially discriminatory judicial system. In fact, about one year after the Riot, Oklahoma s Governor declared martial law in Tulsa, citing among other reasons the pervasive control of the courts by the Ku Klux Klan.^{^[93]} According to the Commission Report: Everyone (on the Commission) agrees that within months of the riot Tulsa s Klan chapter had become one of the nation s largest and most powerful, able to dictate its will with the ballot as well as the whip. Everyone agrees that many of the city s most prominent men were Klansmen in the early 1920 s and that some remained Klansmen throughout the decade. Everyone agrees that Tulsa s atmosphere reeked with a Klan-like stench that oozed through the robes of the Hooded Order.

c. The Oklahoma Supreme Court discouraged lawsuits by limiting municipal liability on the basis of territorial common law,^{^[94]} and acknowledging the role that special deputies played in destroying Greenwood but failing to find the CITY OF TULSA responsible for such conduct.^{^[95]}

d. The CITY OF TULSA summarily denied the restitution claims of African American residents, while paying those of whites, in order to prevent or inhibit the filing or continuance of restitution claims by the African American citizens of Greenwood. In particular, the CITY OF TULSA permitted restitution claims made by white owners of stores who had arms or ammunition looted from their stores. The State of Oklahoma created conditions so adverse to the prosecuting of lawsuits that over 130 complaints filed against insurers, the city, and the state, were prevented from proceeding past the filing stage.

e. According to the Commission Report, the state and local governments were instruments of repression used to prevent African Americans from obtaining justice. In fact, after considering a variety of acts of violent repression of African Americans in Oklahoma, Commission concluded that the discussion of the State and City Defendants culpability in racially motivated attacks on African Americans in the years before, during, and after the Riot could be summed up as follows:

In some government participated in the deed.

In some government performed the deed.

In none did government prevent the deed.

In none did government punish the deed. ^{^[96]}

f. Oklahoma history textbooks published during the 1920s did not mention the Riot at all nor did ones published in the 1930s.

510. Accordingly, the CITY OF TULSA and the GOVERNOR OF THE STATE OF OKLAHOMA should be equitably estopped from asserting any defense premised upon laches or the tolling of a statute of limitations.

511. Alternatively, Defendant the CITY OF TULSA in 1921 also waived the statute of limitations as an affirmative defense by its express commitment to provide restitution for Riot victims. Specifically, the City stated that a claims commission would compensate the victims of the Riot, thereby inducing them not to file suit.^{^[97]}

512. Furthermore, Defendant the GOVERNOR OF THE STATE OF OKLAHOMA resurrected Plaintiffs claims for restitution in 1997 and can not seek harbour behind a statute of limitations defense.

513. More specifically, in 1997 and again in 1999, the State Legislature commissioned a report from the Commission, funded the Commission, and charged it with conducting an investigation to determine the causes of the Riot, identify those parties responsible for the Riot and the victims, and to make recommendations regarding reparations and restitution.

514. House Joint Resolution 1035 (1997), the statute passed by the Oklahoma legislature and that created the Commission, waives the statute of limitations defense. That statute conceded that:

black persons of that era were practically denied equal access to the civil or criminal justice system in order to obtain damages or other relief for the tortious and criminal conduct which had been committed."

and that:

the Greenwood community and the residents who lived and worked there were irrevocably damaged by the tortious and criminal conduct that occurred during the Riot; . . . and ... at the time of the 1921 riot in the City of Tulsa, the Oklahoma Constitution contained provisions, still effective as law, which provided that: All persons have the inherent right to life, liberty, the pursuit of happiness, and the enjoyment of the gains of their own industry. and further that: the courts of justice of the State shall be open to every person, and speedy and certain remedy afforded for every wrong and for every injury to person, property and reputation; and right and justice shall be administered without sale, denial, delay or prejudice. "

515. The Oklahoma State Legislature empowered the Commission to redress these wrongs, and in so doing waived any limitations defense the State may mount.

516. Furthermore, the Oklahoma State Legislature, in adopting and implementing the Commission s findings and recommendations by creating The Tulsa Reconciliation Education and Scholarship Program^{^[98]} and the Tulsa Riot Memorial and Reconciliation Act,^{^[99]} has expressly or implicitly waived any limitations defense it may mount, since these measures adopt the injunctive relief recommended by the Commission.

517. Finally, Governor Keating, acting in his official capacity as GOVERNOR OF THE STATE OF OKLAHOMA, stated that he supported direct payments to the 120 survivors of the bloody riots if the report contained persuasive evidence of state culpability. ^{^[100]} Governor Keating admitted that "Compensation for direct loss occasioned by direct state or city action is not inappropriate. . . . But it has to be shown that there was real harm to existing, living individuals and that direct action by the city and the state caused the harm ^{^[101]} Clearly, the Commission Report demonstrates such harm. Governor Keating s statement demonstrates the State s express or implied intent to waive any limitations defense should legal liability be established.

FIRST CAUSE OF ACTION

FOR DEPRIVATION OF LIFE AND LIBERTY

AND THE PRIVILEGES AND IMMUNITIES

OF UNITED STATES CITIZENSHIP

IN VIOLATION OF THE FOURTEENTH AMENDMENT

OF THE UNITED STATES CONSTITUTION

(Against the CITY OF TULSA, THE CHIEF OF POLICE,

and THE TULSA POLICE DEPARTMENT)

518. Plaintiffs repeat and reallege the above allegations as if fully set forth herein.

519. Defendants deprived the following Plaintiffs of their constitutionally protected interest in their life, liberty, and bodily integrity, and in enjoying the privileges and immunities of their United States citizenship: JOHN ALEXANDER, JUANITA SMITH BOOKER, KINNEY BOOKER, DOROTHY BOOKER BOULDING, JOHNNIE L. GRAYSON BROWN, JOE R. BURNS, ROSA L. GREEN BYNUM, BEATRICE CAMPBELL-WEBSTER, NAOMI HOOKER CHAMBERLAIN, MILDRED MITCHELL CHRISTOPHER, CARRIE HUMPHREY CUDJOE, LUCILLE BUCHANAN FIGURES, ERNESTINE GIBBS, HAROLD GIBBS, HAZEL FRANKLIN HACKETT, MADELEINE HAYNES, JOYCE WALKER HILL, VERA INGRAM, EUNICE CLOMAN JACKSON, DR. HOBART JARRETT, HAZEL DELORES SMITH JONES, MARY TACOMA MAUPIN, ALICE HIGGS LOLLIS, ISHMAEL S. MORAN, SIMON R. RICHARDSON, BEULAH LOREE KEENAN SMITH, GOLDEN WILLIAMS SMITH, DOROTHY WILSON STRICKLAND, LOIS WHITE TAYLOR, BERTRAM C. WILLIAMS, LOUIE BARTON WILLIAMS, and WESS YOUNG.

520. The following plaintiffs had relatives who were killed by Defendants: J.B. BATES, LEROY LEON HATCHER, and CECIL WHITE.

521. The following plaintiffs were physically and emotionally injured by Defendants: CARRIE HUMPHREY CUDJOE, JAMES DURANT, BEULAH LOREE KEENAN SMITH, LOLA SNEED SNOWDEN, and MARIE WHITEHORN

522. Defendants actions were deliberate and premediated. Such actions shock the conscience, and demonstrate a deliberate indifference to life, liberty and bodily integrity.

523. As a consequence of Defendants intentionally discriminatory actions, Plaintiffs JOHN ALEXANDER, JUANITA SMITH BOOKER, KINNEY BOOKER, DOROTHY BOOKER BOULDING, JOHNNIE L. GRAYSON BROWN, JOE R. BURNS, ROSA L. GREEN BYNUM, BEATRICE CAMPBELL-WEBSTER, NAOMI HOOKER CHAMBERLAIN, MILDRED MITCHELL CHRISTOPHER, CARRIE HUMPHREY CUDJOE, LUCILLE BUCHANAN FIGURES, ERNESTINE GIBBS, HAROLD GIBBS, HAZEL FRANKLIN HACKETT, MADELEINE HAYNES, JOYCE WALKER HILL, VERA INGRAM, EUNICE CLOMAN JACKSON, DR. HOBART JARRETT, HAZEL DELORES SMITH JONES, MARY TACOMA MAUPIN, ALICE HIGGS LOLLIS, ISHMAEL S. MORAN, SIMON R. RICHARDSON, BEULAH LOREE KEENAN SMITH, GOLDEN WILLIAMS SMITH, DOROTHY WILSON STRICKLAND, LOIS WHITE TAYLOR, BERTRAM C. WILLIAMS, LOUIE BARTON WILLIAMS, WESS YOUNG, J.B. BATES, LEROY LEON HATCHER, CECIL WHITE, CARRIE HUMPHREY CUDJOE, JAMES DURANT, BEULAH LOREE KEENAN SMITH, LOLA SNEED SNOWDEN, and MARIE WHITEHORN were denied their life, liberty, and bodily integrity, and the enjoyment of the privileges and immunities of United States citizenship,^{^[102]} and have sustained physical and mental injuries, and are entitled to damages in amount to be determined at trial.

SECOND CAUSE OF ACTION

FOR DEPRIVATION OF PROPERTY AND PRIVILEGES

AND IMMUNITIES IN VIOLATION OF THE FOURTEENTH

AMENDMENT OF THE UNITED STATES CONSTITUTION

(Against the CITY OF TULSA, THE CHIEF OF POLICE,

and THE TULSA POLICE DEPARTMENT)

524. Plaintiffs repeat and reallege the above allegations as if fully set forth herein.

525. Defendants deprived the following Plaintiffs of their constitutionally protected property interest in their residences, places of business, land, and personal property: J.B. BATES, ESSIE LEE JOHNSON BECK, J.D. BELL, PHINES BELL, JUANITA SMITH BOOKER, KINNEY BOOKER, DOROTHY BOOKER BOULDING, JEANETTE McNEAL BRADSHAW, TERESA EARLEE BRIDGES DYSART, JOHNNIE L. GRAYSON BROWN, ROSA L. GREEN BYNUM, MURIEL MIGNON LILLY CABELL, MILDRED MITCHELL CHRISTOPHER, MILDRED LUCAS CLARK, OTIS GRANVILLE CLARK, BLANCHE CHATMAN COLE, CARRIE HUMPHREY CUDJOE, HATTIE LILLY DUNN, JAMES DURANT, LUCILLE BUCHANAN FIGURES, ARCHIE JACKSON FRANKLIN, JIMMIE LILLY FRANKLIN, ERNESTINE GIBBS, HAROLD GIBBS, MARGARET TILLEY GIBBS, THERESSA CORNELLA McNEAL GILLIAM, MILDRED JOHNSON HALL HAZEL FRANKLIN HACKETT, LEROY LEON HATCHER, MADELEINE HAYNES, JOYCE WALKER HILL, DR. OLIVIA J. HOOKER, SAMUEL L. HOOKER, JR., WILHELMINA GUESS HOWELL, VERA INGRAM, GENEVIEVE ELIZABETH TILLMAN JACKSON, DR. HOBART JARRETT, WILMA MITCHELL JOHNSON, HAZEL DELORES SMITH JONES, THELMA KNIGHT, CAROL SMITHERMAN MARTIN, MARY TACOMA MAUPIN, RUTH DEAN NASH, SIMEON L. NEAL, ALMADGE J. NEWKIRK, JUANITA MAXINE SCOTT PARRY, IDA BURNS PATTERSON, DELOIS VADEN RAMSEY, JEWEL SMITHERMAN ROGERS, GERLINE HELEN WRIGHT SAYLES, JULIUS WARREN SCOTT, VENEICE DUNN SIMS, BEULAH LOREE KEENAN SMITH, GOLDEN WILLIAMS SMITH, LOLA SNEED SNOWDEN, JAMES L. STEWARD, DOROTHY WILSON STRICKLAND, LOIS WHITE TAYLOR, WILLIE MAE SHELBURN THOMPSON, EFFIE LEE SPEARS TODD, MELVIN C. TODD, QUEEN ESTHER LOVE WALKER, SAMUEL WALKER, TROY SIDNEY WALKER, and MARY LEON BROWN WATSON.

526. Defendants burned, looted, and otherwise destroyed or misappropriated these Plaintiffs property of without a hearing and without due process of law in violation of their property rights and the privileges and immunities of their citizenship as guaranteed under the Fourteenth Amendment of the United States Constitution.^{^[103]}

527. Defendants have never returned such misappropriated property or paid compensation for its loss.

528. Plaintiffs J.B. BATES, ESSIE LEE JOHNSON BECK, J.D. BELL, PHINES BELL, JUANITA SMITH BOOKER, KINNEY BOOKER, DOROTHY BOOKER BOULDING, JEANETTE McNEAL BRADSHAW, TERESA EARLEE BRIDGES DYSART, JOHNNIE L. GRAYSON BROWN, ROSA L. GREEN BYNUM, MURIEL MIGNON LILLY CABELL, MILDRED MITCHELL CHRISTOPHER, MILDRED LUCAS CLARK, OTIS GRANVILLE CLARK, BLANCHE CHATMAN COLE, CARRIE HUMPHREY CUDJOE, HATTIE LILLY DUNN, JAMES DURANT, LUCILLE BUCHANAN FIGURES, ARCHIE JACKSON FRANKLIN, JIMMIE LILLY FRANKLIN, ERNESTINE GIBBS, HAROLD GIBBS, MARGARET TILLEY GIBBS, THERESSA CORNELLA McNEAL GILLIAM, MILDRED JOHNSON HALL HAZEL FRANKLIN HACKETT, LEROY LEON HATCHER, MADELEINE HAYNES, JOYCE WALKER HILL, DR. OLIVIA J. HOOKER, SAMUEL L. HOOKER, JR., WILHELMINA GUESS HOWELL, VERA INGRAM, GENEVIEVE ELIZABETH TILLMAN JACKSON, DR. HOBART JARRETT, WILMA MITCHELL JOHNSON, HAZEL DELORES SMITH JONES, JULIA BONTON JONES, THELMA KNIGHT, CAROL SMITHERMAN MARTIN, MARY TACOMA MAUPIN, RUTH DEAN NASH, SIMEON L. NEAL, ALMADGE J. NEWKIRK, JUANITA MAXINE SCOTT PARRY, IDA BURNS PATTERSON, DELOIS VADEN RAMSEY, JEWEL SMITHERMAN ROGERS, GERLINE HELEN WRIGHT SAYLES, JULIUS WARREN SCOTT, VENEICE DUNN SIMS, BEULAH LOREE KEENAN SMITH, GOLDEN WILLIAMS SMITH, LOLA SNEED SNOWDEN, JAMES L. STEWARD, DOROTHY WILSON STRICKLAND, LOIS WHITE TAYLOR, WILLIE MAE SHELBURN THOMPSON, EFFIE LEE SPEARS TODD, MELVIN C. TODD, QUEEN ESTHER LOVE WALKER, SAMUEL WALKER, TROY SIDNEY WALKER, and MARY LEON BROWN WATSON. have suffered property damage in an amount to be specified at trial.

THIRD CAUSE OF ACTION

FOR VIOLATION OF THE EQUAL PROTECTION

CLAUSE AND THE PRIVILEGES AND IMMUNITIES

CLAUSE OF THE FOURTEENTH AMENDMENT

TO THE UNITED STATES CONSTITUTION

(Against the CITY OF TULSA, THE CHIEF OF POLICE,

and THE TULSA POLICE DEPARTMENT)

529. Plaintiffs repeat and reallege the above allegations as if fully set forth herein.

530. Defendants deprived all of the Plaintiffs of their right to equal protection of the laws and the privileges and immunities of their citizenship as guaranteed under the Fourteenth Amendment of the United States Constitution.

531. The Defendants engaged in a longstanding and official policy, practice, custom, habit and usage to deny African Americans their equal rights under the law. This was done in numerous ways, described below.

532. Defendants permitted Plaintiffs to be physically attacked, even participating in some of the attacks, resulting in bodily injury, death and destruction and theft of property. Defendants, with deliberate indifference and on the basis of race, failed to protect Plaintiffs from repeated criminal acts, failed to equally enforce the laws and branded Plaintiffs with the racial badges of inferiority and slavery in the form of racial epithets. Defendants failure to prevent or aid in preventing the commission of racial crimes exacerbated the Riot and led to further wrongs against Plaintiffs. Defendants failed to adequately train and supervise those persons it deputized and those persons to whom it issued ammunition during the Riot. Defendants failed to meaningfully investigate and act upon complaints filed by Plaintiffs on the basis of race. Defendants routinely underinvestigated, underresponded, undercharged, mishandled and failed to protect Plaintiffs from a series of criminal acts or prosecute those responsible for such acts. Defendants abdicated their responsibility to investigate, develop and charge white citizens with crimes against Plaintiffs, thereby affirming and jointly participating in racially motivated acts to deprive Plaintiffs of their constitutional and statutory rights. Defendants failed to make whole Plaintiffs by providing restitution and reparations it promised and committed to them.

533. Defendants did not treat white citizens in the same or similar manner to Plaintiffs.

534. As a consequence of the intentional racially discriminatory acts of Defendants, all of the Plaintiffs were denied the equal protection of the laws and the privileges and immunities of their United States citizenship in violation of the Fourteenth Amendment,^{^[104]} and are entitled to damages in an amount to be determined at trial.

FOURTH CAUSE OF ACTION

FOR VIOLATION OF U.S.C. 1981

(Against All Defendants)

535. Plaintiffs repeat and reallege the above allegations as if fully set forth herein.

536. Defendants deprived all of the Plaintiffs of their full and equal benefit of all laws and proceedings for the security of persons and property as is enjoyed by white citizens in violation of 42 U.S.C. 1981.

537. Defendants also denied Plaintiffs the same right to sue, be parties, and give evidence, as is enjoyed by white citizens, in violation of 42 U.S.C. 1981.

538. Defendants specifically targeted Plaintiffs on the basis of their race. This intentional discrimination was accomplished by a longstanding and official policy, practice, custom, habit and usage to deny African Americans their equal rights under the law. This was done in numerous ways, described below.

539. Defendants permitted Plaintiffs to be physically attacked, even participating in some of the attacks, resulting in bodily injury, death and destruction and theft of property. Defendants, with deliberate indifference and on the basis of race, failed to protect Plaintiffs from repeated criminal acts, failed to equally enforce the laws and branded Plaintiffs with the racial badges of inferiority and slavery in the form of racial epithets. Defendants failure to prevent or aid in preventing the commission of racial crimes exacerbated the Riot and led to further wrongs against Plaintiffs. Defendants failed to adequately train and supervise those persons it deputized and those persons to whom it issued ammunition during the Riot. Defendants failed to meaningfully investigate and act upon complaints filed by Plaintiffs on the basis of race. Defendants routinely under-investigated, under-responded, undercharged, mishandled and failed to protect Plaintiffs from a series of criminal acts or prosecute those responsible for such acts. Defendants abdicated their responsibility to investigate, develop and charge white citizens with crimes against Plaintiffs, thereby affirming and jointly participating in racially motivated acts to deprive Plaintiffs of their constitutional and statutory rights. Defendants failed to make whole Plaintiffs by providing restitution and reparations it promised to them.

540. Defendants did not treat white citizens in the same or similar manner to Plaintiffs.

541. Consequently, all of Plaintiffs have sustained injuries in an amount to be determined at trial.

FIFTH CAUSE OF ACTION

FOR VIOLATION OF U.S.C. 1983

(Against the CITY OF TULSA, THE CHIEF OF POLICE,

and THE TULSA POLICE DEPARTMENT)

542. Plaintiffs repeat and reallege the above allegations as if fully set forth herein.

543. Plaintiffs were deprived of their federal rights pursuant to Defendants longstanding official policies, practices, or customs of racial discrimination, as described in the allegation set forth above. These policies, practices, or customs were persistent, widespread, common, routine, well-settled, and adopted with reckless or callous indifference to federally protected rights, and causally connected to violations of federal law described below.

544. Defendants permitted Plaintiffs to be physically attacked, even participating in some of the attacks, resulting in bodily injury, death and destruction and theft of property. Defendants, with deliberate indifference and on the basis of race, failed to protect Plaintiffs from repeated criminal acts, failed to equally enforce the laws and branded Plaintiffs with the racial badges of inferiority and slavery in the form of racial epithets. Defendants failure to prevent or aid in preventing the commission of racial crimes exacerbated the Riot and led to further wrongs against Plaintiffs. Defendants failed to adequately train and supervise those persons it deputized and those persons to whom it issued ammunition during the Riot. Defendants failed to meaningfully investigate and act upon complaints filed by Plaintiffs on the basis of race. Defendants routinely underinvestigated, underresponded, undercharged, mishandled and failed to protect Plaintiffs from a series of criminal acts or prosecute those responsible for such acts. Defendants abdicated their responsibility to investigate, develop and charge white citizens with crimes against Plaintiffs, thereby affirming and jointly participating in racially motivated acts to deprive Plaintiffs of their constitutional and statutory rights. Defendants failed to make whole Plaintiffs by providing restitution and reparations it promised to them.

545. Defendants did not treat white citizens in the same or similar manner to Plaintiffs.

546. Consequently, all of the Plaintiffs have sustained injuries and property damage in an amount to be specified at trial.

SIXTH CAUSE OF ACTION

FOR VIOLATION OF U.S.C. 1985

(Against All Defendants)

547. Plaintiffs repeat and reallege the above allegations as if fully set forth herein.

548. The Defendants the GOVERNOR OF THE STATE OF OKLAHOMA and the CITY OF TULSA conspired to deprive all of the Plaintiffs the equal protection of the laws and equal privileges and immunities under the laws, thereby injuring Plaintiffs.

549. In furtherance of this conspiracy, Defendants adopted official policies, practices, or customs of racial discrimination, as described in the allegations set forth above, that injured Plaintiffs in their persons and properties as well as deprived Plaintiffs of having and exercising the equal protection of the laws and equal privileges and immunities of a citizen of the United states, as described below.

550. Defendants permitted Plaintiffs to be physically attacked, even participating in some of the attacks, resulting in bodily injury, death and destruction and theft of property. Defendants, with deliberate indifference and on the basis of race, failed to protect Plaintiffs from repeated criminal acts, failed to equally enforce the laws and branded Plaintiffs with the racial badges of inferiority and slavery in the form of racial epithets. Defendants failure to prevent or aid in preventing the commission of racial crimes exacerbated the Riot and led to further wrongs against Plaintiffs. Defendants failed to adequately train and supervise those persons it deputized and those persons to whom it issued ammunition during the Riot. Defendants failed to meaningfully investigate and act upon complaints filed by Plaintiffs on the basis of race. Defendants routinely under-investigated, under-responded, undercharged, mishandled and failed to protect Plaintiffs from a series of criminal acts or prosecute those responsible for such acts. Defendants abdicated their responsibility to investigate, develop and charge white citizens with crimes against Plaintiffs, thereby affirming and jointly participating in racially motivated acts to deprive Plaintiffs of their constitutional and statutory rights. Defendants failed to make whole Plaintiffs by providing restitution and reparations it promised to them.

551. As a result of the conspiracy between Defendants, all of the Plaintiffs have sustained injuries and property damage in an amount to be specified at trial.

SEVENTH CAUSE OF ACTION

PROMISSORY ESTOPPEL

(Against the GOVERNOR OF THE STATE OF OKLAHOMA and the CITY OF TULSA)

552. Plaintiffs repeat and reallege the above allegations as if fully set forth herein.

553. Defendants clearly and unambiguously promised to provide restitution and/or reparations to the Plaintiffs for the damage Defendants inflicted during the course of the Riot; Defendants reasonably foresaw that Plaintiffs would rely upon those promises; Plaintiffs did rely upon those promises to their detriment; and the hardship and unfairness suffered by the Plaintiffs may only be avoided by the GOVERNOR OF THE STATE OF OKLAHOMA and the CITY OF TULSA restoring the benefits to which the Plaintiffs are due.

1. State of Oklahoma

554. The State Of Oklahoma promised Plaintiffs in 1999 that restitution and/or reparations would be made for damages incurred during the Riot, upon which Plaintiffs reasonably relied to their detriment. Defendants knew that such assertions would result in Plaintiffs reliance and Plaintiffs did in fact reasonably relied on Defendants assurances by not filing suit for restitution prior.

555. More specifically, in 1997, pursuant to House Joint Resolution 1035 (1997), the State Legislature commissioned a report from the Commission, funded the Commission, and charged it with conducting an investigation to determine the causes of the Riot, identify those parties responsible for the Riot and the victims, and to make recommendations regarding reparations and restitution.

556. House Joint Resolution 1035 (1997) conceded that:

and that:

557. Furthermore, Governor Keating, acting in his official capacity as GOVERNOR OF THE STATE OF OKLAHOMA, stated that he supported direct payments to the 120 survivors of the bloody riots if the report contained persuasive evidence of state culpability. ^{^[105]} Governor Keating admitted that "Compensation for direct loss occasioned by direct state or city action is not inappropriate. . . . But it has to be shown that there was real harm to existing, living individuals and that direct action by the city and the state caused the harm ^{^[106]} Clearly, the Commission Report demonstrates such harm.

558. The Oklahoma State Legislature empowered the Commission to redress these wrongs, and it was foreseeable that Plaintiffs would rely upon the recommendations contained within the Commission s Report.

559. Furthermore, the Oklahoma State Legislature, in adopting and implementing the Commission s findings and recommendations by creating The Tulsa Reconciliation Education and Scholarship Program^{^[107]} and the Tulsa Riot Memorial of Reconciliation,^{^[108]} induced reliance by the Plaintiffs, since these measures provide the injunctive relief recommended by the Commission, creating the expectation that monetary relief would be forthcoming.

560. Plaintiffs have indeed relied to their detriment upon Defendant s promises by foregoing other means of compensation in the justified expectation that the State would compensate them for the Riot.

561. Plaintiffs may only be avoid the unfairness and hardship resulting from Defendant s behavior by receiving the compensation promised by the State Of Oklahoma in 1997 and 1999.

2. City of Tulsa

562. Defendant the CITY OF TULSA promised Plaintiffs both in 1921 and 1999 that restitution would be made for damages incurred during the Riot, upon which Plaintiffs reasonably relied to their detriment. Defendant knew that such assertions would result in Plaintiffs reliance.

563. Specifically, the City stated that a claims commission would compensate the victims of the Riot, thereby inducing them not to file suit. In particular, the Tulsa Chamber of Commerce stated that as quickly as possible rehabilitation will take place and reparation made . . . . Tulsa feels intensely humiliated. ^{^[109]} In the June 15, 1921 issue of the Nation, the Chair of the Emergency Committee stated that Tulsa weeps at this unspeakable crime and will make good the damage, so far as it can be done, to the last penny.

564. Plaintiffs did in fact reasonably relied on Defendants assurances by not filing suit for restitution prior to the commencement of this lawsuit. Plaintiffs and their families did not file lawsuits in the belief that the CITY OF TULSA would compensate them for damages suffered during the Riot. In reliance on this promise, Plaintiffs lost their opportunity to seek the damages incurred by the Riot.

PRAYER FOR RELIEF

WHEREFORE, Plaintiffs pray for relief from Defendants as follows:

i. For general and specific damages according to proof;

ii. For the amount of attorney s fees and related legal expenses incurred by Plaintiffs in pursuit of the benefits to which they are entitled;

iii. For exemplary and punitive damages in an amount sufficient to punish Defendants the CITY OF TULSA, the TULSA CHIEF OF POLICE, and the TULSA POLICE DEPARTMENT for their reprehensible behavior;

iv. For pre-judgment interest;

v. For such other and further relief, including injunctive and declaratory relief, that the Court deems just and appropriate.

Plaintiffs request a jury trial.

DATED: February 28, 2003

_____________________________________

James O. Goodwin, OBA #3458

Goodwin & Goodwin

P.O. Box 3257

Tulsa, OK 74101

(918) 582-9181`

(918) 599-0250 (fax)

_____________________________________

Charles J. Ogletree, Jr., BAR #272658

Jesse Climenko Professor ofLaw

Harvard Law School*

320 Hauser Hall

1575 Massachusetts Avenue

Cambridge, MA 02138

(617) 496-2054

(617) 496-3936 (fax)

_____________________________________

Adjoa A. Aiyetoro, BAR #26971

Chief Legal Consultant,

National Coalition of Blacks for Reparations in America (N COBRA)

c/o 4603 South Hall

University of California, Santa Barbara

Santa Barbara, CA 93106-3140

(202) 904-7561

_____________________________________

Michele A. Roberts, BAR #337998

Shea & Gardner

1800 Massachusetts Ave., NW

Washington, DC 20036

(202) 828-2000

(202) 828-2195 (fax)

_____________________________________

Denis C. Sweet III, BAR #8105

Langston Sweet & Freese P.A.

201 N. President St.

Jackson, MS 39201

(601) 969-1356

(601) 968-3866 (fax)

_____________________________________

Eric J. Miller, BAR #194237

Harvard Criminal Justice Institute*

320 Hauser Hall

1575 Massachusetts Avenue

Cambridge, MA 02138

(617) 384-9940

(617) 496-3936 (fax)

_____________________________________

Leslie Mansfield, OBA #18662

Director, Clinical Programs

University of Tulsa Legal Clinic

407 South Florence Avenue

Tulsa, OK 74104-3189

(918) 631-5799

_____________________________________

Michael D. Hausfeld, BAR #153742

Cohen, Milstein, Hausfeld & Toll, P.L.L.C.

110 New York Avenue, N.W.

Suite 500, West Tower

Washington, DC 20005

(202) 408-4600

(202) 408-4699 (fax)

_____________________________________

Suzette M. Malveaux, BAR #464473

Cohen, Milstein, Hausfeld & Toll, P.L.L.C.

110 New York Avenue, N.W.

Suite 500, West Tower

Washington, DC 20005

(202) 408-4600

(202) 408-4699 (fax)

_____________________________________

Jim Lloyd, OBA #5479

200 North Main Suite, D-1

Sand Springs, OK 74063

(918) 246-0200

(918) 246-0203 (fax)

_____________________________________

Sharon Cole Jones, OBA #18205

P.O. Box 2749

Tulsa, OK 74101

(918) 582-9181

_____________________________________

Rose Sanders, BAR #4095

(aka Faye Ora Rose Toure)

P.O. Box 1290

Selma, Alabama 36701

(334) 875-9264

(334) 875-9375 (fax)

_____________________________________

Willie E. Gary, BAR #0187843

Gary, Williams, Parenti, Finney

Lewis, McManus, Watson & Sperando

221 East Osceola

Stuart, FL 34994

(772) 283-8260

(772) 283-3343 (fax)

_____________________________________

Lorenzo Williams, BAR #249874

Gary, Williams, Parenti, Finney

Lewis, McManus, Watson & Sperando

221 East Osceola

Stuart, FL 34994

(772) 464-2352

(772) 464-4226(fax)

* For identification purposes only

[1]. Going to the Territory, in The Collected Essays of Ralph Ellison 601 (John Callahan ed. 1995).

[2]. Jim Crow is the name historians give to the period between the end of Reconstruction and the New Deal, which was characterized by segregation laws. See C. Vann Woodward, The Strange Career of Jim Crow (3rd ed. 2002); Kenneth W. Mack, "Law, Society, Identity, and the Making of the Jim Crow South," 24 L. & Soc. Inquiry 377-409 (1999). Those laws typically provided for segregation on railroads, in schools, in housing, and in public accommodations. Reconstructing the Dreamland: The Tulsa Riot of 1921 79 (2002).

[3]. In a series of cases, the Oklahoma Supreme Court also upheld differential funding of African American and white public schools, and cities throughout the state passed zoning ordinances requiring residential segregation.

[4]. See Wallace v. City of Norman, 60 P. 108 (Okla. Terr. 1900).

[5]. Norman Mob After Singie Smith Jazz, Oklahoma City Black

Dispatch (February 9, 1922).

[6]. See 74 Okl. St. Ann. 8000.1.1 (West 2002).

[7]. Governor Invokes Law Versus Mobbists, Tulsa Star (September 4, 1920).

[8]. Claude Chandler Hung By Mob, Posse Follows Too Late: Body Found West of City, Oklahoma City Black Dispatch (September 3, 1920).

[9]. The Facts Remain the Same, Tulsa Star (September 18, 1920).

[10]. Alfred Brophy, Assessing State and City Culpability: The Riot and the Law, published with Commission Report, 153, 156 (2001).

[11]. Dr. Scott Ellsworth, The Riot, published with the Commission Report, 37, 64 (2001).

[12]. Negro Tells How Others Mobilized, Tulsa Tribune (June 4, 1921).

[13]. To Rebuild Homes for Negro Owners and Probe Blame, Muskogee Phoenix (June 3, 1921)

[15] An Inflammatory Appeal, Black Dispatch (October 15, 1920).

[19]. The Klan s influence also made legislative efforts to obtain restitution impossible.

[20]. Alfred Brophy, Reconstructing the Dreamland 95-97 (2002).

[21]. Allen v. Tulsa, Tulsa County District Court, Case No. 16,013.

[22]. See Redfearn v. American Central Insurance Company, 243 P. 929 (Okla. 1926). See Alfred Brophy, Assessing State and City Culpability: The Riot and the Law, published with Commission Report, 153, 157-58 (2001).

[23]. See Alfred L. Brophy, The Riot in the Oklahoma Supreme Court, 54 Okla. L. Rev. 67 (2001).

[24]. See Wallace v. City of Norman, 60 Pacific 108 (Okla. Terr. 1900).

[25]. Id. at 8000.1.5. See also Brent Staples, Unearthing a Riot, NY Times, December 19, 1999, Section 6 at 64.

[33]. See John Hope Franklin and Scott Ellsworth, History Knows No Fences: An Overview, published with the Commission Report 21, 26-28 (2001) (discussing suppression of discussion of Riot). See also Brent Staples, Unearthing a Riot, NY Times, December 19, 1999, Section 6 at 64 (same).

[35]. The Tulsa Reconciliation Education and Scholarship Program ( TRESP ) established by 70 Okl. St. Ann. 2621 (West 2002) has never been properly funded. At the very least, plaintiffs seek to require the State to adequately fund the TRESP, as required by 70 Okl. St. Ann. 2620-2627.

[36]. The factual references in the factual background are taken from the Commission Report and the documents published along with it; Scott Ellsworth, Death in a Promised Land: The Riot of 1921 (1982); Alfred Brophy, Reconstructing the Dreamland (2002); and the recollection of various Survivors of the Riot.

[37]. See Scott Ellsworth, Death in a Promised Land: The Riot of 1921 (1982).

[38]. Alfred Brophy, Reconstructing the Dreamland : The Tulsa Riot of 1921 (2002).

[39]. Scott Ellsworth, Death in a Promised Land: The Riot of 1921 22 (1982).

[40]. Dr. Scott Ellsworth, The Riot, published with the Commission Report, 37, 40 (2001).

[41]. Dr. Scott Ellsworth, The Riot, published with the Commission Report, 37, 39 (2001).

[42]. See Scott Ellsworth, Death in a Promised Land: The Riot of 1921 (1982). See also Guardsmen With Machine Guns Ready for Any Emergency, St. Louis Post-Dispatch 2 (June 1, 1921) ( One version of the beginning of the trouble says the first firing came shortly after dark, when a negro was stopped by an officer and his gun taken away. He attempted to resist, according to the officer, and was shot dead. Three hours later his body was picked up from the street and taken to Police Headquarters, which was used as a temporary morgue. ).

[43]. Stradford v. American Central Ins. Co, Superior Court of Cook County, Illinois, No. 370,274 (1921), McCullough Deposition at 19.

[44]. See F.W. Prentice, Oklahoma Race Riot, 90 Scribner s 151, 152 (August 1931).

[45]. Dr. Scott Ellsworth, The Riot, published with the Commission Report, 37, 64 (2001).

[48]. Testimony of Binkley Wright published by the Tulsa Reparations Coalition on their web page at https://tulsareparations.z19.web.core.windows.net/.

[49]. Richard Warner, Airplanes and the Riot, published with the Commission Report, 103, 104 (2001).

[50]. See 85 Whites and Negroes Die in Tulsa Riots as 3,000 Armed Men Battle in Streets, 30 Blocks Burned, Military Rule in City, N.Y. Times, June 2, 1921, at 2.

[51]. See Scott Ellsworth, Death in a Promised Land: The Riot of 1921 61 (1982).

[52]. Tulsa Daily World, June 2, 1921 (cited in Prologue to Commission Report at iv).

[53]. Charles F. Barrett, Oklahoma After Fifty Years: A History of the Sooner State and Its People, 1889-1939 (1941).

[55]. Alfred Brophy, Reconstructing the Dreamland : The Tulsa Riot of 1921 (2002).

[56]. R. Halliburton, Jr., The Tulsa Race War of 1921 10 (1975).

[58]. Charles F. Barrett, Oklahoma After Fifty Years: A History of the Sooner State and Its People, 1889-1939 (1941).

[59]. Gerald Jerome Smith, Note: Constitutionality Of States' Use Of Police And Military Force to Arrest, Detain, And Confine American Citizens Because Of Race, 27 Okla. City U. L. Rev. 451 454-55 (2002).

[63]. Commission Report at 20: Reparations are the right thing to do.

[64]. See 74 Okl. St. Ann. 8000.1 (West 2002).

[82]. Larry O Dell, Riot Property Loss, published with the Commission Report, 143, 149 (2001).

[83]. Scholarly studies of the race riot are in substantial agreement with the Commission s assessment. See, e.g., Alfred Brophy, Reconstructing the Dreamland : The Tulsa Riot of 1921 (2002); Roy L. Brooks, Integration or Separation? (1996), Ch. 17; Randall Kennedy, Foreword in Alfred Brophy, Reconstructing the Dreamland : The Tulsa Riot of 1921 (2002).

[93]. Appellee's brief in Sanford v. Markham, 221 P. 36 (Okla. 1923).

[94]. See Alfred L. Brophy, The Riot in the Oklahoma Supreme Court, 54 Okla. L. Rev. 67 (2001).

[95]. See Redfearn v. American Central Insurance Co., 221 P. 929 (1926).

[97]. Alfred Brophy, Reconstructing the Dreamland : The Tulsa Riot of 1921 107 (2002); and at n. 85. (In the June 15, 1921 issue of the Nation, the Chair of the Emergency Committee stated that Tulsa weeps at this unspeakable crime and will make good the damage, so far as it can be done, to the last penny. ).

[100]. Lois Romano, No Vow to Make Amends for Tulsa; Legislators' Sidestepping Disappoints Survivors of 1921 Race Riot, The Washington Post, Thursday, March 1, 2001 Section A.

[101]. Lois Romano, Tulsa Airs a Race Riot's Legacy; State Historical Panel's Call for Restitution Spurs a Debate, The Washington Post, Wednesday, January 19, 2000, at Section A.

[102]. See, e.g., Clarence Thomas, The Higher Law Background of the Privileges or Immunities Clause, 12 Harv. J.L. & Pub. Pol. 63, 68 (1989); Philip B. Kirkland, The Privileges or Immunities Clause: Its Hour Come 'Round at Last, Its Hour Come 'Round at Last? 1972 Washington Univ. L.Q. 405 at 418-420.

[103]. See, e.g., Clarence Thomas, The Higher Law Background of the Privileges or Immunities Clause, 12 Harv. J.L. & Pub. Pol. 63, 68 (1989); Philip B. Kirkland, The Privileges or Immunities Clause: Its Hour Come 'Round at Last, Its Hour Come 'Round at Last? 1972 Washington Univ. L.Q. 405 at 418-420.

[104]. See, e.g., Clarence Thomas, The Higher Law Background of the Privileges or Immunities Clause, 12 Harv. J.L. & Pub. Pol. 63, 68 (1989); Philip B. Kirkland, The Privileges or Immunities Clause: Its Hour Come 'Round at Last, Its Hour Come 'Round at Last? 1972 Washington Univ. L.Q. 405 at 418-420.

[105]. Lois Romano, No Vow to Make Amends for Tulsa; Legislators' Sidestepping Disappoints Survivors of 1921 Race Riot, The Washington Post, Thursday, March 1, 2001 Section A.

[106]. Lois Romano, Tulsa Airs a Race Riot's Legacy; State Historical Panel's Call for Restitution Spurs a Debate, The Washington Post, Wednesday, January 19, 2000, at Section A.

[107]. See 70 Okl. St. Ann. 2621 (West 2002).

[109]. Alfred Brophy, Reconstructing the Dreamland : The Tulsa Riot of 1921 107 (2002).

JOHN MELVIN ALEXANDER; JUANITA	CASE NO. ___________
DELORES BURNETT ARNOLD; J.B.	)
BATES; ESSIE LEE JOHNSON BECK;	) FIRST AMENDED COMPLAINT FOR:
JAMES D. BELL; PHINES BELL;	)
FRANCES BLACKWELL; JUANITA	) (1) DEPRIVATION OF LIFE
WILLIAMS BLAKELY; JUANITA SMITH	) AND LIBERTY AND THE
BOOKER; KINNEY BOOKER; DOROTHY	) PRIVILEGES AND
BOOKER BOULDING; JEANETTE McNEAL	) IMMUNITIES OF UNITED
BRADSHAW; TERESA EARLEE BRIDGES	) STATES CITIZENSHIP IN
DYSART; JOHNNIE L. GRAYSON BROWN;	) VIOLATION OF THE
LEE ELLA STROZIER BROWN; CLARENCE	) FOURTEENTH AMENDMENT
BRUNER; LULA BELLE LACY BULLOCK;	) OF THE U.S.
JOE R. BURNS; ROSA L. GREEN	) CONSTITUTION;
BYNUM; MURIEL MIGNON LILLY	)
CABELL; BEATRICE CAMPBELL-	) (2) DEPRIVATION OF
WEBSTER; JAMES DALE CARTER;	) PROPERTY AND
ROSELLA CARTER; SAMUEL CASSIUS;	) PRIVILEGES AND
NAOMI HOOKER CHAMBERLAIN; MILDRED	) IMMUNITIES OF UNITED
MITCHELL CHRISTOPHER; MILDRED	) STATES CITIZENSHIP IN
LUCAS CLARK; OTIS GRANVILLE	) VIOLATION OF THE
CLARK; SANDY CLARK; BLANCHE	) FOURTEENTH AMENDMENT
CHATMAN COLE; WORDIE "PEACHES"	) OF THE U.S.
MILLER COOPER; CARRIE HUMPHREY	) CONSTITUTION;
CUDJOE; LaVERNE COOKSEY DAVIS;	)
DOLLY MAE DOUFITT; HATTIE LILLY	) (3) VIOLATION OF THE EQUAL
DUNN; JAMES DURANT; LUCILLE B.	) PROTECTION CLAUSE AND
BUCHANAN FIGURES; ARCHIE JACKSON	) THE PRIVILEGES AND
FRANKLIN; JIMMIE LILLY FRANKLIN;	) IMMUNITIES CLAUSE OF
JOAN HILL GAMBREL; ERNESTINE	) THE FOURTEENTH
GIBBS; HAROLD GIBBS; MARGARET	) AMENDMENT OF THE U.S.
TILLEY GIBBS; THERESSA CORNELLA	) CONSTITUTION;
McNEAL GILLIAM; EDWARD L. GIVENS;	)
BERTHA GUYTON; HAZEL FRANKLIN	) (4) VIOLATION OF U.S.C.
HACKETT; MILDRED JOHNSON HALL;	) 1981;
NELL HAMILTON HAMPTON; LEROY LEON	)
HATCHER; MADELEINE HAYNES; JOYCE	) (5) VIOLATION OF U.S.C.
WALKER HILL; DR. OLIVIA J.	) 1983;
HOOKER; SAMUEL L. HOOKER, JR.;	)
WILHELMINA GUESS HOWELL; MILDRED	) (6) VIOLATION OF U.S.C.
HUDSPETH; CHARLES HUGHES; MYRTLE	) 1985;
WELLS HURD; VERA INGRAM; EUNICE	)
CLOMAN JACKSON; GENEVIEVE	) (7) PROMISSORY ESTOPPEL.
ELIZABETH TILLMAN JACKSON; WILLIE	)
BELL WHITE JACKSON; DR. HOBART	)
JARRETT; ARTIE LACY JOHNSON;	)
WILMA MITCHELL JOHNSON; EDWARD	) Filing Date: ___________
EARVEN JONES; HAZEL DOLORES SMITH	) Trial Date: ___________
JONES; JULIA BONTON JONES; PERCY	)
JONES; THELMA THURMAN KNIGHT;	)
LEANNA JOHNSON LEWIS; KATIE MAE	)
JOHNSON LIVINGSTON; ALICE HIGGS	)
LOLLIS; ROANNA HENRY McCLURE;	)
ELDORIS MAE ECTOR McCONDICHIE;	)
CAROL SMITHERMAN MARTIN; MARY	)
TACOMA MAUPIN; WILLIE MUSGROVE	)
MEANS; ISHMAEL S. MORAN; RUTH	)
DEAN NASH; SIMEON L. NEAL;	)
ALMADGE J. NEWKIRK; MYRTLE NAPIER	)
OLIVER; JUANITA MAXINE SCOTT	)
PARRY; IDA BURNS PATTERSON;	)
FREDDIE SCOTT PAYNE; JOAN	)
ALEXANDER POWDRILL; ALICE	)
PRESLEY; DeLOIS VADEN RAMSEY;	)
CORA HAWKINS RENFRO; SIMON R.	)
RICHARDSON; JEWEL SMITHERMAN	)
ROGERS; GERLINE HELEN WRIGHT	)
SAYLES; JULIUS WARREN SCOTT;	)
WILLIAM A. SCOTT; TULETA S.	)
DUNCAN SHAWNEE; VENEICE DUNN	)
SIMMS; HAL CORNBREAD SINGER;	)
NAOMI SIPLIN; BEULAH LOREE KEENAN	)
SMITH; GOLDEN WILLIAMS SMITH;	)
LOLA SNEED SNOWDEN; JAMES L.	)
STEWARD; DOROTHY WILSON	)
STRICKLAND; SARAH TATUM; LOIS	)
WHITE TAYLOR; WILLIE MAE SHELBURN	)
THOMPSON; EFFIE LEE SPEARS TODD;	)
MELVIN C. TODD; KATHRYN MAE	)
TAYLOR TOLIN; BESSIE MAE AUSTIN	)
VESTER; QUEEN ESTHER LOVE WALKER;	)
SAMUEL WALKER; TROY SIDNEY	)
WALKER; OSCAR DOUGLAS WASHINGTON;	)
MARY LEON BROWN WATSON; ALLEN	)
MATTHEW WHITE; CECIL WHITE; MARIE	)
WHITEHORN; MILDRED EVITT WILBURN;	)
BERTRAM C. WILLIAMS; LOUIE BARTON	)
WILLIAMS; WILLIAM HAROLD WOOD;	)
CLOTIE LEWIS WRIGHT; WESS YOUNG;	)
JOHN HOPE FRANKLIN; REV. BRADFORD	)
BISHOP; LISA LATIMER; PATRICE	)
LATIMER; JAYPHEE LATIMER; CAESAR	)
LATIMER; JAMES HAROLD LATIMER;	)
CHARLE SYLVESTER LATIMER; JULIUS	)
PEGUES; ANITA WILLIAMS	)
CHRISTOPHER; ARTHUR JEFFERSON;	)
JESSIE THOMAS; JUANITA ALEXANDER	)
HOPKINS; C.J. HOPKINS; JOHNETTA	)
ADAMS; RHONDA ANDERSON; ROBERT	)
EARL ANDERSON; DIANE ANDERSON	)
STEELE; MARIETTA ANDERSON	)
WAITERS; RUTH ELLA AUTRY, JAMES	)
AUTRY, OTIS AUTRY; ELMER AUTRY;	)
AILEEN JOANNE AUSTIN COBURN;	)
LEONA AUSTIN McCAIN; RAMONA	)
DINKINS WIMBERLY; ERLINE	)
CROSSLIN, BILLIE WAYNE RUCKER; J.	)
C. RUCKER; ROBERT C. RUCKER;	)
ROSEZELLA TURNER; JOHN BAILEY;	)
ROY DAVIS; BERNICE BANKS DAVIS;	)
AUDREY BANKS PARSON: MARY BELL	)
ARRINGTON; R.G. BELL; CATHRYN	)
BELL SNODDY; LISA PRESLEY; JILL	)
ELIZABETH PRESLEY; JEAN WILLIAMS	)
MCGILL; MATTIE DAVIS OLIVER;	)
ALLENE KNIGHTEN RAYFORD; JAMES	)
BERNARD KNIGHTEN; BERNICE LAWLER;	)
LORRAINE MCFARLAND; THELMA KINLAW	)
GERMANY; DOROTHY JONES; NANCY	)
MARTIN, CATHERINE MARTIN, JAMES	)
PRESTON MARTIN; FELTON MARTIN;	)
LESLIE BEARD; MARY PRISCILLA	)
PARKER HARRISON; GENIEIVE	)
JACKSON; DIANA LYNN SHELTON;	)
SHIRLEY SHELTON; OSCAR BOYD;	)
ALICE BOYD VAUGHN; HELEN SIPUEL	)
HUGGINS; LAVADA LOUISE PARKER	)
OSBOURNE; LAWRENCE HERMAN DENNIE;	)
ALFREDA O. DENNIE FRANKLIN;	)
NORMAN JEAN DENNIE LESHIE; FRANK	)
EUGENE RODGERS; IDA LOUISE DENNIE	)
WILLIS; EDNA EARLY WORKS; ORA	)
SMITH; LEONA JERRYE BRUNER	)
ANTHONY; CLIFTON JOE TIPTON;	)
NAOMI LAWSON BROWN; EDWARD	)
LAWSON; BERNARD CARTER; EDDIE HUE	)
CARTER; ROBERT CARTER, JR.;	)
SAMUEL LEE CARTER; BOBBIE JEAN	)
CARTER TENNYSON; JOHNNYE CANNON	)
LAWSON; NATHANIEL CANNON; HENRY	)
CANNON; MILDRED CANNON WALLACE;	)
SARAH CURVAY MAYSHAW; LINDA	)
EDMONDSON GRAVES; NAOMI NASH	)
WILLIAMS WIMBERLY; PATRICIA	)
WILLIAMS; PEGGY ANN MCRUFFIN	)
MITCHELL; AUDELE MCLEOD BEEKS;	)
PATRICIA MCLEOD STEPHENSON;	)
FELICIA MCLEOD JOHNSON; WALLACE	)
MCLEOD, JR.; DELLA SHELTON	)
JACKSON; JOHNNY SHELTON; FAYE	)
MAY; BETTY ANDERSON; MAIME	)
SHELTON; BILLY SHELTON; MARGARET	)
LEE; EUNA VANN SMITH, MARIETTA	)
ANDERSON WAITERS; IRMA THOMAS	)
ANTHONY; LEONTYNE THOMAS HARRELL;	)
JERRY FIELDS THOMAS; OVEID LACY	)
III; ROBERT LACY; NICHOLAS A.	)
BANKS; BERNICE E. DAVIS; AUDREY	)
PARSONS; MAE ETTA REYNOLDS; JOHN	)
W. PATTON; JO ANN EWING; WANDA	)
EWING POPE; ROBERT EWING; BILL	)
EWING; BOBBYE LOUISE GILBERT;	)
FANNIE WILLIAMS; SIMON BERRY JR.;	)
MARGUERITE BAGBY; MAXINE JESSIE	)
VADEN; JOYCE RAMSEY; RAYMOND	)
BEARD, SR.; FLOYD PRICE; CAROLYN	)
PRICE JOHNSON; MILDRED LOUISE	)
DAVIS SCOTT; FRED DAVIS; THERESA	)
DAVIS SCOTT; SANDRA JEAN DAVIS	)
LANDRUM; ROSIE LEE JACKSON; FRED	)
SMITH; FANNIE SMITH VERNER; ERMA	)
SMITH THOMPSON; DELORES	)
HARRINGTON; SHIRLEY RIDLEY; PAT	)
MOORE; SHIRLEY TYUS; SELMA	)
LOCKARD; FRANK LOCKARD; JESSIE	)
MAE LOCKARD; EDWARD LOCKWARD;	)
ERNEST LOCKARD; OSCAR LOCKARD;	)
CORTEZ LOCKARD; EMMA LOCKARD	)
HORN; PATRICIA WILLIAMS; LORENZO	)
CARLOS VANN; CARRIE M. MCDONALD	)
STROTHER; MARY A. WILSON; BERTHA	)
WILSON; ELIZABETH WILSON; JIMMIE	)
WICKAM; FRANK WALKER, SR.; RILEY	)
WALKER, JR.; DENETTE MARIA	)
WALKER; FRANK WALKER, JR., HARRY	)
LEON WALKER; HARRY DANIEL WALKER;	)
EDWINA WALKER CARR; MARCIA	)
WALKER PUCKETT; WILLIAM D.	)
WALKER; OLENE WALKER WASHINGTON;	)
JEANETTE HAWKINS; OLANDER	)
HAWKINS; STARLA HAWKINS;	)
CHARLOTTE WILLIAMS; NAOMI LAWSON	)
BROWN; EDWARD LAWSON; MARCUS	)
LAWSON; MARGARET ANN LAWSON;	)
PALMER LAWSON, JR.; WILBUR	)
FOSTER; RONALD MOORE; DOROTHY	)
WILLIAMS BRANLETT; GRANT	)
WILLIAMS;.TERRY NASH; AUDREY	)
TAYLOR; BYRON TAYLOR; GERALDINE	)
PERRYMAN-TEASE; MILDRED MARIAN	)
HAMEL MILLER; LADAWNA MILLER;	)
PATSY ROBINSON; MARGARET THARPE;	)
MAXINE JACKSON LACY; RAYMOND	)
PRESLEY; WILMA PRESLEY BELL;	)
MAYBELLINE PRESLEY HOOKS; MILDREN	)
PRELSEY KAVANAUGH; BETTY PRESLEY	)
MCMILLAN; ELIZABETH PRESLEY	)
MONDAY; JOYCE MARIE PRESLEY;	)
RONALD DEAN PRESLEY; LEON	)
ROLLERSON; ERIC ROLLERSON; YVONNE	)
ROLLERSON AND WILA ROLLERSON;	)
STANLEY FAIR; JR.; JANE FAIR	)
PRUETT; JANET FAIR; BRENDA FAIR	)
CAMPBELL; GERALDINE FAIR JESSIE;	)
YVONNE FAIR SHAW; AMY GAMBLE	)
EIDSON; BOBBIE JEAN SAULET;	)
MAXIMILLIAN HOWELL; MAXINE	)
JOHNSON LACY; SHIRLEY A. JOHNSON	)
TYUS; JANICE LOU JOHNSON ROSS;	)
MARILYN KAY JOHNSON COLEY; LENA	)
MAE JOHNSON PAYNE; RONALD WAYNE	)
JOHNSON; VAL GENE JOHNSON; SR.;	)
MARY L. EMERSON; BOBBIE WILSON;	)
VASSIE CLARK; MELVIN TIP:	)
JONES; LORRAINE LEWIS; JIMMIE	)
LEWIS; JOE LEWIS; MARTHA MCGLORIE	)
SWINDALL; DONALD JOHN MCGOWAN;	)
PAT GALBRAITH MOORE; ELIZABETH	)
COOLEY CHAPPELLE; JEANNE OSBY	)
GOODWIN; JOBIE ELIZABETH	)
HOLDERNESS; HAZEL LATIMER; LORELL	)
KIRK; MARY LOUPE; CLAUDIA MAUDE	)
SMITHERMAN; BETTY SPEARS; ROSE	)
STRIPLIN; PANSY TILLEY; HARRIET	)
ADAMS SMITH; DONNA ADAMS; THOMAS	)
ADAMS, JR.; EUGENE BOLTON; JAMES	)
BOLTON; ROGER DUNCAN; RITA	)
DUNCAN; SYLVESTER TERRY, JR.;	)
ANNIE ALEXANDER WILSON; DOROTHY	)
JACKSON BREWER; CLARENCE JACKSON;	)
GEORGE ALEXANDER; EVA MAE TILLEY	)
JONES; MAYBELLE WALLACE; DENISE	)
MCCRAY; OTIS MCCRAY III; ARVEN	)
AUTRY,	)
	)
	)
Plaintiffs,	)
	)
v.	)
	)
THE GOVERNOR OF THE STATE OF	)
OKLAHOMA (in his official	)
capacity); THE CITY OF TULSA; THE	)
CHIEF OF POLICE OF THE CITY OF	)
TULSA (in his official capacity);	)
THE CITY OF TULSA POLICE	)
DEPARTMENT; and DOES 1 through	)
100, inclusive,	)
	)
Defendants.	)
	)
_______________________________	)

UNITED STATES DISTRICT COURT

STATEMENT OF JURISDICTION

THAT PRECIPITATED THIS SUIT

A. Plaintiffs And Defendants

E. Findings of The Oklahoma Commission to

FIRST CAUSE OF ACTION

FOR DEPRIVATION OF LIFE AND LIBERTY

SECOND CAUSE OF ACTION

FOR DEPRIVATION OF PROPERTY AND PRIVILEGES

THIRD CAUSE OF ACTION

FOR VIOLATION OF THE EQUAL PROTECTION

FOURTH CAUSE OF ACTION

FIFTH CAUSE OF ACTION

SEVENTH CAUSE OF ACTION

PROMISSORY ESTOPPEL

PRAYER FOR RELIEF