UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
WEKUII RUKORO, Paramount Chief of the Ovaherero Traditional Authority; DAVID FREDERICK, Chief and Chairman of the Nama Traditional Authorities Association,  THE ASSOCIATION OF THE OVAHERERO GENOCIDE IN THE USA INC.; and BARNABAS KATUUO, Individually and as an Officer of The Association of the Ovaherero in the USA, Inc., on behalf of themselves and all other Ovaherero and Nama indigenous peoples,

Plaintiffs, Jury Trial Demanded -against

FEDERAL REPUBLIC OF GERMANY.,

Defendant.

Plaintiffs, by and through their attorneys, McCallion & Associates LLP, bring this Class

Action Complaint against Defendant Federal Republic of Germany as follows:

SUMMARY OF THE COMPLAINT

1. Plaintiffs bring this action on behalf of all the Ovaherero and Nama peoples for the horrific genocide and unlawful taking of property in violation of international law by the German colonial authorities during the 1885 to 1909 period in what was formerly known as South West Africa, and is now Namibia.

2. From 1885 to 1903, over a quarter of Ovaherero and Nama lands (originally over

50,000 square miles) and countless cattle had been seized without compensation by German colonists with the explicit consent of the German colonial authorities. Since cattle grazing was the primary economic base for their survival, the Ovaherero and Nama communities suffered

from these terrible losses. German colonial authorities also turned a blind eye to the widespread and systematic rape of Ovaherero and Nama women and girls, as well as the indiscriminate use of Ovaherero and Nama peoples as forced laborers without compensation.

3. After learning that they were going to be forced into concentration camps, and

that the remainder of their lands and property were going to be confiscated, the Ovaherero rose up in early 1904, followed by the Nama. The uprising was crushed by German Imperial troops under the command of General Lothar von Trotha, who announced that his goal was to annihilate the Ovaherero people. His orders were effectively carried out, resulting in the deaths of over 100,000 Ovaherero and Nama, with the reminder thrown into concentration camps under atrocious and sub-human conditions, where there was an extraordinarily high death toll, and the survivors who were well enough to stand were forced to Work as forced/slave laborer. The Surviving women were subjected to systematic rape and other abuses.

4. After decades of denying that the near destruction and eradication of the

Ovaherero peoples by the German Imperial authorities was, in fact, a genocide, and refusing to even consider the issue of reparations or compensation. Defendant The Federal Republic of Germany ("Germany) recently entered into negotiations with the Republic of Namibia ("Namibia) regarding these issues. However, Germany has refused to include representatives of the Ovaherero and Nama peoples in these discussions, even though they were the primary victims of the atrocities perpetrated by the German colonial authorities. Germany has also refused to explicitly admit that what it did constitutes a genocide under international law, even though it has been quick to pass resolutions and declarations blaming Turkey for the allegedly genocide of the Armenians by the Ottoman Empire during World War I.

READ THE ATTACHMENT FOR DETAILS:
WRIT.REPARATION

Special thanks to Bankie F. Bankie for sourcing this document.