UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF NEW YORK
RAYMONDE ABRAMS, : 2000 Civ.
NICOLE B. SILBERKLEIT,
JANET HERMAN, :
LILY REDNER,
B E R N A R D CARON, : CLASS ACTION
ERNEST HAAR,
HARRY CYBULSKI, :
YVONNE LITTMAN, PLAINTIFFS
CASSANDRA KIRBY CONAHAY FREUND, : TRIAL BY JURY
JEAN-JACQUES FRAENKEL,
LILIANE LICHTENSTEIN, and :
MARIE WEINRAUCH,
on behalf of themselves and
all others similarly situated,
Plaintiffs,
-against-
SOCIETE NATIONALE DES
CHEMINS DE FER FRANCAIS,
Defendant. :
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I. INTRODUCTION
Plaintiffs, by their attorneys, bring this action, both individually and on behalf
other Holocaust victims similarly situated, against the French railroad company, Socittt
Nationale des Chemins de Fer franqais ("SNCF"), for compensatory and punitive damages, and
equitable disgorgement of profits, related to the deportation by SNCF of Jews and other
"undesirables" from their homes in France to Auschwitz and other Nazi death camps during
World War II (the "War"), in violation of customary international law and the law of nations.
SNCF assembled and ran the deportation trains and knew that conditions on those
trains would cause thousands to die before the trains reached their destinations. SNCF also knew
that the French civilians it delivered to the Nazi death and slave labor camps, in Germany and
elsewhere, would be killed or enslaved by the Nazis as part of the Third Reich's policy of
SNIPPETS:
SOCIETE NATIONALE DES CHEMINS DE FER FRANCAIS,
"undesirables" from their homes in France to Auschwitz and other Nazi death camps during
SNCF assembled and ran the deportation trains and knew that conditions on those trains would
SNCF also knew that the French civilians it delivered to the Nazi death and slave labor
SNCF is therefore liable to Plaintiffs and Plaintiff Class because SNCF knowingly engaged in
the first SNCF train deporting Jews left France for Auschwitz.
SNCF operated more than 72 convoys of trains deporting some 75,000 Jews (and tens of
Defendant Socitte Nationale des Chemins de Fer franqais is incorporated, and has its
As discussed below at 1141-43, SNCF, through agents and subsidiaries located in New York
Raymonde Abrams is a United States citizen who lives at 244 Amherst St., Brooklyn, New York.
her parents and her brother were transported to Auschwitz on 20 November 1943 by SNCF Convoy
Harry Cybulski is a United States citizen who lives at 939 Alvord Ave, Flint, Michigan.
Jean-Jacques Fraenkel is a Canadian citizen who lives at 401-539 Niagara St., Victoria,
Sub-class A consists of all those class members who are United States citizens.
This Court has subject matter jurisdiction over this action pursuant to 28 U.S.C. 5 1331,
This Court also has subject matter jurisdiction over this action pursuant to the Alien Tort
Indeed, according to published judicial opinions, when sued in the federal district courts in
SNCF's unlawful and tortious conduct as described herein was done intentionally, maliciously
Second Claim for Relief Equitable Disgorgement of Profits
V) Award the costs, disbursements and reasonable attorneys' fees incurred in the
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