ESTATE OF ARTURO GIRON ALVAREZ . by and through Maria Ana Giron Galindo as Administrator I AND THE 773 INDIVIDUALS IDENTIFIED ON EXHIBIT 1 TO THIS COMPLAINT AND UNKNOWN USE PLAINTIFFS, et a1. c/o Esoritorio Juridico Rodriguez, Faj ardo Asociados Centro Profesional Cipreses, Nivel 5, Ofioina 505 Caracas, Distrito Federal, Republica Bolivariana de Venezuela and Salsbury, Clements, Bekman, Marder Adkins LLC 300 West Pratt Street, Suite 450 Baltimore, Maryland 21201 PLAINTIFFS THE JOHNS HOPKINS UNIVERSITY 3400 North Charles Street Baltimore, NIB 21218 and THE JOHNS HOPKINS UNIVERSITY SCHOOL OF MEDICINE 3400 North Charles Street Baltimore, MD 21218 Serve On: Mark Rotenberg, Esq. 3400 North Charles Street Baltimore, MD 21218 and a a LI ?vTHE igllxadjfl?l H: ?15 COURT 011513108 I BALTIMORE CITY Case No.: - THE JOHNS HOPKINS HOSPITAL 600 North Wolfe Street Baltimore, MD 21287 Serve On: Joanne Pollak, Esq. Resident Agent Administration 4 1 4 600 North Wolfe Street Baltimore, MD 21287 and THE JOHNS HOPKINS BLOOMBERG SCHOOL OF PUBLIC HEALTH, formerly known as THE JOHNS HOPKINS SCHOOL OF HYGIENE AND PUBLIC HEALTH 615 North Wolfe Street Baltimore, MD 21205 - and THE JOHNS HOPKINS HEALTH SYSTEM CORPORATION 600 North Wolfe Street Baltimore, MD 21287 Serve On: Joanne Pollak, Esq. Resident Agent Administration 414 600 North Wolfe Street Baltimore, MD 21287 and THE ROCKEFELLER FOUNDATION 420 Fifth Avenue New York, NY 10018 Serve On: Gregory L. Diskant Patterson Belnap Webb Tyler '1133 Avenue of the Americas New York, NY 10036 and BRISTOL-MYERS SQUIBB COMPANY, formerly known as E.R. SQUIBB SONS, BRISTOL, BRISTOL and the SQUIBB INSTITUTE FOR MEDICAL RESEARCH 345 Park Avenue New York, NY 10154 Serve On: CT Corporation System Resident Agent 111 Eighth Avenue New York, NY 10011 And SQUIBB U.S. PHARMACEUTICAL GROUP, formerly known as E.R. SQUIBB SONS, BRISTOL, BRISTOL and the SQUIBB INSTITUTE FOR MEDICAL RESEARCH Bristol-Myers Squibb U.S. Pharmaceutical Corporation Trust Incorporated 32 South Street Baltimore, IVID 21202 Serve On: CS C?Lawyers Incorporating Service Company 7 St. Paul Street, Suite 820 Baltimore, MD 21202 And MEAD JOHNSON COMPANY, LLC, as the owner of BRISTOL-MYERS SQUIBB U.S. PHARMACEUTICAL GROUP 2701 Patriot Boulevard, Fourth Floor Glenview, IL Serve On: CS C-Lawyers Incorporating Service Company 7 St. Paul Street, Suite 820 Baltimore, MD 21202 DEFENDANTS. COMPLAINT Plaintiffs, by and through their attorneys, Paul D. Bekman, 11 Dale Adkins, Laurence A. Marder, Gregory G. Hopper, Emily C. Malarkey, and James Gentry of Salsbury, Clements, Bekman, Marder Adkins, F. R. Jenkins and Matthew R. Caton of Meridian 361 International Law Group, and Juan Pablo Rodriguez of Escritorio Juridico Rodriguez, Fajardo Asociados, hereby sue Defendants, The Johns Hopkins Hospital, The Johns Hopkins University, The Johns Hopkins University School of Medicine, The Johns Hopkins Bloomberg School of Public Health, The Johns Hopkins Health System Corporation, The Rockefeller Foundation, Bristol?Myers Squibb Company, Bristol?Myers Squibb U.S. Pharmaceutical Group, and Mead Johnson Company, LLC, and state as follows. Summary of the Case 1. From 1945 to 1956, physicians and scientists, and other agents employed by Johns Hopkins and The Rockefeller Foundation, participated in, approved, encouraged, directed, and aided and abetted human subject experiments in Guatemala in which children, soldiers, prison: inmates, hospital patients, and orphans were intentionally exposed to and infected with syphilis, gonorrhea, chancroid, and other diseases (as further described herein, the ?Guatemala Experiments? or the ?Experiments?). 2. The Guatemalan subjects were not told that they were being exposed to or infected with these devastating and potentially fatal diseases, or even that they were being experimented upon. Instead, in an intentional effort to deceive and mislead them, and to keep the true nature of the experiments a secret, the researchers said that they were performing routine medical tests and administering medication for the subjects? own good. This deception continued even after the human experiments ended. 3. The Guatemalans were not told about the nature of the experiments, warned about the consequences of being exposed to and infected with these sexually transmitted diseases, or given any follow?up care, treatment, or education to minimize their pain and suffering. Nothing was done to prevent them from passing the diseases on to their spouses, children, and other descendants. As a result, many .Guatemalans have suffered and died, and will continue to suffer and die, from the venereal diseases with which they were intentionally infected. 4. The Guatemala Experiments were hidden from view until September of 2011, when the United States Presidential Commission for the Study of Bioethical Issues released a report outlining its investigation into the experiments. That Commission concluded ?that the Guatemala experiments involved gross violations of ethics as judged against both the standards of today and the researchers? own understanding of applicable contemporaneous practices.? Leaving no room for doubt about the character of the experiments, the Presidential Commission stated that the researchers and those who oversaw them committed ?egregious moral wrongs.? A Guatemalan Presidential Commission also investigated and concluded the Guatemala Experiments were ?an immoral act of great impact and a crime against humanity.? 5. Johns Hopkins1 and The Rockefeller Foundation2 hel ed design, support, . 1 As used in this Complaint, ?Hopkins? and/or ?Johns Hopkins? refers to The Johns develop, encourage, and ?nance, and participated in and bene?tted from the Guatemala Experiments. [ks institutions and through their agents, servants, employees, and borrowed servants, and in concert with others, Johns Hopkins and Rockefeller created and designed the Guatemala Experiments; approved and recommended them for funding; oversaw, monitored, encouraged, directed, and aided and abetted them while they were ongoing; and helped conceal their unethical, immoral, and tortious nature. 6. In the early 1940?s, Bristol?Myers Squibb?s3 predecessor companies were involved in the investigation and commercial production of various forms of penicillin. They, as institutions and through their agents, servants, employees, and borrowed servants, were interested in studying the ef?cacy of different forms of this drug for treating and/or preventing syphilis and other infectious diseases. Their intent was to develop and sell for pro?t various forms of penicillin. 7. The predecessors of Bristol-Myers Squibb, because of connections in the medical community, knew of the secret non~consensual studies being performed in Guatemala and decided to use those Experiments with human subjects to test various forms of penicillin they had manufactured and their efficacy. They supplied penicillin in various forms for use in the negligently and unethically designed experiments, and were made aware of the study results in Hopkins University, The Johns Hopkins University School of Medicine, The Johns Hopkins Bloomberg School of Public Health (formerly known as The Johns Hopkins School of Hygiene and Public Health), The Johns Hopkins Health System Corporation, and The Johns Hopkins Hospital. 2 The Rockefeller Foundation is also referred to as Rockefeller in this Complaint. 3 As used in this Complaint, Bristol-Myers Squibb refers to the current day Bristol-Myers Squibb Company and Bristol-Myers Squibb U.S. Pharmaceutical Group, both of which were formerly. known as E.R. Squibb Sons, 1110.; Bristol, Myers; Bristol?Myers; Bristol Laboratories; and the Squibb Institute For Medical Research, as well as all other predecessor corporations and entities. order that they might better manufacture and market for pro?t various forms of the drug for use in treating and/or preventing syphilis. The Plaintiffs 8. The Plaintiffs in this case, who seek compensatory and punitive damages from the Defendants, include: I I a. Guatemalans who were subjects in the Experiments referred to in this Complaint (the ?Subject Plaintiffs?), who were intentionally and negligently exposed to and infected with syphilis, gonorrhea, and/ or cha?ncroid, without their actual or informed consent; b. Guatemalans who were spouses, children, sexual partners or descendants of the Subject Plaintiffs, and who acquired syphilis, gonorrhea, and/or chancroid through sexual contact or congenitally from the Subj ect Plaintiffs c. _Descendants of the Plaintiffs entitled to prosecute wrongful death claims under Maryland law as a result of the death of their decedents from complications of venereal diseases. 9. All 774 Plaintiffs are identified by name on the attached Exhibit 1, which is expressly incorporated into this Complaint. Those individuals who were Subject Plaintiffs are highlighted in yellow and marked with the label (Victima Directa). The spouses and descendants of the Subject Plaintiffs follOw underneath each of their names. The Defendants 10. Defendants Johns Hopkins University, The lohns Hopkins Health System Corporation, and The Johns Hopkins-Hospital, are corporate entities created and existing under the laws of the State of Maryland with their principal places of business located in Baltimore City. At all times relevant to this case, from their creation until today, these Defendants have regularly conducted business in Baltimore City. At all times relevant to this case, these Defendants are the successor and/or predecessor corporations to, The Johns Hopkins University School of Medicine and The Johns Hopkins Bloomberg School of Public Health. 11. Defendants The Johns Hopkins University School of Medicine and The Johns Hopkins Bloomberg School of Public Health, formerly known as The Johns Hopkins School of Hygiene and Public Health, are predecessor, and/or successor entities to and subsidiaries of Defendants Johns Hopkins University, The Johns Hopkins Health System Corporation, and The Johns Hopkins Hospital, and at all relevant times were and are owned, controlled, and operated by these Defendants. At all times relevant to this case, from their creation until today, Defendants The Johns Hopkins University School of Medicine and The Johns Hopkins Bloomberg School of Public Health have regularly conducted business in Baltimore City. 12. The Rockefeller Foundation is a corporation created and existing under the laws of the State of New York. At all times relevant to this case, from its creation until today, The Rockefeller Foundation has regularly conducted business in Baltimore City. 13. Bristol?Myers Squibb Company is incorporated under the laws of the State of Delaware. It maintains a principal place of business in the State of New York. At times relevant to this Complaint, it was known as Bristol, Myers; Squibb Sons, Inc.; Bristol Laboratories; and the Squibb Institute For Medical Research, as well as other unknown corporate names. At all times relevant to this case, from its creation until today, Bristol-Myers Squibb Company has regularly conduCted business in Baltimore City. 14. Bristol?Myers Squibb U.S. Pharmaceutical Group is owned by Mead Johnson Company, LLC, which is incorporated under the laws of the State of Delaware, with its principal place of business in the State of Indiana. At times relevant to this Complaint, it was known as Bristol, Myers; Bristol-Myers; ER. Squibb Sons, Inc.; Bristol Laboratories; and the Squibb I Institute For Medical Research, as well as other unknown corporate names. At all times relevant to this case, from its creation until today, Bristol?Myers Squibb U.S. Pharmaceutical Group and Mead Johnson Company, LLC, have regularly conducted business in Baltimore City. Jurisdiction and Venue 15. This Court has jurisdiction over all of the Defendants in this case. I 16. Venue is proper in Baltimore City. 17. Plaintiffs, individually and collectively, whether considered by count or individual claim, are claiming damages in an amount exceeding seventy?five thousand dollars Facts Common To All Counts Hopkins And Rockefeller ?s Early Role In STD Research 18. A part of the business of Johns Hopkins University and its associated organizations has always been medical research and development: In furtherance of this activity, in the ?rst part of the 20th Century, Hopkins established itself as a leading research center in the area of sexually transmitted diseases (STDs), or venereal diseases. In the relatively small world of venereal disease researchers at the time, many preeminent in the field were employed by or were agents of Hopkins. 19. The Rockefeller Foundation was established in 1913. Apart of its business is to investigate and promote research in the area of public health. It has accomplished this mission by providing funding for projects and by placing its personnel on assignment to those projects in order to direct, participate in, control, and oversee the work in question. In the first part of the 20th Century, The Rockefeller Foundation developed an interest in venereal diseases, and directed its money, resources, and personnel towards the investigation of such diseases. 20. In 1914, The Rockefeller Foundation gave Johns Hopkins $15,000 to establish a clinic at its Baltimore campus to study and treat patients with syphilis. The clinic, which became known as ?Department (for [was venerea, the Latin name for the disease), was devoted to the study and treatment of syphilis. 21. In 1915, The Rockefeller Foundation announced its decision to fund a school of public hygiene in the United States. Hopkins was chosen, and in 1916, the Hopkins School of Hygiene and Public Health, today known as the Hopkins Bloomberg School of Public Health, opened its doors. 22. From 1921 to 1929, Dr. Alan Chesney of Johns Hopkins served as the Director of Department L. As the Director and later as Dean of the Hopkins School of Medicine, Dr. Chesney worked to involve Hopkins in the study and treatment of STDs. Indeed, Dr. Chesney spent almost twenty years conducting experiments evaluating the basic mechanisms of immunity in syphilis. He published frequently in the ?eld and obtained numerous grants from private and public sources related to his work at Johns Hopkins. During this time, the United States Government was becoming increasingly concerned with the spread of syphilis and other venereal diseases. 23. In 1929, Dr. J. Earle Moore, a Hopkins Professor, replaced Dr. Chesney as Director of Department L. Dr. Moore had been conducting STD research of his own for some time. at Hopkins. While employed by Hopkins and as a part of his duties there, Dr. Moore advised the Surgeon Generals of the US. Army, Navy, and Public Health Service (PHS) on STDs. 24. Upon becoming Director of Department L, Dr. Moore began to aggressively expand the scope of Hopkins? clinical STD program and to position Hopkins to control the 10 federally funded investigations into the treatment of syphilis and other STDs. Under his direction, Department obtained large grants of money from the Federal Government and from private sources, including The Rockefeller Foundation, to perform clinical research into venereal diseases. In 1937, Hopkins received its ?rst ever grant of federal research funds, and the grant was for the study of syphilis. - 25. In the 19303 and 1940s, there was a significant-increase.- in federally funded research activities and experimentation in the area of STDS, and these activities received more federal funding than any other field of medical research. 26. At the time, it was the express policy of the Federal Government to fund scientific and medical research, but not to control the research or the individual scientists conducting it. To accomplish this, the Federal Government established a system wherein panels of non?governmental scientists and physicians proposed, designed, authorized, supervised and approved federal funding of scientific and medical research and experimentation. This system resulted in private sector control of federally funded venereal disease research and experimentation. 27. By placing its agents and employees on these panels, Hopkins achieved substantial in?uence over federally funded STD research and experimentation. The most important of these panels were the Subcommittee on Venereal Diseases and the Penicillin Panel within the National Research Council the National Advisory Health Council (NAHC), the Syphilis and Antibiotic Study Sections of the National Institutes of Health (the NIH), and the Pan American Sanitary Bureau (PASB). 4 The National Research Council is a private, non?profit organization that shares in the responsibility for advising the Federal Government on questions of public health, science, and technology. Its members are not compensated. ll 28. By in?uencing and controlling these entities, Hopkins physicians and scientists proposed, designed, authorized, supervised and approved the most important federally funded human STD research and experimentation of this time. They also used their representation on these committees to ensure that grants supported their own STD research and experimentation, inclriding a component for Hopkins overhead. 29. Consistent with the express policy of the Federal Government that federally funded research should be controlled by the private sector, these Hopkins agents, servants and employees were not Federal Government employees, were not compensated by the Federal Government, and were not controlled by the Federal Government. Their participation in these panels and committees occurred within the scope of their employment with Johns Hopkins, and Hopkins paid them. Hopkins knew of, supported, and bene?ted from the participation of its agents, servants and employees in these leadership positions. 30. In the early 19403, Dr. Moore, Dr. Chesney and Dr. Harry Eagle, another Hopkins professor, conceived and pursued a joint Hopkins?PHS Venereal Disease Research and Post- Graduate Training Center, and joint Hopkins-PHS Laboratory of Experimental Therapeutics and Venereal Disease Research, all based in Baltimore. The project was sanctioned and authorized by Hopkins President Isaiah Bowman and Rockefeller Trustee and Surgeon General Thomas Parran, MD. The Government began sending numerous members of the PHS to Hopkins for training. 3i. Dr. J. Earle Moore and other employees of Hopkins also established Johns Hopkins as the national command and control center and information clearinghouse for all federally funded investigations into the treatment of syphilis and other venereal diseases. Clinics around the country examined, treated, and followed syphilis patients acCording to a uniform plan 12 developed by Dr. Moore. They recorded their results on Hopkins-designed forms, and mailed these forms to Hopkins in Baltimore. Moore then shared the collected data with colleagues at the Hopkins School of Hygiene and Public Health, including Hopkins Vice President and physician Dr. Lowell J. Reed. Dr. Reed chaired a federally funded Biostatistical Unit, based at Hopkins, which processed data generated in the investigations. Research ?ndings were published in reports distributed by the National Research Council?s Penicillin Panel, which Dr. Moore chaired, and which included other Hopkins physicians. Tuskegee and (2er Hattie 32. Using their positions of in?uence and power in the area of STD research and prevention, Dr. Moore and other agents, servants, employees and borrowed servants of Hopkins led two now infamous research studies involving human subjects. 33. The ?rst of these studies began in 1932 and involved 600 impoverished, uneducated African?American sharecroppers who participated unknowingly in a syphilis experiment officially named the ?Tuskegee Study of Untreated Syphilis in the Negro Male.? The participants in the Tuskegee Study, many of whom had syphilis, were never told they had a debilitating and potentially fatal disease. Rather, they were intentionally deceived as to the nature of their illness, and were led to believe they were receiving effective treatment when, in fact, they only received placebos. Even after penicillin had been discovered to be an effective treatment for syphilis in the mid-19403, the researchers did not prescribe it and simply watched as men and women died from syphilis, their spouses contracted syphilis, and their children were born with congenital syphilis. I 34. Johns Hopkins? Dr. Moore was an architect of the Tuskegee Study and designed, authorized, supervised, conducted, and supported it while at Hopkins. He speci?ed to 13 the PHS doctors in the field the experiment?s sample size, demographics, and speci?cs of the examinations and tests, which continued until 1972, when the study became public knowledge and was terminated. 35. The Terre Haute Experiments began in 1942 while the Tuskegee Study was still underway. Dr. Moore asked members of the NRC Subcommittee on Venereal Diseases, which he chaired, and which included his Hopkins colleagues Dr. Harry Eagle, Dr. Thomas Turner, Dr. Lewis Weed, and Dr. Nels. Nelson, to approve experiments to be conducted on federal prison inmates in Terre Haute, Indiana. The Surgeon General of the Public Health Service, Thomas Parran, M.D., who was a close personal friend of Dr. Moore, a Trustee of The Rockefeller Foundation, and a Scienti?c Director of Rockefeller?s International Health Division, supported the Terre Haute proposal. 36. Dr. Moore?s proposal for experiments on prison inmates at Terre Haute was successful. Starting in September of 1943, experiments were performed to intentionally infect 241 prisoners with gonorrhea. The researchers involved reported directly to Dr. Moore?s Subcommittee on Venereal Diseases, which retained oversight responsibility for their work. 37. Two problems developed during the Terre Haute Experiments. First, members of the NRC became increasingly concerned about the potential for adverse legal action and bad publicity. One member worried that the details of the Terre Haute Experiments would ?fall in the hands Iof a very unscrupulous lawyer,? and that the. waivers signed by the prisoners would not constitute sufficient legal protection for the researchers. Another member was concerned about adverse publicity and public relations. Secondly, the Terre Haute researchers had dif?culty infecting the prisoners, having tried almost every method of transmission except the ?natural method? of infection, ta, sexual contact, which was felt to be impermissible in the 14 United States. 38. The Terre Haute Experiments were terminated in 1944, although Dr. Moore and the other members of the NRC Subcommittee resisted the cessation. 39. The inability of the Terre Haute researchers to develop an effective method for infecting subjects with venereal disease left them unable to address their primary research goals. As a result, their work was un?nished. The researchers needed different subjects in a different setting, where there was less scrutiny. The Guatemala Experiments 40. In 1946, the NRC Penicillin'Panel and its Subcommittee on Venereal Diseases, both chaired by Dr. Moore of Hopkins, were reconstituted into the ?Syphilis Study Section,? a committee within the National Institutes of Health. The membership and purpose of the Study Section to initiate and promote research into syphilis was the same as its predecessor. . 41. The Syphilis Study Section was composed of non?governmental researchers and liaison officers from the PHS, the-Veterans Administration, and the military, but only the non? governmental members of the Section had voting privileges. 42. Dr. Moore was the Chairman of the Syphilis Study Section. Drs. Harry Eagle, Lowell Reed, and Thomas Turner all Johns Hopkins Professors - were on the committee. Dr. Reed was the Vice President of both Johns Hopkins University and Johns Hopkins Hospital during the ?rst half of the Guatemala Experiments, and the seventh President of Johns Hopkins University during the second half of the Guatemala Experiments. At this time, Dr. Reed was also a Scienti?c Director of The Rockefeller Foundation. During the Guatemala Experiments, Dr. Turner was a Professor and Chairman of the Department of Bacteriology at the School of Public Health, and later became the Dean of the School of Medicine. So manyof the doctors on 15 the Syphilis Study Section were senior employees of Johns Hopkins that a number of its meetings were held on the Hopkins campus in Baltimore. I 43. Because of the Syphilis Study Section?s authority and voting rules, Hopkins and The Rockefeller Foundation controlled federal funding for all syphilis research at the time. 44. At the ?rst meeting of the Syphilis Study Section in February of 1946, a proposal was made and approved to conduct the Guatemala Experiments, referred to as the ?experimental transmission of syphilis to human volunteers and improved methods of prophylaxis? in Guatemala. I 45. The Guatemala Experiments were funded through a grant to the Pan American. Sanitary Bureau (PASB). They were the single largest project funded by the National Institutes of Health in 1946 and 1947. 46. The Experiments were to be conducted not on US. citizens (like the prisoners at Terre Haute) but on 'Guatemalans. Studying in Guatemala gave the researchers the opportunity to test additional methods of infecting humans with venereal disease ina foreign location more easily hidden from public scrutiny. The individuals who would be the ?subjects? in the experiments were to be children, orphans, asylum inmates, prisoners, members of the military, and other vulnerable Guatemalans. 47. Guatemala was an ideal location for such experiments for multiple reasons. First, relations between the US. Government and Guatemala were cooperative. The relationship between the military of both countries was good, ensuring secrecy and access to vulnerable, captive populations, such as prison inmates, patients, soldiers, school children, and orphans, many drawn from socio?economically disadvantaged indigenous groups not speaking the prevailing Spanish dialect. 16 48. Also, at the time, the PHS had a pre?existing relationship with Guatemala. Dr. Juan Funes, Guatemala?s leading venereal disease public health official, had trained in the United States. This relationship ensured contact, cooperation, access to, and support by the Guatemalan government. 49. Prostitution was legal in Guatemala, and sex workers underwent regular inspections at clinics controlled by Dr. Furies. This situation afforded a ?living laboratory,? making the transmission. of syphilis and other STDs by physical sexual contact possible. Prostitutes could be infected with venereal disease and then infect a study subject through intercourse, a practical impossibility at Terre Haute. 50. The Guatemala Experiments were undertaken by the same team of doctors and scientists involved in Tuskegee and Terre Haute. In all three experiments, onsite responsibility was given to a young Public Health ServiCe trained physician, Dr. John Cutler. 51. Dr. Cutler arrived in Guatemala in August of 1946. With the support, knowledge, and approval of agents, servants, and employees of Hopkins and The Rockefeller Foundation, Dr. Cutler and other researchers exposed prison inmates in the Penitenciaria Central in Guatemala City; patients in the Asilo de Alienados in Guatemala City; orphans in the Hospicio Nacional de Guatemala in Guatemala City; school children in a school in Puerto de San Jose; school children at Casa del Nino in Guatemala City, and others to syphilis, gonorrhea, chancroid, and a strain of syphilis that infects rabbits known as T. caniculz?. They were also exposed to various human and animal ?uids and tissues potentially containing other pathogens. 52. The primary purpose of the Guatemala Experiments was to develop a way to best transmit syphilis, gonorrhea and chancroid to humans so as to study the natural course and development of these diseases, ways to treat and prevent them, and the potential for humans with 17 latent or untreated syphilis to be re?infected. 5 3. During the Experiments the following occurred: a. Prostitutes were infected with venereal disease and then provided for sex to subjects for intentional transmission of the disease; b. Subjects were inoculated by injection of syphilis spirochetes into the spinal ?uid that bathes the brain and spinal cord, under the skin, and on mucous membranes; 0. An emulsion containing syphilis or gonorrhea was spread under the foreskin-of the penis in male subjects; d. The penis of male subjects was scraped or scarified and then coated with - the emulsion containing syphilis or gonorrhea; e. A woman from the hospital was injected with syphilis, developed skin lesions and wasting, and then had gonorrheal pus from a male subject injected into both of her eyes; and f. Children were subjected to blood'studies to check for the presence of venereal disease. 54. Many of the human subjects developed disease. In addition, researchers subjected the human subjects to repeated blood draws, lumbar punctures and cisternal punctures (of the suboccipital portion of the brain), gynecological examinations, touching and penetration of sexual organs, and forced or coerced sexual contact, all in furtherance of the research goals. These measures were non-therapeutic in nature. 55. The Guatemala Experiments were negligently designed and executed, lacked a logical progression, and lacked any therapeutic value for the human subjects. 5 6 .- Despite the dangerous, harmful, and invasive nature of the Experiments, the 18 Guatemalan subjects were not informed of their nature or risks, and did not (and in many cases could not, children and asylum inmates) give effective informed, voluntary, competent, and understanding consent to be experimented upon. 57. Many subjects were lied to about the nature of the Experiments, and were falsely informed that they were receiving prophylaxis or treatn'lent.S Researchers hid the truth from the . Guatemalan subjects, offering a variety of false explanations about what was being done, saying that they were being treated for non-existent conditions or for their own good. 58. Hopkins and Rockefeller did not limit their involvement to the design, planning, funding and authorization of the Experiments; instead, they exercised control over, supervised, supported, encouraged, participated in, and directed the course of the Experiments. 59. For example, to further his research into whether T. cuniculi (the rabbit syphilis spirochete) was a potential human syphilis vaccine, Dr. Turner, of Hopkins, requested that Dr. Cutler expose human subjects in Guatemala to the rabbit spirochete he was studying. He supplied T. cuniculi from his Hopkins laboratory to the on?site researchers in Guatemala, by sending from Baltimore rabbits carrying the T. cuniculi strains that he had isolated in his Hopkins laboratory. A number of Guatemalans were intentionally exposed to the rabbit syphilis strain. Mention of Dr. Turner?s work was included in the 1946 Annual Report for The Rockefeller Foundation. 60. Additionally, prior to the initiation of the Guatemala Experiments, Dr. Moore and his NRC Subcommittee on Venereal Diseases (meeting at Hopkins in Baltimore) had been studying the effectiveness of penicillin when applied in a medium of peanut oil and beeswax, and, along with Squibb Institute and Bristol Laboratories, who manufactured the product, were 5 Dr. Cutler, for instance, wrote that he had told the ?patients? that they were receiving a new treatment, and that ?this double talk keeps me hopping at times.? 19 planning further experimentation in this area. Experimentation to determine if penicillin could effectively treat syphilis if applied in a medium of peanut oil-beeswax was a major part of the Guatemala Experiments. 61. Dr. Harry Eagle, a Hopkins adjunct professor who was directing the research for the joint Hopkins/PHS laboratories at Hopkins in Baltimore, was also working to determine whether arsenic and bismuth were effective to treat and prevent the development of syphilis. Dr. Eagle suggested that his work would be of interest to the researchers in Guatemala and asked to participate in the experiments. Many subjects in Guatemala were treated with a ?schedule? of arsenic and bismuth injections developed by Dr. Eagle. 62. Dr. Eagle also acted to support the effort in Guatemala by facilitating the cooperation of the Guatemalan Army, which was integral to the success of the Guatemala Experiments. When the wife of Dr. Carlos Tejada, the Chief of the Guatemalan Army Medical Department, fell ill with acute mercury poisoning, Dr. Eagle supplied Dr. Cutler with British anti?lewisite, the antidote for such poisoning, from his lab at Hopkins. British anti-lewisite was not commercially available at the time, so this favor had a strong effect on Dr. Tejada, and ensured his ongoing cooperation for the researchers in Guatemala. The Rockefeller Foundation ?3 Role 63. As stated previously, since 1914, The Rockefeller Foundation (Rockefeller) had been involved in supporting research activities at Johns Hopkins, including research in the area of STDs. As early as 1916, the Trustees of The Rockefeller Foundation resolved to cooperate .with. Hopkins for the advancement of knowledge and the training of workers in the ?eld of public health. 64. Rockefeller?s approach to accomplishing its goals was to work within existing 20 governmental and private organizations through grants and personnel support. This philosophy was originally articulated by Wickliffe Rose, one of the ?rst Trustees of Rockefeller and the General Director of its International Health Division. Rose believed that Rockefeller should be ?a partner, but not a patron.? Accordingly, Rockefeller accomplished its goals by becoming an active participant in government and private organizations. 65. Rockefeller?s partnership with the Government consisted of both efforts of its Trustees serving in government positions, and furnishing its employees to direct governmentally funded research. 66. A part of Rockefeller?s involvement with venereal disease research at Hopkins was to assign Dr. Thomas Turner to Hopkins, and to fund his STD work there. Dr. Turner was employed by the International Health Division of Rockefeller from 1932 to 1936. At the request of Hopkins, Rockefeller assigned Dr. Turner to Hopkins with the mission of expanding its venereal disease research and training programs. Dr. Turner was conducting investigations into treponemal infections (including the spirochete that causes syphilis). In particular, Dr. Turner was interested in a spirochete that caused syphilis in rabbits, T. cuniculi. It was believed that administration of this spirochete might serve as a vaccine for human syphilis. I 67. In 1936, Thomas Parran Jr., M.D., a cousin of Dr. Turner, 'who had long been interested in the public health implications of syphilis, was appointed Scienti?c Director of the International Health Division of The Rockefeller Foundation. Later that same year, he was appointed Surgeon General of the United States. 68. In his roles as Scienti?c Director of the International Health Division of Rockefeller, as Surgeon General, and after 1941 as a Trustee of The Rockefeller Foundation, Dr. Parran worked to foster syphilis research. He was personally involved in the Tuskegee Study, 21 and reported that, ?the lifespan of male Negroes with untreated syphilis was about 20 percent shorter than that of a comparable, uninfected group.? When the Syphilis Study Section approved the grant of federal funds for the Guatemala Experiments, Dr. Parran executed the approval. 69. Dr. Parran was aware that the Guatemala Experiments would be conducted in an improper way on improper subjects. He was quoted as saying in a private conversation, ?you know, we couldn?t do such an experiment in this country.? 70. Virtually all of the human Guatemala Experiments were scheduled to be underway in Guatemala by mid?1947. The study needed a ?responsible? investigator and a discreet individual to administer the grant. 71. Dr. Frederick Soper had been an employee of The Rockefeller Foundation since he graduated from Rush University medical school in 1919. I Employed by the International Health Board of Rockefeller, he had worked in South America, Africa and the Middle East. 72. In IJanuary of 1947, The Rockefeller Foundation assigned its employee Dr. Soper to the position of Director of the Pan American Sanitary Bureau (PASB). Upon his assignment, Dr. Soper was officially designated the ?responsible Investigator? for the Guatemala Experiments. 73. Dr. Soper was given freedom from federal control in developing and conducting the Experiments, and his salary and bene?ts were paid by The Rockefeller Foundation. He reported directly to Dr. George Strode, his supervisor at The Rockefeller Foundation, throughout the Guatemala Experiments. Dr. Soper also regularly briefed Dr. Parran, a-IRockefeller Trustee. 74. In March of 1947, the Syphilis Study Section, still chaired by Dr. Moore of Hopkins, met and voted to continue the Guatemala Experiments, with Dr. Soper as the ?responsible? Investigator. 22 75. As an employee of Rockefeller, Dr. Soper traveled to Guatemala on at least six occasions to inspect the Experiments. As responsible Investigator, he was entitled to, and received, the ?full con?dence? of the local researchers implementing the Experiments. He was aware of all aspects of the Experiments, including the nature and extent to which human subjects were being intentionally exposed to and infected with STDs, including cuniculi, without their consent and without treatment. 76. Dr. Rolla E. Dyer was both the Director of the and a Scienti?c Director of . the International Health Division of The Rockefeller Foundation during the Guatemala Experiments. Dr. Dyer supported the Terre Haute Experiments, and was involved in the initial and subsequent annual review and approval of the Guatemala Experiments. 77. The Guatemala Experiments continued until the 1950s under the supervision of Dr. Soper and Dr. Juan Funes. Dr. Funes traveled to Baltimore for meetings with agents and employees of Hepkins in 1949, and reported to individuals at Hopkins and Rockefeller about the Experiment?s human subjects. Bristol?Myers Squibb ?5 Role 78. Two pharmaceutical companies, Bristol Laboratories and ER Squibb Sons, Inc?s Squibb Institute For Medical Research, also actively participated in the Guatemala Experiments despite knowing that the research subjects did not, and could not, provide adequate informed consent. I 79. Bristol Laboratories and Squibb Institute used the Guatemala Experiments as a clinical trial for testing the ef?cacy of their products. In fact, they supplied penicillin in various forms to be used in the Experiments, later patenting the process that it. 80. Dr. OskarWintersteiner, who discovered the process by which to create sodium 23 penicillin G, was the Director of Research at the Squibb Institute in the 1940s. He joined the Antibiotics Study Section in March 1946, immediately following the approval of the Guatemala Experiments by the Syphilis-Study Section. The Antibiotics Study Section?s function was to promote, develop and correlate research in the antibiotic field. As such, it allocated penicillin to all federally funded experiments requiring penicillin, including Guatemala. 81. Dr. Geoffrey R. Rake was the Medical Director of the Division of Microbiology of the Squibb Institute in the 19403. In that capacity, he obtained and used federal grants to I investigate the use of penicillin as a prophylaxis for syphilis. 82. Dr. Rake was a member of a committee appointed by the Subcommittee on Venereal Diseases (chaired by Dr. Eagle) that was concerned. with the efficacy of different I, - fractions of penicillin both as treatment of and as prophylaxis for syphilis. In July of 1945, Dr. Rake and Dr. Arthur P. Richardson, Head of the Division of Pharmacology'at the Squibb Institute, attended a meeting of the Subcommittee on Venereal Diseases held in Baltimore at - Hopkins that focused on theapplication of penicillin in a medium of peanut oil and beeswax II (FOB). As a result of the meeting, the Subcommittee recommended further syphilis - experimentation using penicillin in POB. 83. In February of 1945, Dr. Richardson attended a meeting chaired by Dr. Moore of Hopkins. One topic addressed during the meeting was the need to secure a supply of peanut oil and beeswax from pharmaceutical companies for use in penicillin experiments. 84. The following year, the committee on which Dr. Rake served was reconstituted as the Syphilis Study Section?s Subcommittee on Treatment of Experimental Syphilis With Penicillin. Under the direction of Dr. Moore of Hopkins, Dr. Rake actively investigated the efficacy of different fractions of penicillin, including penicillin G, at Squibb Institute. As a result 24 of his investigations, the Syphilis Study Section resolved that only penicillin would be used in penicillin-based experiments going forward. 85. Squibb then manufactured and supplied sodium penicillin in a suspension of peanut oil and beeswax for use in the Guatemala Experiments. Its penicillin was in fact tested on human subjects in Guatemala, both as a treatment of and as a prophylaxis for syphilis. patent application?for sodium penicillin was granted on February 15, 1949, after its penicillin had been tested in Guatemala. 86. Bristol Laboratories also manufactured penicillin in the 1940s The Medical Director of Bristol Laboratories was Dr. Delmas K. Kitchen, who was introduced to Dr. Soper, the Responsible Investigator for the Experiments. Dr. Kitchen and Dr. Soper met in 1947 to discuss the Guatemala Experiments. 87. Bristol Laboratories, like Squibb, supplied penicillin for use in the Guatemala Experiments. It, like Squibb, was aware, or should have been aware, that the human researCh subjects in Guatemala, on whom its preduct was being tested, had not and could not give adequate informed consent. I FraudAnd Concealment '88. Correspondence between the researchers involved in the Guatemala Experiments indicate that they were acutely conscious of their wrongdoing, and that they engaged in a campaign to conceal the experiments from public view. Dr. Cutler wrote: is unfortunate that we have to work in such a guarded, even subterranean way, but it seems to be very necessary? and ?it is imperative that the least possible be known and said'about this project, for a few words to the wrong person here, or even I at home, might wreck it or parts of it.? 25 90. On one occasion, Dr. Cutler?s superior expressed concern that they would be exposed to criticism for experimenting on the mentally ill, because if ?some goody organization got wind of the work, they wouldraise a lot of smoke.? He instructed Dr. Cutler: ?In the report, I see no reason to say where the work was done and the type of volunteerf? 91. i As asserted previously, Dr. Parran, a Rockefeller Trustee, privately commented with regard to the Experiments: ?You know, we couldn?t do such an experiment in this country.? 92. After Dr; Cutler left Guatemala, he came to Hopkins in 1950. Once in Baltimore, he continued to process data obtained during the Guatemala Experiments, and drafted reports on his findings. Those reports were never published, but instead, were labeled and identifying details were removed. They remained secret for deCades. 93. After the Experiments concluded, the researchers never revealed what they had done. They never told the Guatemalans subjects who had been exposed or infected about the consequences of their participation, nor did they provide them with any follow-up care, treatment, or education to minimize their pain and suffering, or to prevent them from passing disease to their spouses, children, grandchildren, and great?grandchildren. 94. None of the final reports or any of the results of the Guatemala Experiments were ever submitted for peer review or published. This lack of publication further evidences the concealment of the project. Under normal circumstances, and especially given the enormous amount of money, time, and effort that went into the Experiments, Hopkins, The Rockefeller Foundation, and other researchers involved in STD research ordinarily would have published proli?cally on their projects, work, and results. Dr. Jonathan Zenilman, at Hopkins Professor who served as technical consultant to the Presidential Commission, has concluded: ?Somebody 26 must have told them to stop the work, and put a stop to it, and said don?t publish.? 95. As a result of the secrecy that surrounded the Guatemala Experiments, and the non-disclosure of documents and records related to it, the unethical, immoral, and tortious Guatemala Experiments were not revealed in the United States until September of 2011, when the United States Presidential Commission for the Study of Bioethical Issues wrote a letter to President Barack Obama and issued a report outlining its investigation. 96. In the letter, the Commission explained that it had concluded ?that the Guatemala experiments involved gross violations of ethics as judged against both the standards of today and the researchers? own understanding of applicable contemporaneous practices.? Leaving no room for doubt about the character of the Experiments, the Commission?s report concluded that the researchers committed ?egregious moral wrongs.? 97. The Commission?s report states: ?None of these elements [of informed consent] were satisfied in Guatemala.? As its investigation shows, there is no evidence that consent was sought or obtained from the individual subjects of the research. On the contrary, there were examples of ?active deceit.? 98. The information in the Commission Report was not widely disseminated in Guatemala, and many of the subjects of the Experiments, and their spouses and descendants, still are unaware of what was done to them or their progenitors during the Experiments. 99. The Guatemalan people who were intentionally exposed to and infected with syphilis, gonorrhea, and chancroid as part of the Guatemala Experiments, and who were not treated for their disease, suffered signi?cantly as a result. Their diseases, left untreated, were painful, destructive, dis?guring, permanently damaging, and, in some cases, fatal. 100. Without knowing of their exposure, the Guatemalan research subjects passed 27 syphilis, gonorrhea, and chancroid on to their sexual partners and spouses through sexual contact, and also passed the diseases congenitally to their descendants. These individuals have suffered, and will continue to suffer, as a direct result of the Guatemala Experiments. Count I Lack Of Consent and Lack of Informed Consent 101. Plaintiffs adopt all of the preceding paragraphs and incorporate them by reference. 102. Johns Hopkins, The Rockefeller Foundation, and Bristol-Myers Squibb, as institutions and by and through their agents, servants, employees, and borrowed servants, owed a duty to the Subject Plaintiffs to exercise reasonable care in obtaining their consent and their informed consent, in properly informing them of the nature and risks inherent in the experiments, and to protect them from harm. The duty owed by Defendants to the Subject Plaintiffs arose out of a special relationship that is the same as the duty a doctor owes his or her patient or that a researcher owes his or her human subjects. The duty owed by Defendants to provide consent and informed consent also arose out of obligations imposed by international laws that were recognized and known to Defendants and their agents, servants, employees, and borrowed servants at the time. Defendants? duty not only existed at the time the Guatemala Experiments were occurring, but continued to exist after the Experiments had concluded. 103. Johns Hopkins, The Rockefeller Foundation, and Bristol-Myers Squibb, as institutions and by and through their agents, servants, employees, and borrowed servants, also owed a duty to protect the Subject Plaintiffs? spouses, children, grandchildren, and great- grandchildren (the non?Subject Plaintiffs) from the risk of being infected with and suffering from STDs as a result of their relationships with the Subject Plaintiffs. Defendants knew or should have known that the Subject Plaintiffs, once exposed, infected and untreated, were likely to spread STDs to their sexual partners, spouses, and descendants. This duty was ongoing 28 after the Guatemala Experiments had concluded. 104. Johns Hopkins, The Rockefeller Foundation, and Bristol-Myers Squibb, as institutions and by and through their agents, servants, employees, and borrowed servants, breached their duty to obtain informed, voluntary, competent, and understanding consent, and to otherwise protect the Plaintiffs from harm in the following ways: a 0 By failing to inform, or failing to adequately and properly inform, the Subject Plaintiffs that they were human research subjects; . By failing to inform, or failing to adequately and properly inform, the Subject Plaintiffs of the true nature of the research being performed on them, including the purpose of the research, the means by which it would be carried out, and the effect it would have on them and on their spouses and descendants; . By failing to obtain the Subject Plaintiffs? informed, voluntary, competent, and understanding consent; . By failing to inform the Subject Plaintiffs that they were being purposefully exposed to and infected with . By failing to inform the Subject Plaintiffs that they were not being and would not be treated for By failing to inform the Subject Plaintiffs that their sexual partners were likely to contract diseases through sexual contact; . By failing to inform the Subject Plaintiffs that any children they conceived were likely to acquire STDs from them; . By failing to warn the non?Subject Plaintiffs that they could acquire an STD 29 from their family member involved in the Experiments; i. By failing to disclose the nature of the Guatemala Experiments, failing to warn the Plaintiffs of their risk of having a sexually transmitted disease, and failing to warn the Plaintiffs of the need for treatment for sexually transmitted disease; and . In other ways. 105. Johns Hopkins, The Rockefeller Foundation, and Bristol?Myers Squibb, as institutions and through their agents, servants, employees and borrowed servants, are also liable for the actions of their agents, servants, employees, and borrowed servants who supervised, monitored, oversaw, authorized, recommended, supported, directed, and otherwise exercised control over the Guatemala Experiments. To the extent Defendants? agents, servants, employees, and borrowed seivants did not personally or directly perpetrate the actions described in this Complaint, Defendants are nevertheless jointly and severally liable in tort to the Plaintiffs inasmuch as they, as institutions and by and through their agents, servants, employees and borrowed servants, through their words, actions, conduct, and behavior, planned, encouraged, incited, aided and abetted the acts of the perpetrators of the Guatemala Experiments in the following manners: a. By approving or authorizing, and re-approving or re-authorizing, the Guatemala Experiments; b. By approving or authorizing, and re?approving or re?authorizing, the funding for the Guatemala Experiments I o. By conceiving, formulating, and planning the Guatemala Experiments; (1. By funding the Guatemala Experiments or Causing them to be funded; 30 h. k. l. 106. By encouraging the Guatemala Experiments; By contributing personnel, equipment, supplies and medication to the Guatemala Experiments; By Contributing advice, counsel, and expertise to the Guatemala Experiments; By requesting that speci?c testing and experimentation be performed in the Guatemala Experiments; By allowing the Guatemala Experiments to occur despite knowing that they involved non-therapeutic human experimentation that was harming or was likely to harm the Plaintiffs; By concealing the Guatemala Experiments while they were occurring and after they had been completed; By using the Guatemala Experiments as a clinical trial to test the ef?cacy of penicillin in order to manufacture and market it commercially; I And in other ways. Additionally, to the extent the agents, servants, employees, and borrowed servants of Johns Hopkins, The Rockefeller Foundation, and Bristol-Myers Squibb did not personally or directly perpetrate the actions described in this Complaint, Defendants are nevertheless jointly and severally liable in tort to the Plaintiffs inasmuch as they, as institutions and by and through their agents, servants, employees, and borrowed servants, entered into an agreement and understanding and conspiracy with each other and with non-parties to this lawsuit, and acted in concert with each other and with non?parties to this lawsuit, to intentionally expose and infect the Subject Plaintiffs with venereal disease without their informed, voluntary, '31 competent and understanding consent. Specifically, Defendants, as institutions and through their agents, servants, employees, and borrowed servants engaged in the following understanding, agreement and conspiracy: a. Hopkins and The Rockefeller Foundation, with each other and with non- parties to this lawsuit, formulated and planned the Guatemala Experiments as a natural extension of the Tuskegee Study and Terre Haute Experiments. Hopkins and The Rockefeller Foundation entered into an agreement or understanding with each other and with non?parties to this lawsuit as part of their ongoing efforts to maintain their positions of in?uence and power in the study and treatment of STDs, expand their reputations and in?uence in the medical and international health communities, obtain grant money, and otherwise control medical science in the area of venereal disease. Hopkins and The Rockefeller Foundation knew from their involvement in Tuskegee and Terre Haute that they could not and should not perform the types of human experiments that were performed in the Guatemala Experiments in the United States. All of the Defendants knew that law, regulations and moral and ethical standards applicable at the time required research subjects to ?be informed, and to give voluntary, competent, and understanding consent, and public pressure and the potential for litigation made such experiments impossible in this country. All of the Defendants also knew that they needed to perform additional work to identify infection techniques to overcome the limitations of the 32 Terre Haute experiments. Choosing Guatemala allowed them to conduct their experiments using prostitutes and infection by sexual contact and to perform more coercive and invasive methods in a location where they could hide their actions, and prevent their subjects from learning the true nature of their participation. f. The similarities between the goals, designs, and methods of the Guatemala Experiments and Tuskegee and Terre Haute, and the rapidity with which the Guatemala Experiments were formulated, recommended and adopted, demonstrates that Hopkins and The Rockefeller Foundation formulated and planned the Guatemala Experiments before they were ever approved by the NIH Syphilis Study section; Indeed, the Guatemala Experiments were undertaken by the same team of doctors and scientists involved in Tuskegee and Terre Haute. g. Hopkins, The Rockefeller Foundation, and Bristol-Myers Squibb contributed advice, counsel, expertise, knowledge, research, equipment, personnel, supplies, and medication to the Guatemala Experiments. h. Hopkins, The Rockefeller Foundation, and Bristol?Myers Squibb requested that specific testing and experimentation be performed in the Guatemala Experiments. Not only were they and their agents actively involved in the Experiments, but they also provided encouragement, incited, and aided and abetted the direct perpetrators. i. Hopkins, The Rockefeller Foundation, and. Bristol?Myers Squibb also kept secret the fact that the Guatemala Experiments occurred, as well as the 33 nature and extent of the Experiments, during their course, and for decades after they had concluded. Despite the fact that Defendants? agents regularly published on their research efforts, in a continuing effort to keep them secret, they deliberately never published any of the data obtained from the Guatemala Experiments, or the results of the study. 107. As a result of Defendants? breach of their duty to Plaintiffs to obtain informed, voluntary, competent, and understandingconsent, and to otherwise protect them from harm, aiding and abetting the breach of said duty, and/or (0) involvement in a conspiracy to breach said duty, Defendants caused the Plaintiffs to suffer severe, debilitating and painful persOnal injury to their bodies, as well as mental, emotional, and other non- economic losses. All of the Plaintiffs were forced to incur medical expenses, loss of earnings and loss of earning capacity, and have incurred and likely will in the future incur additional damages and economic losses. WHEREFORE, Plaintiffs claim actual damages against Johns Hopkins, The Rockefeller Foundation, and Bristol-Myers Squibb in an amount exceeding seventy??ve thousand dollars and to be determined by a jury, and punitive damages as described below. Count II Negligence 108. Plaintiffs adopt all of the preceding paragraphs and incorporate them by reference. 109. Johns Hopkins, The Rockefeller Foundation, and Bristol-Myers Squibb, as institutions and by and through their agents, servants, employees, and borrowed servants, owed a duty to the Subject Plaintiffs to exercise reasonable care to protect them from harm. The duty owed by Defendants to the Subject Plaintiffs arose out of a special relationship that is the same as, or akin to, the duty a doctor owes his patient or that a researcher owes his human subjects. 34 Defendants? duty not only existed at the time the Guatemala Experiments were occurring, but continued to exist after the Experiments had concluded. 110. Johns Hopkins, The Rockefeller Foundation, and Bristol-Myers Squibb, as institutions and by and through their agents, servants, employees, and borrowed servants, also owed a duty to the Subject Plaintiffs? spouses, children, grandchildren and great-grandchildren (the non?Subject Plaintiffs) to exercise reasonable care to protect them from harm because Defendants knew, or should have known, that the Subject Plaintiffs, once exposed, infected and untreated, were likely to spread STDs to their sexual partners, spouses, children, grandchildren, and great-grandchildren. This duty continued to exist after the Guatemala Experiments had concluded. 111. Johns Hopkins, The Rockefeller Foundation, and Bristol-Myers Squibb, as institutions and through their agents, servants, employees and borrowed servants, knew or should have known that the personnel that were selected, hired, employed, placed, or caused to be placed in Guatemala to carry out the Guatemala Experiments were exposing the Plaintiffs to an unreasonable risk of harm, and were engaging in unethical, tortious, intentional and negligent conduct that was causing actual harm to the subject Plaintiffs, and that was likely to cause harm to the non?Subject Plaintiffs. 112. Johns Hopkins, The Rockefeller Foundation, and Bristol?Myers Squibb, as institutions and by and through their agents, servants, employees, and borrowed servants, breached their duty of care to the Plaintiffs and were negligent in the following ways: a. By designing and implementing research experiments that exposed the Plaintiffs to an unreasonable risk of bodily harm; b. By designing and implementing research experiments that in fact caused 35 the Plaintiffs to suffer bodily harm; By failing to provide penicillin or other reasonable treatment to the Plaintiffs after they had been infected with By failing to provide penicillin, reasonable treatment, education, or warnings to the Plaintiffs so that their STDs would not. be passed on to their sexual partners and children; I I By failing to inform the Plaintiffs that they had been exposed to SIDS, and that they were likely to be suffering from a disease that required treatment; By failing to inform the Subject Plaintiffs that their sexual partners were likely to contract disease through sexual relations, and that any children they conceived were likely to acquire their disease; . By failing to inform the non-Subject Plaintiffs that their sexual partners, spouses, parents, grandparents, and great-grandparents had been participants . in the Guatemala Experiments, and that they therefore may have, or were likely to have, acquired a disease that required treatment; . By continuing to employ, place, retain, and otherwise permit or allow the personnel in Guatemala to continue to perform the Guatemala Experiments when they knew that said personnel were exposing the Plaintiffs to an unreasonable risk of harm, and were engaging in unethical, tortiOus, intentional and negligent conduct that was causing actual harm to Subject Plaintiffs, and that was likely to cause harm to their sexual partners and descendants; And in other ways. 36 113. To the extent Defendants? agents, servants, employees, and borrowed servants did not personally or directly perpetrate the negligence described above, Defendants are nevertheless jointly and severally liable in tort to the Plaintiffs inasmuch as they, as institutions and by and through their agents, servants, employees, and borrowed servants, through their words, actions, conduct, and behavior, planned, encouraged, incited, aided and abetted the acts of the direct perpetrators of the Experiments in the manners described in detail above. 114. Additionally, to the extent Defendants? agents, servants, employees, and borrowed servants did not personally or directly perpetrate the negligence described above, Defendants are nevertheless jointly and severally liable in tort to the Plaintiffs inasmuch as they, as institutions and by and through their agents, servants, employees, and borrowed servants, entered into an agreement and understanding and conspiracy with each other and with non? parties to this lawsuit, and acted in concert with each other and with non-parties to this lawsuit, to negligently and intentionally expose and infect the Subject Plaintiffs with syphilis and other STDs in furtherance of the Guatemala Experiments, and to perpetrate the negligence described above. 115. As a result of Defendants? breach of duty to Plaintiffs, aiding and abetting the breach of said duty, and/or (0) commission of a conspiracy to breach said duty, Defendants caused the Plaintiffs to suffer severe, debilitating and painful personal injury to their bodies, as well as mental, emotional, and other non-economic losses. All of the Plaintiffs were forced to incur medical expenses, loss of I earnings and loss of earning capacity, and have incurred and likely will in the nature incur additional damages and economic losses. WHEREFORE, Plaintiffs claim actual damages against Johns Hopkins, The Rockefeller 37 Foundation, and Bristol-Myers Squibb in an amount exceeding seventy?five thousand dollars and to be determined by a jury, and punitive damages as described below. Count Corporate Negligence 116. Johns Hopkins, The Rockefeller Foundation, and Bristol?Myers Squibb, as corporate entities who were performing experiments on human research subjects, owed a duty of care to the Subject Plaintiffs to provide them with adequate informed consent, to inform them of the nature of the experiments in which they were participating, the risks of participation, the alternatives to participation, and the consequences of participation, as well as to protect them from- harm. This duty of care is akin to the duty a hospital owes its patient, that a physician owes his or her patient, or that a research institution owes its research subjects. This duty was ongoing even after the Experiments had officially concluded. - 117. Defendants also owed a duty to protect the Subject Plaintiffs? spouses, children, grandchildren and great-grandchildren (the non?Subj ect Plaintiffs) from the risk of being infected with and suffering from STDs as a result of their relationships with the Subject Plaintiffs, and to protect them from harm. This duty too was ongoing even after the Experiments had concluded. 118. Defendants, as institutions, violated their duty of care to the Plaintiffs in the manners set forth in detail in Counts I and 11 above, which are expressly incorporated herein by reference. I 119. Defendants, as institutions, through their words, actions, conduct, and behavior, planned, encouraged, incited, aided and abetted the acts of the direct perpetrators of the Experiments in the manners described in detail above. 120. Defendants, as institutions, entered into an agreement and understanding and conspiracy with each other and with non? parties to this lawsuit, and acted in concert with each 38 other and with nOn?parties to this lawsuit, to negligently and intentionally expose and infect the Subject Plaintiffs with syphilis and other STDs in furtherance of the Guatemala Experiments, and to perpetrate the negligence described above. 121. As a result of Defendants? breach of a corporate duty to the Plaintiffs, aiding and abetting the breach of said duty, andfor (0) commission of a conspiracy to breach said duty, Plaintiffs were caused to suffer severe, debilitating and painful personal injury to their bodies, as well as mental, emotional, and other non-economic losses. All of the Plaintiffs were forced to incur medical expenses, loss of earnings and loss of earning capacity, and have incurred and. likely will in the future incur additional damages and economic losses. WHEREFORE, Plaintiffs claim actual damages against Johns Hopkins, The Rockefeller Foundation, and-Bristol-Myers Squibb in'an?amount exceeding seventy-five thousand dollars and to be determined by a jury, and punitive damages as described below. Cdunt IV Batteyy 122. Plaintiffs adoptall of the preceding paragraphs and incorporate them by reference; 123. JohnS-Hopkins, The Rockefeller Foundation, and Bristol-Myers Squibb, .by and through their agents, servants, employees, and borrowed servants, violated the bodily integrity of the Subject Plaintiffs and intentionally touched them without their consent in the following ways: a. By purposefully exposing them to and inoculating them with sexually transmitted disease; b. By purposefully exposing them to and inoculating them with material known to be infectious to rabbits; 39 c. By subjecting them to non-therapeutic medical testing and procedures, including, but not limited to: blood draws, needle sticks, lumbar and cisternal punctures, gynecologic examinations, and touching and penetration of their sexual organs (1. By forcing and/or coercing them into having sexual relations; e. And in other ways. I 124. Any alleged consent that was given by the Subject Plaintiffs to the Defendants or their agents, servants, employees and borrowed servants was not freely and intelligently given, but rather, was the result of fraud, coercion, misrepresentation, and failure to inform the Plaintiffs that the touchings were related to non-therapeutic human experimentation and medical research. As a result, any alleged consent was not legally valid. 125. The intentional and inappropriate touching of the subject Plaintiffs by the Defendants was harmful and offensive. 126. The intentional and inappropriate touching of the Subject Plaintiffs by the Defendants offended the Plaintiffs? reasonable sense of personal dignity. 127. The intentional and inappropriate touching of the Subject Plaintiffs by the Defendants caused physical pain, injury, and illness. 128. To the extent Defendants? agents, servants, employees, and borrowed servants did not personally or directly perpetrate the batteries described above, Defendants are nevertheless jointly and severally liable in tort to the Plaintiffs inasmuch as they, as institutions and by and through their agents, servants, employees, and borrowed servants, and through their words, actions, conduct, and behavior, planned, encouraged, incited, aided and abetted the acts of the direct perpetrators of the Experiments in the manners described in detail above. 40 129. Additionally, to the extent Defendants? agents, servants, employees, and borrowed servants did not personally or directly perpetrate the batteries described above, Defendants are nevertheless jointly and severally liable in tort to the Plaintiffs inasmuch as they, as institutions and by and through their agents, servants, I employees, and borrowed servants, entered into an agreement and understanding and. conspiracy with each other and non-parties to this lawsuit, and acted in concert with each other and non?parties: to this lawsuit, to intentionally infect the Subject Plaintiffs with. syphilis and other STDs in furtherance of the Guatemala Experiments, and to cOmmit the batteries described above. I A 130. 'As a result of Defendants? batteries of the Plaintiffs, aiding and abetting said batteries, and (0) commission of a conspiracy to commit said batteries, Defendants caused the Plaintiffs to suffer severe, debilitating and painful personal injury to their bodies, as well as mental, emotional, and other non-economic losses. All of the Plaintiffs were forced to incur medical expenses, loss of earnings and loss of earning capacity, and have incurred and likely will in the future incur additional damages and economic. losses. WHEREFORE, Plaintiffs claim actual damages against Johns Hopkins, The Rockefeller Foundation, and Bristol-Myers-Squibb in an amount exceeding seventy?five thousand dollars and to be determined by a jury, and punitive damages as described below. Count Fraud or Deceit By Misrepresentation . 131. Plaintiffs adopt all of the preceding paragraphs and incorporate them by reference. 132. In an effort to coerce and secure the participation of the Guatemalan test subjects in the-Guatemala Experiments, Johns Hopkins, The Rockefeller Foundation, and Bristol-Myers Squibb, as institutions and through their agents, servants, employees, and borrowed servants, made numerous false representations of material fact to the Subject Plaintiffs that were 41 designed to intentionally mislead them, including but not limited to, informing the Subject Plaintiffs that they were receiving necessary medical treatment. 133. Defendants, as institutions and through their agents, servants, employees, and borrowed servants, knew at the time they. made these representations that they were false, or, at the very. least, made these representations with such reckless indifference to their truth that it would be reasonable to charge the Defendants with knowledge of their falsity. 134. Defendants, as institutions and through their agents, servants, employees, and borrowed servants, knew at the time they made these representations that a reasonable person would rely on them. These persons intended the Subject Plaintiffs to act in reliance on their false representations of material fact, and knew that the Subject Plaintiffs were likely to rely on them. 135. The Subject Plaintiffs did in fact justifiably rely on Defendants? false representations of material fact. 136. To the extent Defendants? agents, servants, employees, and borrowed servants did not personally or directly perpetrate the fraud described above, Defendants are nevertheless jointly and severally liable in tort to the Plaintiffs inasmuch as they, as institutions and and by and through their agents, servants, employees and borrowed servants, through their words, actions, conduct, and behavior, planned, encouraged, incited, aided and abetted the acts of the direct perpetrators of the Experiments in the manners described in detail above. 137. Additionally, to the I extent Defendants? agents, servants, employees, and borrowed servants did not personally or directly perpetrate the fraud described above, Defendants are nevertheless jointly and severally liable in tort to the Plaintiffs inasmuch as they, as institutions and by and through their agents, servants, employees, and borrowed servants, 42 entered into an agreement and understanding and conspiracy with each other and non?parties to this lawsuit, and acted in concert with each other and non?parties to this lawsuit, to intentionally infect the Subject Plaintiffs with syphilis and other STDs in furtherance of the Guatemala Experiments, and to commit the fraud described above. 138. As a result of the Defendants? fraud and deceit, aiding and abetting the fraud or deceit, and/or commission'of a conspiracy to commit fraud and deceit, Defendants caused the Plaintiffs to suffer severe, debilitating and painful personal injury to their bodies, as well as mental, emotional, and other non?economic losses. All of the Plaintiffs were forced to incur medical expenses, .loss of earnings and loss of earning capacity, and have incurred and likely will in the future incur additional damages and economic losses. WHEREFORE, Plaintiffs claim actual damages against J'ohns Hopkins, The Rockefeller Foundation, and Bristol-Myers Squibb in an amount exceeding seventy-five thousand dollars and to be determined by a jury, and punitiye damages as described below. Count VI Fraudulent Concealment 139. Plaintiffs adopt all of the preceding paragraphs and incorporate them by reference. 140. Johns Hopkins, The Rockefeller Foundation, and Bristol-Myers Squibb, as institutions and by and through their agents, servants, employees, and borrowed servants, actively worked to conceal the actions of the researchers who participated in the Guatemala Experiments, as well as the actions of those who supervised, monitored, oversaw, authorized, recommended, supported, directed, and otherwise exercised control over the Experiments. They intentionally concealed from the Subject Plaintiffs and their sexual partners and descendants material facts that they had a duty to disclose, including but not limited to: failing to inform the Plaintiffs that they were human research subjects, failing to inform the Plaintiffs of the true 43 nature of the research being performed on them, failing to inform Plaintiffs that they were being exposed to and inoculated with sexually transmitted disease, failing to inform the Plaintiffs that they were or likely were infected with sexually transmitted disease, failing to inform the Plaintiffs that they were. not beingtreated for sexually transmitted disease, failing to inform the Plaintiffs that. their sexual partners were likely to contract .or were likely to have contracted disease. through sexual relations with them, and failing to inform the Plaintiffs that any children they would conceive or had conceived were likely to acquire their disease. 141. J-ohns Hopkins, The Rockefeller Foundation, and Bristol?Myers Squibb, as institutions and by and through their agents, servants, employees, and borrowed servants, actively and intentionally concealed material facts from the non?Subj ect Plaintiffs, namely, that their'sexual partners, spouses, parents, grandparents, and great- grandparents had been subjects in the Guatemala Experiments, that they therefore may have, or Were likely to have, acquired a disease that required treatment. 142. By intentionally concealing these material facts, and others, from the Plaintiffs, Defendants, as institutions and through their agents, servants, employees and borrowed servants, intended to defraud or deceive the Plaintiffs. In fact, because of Defendants? concealment of material facts, the Plaintiffs actually did justi?ably rely on Defendants and acted in a manner different than how they would have acted had they known the true facts, including but not limited to, participating in the Guatemala Experiments, failing to obtain treatment for disease, and failing to warn their sexual partners and children that they may be infected with a sexually- trans'mitted disease. 143. To the extent Defendants? agents, servants, employees, and borrowed servants did . not personally or directly perpetrate the fraudulent concealment described above, Defendants are 44 nevertheless jointly and severally liable in tort to the Plaintiffs inasmuch as they, as institutions and through their agents, servants, employees, and borrowed servants, through their words, actions, conduct, and behavior, planned, encouraged, incited, aided and abetted the acts of the direct perpetrators of the Experiments in the manners described in detail abOve. 144. Additionally, to the extent the Defendants? agents, servants, employees, and borrowed servants did not personally or directly perpetrate the fraudulent concealment described above, Defendants are nevertheless jointly and severally liable in tort to the Plaintiffs inasmuch as they, as institutions and by and through their agents, servants, employees, and borroWed servants, entered into an agreement and understanding and conspiracy with each other and non? parties to this lawsuit, and acted in concert with each other and non?parties to this lawsuit, to intentionally infect the Subject Plaintiffs syphilis and other STDs in furtherance of the Guatemala. Experiments and to commit the fraudulent conCealment that is described above. 145. As a result of the Defendants? fraudulent concealment, aiding-and abetting the fraudulent concealment, and/or (0) commission of a conspiracy to commit fraudulent concealment, Defendants caused the Plaintiffs to suffer severe, debilitating and painful personal injury to their bodies, as well as mental, emotional, and other non-economic losses. All of the Plaintiffs were forced to incur medical expenses, loss of earnings and loss of earning capacity, and have incurred and likely will-in the future incur additional damages and economic losses. I WHEREFORE, Plaintiffs claim actual damages against Johns Hopkins, The Rockfeller Foundation, and Bristol?Myers Squibb in amount exceeding seventy-five thousand dollars and to be determined by a jury, and punitive damages as described below. 45 Intentional Infliction of Emotional Distress 146. Plaintiffs adopt all of the preceding paragraphs and incorporate them by reference. 147.? The conduct of Johns Hopkins, The Rockefeller Foundation, and Bristol-Myers Squibb, as' institutions and by and through. their agents, servants, employees, and borrowed servants, in organizing, approving, funding, implementing, cooperating in, participating in, perpetrating, and concealing the Guatemala Experiments, was intentional and reckless. 148. The conduct of the Defendants, as institutions and through their agents, servants, employees, and borrowed servants, in organizing, approving, funding, implementing, cooperating in, participating in, perpetrating, and concealing the Guatemala Experiments, was extreme and outrageous. I 149. To the extent Defendants? agents, servants, employees, and borrowed servants did not personally or directly perpetrate the intentional in?ection Hof emotional distress described above, Defendants are nevertheless jointly and severally liable in tort to the Plaintiffs inasmuch as they, as institutions and through their agents, servants, employees and borrowed servants, through their words, actions, conduct, and behavior, planned, encouraged, incited, aided and abetted the acts of the direct perpetrators of the Guatemala Experiments in the manners described in detail above. 150. Additionally, to the extent Defendants? agents, servants, employees, and borrowed servants did not personally or directly perpetrate the intentional in?iction of emotional distress described above, Defendants are nevertheless jointly and severally liable in tort to the Plaintiffs inasmuch as they, as institutions and by and through their agents, servants, employees, and borrowed servants, entered into an agreement and understanding and conspiracy with each other and non?parties to this lawsuit, and acted in concert with each other and non-parties to this 46 lawsuit, to intentionally infect the Subject Plaintiffs with syphilis and other STDs in furtherance of the Guatemala Experiments and to commit the intentional infliction of emotional distress that is described above. 151. The conduct of the Defendants, as institutions and through their agents, servants, employees, apparent agents and borrowed servants, in organizing, approving, funding, implementing, cooperating in, participating in, perpetrating, concealing, aiding and abetting, and/or (0) commission of a civil conspiracy to perpetrate the Guatemala Experiments and the actions described at length in this Complaint, caused severe emotional distress to the Plaintiffs. WHEREFORE, Plaintiffs claim actual damages against Johns Hopkins, The Rockefeller Foundation, and Bristol?Myers Squibb in an amount exceeding seventy?five thousand dollars and to be determined by a jury, and punitive damages as described below." Count Uniust Enrichment 152. Plaintiffs adopt all of the preceding paragraphs and incorporate them by reference. 153. Many bene?ts were conferred upon the Defendants and the Defendants? agents, servants, employees, and borrowed servants through the Subject Plaintiffs? participation in the Guatemala Experiments. Through their research and experimentation on these Plaintiffs, Hopkins, Rockefeller, and Bristol?Myers Squibb gained recognition for their institutions, furthered their reputations- and the reputations of their agents and employees in the area of venereal disease research, attracted leading scholars, gained positions of power on government committees, obtained grant monies, furthered their work towards patent applications, developed and sold their pharmaceutical products, and benefitted financially in other ways. 154. The Defendants, as institutions and through their agents, servants, employees and borrowed servants, appreciated and were aware of the benefits conferred upon them by the 47 Plaintiffs, and in fact intentionally exploited Plaintiffs? vulnerability to achieve these bene?ts, recognizing that the Experiments could not be conducted on subj ects in the United States. 155. The circumstances under which Defendants received these benefits from the Plaintiffs render it inequitable for Defendants to retain the bene?ts without payment to Plaintiffs. In essence, Defendants have been unjustly enriched by the Subject Plaintiffs? unwitting and 'nonconsensual participation in the Experiments, and are liable to all of the Plaintiffs for the value of the bene?t they received at Plaintiffs? expense. I WHEREFORE, Plaintiffs claim actual damages against Johns Hopkins, The Rockefeller Foundation, and Bristol?Myers Squibb in an amount exceeding seventy?five thousand dollars and to be determined by a jury, and punitive damages as described below. Wrongful Death - 156. Plaintiffs adopt all of the preceding paragraphs and incorporate them by reference. 157. Plaintiffs No. 1, 2, 5, 9, 10, 12, 13, 19, 35, 49, 52, 59, 69, 77, 78, 79, 80, 87, 88, 169,171,173, 187,194, 215, 217, 221, 241, 255, 267, 269, 275, 291, 294, 302, 307, 308, 313, 314, 316, 328,, 337, 342, 350, 355, 357, 361, 362, 366, 370, 374, 376, 377, 382, 383, 384, 388, 396, 403, 406, 407, 408, 411, 412, 419, 437, 438, 453, 454, 467, 468, 469, 486, 487, 499, 507, 510, 522, 523, 540, 548, 548, 557, 558, 564, 567, 577, 582, 583, 598, 599, 600, 601, 616, 630, 653, 656, 662, 663, 664, 685, and 686 died from complications caused by the diseases they contracted as a result of the Guatemala Experiments. Their surviving spouses, children, and parents, including but not limited to the remaining Plaintiffs and other unknown Use Plaintiffs (collectively, the Wrongful Death Plaintiffs) have a cause of action under the Maryland Wrongful Death Act, Courts and Judicial Proceedings Article 3- 48 901 et seq, to recover for pecuniary loss and for the mental anguish, emotional pain and suffering, loss of society, companionship, comfort, protection, marital care, parental care, ?lial care, attention, advice, counsel, training, guidance, and education occasioned by the loss of their loved ones. WHEREFORE, the wrongful Death Plaintiffs claim actual damages against Johns Hopkins, The Rockefeller Foundation, and Bristol Myers-Squibb in an amount exceeding seventy?five thousand dollars and to be determined by a jury, and punitive damages as described below. QM Punitive Damages 158. Plaintiffs adopt all of the preceding paragraphs and incorporate them by reference. 159.. In perpetrating the acts described in Counts I through IX above, Johns Hopkins, The Rockefeller Foundation, and Bristol-Myers Squibb, as institutions and by and through their agents, servants, employees, and borrowed servants, acted with actual malice, acted unlawfully, deliberately, knowingly, intentionally, and/or wantonly, and in an extraordinary and outrageous manner characterized by wanton and reckless disregard for the rights of the Plaintiffs. The actions of the Defendants and their agents, servants, employees;land borrowed servants described in this Complaint were undertaken without legal justi?cation or excuse, but instead, with an evil or rancorous motive, the purpose being to deliberately and willfully injure the Plaintiffs and to act with reckless disregard for their safety and their lives. 160. As a result of the malicious, unlawful, deliberate, knowing, intentional, wanton, extraordinary and outrageous conduct associated with experimenting on'the Subject Plaintiffs without their consent; negligence; battery; intentional misrepresentation; fraud; deceit; concealment; intentional in?iction of emotional distress; unjust enrichment; and other actions 49 described in Counts I through IX above, the allegations of which are expressly incorporated herein by reference, Plaintiffs are entitled to an award of punitive damages. WHEREFORE, Plaintiffs claim punitive damages against Johns Hopkins, The Rockefeller Foundation, and Bristol?Myers Squibb in the amount of $1,000,000,000 (one billion dollars). Pending Admission Pro I-Iac Vice: i PAUL D. BEKMAN E. DALE ADKINS LAURENCE A. MARDER GREGORY G. HOPPER EMILY C. MALARKEY JAMES GENTRY SALSBURY, CLEMENTS, BEKMAN, MARDER ADKINS, LLC 300 West Pratt Street, Suite 450 Baltimore, MD 21201 (410) 539?6633 . Attorneys for Plaint?s F. R. JENKINS MATTHEW R. CATON MERIDIAN 361 INTERNATIONAL LAW GROUP PLLC 97A Exchange Street, Suite 202 Portland, ME 04101 (866) 338?7087 I JUAN PABLO RODRIGUEZ ESCRITORIO JURIDICO. RODRIGUEZ FAJARDO ASOCIADOS Centro Profesional Cipreses, Nivel Oficina 505 Caracas, Distrito Federal, Republica Bolivariana de Venezuela 50 EXHIBIT 1 1 Estate of Arturo Giron Alvarez San Andres Villa Seca, Retalhuleu 2 Estate of Basilia Galindo de Giron Wife San Andres Viila Seca, Retalhuieu 3 Leshia Lucila Giron Galindo daughter San Andres Villa Seca, Retalhuleu 4 Evelyn Noelia Giron Galindo Granddaughter San Andres Villa Seca, Retalhuleu 5 Estate of Mercedes Giron Gaiindo daughter San Andres Villa Seca, Retaihuleu 6 Maria Ana Giron Galindo daughter San Andres Villa Seca, Retalhuleu 7 Yngrid Rivera Giron Granddaughter San Andres Villa Seca, Retalhuleu 8 Cristian Josue Giron Galindo Grandson San Andres Vilia Seca, Retalhuleu 9 Estate of Martin Caal San Pedro Carcha, Alta Verapaz 10 Estate of Dominga Pec Wife San Pedro Carcha, Alta Verapaz 11 Jose Maria Caal Cuc grandson San Pedro Carcha, Alta Verapaz 12 Estate ofJose Pec San Pedro Carcha, Alta Verapaz 13 Estate of Dolores Cuc Wife San Pedro Carcha, Alta Verapaz 14 Jose Maria Caal Cuc Son [Grandson San Pedro Carcha, Alta Verapaz 15 Martin Caai Cuc Son/Grandson San Pedro Carcha, Alta Verapaz 16 Dolores Caal Hor GranddaUghter San Pedro Carcha, Alta Verapaz 17 Dominga Caal Hor Granddaughter San Pedro Carcha, Alta Verapaz 18 Carmen Caal Yaxcal Granddaughter San Pedro Carcha, Alta Verapaz 19 Estate of Juana Cu Cohan, Alta Verapaz 20 Cu daughter Cohan, Alta Verapaz 21 Jose Cu Son Cohan, Alta Verapaz 22 Estate of Magdalena Cu daughter Cohan, Alta Verapaz 23 Jose Alfredo Chen Grandson Cohan, Alta Verapaz 24 Cesar Armando Chen Grandson Cohan, AIta Verapaz 25 juan Cu Grandson Cohan, Alta Verapaz 26 Roumualda Cu Granddaughter Cohan, Alta Verapaz 27 Oscar Cu Grandson Cohan, Alta Verapaz 28 Juana Cu Granddaughter Cohan, Alta Verapaz 29 Mary Eugenia Cu Grandgranddaughter Cohan, Alta Verapaz 3D Wilmar A. Cu Grandgrandson Cohan, Alta Verapaz 31 Walter Anibal Cu Grandgrandson Cohan, Alta Verapaz 32 Sergio Estuardo Yat Grandgrandson Cohan, Aita Verapaz 33 Josue Daniel Yat Grandgrandson Cohan, Alta Verapaz 34 Maria Isabel Cuc Cu Grandgranddaughter Cohan, Alta Verapaz 35 Estate of FranciSCo Coyr Cohan, Alta Verapaz 36 Luisa Bol Tot Wife Cohan, Alta Verapaz 37 Edelberto Coy Boi Son Cohan, Alta Verapaz' 38 Dora Marina Coy Bol daughter Cohan, Alta Verapaz 39 Marlen Yasmin Lopez Coy Granddaughter Cohan, Alta Verapaz 4O Doris Johana Lopez Coy Granddaughter Cohan, Alta Verapaz 41 Carlos Enrique Coy Bol Son Cohan, Aita Verapaz 42 Delia Alicia Coy Bol daughter Cohan, Alta Verapaz 43 Nikte Alejandra Fuentes Covr Granddaughter Cohan, Alta Verapaz 44 Genoveva Fuentes Coy Granddaughter Cohan, Alta Verapaz 45 Juan ManUel Fuentes Coy Grandson Cohan, Alta Verapaz 46 Hailey Edelherto Coy Caal Grandson Cohan, Alta Verapaz 47 Jorge Francisco Lopez Coy Grandson Cohan, Alta Verapaz 48 Ana Mercedes Bol 1c Grandgranddaughter Cohan, Alta Verapaz 49 Estate of Gloria Judith Fuentes Quintana VD Guatemala, Guatemala 50 Miriam Salvatierra Fuentes Daughter Guatemala, Guatemala 51 Hector Ricardo-Bardales Paz VD Guatemala, Guatemala 52 Estate of Eva Horst de Bardales Wife Guatemala, Guatemala 53 HectorJose Bardales Horst SON Guatemala, Guatemala 54 Margarita Mendoza Gonzalez VD Guatemala, Guatemaia 55 Carlos Alberto Mendoza VD Guatemala, Guatemala 56 Berta Villatoro WIFE Guatemala, Guatemala 57 Luis Fernando Mendoza Viliatoro SON Guatemala, Guatemala 58 Antonio Caai Ramirez Savaxhe, Peten 59 Estate of Asuncion Pop Wife Savaxhe, Peten 60 Guillermo Caal Pop Son Savaxhe, Peten 61 Antonio Caal 'Pop Son Sayaxhe, Peten 62 Aureiia Caal Pop daughter Cohan, Alta Verapaz .63 Ramiro Galvez Villalohos VD Puerto de San Jose, Escuintla EXHIBIT 1 64 Graciela de Gaivez Wife Puerto de San Jose, Escuintla 65 Damon's Gaivez Daughter Puerto de San Jose, Escuintla 66 Nancy Andrea Marcucci Galuez Granddaughter Puerto de San Jose, Escuintla 67 Ebelyn Galvez Daughter Puerto de San Jose, Escuintla 68 Katherine Benavente Galvez Granddaughter Puerto de San Jose, Escuintla 69 Estate ofAntoni Benauente Galvez Grandgrandson Puerto de San Jose, Escuintla 70 Ronald Benairente Galuez Grandson Puerto de San Jose, Escuintla 71 Laura Yesenia Galvez Ortiz Daughter Puerto de San Jose, Escuintla 72 Dayrr? Yesenia Juarez Gaiuez Granddaughter Puerto de San Jose, Escuintia 73 Diana Stphanie Juarez Galvez Granddaughter Puerto de San Jose, Escuintla 74 Zoyla Josavet Galvez Ortiz Daughter Puerto de San Jose, Escuintla 7S Otoniei Galvez Ortiz SON Puerto de San Jase, Escuintla 76 Ramiro Galvez Ortiz SON Puerto de San Jose, Escuintla 77 Estate of Dalwn Juarez Galvez Grandgrandson Puerto de San Jose, Escuintla 78 Estate of Ronald Daniel Benavente Galvez Grandgrandson Puerto de San Jose, Escuintla 79 Estate of Haiberson Contreras Benavente Grandgrandson Puerto de San Jose, Escuintla 80 Estate of Mariano Humberto Guzman Santa Catalina, La Tinta, Alta Verapaz 81 Alba Violeta Echeverria de Guzman Wife Santa Catalina, La Tinta, Alta Verapaz 82 Rocksanda Ixmucane Guzman E. daughter Santa Catalina, La Tinta, Alta Verapaz 83 Emanuel Pop Guzman Grandson La Tinta, Panzos, Alta Verapaz 84 Cecia Jemima Pop Guzman Granddaughter Santa Catalina, La Tinta, Alta Verapaz 85 Arely Cristabel Pop Guzman Granddaughter La Tinta, Panzos, Alta Verapaz 86 Geisi Gemali Pop Guzman Granddaughter La Tinta, Panzos, Alta Verapaz 87 Estate of Matias Paredes Arteaga VD Puerto de San Jose, Escuintla 88 Estate of Francisca Javier Calderon Wife Puerto de San Jose, Escuintla 89 Miriam Paredes Calderon Daughter Puerto de San Jose, Escuintla 90 Zenaida Paredes Calderon Daughter Puerto de San Jose, Escuintla 91 Brenda Madely Hernandez Paredes Granddaughter Puerto de San Jose, Escuintia 92 Carol Arehir Hernandez Paredes Granddaughter Puerto de San Jose, Escuintla 93 Virginia Hernandez Paredes Granddaughter Puerto de San Jose, Escuintla 94 Zenaida Marlerny Hernadez Paredes Granddaughter Pnerto de San Jose, Escuintla 95 Abdeel Isai Mateo Paredes Grandson Puerto de San Jose, Escuintla 96 Junior Jose Mateo Paredes Grandson Puerto de San Jose, Escuintla 97 Mabelly Esmeralda Mateo Paredes Granddaughter Puerto de San Jose, Escuintla 98 Evean Mateo Paredes Granddaughter Puerto de San Jose, Escuintla 99 Estate of Mario Ernesto Gonzalez San Pedro Carcha, Alta Verapaz 100 Estate of Maria de Jesus Lopez de Gonzalez Wife San Pedro Carcha, Alta Verapaz 101 Elena Francisca Gonzalez Lopez daughter San Pedro Carcha, Alta Verapaz 102 Leopoldo Miranda Flores VD Puerto de San Jose, Escuintla 103 Alicia Flores Diaz Wife Puerto de San Jose, Escuintla 104 Diana Geraldin Miranda Flores Daughter Puerto de San Jose, Escuintla 105 Maria Concepcion Urbina de 3a Cruz VD Puerto de San Jose, Escuintla 106 Oscar Rene Urbina SON Puerto de San Jose, Escuintla 107 Angelina Urbina Daughter Puerto de San Jose, Escuintla 108 Reyna Isabel Garcia Urbina Daughter Puerto de San Jose, Escuintla 109 Estate ofJuIio Caal Flores VD Coban, Alta Verapaz 110 Estate of Mercedes Bol Wife Coban, Alta Verapaz 111 Roberto Bol Son Coban, Alta Verapaz 112 Ricardo Bol Son Coban, Alta Verapaz 113 Maria Elena Bol daughter Coban, Alta Verapaz 114 Jorge Armando Bol Son Coban, Alta Verapaz 115 Miriam Esperanza Bol Sagui Granddaughter Coban, Alta Verapaz 116 Erwin Armando Bol Yat Grandson Coban, Alta Verapaz 117 Carlos Humberto Bol Tot Grandson Coban, Alta Verapaz 118 Astrid Fabiola Bol Sagui Granddaughter Coban, Alta Verapaz 119 Maria Arturo Bol Macz Grandson Coban, Alta Verapaz 120 Gloria Bol Macz Granddaughter Coban, Aita Verapaz 121 Felipe Gabriel Bol Macz Grandson Coban, Alta Verapaz 122 Zoila Maribel Feucht Bol Granddaughter Coban, Alta Verapaz 123 Viima Esperanza Feucht Bol Granddaughter Coban, Alta Verapaz 124 Thelme Edelmira Feucht Bol Granddaughter Coban, Alta Verapaz 125 Elba Judith Feucht Granddaughter Coban, Alta Verapaz 126 Edwin Orlando Feucht Bol Grandson Coban, Alta Verapaz 127 Maynor Enrique Bol Maas Grandson Coban, Alta Verapaz ?it EXHIBIT 1 128 Mariela Eugenia Bol Mass Granddaughter Cohan, Alta Verapaz 129 Julio Armando Bol Mass Grandson Cohan, Alta Verapaz 130 Estate ofJose Trinidad Duarte Luch VD San Martin Jilotepeque, Chimaltenangc 131 Estate of Andrea Barillas Wife Jutiapa, Jutiapa 132 Consuelo Dauarte Barillas Daughter Jutiapa, Jutiapa 133 Amparo Duarte Barillas Daughter Jutiapa, Jutiapa 134 Jose Arnoldo Duarte Bariilas SON Jutiapa, Jutiapa 135 Javier Estuardo Aldana Duarte Grandson Guatemala,Guatemala 136 Edgar Roberto Aidana Duarte Grandson Guatemala, Guatemala 137 Wendy Carolina Aldana Duarte Granddaughter Guatemala, Guatemala 138 Marlen Andrea Aldana Duarte Granddaughter Guatemala, Guatemala 139 HenryAmilcar Flores. Duarte Grandson .iutiapa, Jutiapa 140 Juan Antonio Pereira Duarte Grandson .iutiapa, Jutiapa 141 German Oswaldo Chajon Duarte Grandson Jutiapa, Jutiapa 142 Revna Consuelo Chajon Duarte Granddaughter Jutiapa, Jutiapa 143 Victor Vitente Catu Coy Son San Pedro Carcha, Alta Verapaz 143 . Estate of Maria Julia Mendoza Escobar VD Puerto de San Jose, Escuintla 144 Alma America Arriaga Mendoza Daughter Puerto de San Jose, Escuintla 145 Estate of Juan de Dios Alvarado VD Jovabaj, Quiche 146 Estate of Ana Josefa Ortega de A Wife Joyabaj, Quiche . 147 Estate of Francisca Alvarado Granddaughter San Pedro Carcha, Alta Verapaz 148 Hilda Alvarado Grandgranddaughter San Pedro Carcha, Alta Verapaz 149 Nestor Contreras Roldan - VD Puerto de San Jose, Esculntla 150 Estate Of Maria Luisa Morales Wife Puerto de San .iose, Esculntla 151 Herrnelinda Contreras Morales Daughter Puerto de San Jose, Escuintla 152 Abner Abiel Contreras Morales SON PUerto de San Jose, Escuintla 153 Servio Ademar Contreras Morales SON Puerto de San Jose, Escuintla 154 Estate of Miguel Angel Coronado S. Coban, Alta Verapaz 155 Victor Manuel Coronado Pop Son Coban, Alta Verapaz 156 Evelyn Mayveli Coronado Sura Granddaughter Coban, Alta Verapaz 157 Gilda Marleny Coronado Sura Granddaughter Coban, Alta Verapaz 158 Aida Ofelia Coronado Wellman daughter Coban, Alta Verapaz 159 Estate Of Juan De Jesl'Js Lorenzo VD Puerto de San Jose, Escuintla 160 Eldlfonsa Lopez Lemus Wife Puerto de San Jose, Escuintla 161 Fredy Rodolfo Lorenzo Lopez SON Puerto de San Jose, Escuintla 162 Norma Alicia Lorenzo Lopez Daughter Puerto de San Jose, Escuintla 163 Maire Lucrecia Lorenzo Lopez Daughter Puerto de San Jose, Escuintia 164 Mirza Odilia Lorenzo Lopez Daughter Puerto de San Jose, Escuintla 165 Icton Castillo Lopez VD Puerto de San Jose, Escuintla 166 Norma Eliett Castillo Paredes Daughter Puerto de San Jose, Escuintla 167 Emma Ruth Castillo Paredes . Daughter Puerto de San Jose, Escuintla 168 Yolanda Paredes Daughter Puerto de San Jose, Escuintla 169 Estate Ofloel Antonio Alvarez Castillo Grandson Puerto'de San Jose, Escuintla 170 Maria Luisa Casteilanos Castillo Granddaughter Puerto de San Jose, Escuintla 171 Estate ofJuIio Juarez VD San Pedro Carcha, Alta Verapaz 172 Carlos Alfredo Juarez Alvarado Son San Pedro Carcha, Alta Verapaz 173 Estate of Matilde Alvarado de Juarez Wife San Pedro Carcha, Alta Verapaz 174 Jose Maria Carranza VD Puerto de San Jose, Escuintla 175 Jose Victor Ortega Arana VD Puerto de San Jose, Escuintla 176 Zoe Rocio Ortega Alvarenga Daughter Puerto de San Jose, Escuintla 177 Sabrina Berenice Ortega Alvarenga Daughter Puerto de San Jose, Escuintia 178 Sefora Veronica Ortega Alvarenga Daughter Puerto de San Jose, Esculntla 179 Francisco Rufino Robles VD Puerto de San Jose, Escuintla 180 Adelina Garcia De Robles Wife Puerto de San Jose, Escuintla 181 Rudy Concepcion Robles Lopez SON Puerto de San Jose, Escuintla 182 Amarilis Ninet Robles Garcia Daughter Puerto de San Jose, Escuintla 183 Jefferson ivan Robles Garcia Grandson Puerto de San Jose, Escuintla 184 Emilio Fernando Ramirez Aceituno VD Puerto de San Jose, Escuintla 185 Carlos Flores Melgar VD Puerto de San Jose, Escuintla 186 Carlos Enrique Herrera Zu?iga VD Puerto de San Jose, Escuintla 187 Estate OfJose Carlos Herrera Gonzalez SON Puerto de San Jose, Escuintla 188 Alejandro Corado VD Puerto de San Jose, Escuintla 189 Alicia Guzman De Corado Wife Puerto de San Jose, Escuintla 190 Arnilcar Oswaldo Corado Guzman SON Puerto de San Jose, Escuintla .1 'i I I I EXHIBIT 1 191 Ana Elisa Corado Guzman Daughter Puerto de San Jose, Escuintla 192 Emiisa Maricel Corado Guzman Daughter Puerto de San Jose, Escuintla 193 Basilio Perez VD Puerto de San Jose, Escuintla 194 Estate Of Maria Cristina Espaderos De P?rez Wife Puerto de San Jose, Escuintla 195 Maria Dolores Perez ESpaderos Daughter Puerto de San Jose, Escuintla 196 Maria Antonieta Perez Espaderos Daughter Puerto de San Jose, Escuintla 197 Julio Alfredo Perez Espaderos SON Puerto de San Jose, Escuintla 198 Brigido Cruz Flores VD Puerto de San Jose, Escuintla 199 Rafael Rodas Pereira VD Puerto de San Jose, Escuintla 200 Marlin Siomara Rodas Martinez Daughter Puerto de San Jose, Escuintla 201 Orfa Iris Rodas Martinez Daughter Puerto de San Jose, Escuintla 202 Gloria Noemi Rodas Martinez Daughter Puerto de San Jose, Escuintla 203 Edgar Yojani Rodas Martinez SON Puerto de San Jose, Escuintla 204 Ronylans Rodas Martinez SON Puerto de San Jose, Escuintla 205 Eric Orlando Rodas Martinez SON Puerto de San Jose, Escuintla 206 Raul Flores Melgar VD Puerto de San Jose, Esculntla 207 Agripino Huertas De Leon VD Puerto de San Jose, Escuintla 208 Aurora Palacios Villalobos VD Puerto de San Jose, Escuintla 209 Nora Maria Hernandez Palacios Daughter Puerto de San Jose, Escuintla 210 Yolanda Hernandez Palacios Daughter Puerto de San Jose, Escuintla 211 Adrian Hernandez Palacios SON Puerto de San Jose, Escuintla 212 Maria Luisa Mazariegos Montejos VD Puerto de San Jose, Escuintla 213 Jose Luis Siages Husband Puerto de San Jose, Escuintla 214 Jose Maria Escobar Lopez VD Puerto de San Jose, Escuintla 215 Estate Of Victorina Gonzalez De Escobar Wife Puerto de San Jose, Escuintla 216 Margarita Ruano Garcia VD Puerto de San Jose, Escuintla 217 Estate Of Venancio Martinez Husband Puerto de San Jose, Escuintla 218 Elvia Beatriz Martinez Ruano Daughter PUerto de San Jose, Escuintla 219 Hilda Angelica Martinez Ruano Daughter Puerto de San Jose, Escuintla 220 Alba Ruth Martinez Ruano Daughter Puerto de San Jose, Escuintla 221 Estate Of Tulio Cesar Morales VD Puerto de San Jose, Escuintla 222 Manuela De Jesus Zepeda Viuda De Morales Wife Puerto de San Jose, Escuintla 223 Edgar Stuardo Morales Zepeda SON Puerto de San Jose, Escuintla 224 Maricela Morales Zepeda Daughter Puerto de San Jose, Escuintla 225 Hector Leonel Morales Zepeda SON Puerto de San Jose, Escuintla 226 Aurora Morales Zepeda Daughter Puerto de San Jose, Escuintla 227 Maria Teresa De Jesus Santos Caceres VD Puerto de San Jose, Escuintla 228 Marco Tulio Martinez Suriano Husband Puerto de San Jose, Escuintla 229 Marco Tulio Martinez Santos SON Puerto de San Jose, Escuintla 230 Sara Martinez Santos Daughter Puerto de San Jose, Escuintla 231 Maria Eugenia Lorenzo Martinez Granddaughter Puerto de San Jose, Escuintla 232 Cindy Carolina Lorenzo Martinez Granddaughter Puerto de San Jose, Escuintla 233 Reyes Rodriguez Chutan VD Puerto de San Jose, Escuintla 234 Aura Cellnda Castillo Rodriguez Daughter Puerto de San Jose, Escuintla 235 Maria Evangelina Castillo Rodriguez Daughter Puerto de San Jose, Escuintla 236 Candelaria Castillo Rodriguez Daughter Puerto de San Jose, Escuintla 237 Luis Ernesto Castillo Rodriguez SON Puerto de San Jose, Escuintla 238 Ismael Hernandez Hernandez VD Puerto de San Jose, Escuintla 239 Orfa Victoria Hernandez Valladares Daughter Puerto de San Jose, Escuintla 240 Gloria Maritza Osorio VD Puerto de San Jose, Escuintla 241 Estate Of Marco Antonio Ortiz Lorenzana Husband Puerto de San Jose, Escuintla 242 Regina Floridalma Ortiz Osorio Daughter Puerto de San Jose, Escuintla 243 Hugo Josue Ortiz Osorio SON Puerto de San Jose, Escuintla 244 Gilberto Morales Reyes VD Puerto de San Jose, Escuintla 245 Maria Olinda Morales Blandon Daughter Puerto de San Jose, Escuintla 246 Martha Julia Morales Blandon Daughter Puerto de San Jose, Escuintla 247 Estate Of Jose Ovidio Cifuentes Del Avila VD PUerto de San lose, Escuintla 248 Ethelvina Castillo Viuda De Cifuentes Wife PUerto de San?Jose, Escuintla 249 Francisco Escobar Donis VD Puerto de San Jose, Escuintla 250 lsabel Hernandez De Escobar Wife Puerto de San Jose, Escuintla 251 Victor Hugo Escobar Hernandez SON Puerto de San Jose, Escuintla 252 Brenda Angelica Escobar Hernandez Daughter Puerto de San Jose, Escuintla 253 Norma Liliana Escobar Hernandez Daughter Puerto de San Jose, Escuintla 254 Jorge Alberto Escobar Hernandez SON Puerto de San Jose, Escuintla EXHIBIT 1 255 Estate Marian Elizabeth Escobar Castillo Granddaughter Puerto de San Jose, Escuintla 256 Eulogio Garcia Cruz VD Puerto de San Jose, Escuintla 257 Edesrnira Vasquez Muralles De Garcia Wife Puerto de San Jose, Escuintla 258 Hugo Leonel Garcia Vasquez SON Puerto de San Jose, Escuintla - 259 Edgar Rolando Garcia Vazquez SON Puerto de San Jose, Escuintla 260 Disifredo Hernandez Perez VD Puerto de San Jose, Escuintla 261 Maria Esperanza Garcia De Hernandez Wife Puerto de San Jose, Escuintla 262 Orquidia Tamara Hernandez Garcia Daughter PUerto de San Jose, Escuintla 263 Edras Bonerges Hernandez Garcia SON Puerto de San Jose, Escuintla 264 Clavellina Senovia Hernandez Garcia Daughter Puerto de San Jose, Escuintla 265 Kolther Jonatan Hernandez Garcia SON Puerto de San Jose, Escuintla 266 Keneth Azurdia Hernandez Grandson Puerto de San Jose, Escuintla 267 Estate Of Kristel Jazzeth Hernandez Calderon Granddaughter Puerto de San Jose, Escuintla 268 Maria Virginia Argueta Menendez VD Puerto de San Jose, Escuintla 269 Estate Of Eugenio Heigig Husband Puerto de San Jose, Escuintla 270 Ana Elizabeth Herzig Argueta Daughter Puerto de San Jose, Escuintla 271 Theima Judith Herzig Argueta Daughter Puerto de San Jose, Escuintia 272 Antonio Enrique Herzig Argueta SON Puerto de San Jose, Escuintla 273 Hector Ricardo Herzig Argueta SON Puerto de San Jose, Escuintla 274 Emilio Saenz VD Puerto de San Jose, Escuintla 275 Estate of Alba Acuna De Saenz Wife Puerto de San Jose, Escuintla 276 Israel Saenz Acu?a SON Puerto de San Jose, Escuintla 277 Zoila Esperanza Saenz Acu?a Daughter Puerto de San Jose, Escuintla 278 Mario Arnoldo Saenz Acu?a SON Puerto de San Jose, Escuintla 279 Lidia Veronica Saenz Acu?a Daughter Puerto de San Jose, Escuintla 280 Gloria Marlene Saenz Chanquin Granddaughter Puerto de San Jose, Escuintla 281 Elba Dominga Saenz Chanquin Granddaughter Puerto de San Jose, Escuintla 282 Wilmer Alexander Gutierrez Saenz Grandson Puerto de San Jose, Escuintla 283 Emerson Emilio Gutierrez Saenz Grandson Puerto de San Jose, Escuintla 284 Berta Luz Lopez Ramos VD Puerto de San Jose, Escuintia 285 Humberto Antonio Olivarez Lopez SON Puerto de San Jose, Escuintla 286 Juan De Dios Olivares Lopez SON Puerto de San Jose, Escuintla 287 Lilian Amparo Oiivares Lopez Daughter Puerto de San Jose, Escuintla 288 Braulio Nu?ez Salan VD Puerto de San Jose, Escuintla 289 Braulio Francisco Nunez Calito SON Puerto de San Jose, Escuintla 290 Aura Violeta Nu?ez Martinez Daughter Puerto de San Jose, Escuintla 291 Estate of Berta Catalina Urbina De La Cruz VD Puerto de San Jose, Escuintla 292 Jacoba Gallardo Urbina Daughter Puerto de San Jose, Escuintla 293 Francisca Minta Coronado {Jerez VD Puerto de San Jose, Escuintla 294 Estate OfJuan Jose Orellana Husband Puerto de San Jose, Escuintla 295 Clementina Elizabet Orellana Cororiado Daughter Puerto de San Jose, Escuintla 296 Maria Del Rosario Orellana Coronado Daughter Puerto de San Jose, Escuintla 297 Rom;r Rene Montepeque Coronado SON Puerto de San Jose, Escuintia 298 Francisco Valenzuela Aceituno VD Puerto de San Jose, Escuintla 299 Aura Yolanda Grau De Valenzuela Wife Puerto de San Jose, Escuintla 300 Maria Juiieta Valenzuela Grau Daughter Puerto de San Jose, Escuintla 301 Veronica Patricia Valenzuela Grau Daughter Puerto de San Jose, Escuintla 302 Estate of Hector Arriaza Aivarez VD Puerto de San Jose, Escuintla 303 Angela Chinchilla Poitan De Arriaza Wife Puerto de San Jose, Escuintla 304 Celso Esduardo Arriaza Chinchilla SON Puerto de San Jose, Escuintla 305 Maria Mirtala Arriaza Chinchilla Daughter Puerto de San Jose, Escuintla 306 Beronica Arriaza Chinchilla Daughter Puerto de San Jose, Escuintla 307 Estate of Mateo Caai Tzib VD San Pedro Carcha, Alta Verapaz 308 Estate of Dominga Tzui Wife San Pedro Carcha, Alta Verapaz 309 Candelaria Caal Tzul daughter San Pedro Carcha, Alta Verapaz 310 Jose Caal Tzul Son San Pedro Carcha, Alta Verapaz 311 Angelina Caal Tzul daughter San Pedro Carcha, Alta Verapaz 312 Mateo Caal Butz Grandson San Pedro Carcha, Alta Verapaz 313 Estate of Mirna Consuelo Caal Butz Granddaughter San Pedro Carcha, Alta Verapaz 314 Estate of Telma Beatris Caal Tzul Granddaughter San Pedro Carcha, Alta Verapaz 315 Ofeiia Hernandez VD Puerto de San Jose, Escuintla 316 Estate Of Joel Chang Husband Puerto de San Jose, Escuintla 317 Maricela Alvarez Hernandez Daughter Puerto de San Jose, Escuintla 318 Sandra Ma Hernandez Daughter Puerto de San Jose, Escuintla EXHIBIT 1 319 Fredv Fermin P?rez Hernandez SON Puerto de San Jose, Escuintla 320 Jorge Jose Alvarez Hernandez SON Puerto de San jose, Escuintla 321 Lidia Gonzalez Herrera VD Puerto de San Jose, Escuintla 322 Freddy Guillermo Calito Gonzalez SON Puerto de San Jose, Escuintla 323 Mario Miguel Calito Gonzalez SON Puerto de San Jose, Escuintla 324 Irma Yolanda Calito Gonzalez Daughter Puerto de San Jose, Escuintla 325 Monica Siboney Caiito Gonzalez Daughter Puerto de San Jose, Escuintla 326 Berta Luz Lopez Hernandez VD Puerto de San Jose, Escuintla 327 Dora Jeaneth Marin Lopez Daughter. Puerto de San Jose, Escuintla 328 Estate Of Enrique Pensamiento VD Puerto de San Jose, Escuintla 329 Filornena Pensamiento Aguilar Daughter Puerto de San Jose, Escuintla 330 Zonia Elizabeth Pensamiento Aguilar Daughter Puerto de San Jose, Escuintla 331 Mildred Alvarado Pensamiento Granddaughter Puerto de San Jose, Escuintla 332 Lilian Zu'cely Alvarado Pensamiento Granddaughter Puerto de San Jose, Escuintla 333 Cindy Paola Garcia Pensamiento Granddaughter Puerto de San Jose, Escuintla 334 Leslie Karina Garcia Pensamiento Granddaughter Puerto de San Jose, Escuintla 335 Evelyn Noemi Garcia Pensamiento Granddaughter Puerto de San Jose, Escuintla 336 Selvin Enrique Garcia Pensamiento Grandson Puerto cle San Jose, Escuintla 337 Estate Of Genoveva Coronado Contreras VD Puerto de San Jose, Escuintla 338 Ana Gertrudis Gallardo Coronado Daughter Puerto de San Jose, Escuintla 339 Francisco Cruz Aceituno VD Puerto de San Jose, Escuintla 340 Gloria Esperanza Chinchilla De Cruz Wife Puerto de San Jose, Escuintla 341 Rosa Gonzalez Herrera VD Puerto de San Jose, Escuintla 342 Estate Of Fernando Eduardo Velasquez Husband Puerto de San Jose, Escuintla 343 Thelma Angelica Velasquez Gonzalez Daughter Puerto de San Jose, Escuintla 344 Claudia Lorena Velasquez Gonzalez Daughter Puerto de San Jose, Escuintla 345 Maira Velasquez Gonzalez Daughter Puerto de San Jose, Escuintla 346 Rosa Cruz Velasquez Gonzalez Daughter Puerto de San Jose, Escuintla 347 Amanda Estrada VD Puerto de San Jose, Escuintla 348 Rosa Amanda Velasquez Santic Granddaughter Puerto de San Jose, Escuintla 349 Francisco Garcia Alvarez VD Coban, Alta Verapaz 350 Estate of Adelina Moilinedo de Garcia Wife San Pedro Carcha, Alta Verapaz 351 Benedicta Garcia Mollinedo daughter San Pedro Carcha, Alta Verapaz 352 Blanca Marina Garcia Mollinedo daughter San Pedro Carcha, Alta Verapaz 353 Francisco Roberto Yaxcai Garcia Grandson San Pedro Carcha, Alta Verapaz 354 Juan Francisco Garcia Mollinedo Son San Pedro Carcha, Alta Verapaz 355 Estate ofJosue David Garcia Mendez Grandson Cohan, Alta Verapaz 356 Walter Rufino Garcia Moilinedo Son San Pedro Carcha, Alta Verapaz 357 Estate of Haw Magaly Garcia Contreras Granddaughter Cohan, Alta Verapaz 358 Maria Julieta Garcia daughter San Pedro Carcha, Alta Verapaz . 359 Jaime Arnulfo Yat Garcia Grandson San Pedro Carcha, Alta Verapaz 360 Sergio Noe Garcia Mendez Grandson Coban, Alta Verapaz 361 Estate of Sadia Alejandra Garcia Mendez Granddaughter Coban, Alta Verapaz 362 Estate of Vitaiino Yaxcal Garcia Grandson San Pedro Carcha, Alta Verapaz 363 Carmen Vitalia Yaxcal Garcia Granddaughter San Pedro Ca rcha, Alta Verapaz 364 Rosa Stella Garcia daughter Coban, Alta Verapaz 365 Mercid Stella Monzon Garcia Granddaughter Coban, Alta Verapaz 366 Estate of Katherine Kazandra Garcia Contreras Granddaughter Coban, Alta Verapaz 367 Walter Gustavo Garcia Contreras Grandson Coban, Alta Verapaz 368 Jetzer de Jesus Herrera Garcia Grandson San Pedro Carcha, Alta Verapaz 369 Lovda Adelina Herrera Garcia Granddaughter San Pedro Carcha, Alta Verapaz 370 Estate Of Ricardo Toledo Ceballos VD Puerto de San Jose, Escuintla 371 Luis Alberto Toledo Vasquez SON Puerto de San Jose, Escuintla 372 Clemente Vaisquez VD Puerto de San Jose, Escuintla 373 Maria Leonor Pineda De Vasquez Wife Puerto de San Jose, Escuintla 374 Estate Of Florinda Vallejo Franco VD Puerto de San Jose, Escuintla 375 Flora Luz Pineda Vallejo Daughter Puerto de San Jose, Escuintla 376 Estate Of Santiago Mazariegos Montejos VD Puerto de San Jose, Escuintla 377 Estate ofJuana Baudilia Viuda De Mazariegos Wife Puerto de San Jose, Escuintla 378 Lesbia Veronica Mazariegos Daughter Puerto de San Jose, Escuintla 379 Dora Dillys Mazariegos Herrera Daughter Puerto de San Jose, Escuintla 380 Edvin Mazariegos Linares SON Puerto de San Jose, Escuintla 381 Julio Hernandez VD Puerto de San Jose, Escuintla 382 Estate Of Virginia Flores VD Puerto de San Jose, Escuintla EXHIBIT 1 383 Estate of Victor Manuel Montepeque Flores Son Puerto de San Jose, Escuintla 384 Estate Of Estela Toledo Ceballos VD Puerto de San Jose, Escuintla 385 Milton Laurenti Cortez Toledo Son Puerto de San Jose, Escuintla 386 Rosa Amaiia Chacon Leiva VD Puerto de San Jose, Escuintla 387 Miguel Enrique Contreras Chacon Son Puerto de San Jose, Escuintia 388 Estate Of Elfego Contreras De La Cruz VD Puerto de San Jose, Escuintla 389 Elfego Rene Contreras Higueros Son Puerto de San Jose, Escuintla 390 Yesenia Gumercinda Contreras Guirola Granddaughter Puerto de San Jose, Escuintla 391 Adalia Sibilia Contreras Paredes Daughter Puerto de San Jose, Escuintla 392 Nilton Waidir Contreras Paredes SON Puarto de San Jose, Escuintla 393 Sandor Alexander Contreras Paredes SON Puerto de San Jose, Escuintla 394 Franz Asdrubal Contreras Paredes SON Puerto de San Jose, Escuintla 395 Ardany Contreras Paredes SON Puerto de San Jose, Escuintia 396 Estate Of Manuel Oreilana VD Puerto de San Jose, Escuintla 397 Manuela Higueros Viuda De Orellana Wife Puerto de San Jose, Escuintla 398 ldania Sibonev Orellana Higueros DBUgh'ter Puerto de San Jose, Escuintla 399 Boris Melvin Son Puerto'de San Jose, Escuintla 400 Ruth Evelin Orellana 'Higue'ros Daughter Puerto de San Jose, Escuintla 401 Melvin Estuardo Orellana Guzman Son Puerto de San Jose, Escuintla 402 Mayra Elvira Orellana Guzman Daughter Puerto de San Jose, Escuintla 403 Estate Of Betzaida Slbonev Breganza Oreilana Granddaughter Puerto de San Jose, Escuintla 404 Allan Stewart Breganza Orellana Grandson Puerto de San Jose, Escuintla 405 Cristoffer Panama Orellana Grandson Puerto de San Jose, Escuintla 406 Estate of C. Augusto Velasquez M. VD Huehuetenango, Guatemala 407 Estate of Olivia Herrera de VelaSquez Wife Huehuetenango, Guatemala 408 Estate of Argentina Velasquez daughter Huehuetenango, Guatemala 409 Irma Noelia Lopez Velasquez Granddaughter Huehuetenango, Guatemala 410 Lidia Blandina Lopez Veiasquez Granddaughter Huehuetenango, Guatemala 411 Estate of Fidel Catu VD San Pedro Carcha, Alta Verapaz 412 Estate of Angela Coy de Catu Wife San Pedro Carcha, Alta Verapaz 414 Ambrocio Fide? Catu Coy Son San Pedro Carcha, Alta Verapaz 415 Erwin Rolando Catun Coyr Grandson San Pedro Carcha, Alta Verapaz 416 Gleidv Esperanza Catun {cal Granddaughter San Pedro Carcha, Alta Verapaz 417 Alvaro Joel Catun Tzul Grandson San Pedro Carcha, Alta Verapaz 418 Cristian Josue Catun Tzul Grandson San Pedro Carcha, Alta Verapaz 419 Estate of Jose Maria Valiente VD San Pedro Carcha, Alta Verapaz 420 Clara Luz Fernandez Viuda de Valiente Wife Coban, Alta Verapaz 421 Zully Valiente Fernandez daughter San Pedro Carcha, Alta Verapaz 422 Luz Maria Valiente Fernandez daughter San Pedro Carcha, Alta Verapaz 423 Jose Rodolfo Valiente Fernandez Son Coban, Alta Verapaz 424 Walter Denis Valiente Fernandez Son San Pedro Carcha, Alta Verapaz 425 Sonia Maritza Valiente Fernandez daughter San Pedro Carcha, Alta Verapaz 426 Melvyn Rossmerv Valiente Fernandez daughter San Pedro Carcha, Alta Verapaz 427 Zully Alejandra Luna Valiente Granddaughter San Pedro Carcha, Alta Verapaz 428 Flor de Maria Reyes Valiente Granddaughter San Pedro Carcha, Alta Verapaz 429 Luz Marcela Valiente Aguilar Granddaughter Coban, Alta Verapaz 430 Lourdes Anabella Valliente A. Granddaughter San Pedro Carcha, Aita Verapaz 431 Anibal Rodolfo Valiente Aguilar Grandson I San Pedro Carcha, Aita Verapaz 432 Deimy Denisse Valiente Oliva Granddaughter Puerto Barrios, Izabal 433 Jose Leonel Guililermo Valiente Grandson San Pedro Carcha, Alta Verapaz 434 Hugo Adalberto Valiente Grandson San Pedro Carcha, Alta Verapaz 435 Kevin Omar Valiente Grandson San Pedro Carcha, Alta Verapaz 436 Luis Jose Luna Valiente Grandson San Pedro Carcha, Alta Verapaz 437 Estate of Francisco Sub VD Coban, Alta Verapaz 438 Estate of Dominga Cac Quim de Sub Wife San Pedro Carcha, Alta Verapaz 439 Francisco Sub Cac Son San Pedro Carcha, Alta Verapaz 440 Antonio Sub Cac Son san Pedro Carcha, Alta Verapaz 441 Juan Sub Cac Son San Pedro Carcha, Alta Verapaz 442 Miguel Sub Cac Son San Pedro Carcha, Aita Verapaz 443 Pedro Hector Sub lco Granddaughter Panzos, Alta Verapaz 444 Juana Sub Ico Granddaughter Panzos, Alta Verapaz 445 Laura Sub Ico Granddaughter Coban, Aita Verapaz 446 Martha Sub Ico Granddaughter Panzos, Aita Verapaz 447 Francisco Sub Ico Grandson Coban, Alta Verapaz EXHIBIT 1 448 Alfredo Sub Caal Grandson Panzos, Alta Verapaz 449 Mario Sub Caal Grandson Panzos, Alta Verapaz 450 Fernando Sub Caal Grandson Coban, Alta Verapaz 451 Jorge Eliseo Sub Chen Grandson Coban, Alta Verapaz 452 Enrique Sub Chen Grandson Panzos, Alta Verapaz 453 Estate of Jorge Sanchez VD San Pedro Carcha, Alta Verapaz 454 Estate of Maria Delgado de Sanchez Wife San Pedro Carcha, Alta Verapaz 455 Secundino Sanchez Delgado Son San Pedro Carcha, Alta Verapaz 456 Marco Tulio Sanchez D. Son San Pedro Carcha, Alta Verapaz. 457 Julia Izabel Chavarria (WIFE) Wife San Pedro Carcha, Alta Verapaz 458 Berly Gabriela Sanchez Ch. Granddaughter San Pedro Carcha, Alta Verapaz 459 Secundino Sanchez Chavarrla Grandson San Pedro Carcha, Alta Verapaz 460 Arturo Sanchez Chauarria Grandson San Pedro Carcha, Alta Verapaz 461 Sussan L. Sanchez Chavarria Grandgranddaughter San Pedro Carcha, Alta Verapaz 462 Sussan Gabriela Lanza Grandgranddaughter Cohan, Alta Verapaz 463 Maria Albertina Grajeda Granddaughter Morales, Izabal 464 Marco Tulio Sanchez Grajeda Grandson Guatemala, Guatemala 465 Jorge Mario Sanchez Grajeda Grandson Guatemala, Guatemala 466 Maria Angelica Sanchez G. Granddaughter San Pedro Carcha, Alta Verapaz 457 Estate of Fidel Ramos VD San Pedro Carcha, Alta Verapaz 468 Estate of Ines Chavarria Ladidos Wife San Pedro Carcha, Alta Verapaz 469 Estate of Lotario Ramos Chavarria Son San Pedro Carcha, Alta Verapaz 470 Zoila Cleotilde Delgado {wife} Wife San Pedro Carcha, Alta Verapaz 471 Ana Ramos Delgado Granddaughter San Pedro Carcha, Alta Verapaz 472 Cristopher E. Ramos Grandgrandson San Pedro Carcha, Alta Verapaz 473 Doris Beatriz Ramos D. Granddaughter San Pedro Carcha, Alta Verapaz 474 Flor de Maria Ramos D. Granddaughter San Pedro Carcha, Alta Verapaz 475 Edgar Antonio Ramos D. Grandson Raxruha, Alta Verapaz 476 Jackeline Yanira Ramos Grandgranddaughter San Pedro Carcha, Alta Verapaz 477 Juan Pablo Ramos D. Grandson San Pedro Carcha, Alta Verapaz 478 Jorge Marlo Ramos Delgado Grandson San Pedro Carcha, Alta Verapaz 479 Doris Elena Ramos Grandgranddaughter San Pedro Carcha, Alta Verapaz 480 Alejandra Maria Ramos Grandgranddaughter San Pedro Carcha, Alta Verapaz 481 Jorge Mario Ramos S. grandgrandson San Pedro Carcha, Alta Verapaz 482 Fidel Arturo Ramos Delgado Grandson San Pedro Carcha, Alta Verapaz 483 Mayra E. Ramos Perez Grandgranddaughter San Pedro Carcha, Alta Verapaz 484 Elsa Cleotilde Ramos Perez Grandgranddaughter San Pedro Carcha, Alta Verapaz 485 Fidel Antonio Ramos Perez Grandgrandson San Pedro Carcha, Alta Verapaz 486 Estate of Alberto Garcia VD San Pedro Carcha, Alta Verapaz 487 Estate of Candelaria Pop de Garcia Wife San Pedro Carcha, Alta Verapaz 488 Dolores Pop daughter San Pedro Carcha, Alta Verapaz 489 Maria Pop daughter San Pedro Carcha, Alta Verapaz 490 Teodora Col Pop Granddaughter Coban, Alta Verapaz 491 Rafael Col Pop Grandson Coban, Alta Verapaz 492 Carlos Caliz Pop Grandson Coban, Alta Verapaz 493 Cristina Caliz Pop Granddaughter San Pedro Ca rcha, Alta Verapaz 494 Rene Caliz Pop Grandson San Pedro Carcha, Alta Verapaz 495 Domingo Caliz Pop Grandson Sayaxche, Peten 496 Juana Caliz Pop Granddaughter Coban, Alta Verapaz 497 Olivia Caliz Pop Granddaughter San Pedro Carcha, Alta Verapaz 498 Berta Lidia Caiiz Pop Granddaughter San Pedro Carcha, Alta Verapaz 499 Estate of Maria Lopez VD San Pedro Carcha, Alta Verapaz 500 Samuel Enrique Lopez Son San Pedro Carcha, Alta Verapaz 501 Dominga Bol (Wife) San Pedro Carcha, Alta Verapaz 502 Maria del Carmen Lopez Bol Granddaughter San Pedro Carcha, Alta Verapaz 503 Estela Marina Lopez Grandgranddaughter Cohan, Alta Verapaz 504 Ramona Lopez Bol Granddaughter San Pedro Carcha, Alta Verapaz 505 Jose V. Lopez Bol Grandson San Pedro Carcha, Alta Verapaz 506 Carlos Enrique Lopez Bol Grandson San Pedro Carcha, Alta Verapaz 507 Estate of Rodolfo de Leon VD San Agustin ACazaguastlan, El Progreso 508 Angelina Ixirn de de Leon Wife San Pedro Carcha, Alta Verapaz 509 Jose Antonio de Leon Ixim Son San Pedro Carcha, Alta Verapaz 510 Estate Aura Elena de Leon Ixim Daughter San Pedro Carcha, Alta Verapaz 511 Maritza de Leon Ixirn Daughter San Pedro Carcha, Alta Verapaz EXHIBIT 1 512 Zoila Marina de Leon lxim Daughter San Pedro Carcha, Alta Verapaz 513 Telma Carlota de Leon lxim Daughter San Pedro Carcha, Alta Verapaz 514 Elsa Carmen de Leon ixirri Daughter San Pedro Carcha, Alta Verapaz 515 Wiima de Leon Ixim Daughter San Pedro Carcha, Alta Verapaz 516 Lucas Romeo de Leon Ixim Son San Pedro Carcha, Alta Verapaz 517 Quetzali de Leon Caal Granddaughter San Pedro Carcha, Alta Verapaz 518 Gabriela de Leon Caal Granddaughter San Pedro Carcha, Alta Verapaz 519 Ana Susana de Leon Caal Granddaughter San Pedro Carcha, Aita Verapaz 520 Edna J. de Leon Caal Granddaughter San Pedro Carcha, Alta Verapaz 521 Jose B. de Leon Caal Grandson San Pedro Carcha, Alta Verapaz 522 Estate of Alejandra de Leon Caal Granddaughter San Pedro Carcha, Alta Verapaz 523 Estate of Rodolfo A. de Leon Caal Grandson San Pedro Carcha, Alta Verapaz 524 Sara E. Mendez de Leon granddaughter San Pedro Carcha, Alta Verapaz 525 Aura Violleta Mendez Granddaughter San Pedro Carcha, Alta Verapaz 526 Loida Susana Mendez Granddaughter San Pedro Carcha, Alta Verapaz 527 Debora Mendez de Leon Granddaughter San Pedro Carcha, Alta Verapaz 528 Leidy Areliy Mendez Grandgranddaughter San Pedro Carcha, Aita Verapaz 529 Erwin Manuel Mendez Grandson San Pedro Carcha, Alta Verapaz 530 Nancy F. Requena de Leon Granddaughter San Pedro Carcha, Alta Verapaz 531 Celso Requena de Leon Grandson San Pedro Carcha, Alta Verapaz 532 Diana M. Requena de Leon Granddaughter Cohan, Alta Verapaz 533 Ericka Marina Chocooj de Leon Granddaughter San Pedro Carcha, Alta Verapaz 534 Heidi C. Barahona de Leon Granddaughter San Pedro Carcha, Alta Verapaz 535 Thelma S. Barahona de Leon Granddaughter San Pedro Carcha, Alta Verapaz 536 Sergio Barahona de Leon Grandson San Pedro Carcha, Alta Verapaz 537 Henry Barahona de Leon Grandson San Pedro Carcha, Alta Verapaz 538 Maynor Barahona de Leon Grandson San Pedro Carcha, Alta Verapaz 539 Luis Eliseo Barahona Grandson San Pedro Carcha, Alta Verapaz 540 Estate of Kevin Roderino Barahona Grandson San Pedro Carcha, Alta Verapaz 541 Gloria Estela Garcia de Leon Granddaughter San Pedro Carcha, Alta Verapaz 542 Elsa J. Garcia de Leon Granddaughter San Pedro Carcha, Alta Verapaz 543 Angelica M. Garcia de Leon Granddaughter San Pedro Carcha, Alta Verapaz 544 Evelyn Chen de Leon Granddaughter San Pedro Carcha, Alta Verapaz 545 Osmar Chen de Leon Grandson San Pedro Carcha, Alta Verapaz 546 Yasmin D. de Leon Granddaughter San Pedro Carcha, Alta Verapaz 547 Edin Arturo Chen de Leon Grandson San Pedro Carcha, Alta Verapaz 548 Estate of Gloria Raquel de Leon Cuz Granddaughter Cohan, Alta Vera paz 549 Estate of Rocio Esther de Leon Cuz Granddaughter San Pedro Carcha, Alta Verapaz 550 Rodolfo A. de Leon Cuz Grandson San Pedro Carcha, Aita Verapaz 551 Josue Daniel de Leon Cuz Grandson San Pedro Carcha, Alta Verapaz 552 Jose Guillermo de Leon Cuz Grandson San Pedro Carcha, Alta Verapaz 553 Ana Isabel de Leon Cuz Granddaughter San Pedro Carcha, Alta Verapaz 554 Romeo Lucas de Leon Cuz Grandson San Pedro Carcha, Alta Verapaz 555 Eddy Antonio de Leon Cuz Grandson San Pedro 556 Ligia Nohemy de Leon Cuz Granddaughter San Pedro Carcha, Alta Varapaz 557 Estate of Felix Molina Pop VD Cohan, Alta Verapaz 558 Estate of Carmen Juarez Yaxcal Wife San Juan Chamelco, Alta Verapaz 559 Jose Maria Molina Juarez son San Juan CharneIco, Alta Verapaz 560 Alfonzo Molina Juarez Son San Juan Chamelco, Alta Verapaz 561 Olivia Molina Juarez Daughter San Juan Chamelco, Alta Verapaz 562 Mariela C. Molina Macz Daughter San Juan Chamelco, Alta Verapaz 563 Margarita Garcia Alvarez VD Cubulco, Baja Verapaz 564 Estate of Victor Manuel Garcia Husband Cubulco, Baja Verapaz 565 Carlos Garcia Garcia Son Cubulco, Baja Verapaz 566 Odilia Garcia Garcia daughter Cubulco, Baja Verapaz 567 Estate of Ana Victoria Garcia Garcia daughter Cubulco, Baja Verapaz 568 Olga Marina Garcia Garcia Daughter Cubulco, Baja Verapaz 569 Gembiy Cristei Garcia Garcia Granddaughter Cubuico, Baja Verapaz 570 Laureen Dndina Garcia Garcia Granddaughter Cubulco, Baja Verapaz 571 Crisly Deamileth Garcia Garcia Granddaughter Cubulco, Baja Verapaz 572 Lucero Cecibel Herrera Garcia Granddaughter Cubulco, Baja Verapaz 573 Karla A. Herrera Garcia Granddaughter Cubulco, Baja Verapaz 574 Dalila Zulerna Garcia Lopez Granddaughter Cubulco, Baja Verapaz 575 - Cefora Taina Garcia Lopez Granddaughter Cubulco, Baia Verapaz EXHIBIT 1 576 Maria A. Garcia Lopez Granddaughter Cuhulco, Baja Verapaz 577 Estate of Adan Vasquez VD San Pedro Carcha, Alta Verapaz 578 Hilda Izabel Meza Sucul Daughter San Pedro Carcha, Alta Verapaz 579 Manuela deJesus Vasquez Sucui Daughter San Pedro Carcha, Alta Verapaz 580 Douglas Danilo Elias Vasquez Grandson San Pedro Carcha, Alta Verapaz 581 Mayra L. Elias Vasquez Granddaughter San Pedro Carcha, Alta Verapaz 582 Estate ofJesus Felipe Vega Albures VD Barrio San Antonio, San Marcos 583 Estate of Natalia Macz Wife Cohan, Alta Verapaz 584 Rosa Vega Macz Daughter Cohan, Alta Verapaz 585 Blanca Aurora Vega Macz Daughter Cohan, Alta Verapaz S86 Luis Felipe Vega Macz Son Cohan, Alta Verapaz 587 Rocio Yordene Mendez Vega Granddaughter Cob?an, Alta Verapaz 588 Natalia Antonieta Mendez V. Granddaughter San Pedro Carcha, Alta Verapaz 589 Felipe Antonio Mendez Vega Grandson Cohan, Alta Vera paz 590 Byron Estuardo Mendez Vega Grandson Cohan, Alta Verapaz 591 Jaime Rene Molina Vega Grandson Cohan, Alta Verapaz 592 Marlo Felipe Molina Vega Grandson Cohan, Alta Verapaz 593 Eddyr Omar Molina Vega Grandson San Pedro Carcha, Alta Verapaz 594 Luis Felipe Vega Alvarado Grandson San Pedro Carcha, Alta Verapaz 595 Vivian Sucel Vega Alvarado Granddaughter Cohan, Alta Verapaz 596 Maria Fernanda Vega A. Granddaughter San Pedro Carcha, Alta Verapaz 597 Luis Enrique Vega Alvarado Grandson Cohan, Alta Verapaz 598 Estate of Juan Mendez VD San Pedro Carcha, Alta Verapaz 599 Estate of Abraham Mendez Coc son San Pedro Carcha, Alta Verapaz 600 Estate of Ezequiel Mendez Che son San Pedro Carcha, Alta Verapaz 601 Estate of Leonilda Mendez Coc (-1-) Daughter San Pedro Carcha, Alta Verapaz 602 Dominga Mendez Coc Daughter San Pedro Carcha, Alta Verapaz 603 Luvia Aracer Mendez Pacay Daughter San Pedro Carcha, Alta Verapaz 604 Rodolfo Mendez Choc Grandson San Pedro Carcha, Alta Verapaz 605 Juan Jose Mendez Choc Grandson Fray Bartolome delas Casas Alta Verapa 606 Leona Mendez Choc Granddaughter San Pedro Carcha, Alta Verapaz 607 Benjamin Mendez Choc Grandson San Pedro Carcha, Alta Verapaz 608 Amilcar Ollverio Mendez Choc Grandson San Pedro Carcha, Alta Verapaz 609 Hector Rolando Mendez Pacay Grandson San Pedro Carcha, Alta Verapaz 610 Irene Oralda Mendez Vidaurre Granddaughter Fray Bartolome delas Casas Alta Verapa 611 Susana Maribel Mendez V. Granddaughter Fray Bartolome delas Casas Alta Verapa 612 Hilma Luisa Mendez Pacay Granddaughter San Pedro Carcha, Alta Verapaz 613 Delia Magaly Mendez Pacay Granddaughter San Pedro Carcha, Alta Verapaz 614 Juan Ramiro Caal Mendez Grandson San Pedro Carcha, Alta Verapaz 615 Walter Adolfo Tzi Mendez Grandson San Pedro Carcha, Alta Verapaz 616 Estate of Carlos W. de la Cruz Mendez Grandson San Pedro Carcha, Alta Verapaz 617 Floricelda E. Mendez Granddaughter San Pedro Carcha, Alta Verapaz 618 Alex Adan Caal Mendez Grandson San Pedro Carcha, Alta Verapaz 619 Eva Lorena Caal Mendez Granddaughter San Pedro Carcha, Alta Verapaz 620 Esteban Mendez Grandson San Pedro Carcha, Alta Verapaz 621 Juan Estuardo Coc Mendez Grandson San Pedro Carcha, Alta Verapaz 622 Geidy Amarilis Coc Mendez Granddaughter San Pedro Carcha, Alta Verapaz 623 Byron R. de la Cruz Sierra Grandgrandson San Pedro Carcha, Alta Verapaz 624 Carlos Leonel de la Cruz Dubon Grandgrandson San Pedro Carcha, Alta Verapaz 625 Marvin Israel de la Cruz D. Grandgrandson San Pedro Carcha, Alta Verapaz 626 Ruben Yaxcal Mendez Grandgrandson San Pedro Carcha, Alta Verapaz 627 Blanca Yaxcal Mendez Grandgranddaughter San Pedro Carcha, Alta Verapaz 628 Raquel Mendez Coc Grandgranddaughter San Pedro Carcha, Alta Verapaz 629 Jaime Mendez Coc Grandgrandson San Pedro Carcha, Alta Verapaz 630 Estate of Carlos Lopez VD San Pedro Carcha, Alta Verapaz 631 Margarita Lopez Caai Daughter San Pedro Carcha, Alta Verapaz 632 Estate-Of celinda Lopez 'Caal daUghter San Pedro Carcha, Alta Verapaz 633 Zoila Lopez Caal daughter San Pedro Carcha, Alta Verapaz 634 Candelaria Lopez Caal daughter San Pedro Carcha, Aita Verapaz 635 Carlos Lopez Caal son San Pedro Carcha, Alta Verapaz 636 Zoila Maas Lopez de Chen Granddaughter San Pedro Carcha, Alta Verapaz 637 Margarita Chen Lopez Granddaughter San Pedro Carcha, Alta Verapaz- 638 Eva Fidelina Chub Lopez Granddaughter San Pedro Carcha, Alta Verapaz 639 Margarita Pop Lopez Granddaughter San Pedro Carcha, Alta Verapaz EXHIBIT 1 640 Juana Pop Lopez Granddaughter San Pedro Carcha, Aita Verapaz 641 Carmela Pop Lopez Granddaughter San Pedro Carcha, Alta Verapaz 642 Jorge Pop Lopez Grandson San Pedro Carcha, Alta Verapaz 643 Alfonso Pop Lopez Grandson San Pedro Carcha, Alta Verapaz 644 Rolando Pop Lopez Grandson San Pedro Carcha, Alta Verapaz 645 Rafael Pop Lopez Grandson San Pedro Carcha, Alta Verapaz 646 Mario Lopez Xol Grandson San Pedro Carcha, Alta Verapaz 647 Arnulfo Lopez Xol Grandson San Pedro Carcha, Alta Verapaz 648 Ana Florinda Lopez Xol Granddaughter San Pedro Carcha, Alta Verapaz 649 Manuel Chun VD Cahabon, Alta Verapaz 650 Manuel Chun Pec son Cahabon, Alta Verapaz 651 Juan Aiberto Ch un Pec son Cahabon, Alta Verapaz - 652 Marta Chun Pec Daughter Cahabon, Alta Verapaz 653 Estate of Job Corzantes VD Tactic, Alta Verapaz . 654 Carmen Calel Jom Wife San Cristobal Verapaz, Alta Verapaz 655 Oscar Oswaido Corzantes Calel Son San Cristobal Verapaz, Aita Verapaz 656 Estate of Jose Molina VD San Pedro Carcha, Alta Verapaz 657 Maria Angeiina Molina Cu Daughter San Pedro Carcha, Alta Verapaz 658 Jose Eduardo Molina grandson San Pedro Carcha, Alta Verapaz 659 Oswaldo Filiberto Moiina grandson San Pedro Carcha, Alta Verapaz 660 Maria Edaigiza Molina Lopez Grandgranddaughter San Pedro Carcha, Alta Verapaz 661 Kurt Melquisedec Molina Lopez Grandgrandson San Pedro Carcha, Alta Verapaz 662 Estate of Maria Mendez VD San Pedro Carcha, Alta Verapaz 663 Estate of Felipe Newr Ramirez Gomez Husband San Pedro Carcha, Alta Verapaz 664 Estate of Marco Antonio Mendez Son San Pedro Carcha, Alta Verapaz 665 Ursula Isabel Ramirez Mendez Daughter San Pedro Carcha, Alta Verapaz 666 Reginaldo Ramirez Mendez Son San Pedro Carcha, Alta Verapaz 667 Dora Lilv Ramirez Mendez Daughter San Pedro Carcha, Alta Verapaz 668 Marlon Giovani Mendez Pacay Grandson San Pedro Carcha, Aita Verapaz 669 Nelson Antonio Mendez Pacayr Grandson San Pedro Carcha, Alta Verapaz 670 Alvaro Daniio Mendez Pacav Grandson San Pedro Carcha, Alta Verapaz 671 Dary Alejandro Barahona Ramirez Grandson San Pedro Carcha, Alta Verapaz 672 Eneida Grisel Barahona Ramirez Granddaughter San Pedro Carcha, Alta Verapaz 673 Dora Alejandra Barahona Ramirez Granddaughter San Pedro Carcha, Alta Verapaz 674 Ivone Alejandra Barahona Ramirez Granddaughter San Pedro Carcha, Alta Verapaz 675 Gabriela Alejandra Barahona Ramirez Granddaughter San Pedro Careha, Alta Verapaz 676 Miriam Susette Santa Maria Ramirez Granddaughter San Pedro Carcha, Alta Verapaz 677 Karen Maitte Santa Maria Ramirez Granddaughter San Pedro Carcha, Alta Verapaz 678 Marvr Isabel Santa Maria Ramirez Granddaughter San Pedro Carcha, Alta Verapaz 679 Leslie Eunice Santa Maria Ramirez Granddaughter San Pedro Carcha, Alta Verapaz 680 Carol Guisela Santa Maria Ramirez Granddaughter San Pedro Carcha, Alta Verapaz 681 Ronaid Rigoberto Santa Maria Ramirez grandson San Pedro Carcha, Alta Verapaz 682 Krisna Nohemy Santa Maria Ramirez Granddaughter San Pedro Carcha, Alta Verapaz 683 Franklin Amaurv Ramirez Hernandez grandson San Pedro Carcha, Alta Verapaz 684 Nery Vinicio Ramirez Hernandez grandson San Pedro Carcha, Aita Verapaz 685 Estate of Juan Flores Caal VD San Pedro Carcha, Aita Verapaz 686 Estate of Maria de Jesus Flores Pop Wife San Pedro Carcha, Alta Verapaz 687 Luis Flores Pop Son San Pedro Carcha, Alta Verapaz 688 Juan Gerardo Flores Pop Son San Pedro Carcha, Alta Verapaz 689 Carlos Valiente Delgado VD San Pedro Carcha, Alta Verapaz 690 Nidia Soiangex Alvaradado Wife San Pedro Carcha, Alta Verapaz 691 Gema Francisca Valiente A. Daughter Coban, Alta Verapaz 692 Nvdia Eunice Valiente A. Daughter San Pedro Carcha, Alta Verapaz 693 Alrna Nizzet Valiante A. Daughter Coban, Alta Verapaz 694 Pahola A. Valiente Alvarado Daughter San Pedro Carcha, Alta Verapaz 695 Carlos Napoleon Valiente A. SON San Pedro Carcha, Alta Verapaz 696 Shawinie Davana Rivera V. Granddaughter Coban, Alta Verapaz 697 Luis Josue Tut Valiente Grandson San Pedro Carcha, Alta Verapaz 698 Jazmin Nizeth Vaiiente A. Granddaughter Coban, Alta Verapaz 699 Emanuel A. Valiente Alvarado Grandson San Pedro Carcha, Alta Verapaz 700 Nidia Argentina Vaiiente J. Granddaughter San Pedro Carcha, Alta Verapaz 701 Julye M. Valiente Jeronimo Granddaughter San Pedro Carcha, Aita Verapaz 702 Astrid Lorena Vaiiente J. Granddaughter San Pedro Carcha, Aita Verapaz 703 VD San Pedro Carcha, Alta Verapaz Vicenta Guerrero EXHIBIT 1 704 Jose Alberto Mendoza Guerrero SON San Pedro Carcha, Alta Verapaz 705 Carlos Salvador Mendoza Guerrero SON San Cristobal Verapaz, Aita Verapaz 706 Luis Raymundo Mendoza Garcia Grandson El Estor, lzabai 707 Havy Viviana Mendoza Garcia Granddaughter Cohan, Alta Verapaz 708 Selvin Salvador Mendoza Morales Grandson Coban, Alta Verapaz 709 Edna Susana Mendoza Morales Granddaughter San Pedro Carcha, Aita Verapaz 710 Bianka Jackeline Mendoza Requena Grandgranddaughter San Pedro Carcha, Alta Verapaz 711' Luis Diego Antonio Mendoza Requena Grandgrandson San Pedro Carcha, Alta Verapaz 712 AmilcarJosue Gabriel Peralta Mendoza Grandgrandson San Pedro Carcha, Alta Verapaz 713 Jennifer Viviana Peralta Mendoza Grandgranddaughter San Pedro Carcha, Alta Verapaz 714 Seivin Jose Roberto Peralta Mendoza Grandgrandson San Pedro Carcha, Alta Verapaz 715 Grethel Sofia Mendoza Montenegro Grandgranddaughter Guatemala, Guatemala 716 Juan Caal Pacay VD San Cristobal Verapaz, Alta Verapaz 717 Carmen Albina Caal Chiquin Daughter San Cristobal Verapaz, Aita Verapaz 718 Carmen Abigail Garcia Caal Granddaughter Cohan, Aita Verapaz 719 Jose Victoriano Cruz Estrada VD San Cristobal Verapaz, Alta Verapaz 720 Ofelia Mus Lemus Wife San Cristobal Verapaz, Alta Verapaz 721 Alida Soledad CruzMus Daughter San Cristobal Verapaz, Alta Verapaz 722 Maria Esperanza Cruz Mus Daughter San Cristobal Verapaz, Alta Verapaz 723 Daniel de Leon VD San Jeronimo, Baja Verapaz 724 Catarina Ixtecoc Valey Wife San Jeronirno, Baja Verapaz 725 Maria Josefina de Leon pratac Daughter San Jeronirno, Baja Verapaz 726 Alberto de Leon lxtecoc SON San Jeronirno, Baja Verapaz 727 Aura Marina de Leon Ixxtecoc Daughter - San Jeronirno, Baja Verapaz 728 Lester Daniel de Leon Garcia Grandson San Jeronimo, Baja Verapaz 729 Norma Judith de Leon Sis Granddaughter San Jeronirno, Baja Verapaz 730 Ana Barbara de Leon Sis Granddaughter San Jeronirno, Baja Verapaz 731 Yohan Osiel Guzman de Leon Grandson San Jeronimo, Baja Verapaz 732 Elder Tomas Ac de Leon Grandson San Jeronimo, Baja Verapaz 733 Jose Lopez Hernandez VD Salama, Baja Verapaz 734 Brigido LOpez Juc SON Salama, Baja Verapaz 735 German Servando Lopez Juc SON Salama, Baja Verapaz 736 Julieta Lopez Rodriguez Daughter Salama, Baja Verapaz 737 Rosa Delia Lopez Juc Daughter Salama, Baja Verapaz 738 Bernanrdino Lopez Juc SON Salama, Baja Verapaz 739 Leslvr Roel de 105 Santos Lopez Grandson Salama, Baja Verapaz 740 Mayra Azucena Lopez Gaieano - Granddaughter Salama, Baja Verapaz 741 Reyna Maricela Lopez Galeano Granddaughter Salama, Baja Verapaz 742 ErickAlexander Lopez Rodriguez Grandson Salama, Baja Verapaz 743 Sindy Judith Lopez Rodriguez Granddaughter Salama, Baja Verapaz 744 Darvin Estuardo Lopez Rodriguez Grandson Salama, Baja Verapaz 745 Mario Wilfredo Lopez Rodriguez Grandson Saiama, Baja Verapaz 746 Elrner Antonio Lopez Velasquez Grandson Saiama, Baja Verapaz 747 Nineth Azucena Lopez Lopez Grandgranddaughter Salama, Baja Verapaz 748 Midler Delia Sarahi Velasquez Lopez Granddaughter Salama, Baja Verapaz 749 CesarJoel Lopez Rodriguez Grandson Salama, Baja Verapaz 750 Elm; Adalv Velasquez Lopez Granddaughter Salama, Baja Verapaz 751 Elba Dalila Lopez Galeano Granddaughter Salama, Baja Verapaz 752 ,Esteban Lopez VD Salama, Baia Verapaz 753 Tecia Alvarez de Lopez Wife Salama, Baja Verapaz 754 Jose Domingo Lopez Alvarez SON Salama, Baja Verapaz 755 Marco Antonio Lopez Aivarez SON Salama, Baja Verapaz 756 Emiliano Alvarez VD Salama, Baja Verapaz 757 Cornelia Alvarez Perez Daughter Salama, Baja Verapaz 758 Brenda Marisol Alvarez Granddaughter Salama, Baja Verapaz 759 Edwin Gustavo Luna Alvarez Grandgrandson Salama, Baja Verapaz 760 Carlos Humberto Luna Alvarez Grandgrandson Saiama, Baja Verapaz 761 Dennis Ruben Luna Alvarez Grandgrandson Saiama, Baja Verapaz 762 Antonio Perez Santiago VD Salama, Baja Verapaz 763 Antonia Andres Alonzo Wife Salama, Baja Verapaz 764 Enrique Perez Andres SON Salama, Baja Verapaz 765 Marta Irene Perez Garcia Granddaughter Salama, Baja Verapaz 766 Leyla Lorena Perez Garcia Graddaughter Salama, Baja Verapaz 767 Domingo Perez Andres SON Salama, Baja Verapaz EXHIBIT 1 768 Jose Claro Perez Andres SON Salama, Baja Verapaz 769 Delia Elizabeth Perez Guevara Granddaughter Salama, Baja Verapaz 770 Gioria Evangelina Perez Guevara Granddaughter Salama, Baja Verapaz 771 Luis Aiberto Perez Guevara Grandson Salama, Baja Verapaz 772 Maria Victoria Perez Guevara Granddaughter Salama, Baja Verapaz 773 Jorge Anibal Perez Guevara Grandson Salama, Baja Verapaz 774 Grandson Salama, Baja Verapaz Carlos Enrique Perez Garcia 9333:: . - ESTATE OF ARTURO GIRON ALVAREZ, et by and through Maria Ana Giron Galindo as Administrator PLAINTIFFS V. THE JOHNS HOPKINS UNIVERSITY, et al. DEFENDAN TS. f: IN THE CIRCUIT COURT FOR BALTIMORE CITY Case No: DEMAND FOR JURY TRIAL Plaintiffs elect to have their case tried before a jury. (PMW PAUL D. BEKMAN E. DALE ADKINS HI LAURENCE A. MARDER GREGORY- G. HOPPER EMILY C. MALARKEY JAMES GENTRY SALSBURY, CLEMENTS, BEKMAN, MARDER ADKINS, LLC 300 West Pratt Street, Suite 450' Baltimore, 21201 (410) 539-6633 Attorneys for Plaintiff? .-