Second Amended Class Action Complaint

In the United States District Court for the District of Columbia

This class action complaint is brought by and on behalf of Holocaust survivors, former residents of geographic areas of what is today or what once was, during the period of time relevant to this Complaint, part of Hungary or subject to its control. Plaintiffs, Rosalie Simon, Helen Herman, Charlotte Weiss, Helena Weksberg, Rose Miller, Esther Zelikovitch as Heir at Law to Tzvi Zelikovitch, Asher Yogev as Heir at Law to Tzvi Zelikovitch, Yosef Yogev as Heir at Law to Tzvi Zelikovitch, 1 Magda Kopolovich Bar-Or, Zehava Friedman, Yitzhak Pressburger, Alexander Speiser, Ze’ev Tibi Ram, Vera Deutsch Danos, Ella Feuerstein Schlanger, and Moshel Perel bring the suit on their own behalf and on behalf of all Hungarian Holocaust survivors and the immediate families of Hungarian Holocaust victims.

The suit is brought against two defendants directly complicit in the Hungarian Holocaust: Hungary, and the Hungarian National Railway. The defendants orchestrated, collaborated and participated in the confiscation of the personal possessions of their Hungarian Jewish victims, including Plaintiffs, and their transportation by train to the killing fields and death camps of Nazi Germany-occupied Poland and the Ukraine, where the Jews were tortured and the vast majority died.