(Against all Defendants)   13. Plaintiffs bring this action as a Class Action pursuant to Rules 23(a), (b)(1), (b)(2)  and (b)(3) of the Federal Rules of Civil Procedure on behalf of all persons who are or  were descendants of Freedmen minor allottees of the Five Civilized Tribes.    15. In 1898, the United States enacted the Curtis Act, allotting the land of the Five  Civilized Tribes.  The land was not allotted earlier under the Dawes Act.  In 1908  Congress removed restrictions from Freedmen allotments, except land allotted to minors.   Congress imposed specific fiduciary duties on the Secretary of Interior with respect to  Freedmen minor allottees.  Plaintiffs seek an accounting in relation to revenue from  leases on land allotted to their minor Freedmen   16. The Class consists of thousands of persons located throughout the United States,  thus, the members of the Class are so numerous that joinder of all Class members in  impracticable.  The exact number of Class members is not presently known to plaintiffs,  but can readily be determined by appropriate discovery.   17. Plaintiffs will fairly and adequately protect the interests of the members of the  Class and have retained counsel competent and experienced in class actions.  Plaintiffs  have no interests that are adverse or antagonistic to those of the Class.   18. A class action is superior to other available methods for the fair and efficient  adjudication of this controversy.  Because the damages suffered by many individual Class  members may be relatively small, the expense and burden of individual litigation make it  virtually impossible for the Class members to individually seek redress for the wrongful  conduct alleged herein.   35. Plaintiffs allege all that has been alleged above as though fully restated herein.   36. Defendants have a duty under Section 6 of the Act of May 27, 1908 to provide an   accounting to descendants of minor Freedmen  of royalties derived from leases on  restricted land held by Freedmen minors.   38. Defendants deny that they owe any fiduciary duty whatsoever to Plaintiffs and in  so doing have denied Plaintiffs’ demand for an accounting.  Secretary of the Interior  :  1849 C. Street, NW  :  Washington, D.C. 20240  :  :  and  :  : 