• Introduction

• Scheme to infiltrate and control "Valley of Lakes"

• Land Development Scheme

• Lake Algonquin Scheme

• Building Fees Scheme

• Real Estate Scheme

• Sewage System Schemes

• Arnold Palmer Golf Course Scheme

• Bank's scheme to conceal insolvency of CBG Ltd.

• Scheme to continue Racketeering using Chapter 11 Bankruptcy protection

• Bank's Scheme to operate and manage the Racketeering Enterprise

• Scheme to conceal Racketeering Activity prior to merger and to continue Pattern of Racketeering Indefinitely

• Enterpise

• Pattern of Unlawful Racketeering Activity

• Summary of each defendant's association with and participation in the pattern of Racketeering Activity

• Summary of each plaintiff's injury to Business or Property

• Count II: Interstate Land Sales Full Disclosure Act

• Count III: Civil Rights Violations

• Count IV: N.J. Real Estate Sales Full Disclosure Act

• Count V: Common Law Fraud and Deceit

383. Plaintiffs repeat and reallege the allegations contained in COUNT I of this complaint as fully as if set forth here.

384. Count III is brought by all of the plaintiffs as a class action against the Defendant CBG, FRANK CEDRONE, FIRST EASTERN BANK, MLA, and the PROPERTY OWNERS ASSOCIATION OF THE VALLEY OF LAKES.

385. Jurisdiction is conferred on this court by 28 U.S.C. 1331.

386. By virtue of owning property in the "Valley of Lakes" subdivision, the plaintiffs have a property interest and liberty interests secured by the Constitution and laws of the United States.

387. The defendants have systematically deprived plaintiffs of property interests and/or liberty interests under color of statute, ordinance, regulation, or usage.

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