• 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

340. The racketeering enterprise, within the meaning of 18 U.S.C. Section 1961, is an association in fact of FRANK M. CEDRONE, C.B.G. LIMITED ,ONEIDA WATER COMPANY ,VALLEY UTILITIES COMPANY, INC., FIRST EASTERN CORPORATION, FIRST EASTERN BANK, N.A., MLA MANAGEMENT ASSOCIATES, INC., RALPH CONTE, and ARLENE RAINESS, and THE PROPERTY OWNERS ASSOCIATION OF THE VALLEY OF LAKES, and other individuals organized around the "Valley of Lakes and Eagle Rock Resort" based on each defendant's particular function within the enterprise. These various associates function as a continuing unit.

341. In the alternate, the racketeering enterprise is C.B.G. Ltd., and FRANK M. CEDRONE is employed by and associated with C.B.G. Ltd., RALPH CONTE was employed by C.B.G. LTD. and is associated with C.B.G. LTD., and x, y, z are associated with the enterprise.

342. The enterprise IS AN ENTITY SEPARATE AND APART FROM THE PATTERN OF ACTIVITY IN WHICH IT ENGAGES, to wit:

a. the enterprise has a distinct structure based on the essential functions of operating what defendants refer to as the "Valley of Lakes and Eagle Rock Resort", e.g., marketing functions, security functions, financing functions, etc.;

b. the enterprise has employed numerous employees in order to discharge the functions of the "Valley of Lakes and Eagle Rock Resort."

c. the enterprise has a distinct structure including the Valley Administration Building, a security force with guard houses, marketing force.

d. the enterprise has recorded fraudulent covenants and restrictions and promulgated rules and regulations to organize the enterprise.

343. Exhibit 94, a document prepared by C.B.G. Ltd., substantially describes the structure of the ongoing organization of the enterprise.

344. The COMMON PURPOSE of the enterprise is (1) to defraud unsuspecting purchasers of unimproved lots by selling them lots at inflated prices based on fraudulent promises and pretenses regarding the building of the "premiere resort in Pennsylvania; and (2) to extort yearly maintenance fees from property owners while failing to provide the promised maintenance and other services.

345. The enterprise is engaged in interstate or foreign commerce.

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