- 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
COUNT II
CLASS ACTION UNDER THE
INTERSTATE LAND SALES
FULL DISCLOSURE ACT
(15 UNITED STATES CODE SECTION 1701 et.seq.)
375. Plaintiffs repeat and reallege the allegations contained in COUNT I of this complaint as fully as if set forth here.
376. Count II of this complaint is brought by Plaintiff, LEON R. DONGELEWICZ and MARGARET J. DONGELEWICZ, FRANCIS X. BURNS, LAURA BURNS, LOIS A. BURNS, John B. Knox and BETSY C. KNOX, SENTA M. SHERIDAN, GER D. J. SMIT, WACLAW SZCZESNIAK and DANUTA SZCZESNIAK, as a class action against Defendant CBG, FRANK CEDRONE, FIRST EASTERN BANK, and RALPH CONTE. for compensatory damages, as well as attorney fees, costs under the provisions of the Interstate Land Sales Full Disclosure Act, 15 USC Section 1701-1720, and specifically under the provisions of Sections 1703 and 1709 of said Act.
377. Jurisdiction is conferred on this court by Section 1719 of the Interstate Lands Sales Full Disclosure Act, and 28 U.S.C. 1331.
378. Plaintiffs are purchasers within the provisions of the Interstate Land Sales Full Disclosure Act.
379. Defendant FRANK CEDRONE is the developer, or agent of the developer, within the meaning of 15 USC Section 1709(a).
380. Defendant RALPH CONTE is the agent of the developer, within the meaning of 15 USC Section 1709(a).
381. Defendant FIRST EASTERN BANK aided and abetted the fraud, and other wrongdoing of the developer, and/or is an agent of the developer within the meaning of 15 USC Section 1709(a).
382. The defendants willfully violated the provisions of the Interstate Land Sales Full Disclosure Act thereby causing plaintiffs to sustain damages.
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