• 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

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

389. Count IV 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, JOHN T. MIELE, SENTA M. SHERIDAN, GER D. J. SMIT , WACLAW SZCZESNIAK and DANUTA SZCZESNIAK, as a class action against Defendant FIRST EASTERN BANK, C.B.G., FRANK CEDRONE, AND RALPH CONTE, under the provisions of the New Jersey Real Estate Sales Full Disclosure Act N.J.S.A. 45:15-16.47.

390. The court has jurisdiction of this state claim under the doctrine of pendent jurisdiction.

391. Plaintiffs are purchasers within the meaning of the New Jersey Real Estate Sales Full Disclosure Act.

392. The plaintiffs have suffered ascertainable loss of moneys as a result of the failure of the defendants to comply fully with the provisions of N.J.S.A. 45:15- 16.47.

393. Defendant First Eastern Bank is "a person who directly or indirectly controls a subdivision or developer" within the meaning of N.J.S.A. 45:15-16.47.

394. Defendant Frank Cedrone is the general partner of the developer C.B.G. within the meaning of N.J.S.A. 45:15-16.47.

395. Defendant CBG is the alleged developer of the "Valley of Lakes" within the meaning of N.J.S.A. 45:15-16.28.

396. Defendant Ralph Conte is the New Jersey Broker responsible for selling the subdivided lands in New Jersey on behalf of the developer within the meaning of N.J.S.A. 45:15-16.28.

397. Defendants Frank Cedrone, CBG, and Ralph Conte knowingly engaged in false, deceptive, misleading promotional methods, sales methods, and advertising, and/or fraudulent diverted funds or assets so as to defeat the rights of subdivision purchasers, and/or made intentional misrepresentations and concealed material facts in an application for registration.

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