- 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
PATTERN OF UNLAWFUL RACKETEERING ACTIVITY
346. All of the predicate acts of racketeering activity are directly related to the land development plan of C.B.G. Ltd., as defined by the numerous property reports filed with the U.S. Department of Housing and Urban Development, and their state counterparts (E.g., Exhibits 14, 15, 16), and the fraudulent covenants and restrictions recorded by C.B.G. Ltd. (Exhibit 10).
347. All of the predicate acts of racketeering activity are part of the nexus of the affairs and functions of the racketeering enterprise.
348. The defendants were enabled to commit the predicate offenses by virtue of their position in the enterprise or involvement in or control over the affairs of the enterprise.
349. All of the predicate acts of racketeering activity occurred after the effective date of 18 U.S.C. Section 1961 et. seq.
350. The predicate acts of racketeering activity began on or about September 30, 1986.
351. The pattern of racketeering activity is currently ongoing and open ended, and threatens to continue indefinitely unless this Court enjoins the racketeering activity.
352. Numerous schemes have been completed involving repeated criminal conduct that by its nature projects into the future with a threat of repetition.
353. The predicate acts have the same or similar purposes, results, participants, victims, and methods of commission.
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