- 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
SUMMARY OF EACH DEFENDANT'S ASSOCIATION WITH THE RACKETEERING ENTERPRISE AND PARTICIPATION IN THE PATTERN OF RACKETEERING ACTIVITY.
354. At all times herein the defendants made numerous interstate telephone calls, in the course of business, for purposes of carrying out the various schemes detailed supra.
355. Defendant FIRST EASTERN BANK, N.A., and its hold company, Defendant FIRST EASTERN CORPORATION, were associated with the racketeering enterprise as its primary financier, and as part of its CORPORATE POLICY sanctioned by its board of directors violated:
a. 18 U.S.C. 1962(a) by using or investing, directly or indirectly, proceeds for the operation of the racketeering enterprise which were received from a pattern of racketeering which the defendant participated as principal by committing numerous violations of 18 U.S.C. 1951, fraud in the sale of securities in violation by violating Section 10(b) of the Securities Exchange Act of 1934 and SEC Rule 10b-5, 18 U.S.C. 1343, and 18 U.S.C. 1341 as detailed infra; and/or
b. 18 U.S.C. 1962(c) by conducting or participating directly in the conduct of the racketeering enterprise through a pattern of racketeering activity by committing numerous violations of 18 U.S.C 1951, fraud in the sale of securities by violating Section 10(b) of the Securities Exchange Act of 1934 and SEC Rule 10b-5, 18 U.S.C. 1343, and 18 U.S.C. 1341 as detailed infra; and/or
c. 18 U.S.C. 1962(d) by conspiring to violate any of the provisions of 18 U.S.C. 1962; and/or d. aided and abetted in the commission of at least two predicate offenses which were part of the pattern of racketeering in violation of the common law doctrine of aiding and abetting.
356. Defendant FRANK M. CEDRONE, was associated with the racketeering enterprise as its primary manager, and violated:
a. 18 U.S.C. 1962(a) by using or investing, directly or indirectly, proceeds for the operation of the racketeering enterprise which were received from a pattern of racketeering which the defendant participated as principal by committing numerous violations of [extortion], [securities fraud], [wire fraud] and [mail fraud] as detailed infra; and/or
b. 18 U.S.C. 1962 (b) by acquiring and/or maintaining an interest in or control of the racketeering enterprise by a pattern of racketeering activity consisting of numerous violations of [extortion], [wire fraud], and [mail fraud] as detailed infra; and/or
c. 18 U.S.C. 1962(c) by conducting or participating directly in the conduct of the racketeering enterprise through a pattern of racketeering activity by committing numerous violations of 18 U.S.C 1951, fraud in the sale of securities by violating Section 10(b) of the Securities Exchange Act of 1934 and SEC Rule 10b-5, 18 U.S.C. 1343, and 18 U.S.C. 1341 as detailed infra; and/or
d. 18 U.S.C. 1962(d) by conspiring to violate any of the provisions of 18 U.S.C. 1962; and/or
e. aided and abetted in the commission of at least two predicate offenses which were part of the pattern of racketeering in violation of the common law doctrine of aiding and abetting.
357. Defendant C.B.G. LIMITED, is associated with the racketeering enterprise and violated:
a. 18 U.S.C. 1962(a) by using or investing, directly or indirectly, proceeds for the operation of the racketeering enterprise which were received from a pattern of racketeering which the defendant participated as principal by committing numerous violations of [extortion], [securities fraud], [wire fraud] and [mail fraud] as detailed infra; and/or
b. 18 U.S.C. 1962 (b) by acquiring and/or maintaining an interest in or control of the racketeering enterprise by a patter of racketeering activity consisting of numerous violations of [extortion], [wire fraud], and [mail fraud]as detailed infra; and/or
c. 18 U.S.C. 1962(c) by conducting or participating directly in the conduct of the racketeering enterprise through a pattern of racketeering activity by committing numerous violations of 18 U.S.C 1951, fraud in the sale of securities by violating Section 10(b) of the Securities Exchange Act of 1934 and SEC Rule 10b-5, 18 U.S.C. 1343, and 18 U.S.C. 1341 as detailed infra; and/or
d. 18 U.S.C. 1962(d) by conspiring to violate any of the provisions of 18 U.S.C. 1962; and/or
e. aided and abetted in the commission of at least two predicate offenses which were part of the pattern of racketeering in violation of the common law doctrine of aiding and abetting.
358. Defendant ONEIDA WATER COMPANY, is associated with the racketeering enterprise and violated:
a. 18 U.S.C. 1962(c) by conducting or participating directly in the conduct of the racketeering enterprise through a pattern of racketeering activity by committing numerous violations of 18 U.S.C 1951, fraud in the sale of securities by violating Section 10(b) of the Securities Exchange Act of 1934 and SEC Rule 10b-5, 18 U.S.C. 1343, and 18 U.S.C. 1341 as detailed infra; and/or
b. 18 U.S.C. 1962(d) by conspiring to violate any of the provisions of 18 U.S.C. 1962; and/or
c. aided and abetted in the commission of at least two predicate offenses which were part of the pattern of racketeering in violation of the common law doctrine of aiding and abetting.
359. Defendant VALLEY UTILITIES COMPANY, INC., is associated with the racketeering enterprise and violated:
a. 18 U.S.C. 1962(c) by conducting or participating directly in the conduct of the racketeering enterprise through a pattern of racketeering activity by committing numerous violations of 18 U.S.C 1951, fraud in the sale of securities by violating Section 10(b) of the Securities Exchange Act of 1934 and SEC Rule 10b-5, 18 U.S.C. 1343, and 18 U.S.C. 1341 as detailed infra; and/or
b. 18 U.S.C. 1962(d) by conspiring to violate any of the provisions of 18 U.S.C. 1962; and/or
c. aided and abetted in the commission of at least two predicate offenses which were part of the pattern of racketeering in violation of the common law doctrine of aiding and abetting.
360. Defendant MLA MANAGEMENT ASSOCIATES, INC., is associated and/or employed by the racketeering enterprise as its primary manager, and violated:
a. 18 U.S.C. 1962(c) by conducting or participating directly in the conduct of the racketeering enterprise through a pattern of racketeering activity by committing numerous violations of 18 U.S.C 1951, fraud in the sale of securities by violating Section 10(b) of the Securities Exchange Act of 1934 and SEC Rule 10b-5, 18 U.S.C. 1343, and 18 U.S.C. 1341 as detailed infra; and/or
b. 18 U.S.C. 1962(d) by conspiring to violate any of the provisions of 18 U.S.C. 1962; and/or
c. aided and abetted in the commission of at least two predicate offenses which were part of the pattern of racketeering in violation of the common law doctrine of aiding and abetting.
361. Defendant RALPH CONTE was associated, and/or employed by the racketeering enterprise as the New Jersey Broker responsible for conducting all marketing in New Jersey, and violated:
a. 18 U.S.C. 1962(c) by conducting or participating directly in the conduct of the racketeering enterprise through a pattern of racketeering activity by committing numerous violations of 18 U.S.C 1951, fraud in the sale of securities by violating Section 10(b) of the Securities Exchange Act of 1934 and SEC Rule 10b-5, 18 U.S.C. 1343, and 18 U.S.C. 1341 as detailed infra; and/or
b. 18 U.S.C. 1962(d) by conspiring to violate any of the provisions of 18 U.S.C. 1962; and/or
c. aided and abetted in the commission of at least two predicate offenses which were part of the pattern of racketeering in violation of the common law doctrine of aiding and abetting.
362. Defendant ARLENE REINESS is associated with the racketeering enterprise, and together with her live in lover, RALPH CONTE, operated the marketing of lots in the New Jersey market, from her house at 312 Rex Land Drive, Boonton, New Jersey, and violated:
a. 18 U.S.C. 1962(c) by conducting or participating directly in the conduct of the racketeering enterprise through a pattern of racketeering activity by committing numerous violations of 18 U.S.C 1952, fraud in the sale of securities by violating Section 10(b) of the Securities Exchange Act of 1934 and SEC Rule 10b-5, 18 U.S.C. 1343, and 18 U.S.C. 1341 as detailed infra; and/or
b. 18 U.S.C. 1962(d) by conspiring to violate any of the provisions of 18 U.S.C. 1962; and/or
c. aided and abetted in the commission of at least two predicate offenses which were part of the pattern of racketeering in violation of the common law doctrine of aiding and abetting.
363. Defendant THE PROPERTY OWNERS ASSOCIATION OF THE VALLEY OF LAKES, an Unincorporated Association, associated with the racketeering enterprise, and violated:
a. 18 U.S.C. 1962(c) by conducting or participating directly in the conduct of the racketeering enterprise through a pattern of racketeering activity consisting of numerous violations of 18 U.S.C. 1341 [Exhibits 211 and 212]; and/or
b. 18 U.S.C. 1962(d) by conspiring to violate any of the provisions of 18 U.S.C. 1962; and/or
c. aided and abetted in the commission of at least two predicate offenses which were part of the pattern of racketeering in violation of the common law doctrine of aiding and abetting.
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