(I) ENTERPRISE

(I) ENTERPRISE

  • PATTERN OF UNLAWFUL RACKETEERING ACTIVITY
    • All of the predicate acts of racketeering activity are directly related to the plan of WA State Bar Associates, as the interrelationship with those agencies, boards, employees, commissions, officials which are all staffed by WA Stat bar associates by which to manage the racketeering enterprise by virtue of being unaccountable for their conduct in the rules they establish, interpret, administer, and judge.
    • All of the predicate acts of racketeering activity are part of the nexus of the affairs and functions of the racketeering enterprise.
    • 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.
    • All of the predicate acts of racketeering activity occurred after the effective date of 18 U.S.C. Section 1961 et. seq.
    • The predicate acts of racketeering activity began on or about September 30, 1986.
    • The pattern of racketeering activity is currently ongoing and open ended, and threatens to continue indefinitely unless this Court enjoins the racketeering activity.
    • Numerous schemes have been completed involving repeated criminal conduct that by its nature projects into the future with a threat of repetition.
    • The predicate acts have the same or similar purposes, results, participants, victims, and methods of commission.
  • SUMMARY OF EACH DEFENDANT’S ASSOCIATION WITH THE RACKETEERING ENTERPRISE AND PARTICIPATION IN THE PATTERN OF RACKETEERING ACTIVITY.
  • SUMMARY OF EACH PLAINTIFF’S INJURY TO BUSINESS OR PROPERTY
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