Transcription
!4:16-cv-11247-PDB-APP Doc # 1-1 Filed 04/06/16 Pg 1 of 30Pg ID 119PLAINTIFFS’ RICO CASE STATEMENT PURSUSUANT TO THELOCAL RULES’ STANDING ORDER IN CIVIL RICO CASESPlaintiffs hereby file their RICO Case Statement as required by Local Rule 11.1 as follows:Responses1.! The alleged conduct that is claimed to be in violation of 18 U.S.C. 1962 (a), (b), (c)and/or (d).Plaintiffs assert claims for violations of 18 U.S.C. Sec. 1962 (c) and (d). The individualRICO Defendants and Enterprise Actors named herein formed an association in factenterprise with the intent and purpose of balancing the Flint City budget through a pattern ofracketeering activity. This association in fact enterprise misrepresented the suitability of thetoxic Flint River water to Flint’s residents for approximately a two year period, and billedFlint’s residents at rates that were the highest in the nation for toxic water that was unsuitablefor use. By collecting an estimated 50 million in revenue during the two year period Flintwas connected to the Flint River, Flint’s City budget deficit was reversed and resulted in a3.3 million dollar surplus as of June 30, 2015.Furthermore, the individual RICO defendants conspired to balance Flint City budgetthrough the sale of free toxic Flint River water known to be unsuitable for any use anduntreated pursuant established Federal, State and local water quality standards. Theindividual RICO defendants and enterprise actors, named herein, formed the associate in factenterprise to further the conspiracy and ultimately balance the Flint City budget. For overtwo years, this enterprise carried out numerous and repeated acts that furthered theconspiracy many of which, qualify as predicate acts under the Civil RICO statute, giving riseto RICO liability under 18 U.S.C. Sec. 1962 (c) and (d). The specific conduct and predicate!
!4:16-cv-11247-PDB-APP Doc # 1-1 Filed 04/06/16 Pg 2 of 30Pg ID 120acts carried out by the RICO defendants and enterprise actors are set forth below in greaterdetail in their applicable sections pursuant to Local Rule 11.1.2.! The identity of each defendant and the alleged misconduct and basis of liability foreach.Defendant Richard Snyder is the Governor of Michigan, sued in his individual capacity.He was at all times acting within and outside the scope of his employment and/or authority undercolor of law. Governor Snyder participated in, directed and facilitated the fiscal scheme to balanceFlint’s budget through the sale of free but toxic Flint River water. Defendant Snyder violatedclearly established Constitutional rights of Plaintiffs and the putative class.Defendant Dennis Muchmore (“Muchmore”) was Governor Snyder’s Chief of Staff, andat all times relevant hereto was acting within and outside the scope of his employment and/orauthority under color of law. Muchmore as the Governor’s Chief of Staff had numerouscorrespondences with Snyder and others that provided Snyder ongoing and actual notice of thecontinuing problems in Flint regarding the toxic water, which resulted in lead poisoning andproperty damage to the residents caused by the fiscal deficit in Flint. Defendant Muchmore wasan integral actor in the scheme that intentionally defrauded, misrepresented and falsifiedinformation and warning signs relating to the property and financial affairs of Flint as it affectedits citizenry, by planning, directing, coordinating and facilitating the State’s insufficient responseto the free but toxic Flint River water and failing to warn and protect the residents of the City ofFlint of the consequences of the toxic water regarding damage to their property and businesses.Defendant Ed Kurtz served Governor Snyder as Flint’s Emergency Manager from Augustof 2012, until July of 2013. Kurtz facilitated the switch to the Flint River as a primary watersource despite knowledge is was unsuitable for use and that unable to be properly treated viaFlint’s water treatment plant and budget constraints.!
!4:16-cv-11247-PDB-APP Doc # 1-1 Filed 04/06/16 Pg 3 of 30Pg ID 121Defendant Darnell Earley (“Earley”) was Governor Snyder’s Emergency Manager inFlint from November 1, 2013, through January 12, 2015, and at all times relevant hereto wasacting within and outside the scope of his employment and/or authority under color of law. He issued in his individual capacity. Earley made the decision to switch to Flint River water on animpossibly reckless timeframe, preventing Flint’s water treatment plant from properly analyzingand treating a new source of corrosive water. Defendant Earley was an integral actor in anenterprise that defrauded, misrepresented and falsified information and warning signs relating tothe property and financial affairs of Flint as it affected its citizenry. Earley made false and/ormisleading statements representing that the water was safe to drink as it poisoned thousands.Defendant Earley violated clearly established constitutional rights of Plaintiffs and the Putativeclass.Defendant Gerald Ambrose (“Ambrose”) was Governor Snyder’s Emergency Managerfrom January 13, 2015, until April 28, 2015, and was at all times relevant hereto acting withinand outside the scope of his employment and/or authority under color of law. He is sued in hisindividual capacity. Defendant Ambrose was also an employee of the state as a financial advisorfor Flint’s financial emergency from January, 2012, until December, 2014. He was involved inand directed the state’s decision to transition Flint from safe, treated water on an impossiblyaggressive timeline to corrosive, untreated water from an unprepared water treatment plant.Defendant Ambrose was an integral actor in an enterprise that defrauded, misrepresented andfalsified information and warning signs relating to the property and financial affairs of Flint as itaffected its citizenry. When the City of Flint through its City Council attempted to disconnectfrom the Flint River by a vote of 7-1, Ambroes vetoed the vote despite knowledge the Flint Riverwater was causing toxic condition in Flint and unsuitable for use. He also made false and/or!
!4:16-cv-11247-PDB-APP Doc # 1-1 Filed 04/06/16 Pg 4 of 30Pg ID 122misleading statements representing that the water was safe to drink as it poisoned thousands.Defendant Ambrose violated clearly established constitutional rights of Plaintiffs and the putativeclass.Defendant Liane Shekter Smith (“Shekter Smith”) was at all relevant times Chief of theOffice of Drinking Water and Municipal Assistance for MDEQ, acting within and outside thescope of her employment and/or authority under color of law, until she was removed from herposition on October 19, 2015. Defendant Shekter Smith was grossly negligent in that sheknowingly participated in, approved of, and caused the decision to transition Flint’s water sourceto a highly corrosive, inadequately studied and treated alternative. She was an integral actor in anenterprise that defrauded, misrepresented and falsified information and warning signs relating tothe property and financial affairs of Flint as it affected its citizenry. She disseminated falsestatements to the public that led to the continued consumption of dangerous water despiteknowing or having reason to know that the water was dangerous. Defendant Shekter Smithviolated clearly established constitutional rights of Plaintiffs and the putative class.Defendant Daniel Wyant (“Wyant”) was at all relevant times the Director of MDEQ untilthe Governor accepted his resignation on or about December 29, 2015, acting within and outsidethe scope of his employment and/or authority under color of law. Wyant participated in, directed,and oversaw the MDEQ’s repeated violations of federal water quality laws, the failure to properlystudy and treat Flint River water, and the MDEQ’s program of systemic denial, lies, and attemptsto discredit honest outsiders. He was an integral actor in an enterprise that defrauded,misrepresented and falsified information and warning signs relating to the property and financialaffairs of Flint as it affected its citizenry. He disseminated false statements to the public that ledto the continued consumption of dangerous water despite knowing or having reason to know that!
!4:16-cv-11247-PDB-APP Doc # 1-1 Filed 04/06/16 Pg 5 of 30Pg ID 123the water was dangerous. Defendant Wyant violated clearly established constitutional rights ofPlaintiffs and the putative class.Defendant Stephen Busch (“Busch”) was at all relevant times the District Supervisorassigned to the Lansing District Office of the MDEQ and was acting within and outside the scopeof his employment and/or authority under color of law. He participated in MDEQ’s repeatedviolations of federal water quality laws, the failure to properly study and treat Flint River water,and the MDEQ’s program of systemic denial, lies, and attempts to discredit honest outsiders. Hepersonally falsely reported to the EPA that Flint had enacted an optimized corrosion control plan,providing assurances to Plaintiffs and the putative class that the water was safe when he knew orshould have known that these assurances were false. He was an integral actor in an enterprise thatdefrauded, misrepresented and falsified information and warning signs relating to the propertyand financial affairs of Flint as it affected its citizenry. Defendant Busch violated clearlyestablished constitutional rights of Plaintiffs and the putative class.Defendant Patrick Cook (“Cook”) was at all relevant times Water Treatment Specialistassigned to the Lansing Community Drinking Water Unit of the MDEQ and was acting withinand outside the scope of his employment and/or authority under color of law. Cook is individuallyliable because he, as the Lansing Community Drinking Unit manager, in a grossly negligentmanner, participated in, approved, and/or assented to the decision to allow Flint’s water to bedelivered to residents without corrosion control or proper study and/or testing. He was an integralactor in an enterprise that defrauded, misrepresented and falsified information and warning signsrelating to the property and financial affairs of Flint as it affected its citizenry. Defendant Cookviolated clearly established constitutional rights of Plaintiffs and the putative class.Defendant Michael Prysby (“Prysby”) was at all relevant times Engineer assigned to!
!4:16-cv-11247-PDB-APP Doc # 1-1 Filed 04/06/16 Pg 6 of 30Pg ID 124District 11 (Genesee County) of the MDEQ and was acting within and outside the scope of hisemployment and/or authority and was acting within the scope of his employment and/or authorityunder color of law. Prysby is individually liable because he, as the Engineer assigned to District11, participated in, approved, and/or assented to the decision to switch the water source, failed toproperly monitor and/or test the Flint River water, and provided assurances to Plaintiffs and theputative class that the Flint River water was safe when he knew or should have known thosestatements to be false. He was an integral actor in an enterprise that defrauded, misrepresentedand falsified information and warning signs relating to the property and financial affairs of Flintas it affected its citizenry. Defendant Prysby violated clearly established constitutional rights ofPlaintiffs and the Putative class.The individuals affiliated with The City of Flint that participated in the bad acts set forthherein and were a part of the association in fact enterprise include. (1) The Mayor of Flint DayneWalling (2) Howard Croft, Director of Public Works (3) Michael Glasgow, employee of the Cityof Flint and Water quality Supervisor at the Flint water treatment Plant.(a)!Dayne Walling represented to Flint residents on April 25, 2014 that the Cityof Flint’s water from the Flint River was safe for use and of high quality whilehe knew or should have known that proper corrosion controls had not beenimplemented.(b)!Howard Croft was the director of public works for the City of Flint anddistributed water from Flint’s known outdated and unprepared WaterTreatment Plant to further the fiscal scheme to balance Flint’s budget.Engineering reports from defendants ROWE and LAN were provided to Croftand his department, yet the required steps set forth in those reports were!
!4:16-cv-11247-PDB-APP Doc # 1-1 Filed 04/06/16 Pg 7 of 30Pg ID 125knowingly never implemented while Flint River water was distributed to Flintresidents anyway.(c)! Michael Glasgow was the water quality supervisor for Flint’s water treatmentplant and knew that the required water treatment protocols set forth byaccepted water quality standards and the engineering reports produced bydefendants LAN and ROWE had not been implemented prior to distributingFlint River water starting on April 25, 2014. Glasgow wrote correspondenceto MDEQ and Flint’s Emergency Manger stating this to be true, but nothingwas done to address these failures for two years until a State of Emergencywas declared and the City had become a toxic disaster zone.Defendant Bradley Wurfel (“Wurfel”) was at all relevant times the Director ofCommunications for MDEQ and was acting within and outside the scope of his employmentand/or authority under color of law. Wurfel resigned from his position on December 29, 2015.Wurfel repeatedly denied the increasingly obvious disaster as it unfolded and attempting todiscredit the only reliable people in the picture. Wurfel repeatedly made public statements thatcreated, increased, and prolonged the risks and harms facing Plaintiffs and the putative class.Defendant Prysby was an integral actor in an enterprise that defrauded, misrepresented andfalsified information and warning signs relating to the property and financial affairs of Flint as itaffected its citizenry. Defendant Prysby violated clearly established constitutional rights ofPlaintiffs and the Putative classDefendant Linda Dykema, was director of the MDHHS Division of EnvironmentalHealth, acting within and outside and outside her scope of employment and color of authority andis sued in her individual capacity. Dykema continuously refused to turn over the blood lead levels!
!4:16-cv-11247-PDB-APP Doc # 1-1 Filed 04/06/16 Pg 8 of 30Pg ID 126regarding seasonal blood lead levels as compared to Flint and other cities in Michigan. Dykemacontinuously refused to respond to FOIA requests and ignored the studies of Dr. Hanna-Attisha’sand Miguel Del Toral. Dykema was an integral actor in the government scheme that defrauded,misrepresented and falsified information and warning signs relating to the property and financialaffairs of Flint as it affected its citizenry.Defendant Eden Wells (“Wells”), was at all relevant times Chief Medical Executivewithin the Population Health and Community Services Department of the MDHHS and wasacting within and outside the scope of her employment and/or authority under color of law and issued in her individual capacity. Wells participated in, directed, and/or oversaw the department’sefforts to hide information to save face, and to obstruct the efforts of outside researchers. Further,Wells knew as early as 2014 of problems with lead and legionella contamination in Flint’s waterand instead of fulfilling her duty to protect and notify the public, she participated in hiding thisinformation. Wells violated state law by working only part time in her position as Chief MedicalExecutive. Defendant Wells was an integral actor in an enterprise that defrauded, misrepresentedand falsified information and warning signs relating to the property and financial affairs of Flintas it affected its citizenry. Defendant Wells violated clearly established constitutional rights ofPlaintiffs and the putative class.Defendant Nick Lyon was at all relevant times Director of MDHHS and was acting withinand outside the scope of his employment and/or authority under color of law and is sued in hisindividual capacity. He participated in, directed, and/or oversaw the department’s efforts to hideinformation regarding the increased blood lead levels in the children of Flint to save face, and toobstruct and discredit the efforts of outside researchers. He knew as early as 2014 of problemswith lead and legionella contamination in Flint’s water and instead of fulfilling his duty to protect!
!4:16-cv-11247-PDB-APP Doc # 1-1 Filed 04/06/16 Pg 9 of 30Pg ID 127and notify the public, he participated in hiding this information. Lyon violated state law by hiringand supervising a part time employee as Chief Medical Executive. Defendant Lyons was anintegral actor in an enterprise that defrauded, misrepresented and falsified information andwarning signs relating to the property and financial affairs of Flint as it affected its citizenry.Defendant Lyons violated clearly established constitutional rights of Plaintiffs and the putativeclass.Defendant Nancy Peeler was at all relevant times a MDHHS employee in charge of itschildhood lead poisoning prevention program, acting within and outside the scope of heremployment and/or authority under color of law and is sued in her individual capacity. Sheparticipated in, directed, and/or oversaw the department’s efforts to hide information regardingthe increased blood lead levels in the children to save face, and actively sought to obstruct anddiscredit the efforts of outside researchers. Even when her own department had data that verifiedoutside evidence of a lead contamination problem, she continued trying to generate evidence tothe contrary. Defendant Peeler was an integral actor in an enterprise that defrauded,misrepresented and falsified information and warning signs relating to the property and financialaffairs of Flint as it affected its citizenry. Defendant Peeler violated clearly establishedconstitutional rights of Plaintiffs and the putative class.Defendant Robert Scott was at all relevant times Data Manager for MDHHS’s HealthyHomes and Lead Prevention Program, acting within and outside the scope of his employmentand/or authority under color of law and is sued in his individual capacity. He participated in,directed, and/or oversaw the department’s efforts to hide information to save face, and activelysought to obstruct and discredit the efforts of outside researchers. Even when his own departmenthad data that verified outside evidence of a lead contamination problem, he continued trying to!
!4:16-cv-11247-PDB-APP Doc # 1-1 Filed 04/06/16 Pg 10 of 30Pg ID 128generate evidence to the contrary. He also served a key role in withholding and/or delayingdisclosure of data that outside researchers provided that was needed to protect the people of Flint.Defendant Scott was an integral actor in an enterprise that defrauded, misrepresented and falsifiedinformation and warning signs relating to the property and financial affairs of Flint as it affectedits citizenry. Defendant Scott violated clearly established constitutional rights of Plaintiffs andthe putative class.Rowe Engineering Inc. is a Michigan corporation with its principal place of business inFlint Michigan. Rowe is a Defendant in this action based on intentionally providing negligentprofessional engineering services in preparing Flint’s water treatment facility to treat water fromthe Flint River. On June 29, 2013, Engineer Defendant Rowe met with representatives of Flint,Genesee County Drain Commissioners Office and the MDEQ to discuss:a.! using the Flint River as a water source;b.! the ability to perform the necessary upgrades to the Flint Water Treatment Plant;c.! the ability to perform quality controld.! the ability for Flint to provide water to Genesee County;e.! the ability to meet an April or May 2014 timeline; andf.! Developing a cost analysis.According to incomplete meeting minutes, “the conversation was guided with focus onengineering, regulatory, and quality aspects ” of the items previously referenced and thefollowing determinations were made:a.! The Flint River would be more difficult to treat, but was viable as a source;b.! It was possible to engineer and construct the upgrades needed for the treatmentprocess;!
!4:16-cv-11247-PDB-APP Doc # 1-1 Filed 04/06/16 Pg 11 of 30Pg ID 129c.! It was possible to perform quality control “with support from LAN engineeringwhich works with several water system around the state, quality control count beaddressed[;]”d.! The Flint Water Treatment Plant did not have the capacity to treat and distributesufficient water to meet the needs of Flint and Genesee County;e.! There were many obstacles to overcome, but completion by the April or May 2014timeline was reachable;f.! The next steps were for Rowe to present Flint with a proposal that would includeengineering, procurement, and construction needs for the project along with costestimates.g.! The ability to meet an April or May 2014 timeline; andh.! Developing a cost analysis.This 2013 meeting was actually a follow up analysis to a previously conducted Flint Riverviability study performed by Rowe in 2011. The objectives and conclusions offered by Rowe andaccepted by the defendants blatantly contradicted Rowe’s previous 2011 feasibility study thatexpressed major concerns that refuted the proposition that the Flint River could be utilized as aviable primary water source. It was therefore known by all government representatives at the timeof the 2013 Rowe meeting that Rowe’s follow up report was contradictory to their originalconclusions, that substantial steps were needed to be taken before distributing Flint River waterto Flint residents would be an acceptably safe endeavor. The 2013 Rowe report set forth anapparent plan for upgrading the Flint water treatment plant for purposes of treating the Flint Riverwater that would be distributed. Rowe’s plan emphasized the need to implement corrosioncontrols and the continued involvement of LAN Engineering/Rowe to maintain the system.!
!4:16-cv-11247-PDB-APP Doc # 1-1 Filed 04/06/16 Pg 12 of 30Pg ID 130The follow up report and plan presented by Rowe, and adopted by the governmentdefendants, was nothing more than a piece of paper from an “expert” source to provide backingand legitimize the defendants’ financially motivated decision to disconnect from the pricierDWSD water source to the cheaper and toxic Flint River. The necessary steps provided for in theRowe / LAN report were never adequately implemented , and in some cases not implemented atall prior to connecting to the Flint River on April 25, 2014. By taking no substantial steps tocombat corrosion and lead contamination prior to connecting to the Flint River on April 25, 2014,Rowe, LAN, MDEQ, Flint government representatives, and all of the individually namedDefendants knew as a matter of fact that they were delivering water that exposed the entire cityof Flint to toxic conditions.Rowe, through its agents, servants and employees, was an integral actor in the governmentscheme that defrauded, misrepresented and falsified information and warning signs relating tothe property and financial affairs of Flint as it affected its citizenry. Rowe maintains an office inFlint, Genesee County, Michigan; regularly conducts business in Flint, Michigan; and hascommitted torts in Flint, Michigan, which are among the basis for personal jurisdiction underMCL 600.705. Rowe, through its agents, servants and employees, was an integral actor in thegovernment scheme that defrauded, misrepresented and falsified information and warning signsrelating to the property and financial affairs of Flint as it affected its citizenry.Defendant LAN is a Texas corporation with its principal place of business in Texas.LAN is a defendant in this action based on its role of providing grossly negligent and/or recklessprofessional engineering services in preparing Flint’s water treatment facility to treat water fromthe Flint River.LAN maintains an office in Flint, Genesee County, Michigan, regularly conducts business!
!4:16-cv-11247-PDB-APP Doc # 1-1 Filed 04/06/16 Pg 13 of 30Pg ID 131in the Eastern District of Michigan, and has committed a tort in the State of Michigan, amongbases for personal jurisdiction under MCL 600.705, and each of these bases extends to thisDistrict specifically. LAN, was hired by the Enterprise Actors MDEQ, City of Flint, and RICOdefendant Emergency Managers to render engineering services. LAN, through its agents,servants and employees, was an integral actor in the government scheme that defrauded,misrepresented and falsified information and warning signs relating to the property and financialaffairs of Flint as it affected its citizenry.VEOLIA NORTH AMERICA, LLC: Defendant Veolia North America, LLC (“Veolia”)is a Delaware corporation with its principal place of business in Illinois. Veolia is a Defendant inthis action based on providing grossly negligent and or reckless professional engineering servicesin reviewing Flint’s water system and declaring the water safe to drink. Veolia maintains an officein Westland, Wayne County, Michigan, transacts business in the State of Michigan, including thebusiness it performed for the City of Flint in 2015.Plaintiffs have a reasonable, good faith basis to believe that there are otherwrongdoers who will be identified during the course of discovery, including individuals who havedirected, approved, and/or known about the wrongful and unlawful conduct complained of.3.! List the alleged wrongdoers, other than the defendants listed above, and state thealleged misconduct of each wrongdoer:The State of Michigan directs, controls, and operates the Michigan Department ofEnvironmental Quality (“MDEQ”) and the Michigan Department of Health and Human Services(“MDHHS”). The State of Michigan also stood in the shoes of the City of Flint at all timesrelevant hereto, having entirely absorbed the authority of the City of Flint.Michigan Department of Environmental Quality (“MDEQ”) is the state-agency!
!4:16-cv-11247-PDB-APP Doc # 1-1 Filed 04/06/16 Pg 14 of 30Pg ID 132responsible for implementing safe drinking water laws, rules, and regulations in Michigan, andFlint specifically. The MDEQ failed to require corrosion control for Flint River water in violationof the federal Lead and Copper Rule, misled the federal EPA, conducted illegal and impropersampling of Flint’s water, lied to the public about the safety of Flint’s water, and attempted topublicly discredit outside individuals that offered evidence of the water’s contamination. TheMDEQ, through its agents, servants and employees, was an integral actor in an enterprise thatdefrauded, misrepresented and falsified information and warning signs relating to the propertyand financial affairs of Flint as it affected its citizenry. The MDEQ was consistently moreconcerned with satisfying its own distorted perceptions of technical rules than carrying out itsduty to the people of Flint, and did so to carry out the State and Local government’s financiallymotivated cost-cutting scheme.Michigan Department of Health and Human Services (“MDHHS”) is the state agencyresponsible for public health. Instead of protecting public health, MDHHS deliberately hid datconfirming an increase in lead poisoned infants in Flint that would have revealed the public healthcrisis. MDHHS, through its agents, servants and employees, was an integral actor in an enterprisethat defrauded, misrepresented and falsified information and warning signs relating to theproperty and financial affairs of Flint as it affected its citizenry. MDHHS’s failure to properlyanalyze data led it to conclude that there was no increase in lead contamination in Flint’s children,and it resisted and obstructed the efforts of outside researchers and the county health departmentto determine whether that was the case.The City of Flint is a municipal corporation, who as described above, was financiallycontrolled by The State of Michigan via an “Emergency Manger” since 2011. Despite beingcontrolled by the State and Governor via “Emergency Managers”, The City of Flint through!
!4:16-cv-11247-PDB-APP Doc # 1-1 Filed 04/06/16 Pg 15 of 30Pg ID 133numerous employees that are named RICO defendants herein actively participated in the schemeby distributing water known to be untreated and toxic to Flint’s homes and residents, andrepeatedly reassured Flint’s residents that the Flint River water was suitable for use.4.! The Identity of the alleged victims and the manner in which each victim wasallegedly injured.1.!Plaintiffs are residents, property-owners and business owners who at all relevant timesfrom April 2013, when Emergency Manager Kurtz decided to not renew Flint’s contract withDWSD, consistent with the Governor and all other Individual Enterprise Defendants’ over-archingfiscal scheme to balance the budget at all costs in conscious disregard of the property, andprosperity of the citizens of Flint. When the Flint River came online in April, 2014, the plaintiffsand the putative class and their property were immediately exposed and re-exposed to the toxicwater. This has continued unabated, in disregard for all reports, warnings and notices that thewater was unfit for any use, up and until the Mayor announced that water-billing was to besuspended in March of 2016. Therefore, plaintiffs were fraudulently induced to pay for toxic FlintRiver water for a span of approximately two years causing property damage, loss in property value,and the cost of toxic water that average over 900/year per NLAWRENCEWASHINGTON, CHRISTA GODIN, ANGEL ARRAND, AUSTON ARRAND, WILLIAMZIETZ III, DEBORAH SMITH, SHANIKA MIXON, ABY NDOYE and ROBIN DAVIS5.! A description of the pattern of racketeering activity or collection of unlawful debtsalleged for each RICO claim:The following predicate acts by the RICO defendants constitute violations of 11 USC 152(7), which states that “in a personal capacity or as an agent or officer of any person or corporation,!
!4:16-cv-1
PLAINTIFFS' RICO CASE STATEMENT PURSUSUANT TO THE LOCAL RULES' STANDING ORDER IN CIVIL RICO CASES Plaintiffs hereby file their RICO Case Statement as required by Local Rule 11.1 as follows: Responses 1.!The alleged conduct that is claimed to be in violation of 18 U.S.C. 1962 (a), (b), (c) and/or (d).
