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3.7
The chain of criminal activity in the RICO causes of action in this Complaint is
comparable to the mythical trip of the man in route to Saint Ides. As the racketeering
enterprise of the Racketeering Defendants aged, it both picked up new participants and
deepened the involvement of the Racketeering Lawyer/former Guardian.
3.8
The Racketeering Lawyer/former Guardian desired to obtain as much money
from the assets of Gary Wayne Thompson as possible without the illegal conduct of the
RICO Enterprise being detected. To fulfill his goal, the Racketeering Lawyer/former
Guardian first was willing to take an oath to be a diligent guardian for Gary Wayne
Thompson, which oath he knew he would violate; then, he began to steal, followed by
numerous violations of the law, which he attempted to conceal with false swearings and
intentional misrepresentations.
3.9
As part of the illegal activity of the RICO Enterprise, the Racketeering
Lawyer/former Guardian charged Gary Wayne Thompson administrative fees that would
have been legal had the Racketeering Lawyer/former Guardian not operated a RICO
Enterprise, and, frequently, illegally charged Gary Wayne Thompson for administrative
fees. Mark Andrew Gomez, in order to conceal the operation of the RICO Enterprise,
fraudulently destroyed and fabricated records that documented expenses and income of
Gary Wayne Thompson.
3.10
The Racketeering Lawyer/former Guardian needed persons to help him so that
he could conceal the amount of money that he was stealing from Gary Wayne Thompson.
This assistance he needed in order that the RICO Enterprise could maximize the amount
of thefts possible from Gary Wayne Thompson without detection.
