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3.11
To assist him in his thievery, the Racketeering Lawyer/former Guardian enlisted
the Other Racketeering Defendants. The financial benefits obtained by most of the Other
Racketeering Defendants from their criminal conduct were relatively small in comparison
to the easy, quick money obtained by the Racketeering Lawyer/former Guardian and the
insiders in the RICO Enterprise, such as Jamie Robertson, who is the “significant other”
of Mark Andrew Gomez.
3.12
The execution of the schemes of the Racketeering Lawyer/former Guardian and
the Other Racketeering Defendants utilized numerous predicate criminal acts. This
execution phase of this RICO Enterprise will be detailed in the Factual Information
section of this Complaint.
4. Jurisdiction
4.1
Mark Andrew Gomez, Leigh Ann Ware (formerly Leigh Ann Robertson),
James Bret Robertson, Jamie Robertson, Derwin Ware and Nathaniel Russell, some of
the defendants, are residents of Coweta County, Georgia, thereby giving this Court
jurisdiction in this matter.
5.
Venue
5.1
Venue is in Coweta County, as Mark Andrew Gomez, Leigh Ann Ware
(formerly Leigh Ann Robertson), James Bret Robertson, Jamie Robertson, Derwin Ware
and Nathaniel Russell are residents of Coweta County, Georgia. They are joint tortfeasors
with the other defendants and substantial equitable relief is sought against them and the
other defendants.
