56
8.6.2
The Other RICO Defendants, on a regular basis, intentionally misrepresented
and negligently misrepresented services provided to Gary Wayne Thompson and charges
to Gary Wayne Thompson, all in furtherance of the RICO Enterprise.
8.6.3
These acts of false swearing, intentional misrepresentations and negligent
misrepresentations by the Racketeering Lawyer/former Guardian and the Other
Racketeering Defendants were to conceal the pattern of racketeering activities and the
existence of the RICO Enterprise.
8.6.4
The Racketeering Lawyer/former Guardian engaged in false swearings on
each or the four occasions that he made annual reports to the Probate Court of Coweta
County. On each of the occasions of the annual reports, Mark Andrew Gomez, in
addition to engaging in false swearings also made intentional misrepresentations and
negligent misrepresentations.
8.6.5
The Racketeering Lawyer/former Guardian in petitioning the Probate Court
among other misstatements, frequently made the following false swearings.
2.
The income from said assets is insufficient for the maintenance,
support and education of . . . said ward . . .
and
3. There are no other assets available to petitioner to maintain, support
and educate the person (s) indicated in Paragraph 2 above.
8.6.6
These are two examples of false swearings, buttressed with intentional
misrepresentation on numerous occasions. These false swearings and intentional
misrepresentations were made in furtherance of the RICO Enterprise. The negligent
misrepresentations contained in the petitions were the by-product of the RICO Enterprise.