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Superior Court of Coweta County enters an order not relieving the particular
defendant of civil liability identified in this Complaint..
10.
FIRST CAUSE OF ACTION
[By Rhonda McClendon, as Guardian of Gary Wayne Thompson, an incapacitated
adult for the RICO (Racketeer Influenced and Corrupt Organizations) Act.
O.C.G.A. § 16-14-1, et seq., Actionable Conduct Against Mark Andrew Gomez, Tina
Barron, Leigh Ann Ware (formerly Leigh Ann Robertson), James Bret Robertson,
Jamie Robertson, Derwin Ware, Nathaniel Russell, John Doe 1, John Doe 2, John
Doe 3, Jane Doe 1, Jane Doe 2 and Jane Doe 3]
10.1
Overview of RICO Cause of Action
10.1.1
Gary Wayne Thompson has suffered and continues to suffer damages as a
result of Mark Andrew Gomez, Tina Barron, Leigh Ann Ware (formerly Leigh Ann
Robertson), James Bret Robertson, Jamie Robertson, Derwin Ware, Nathaniel
Russell, John Doe 1, John Doe 2, John Doe 3 Jane Doe 1, Jane Doe 2 and Jane Doe 3
collectively entering into and executing a RICO Enterprise and a conspiracy – in
violation of the RICO (Racketeer Influenced and Corrupt Organizations) Act.
O.C.G.A. § 16-14-1, et seq., (or, RICO).
10.1.2
The acts and conduct of the Racketeering Lawyer/former Guardian and Other
Racketeering Defendants constitute a continuous and ongoing pattern of racketeering
activity, and a conspiracy to conduct such a pattern of racketeering activity, within
the meaning of RICO in such a manner to damage the property and person of Gary
Wayne Thompson.
10.1.3
The Racketeering Lawyer/former Guardian and the Other Racketeering
Defendants engaged in conduct in violations of the laws of Georgia, and,
particularly, committed more than two acts of racketeering activity as identified in
