6
1.19
Mark Andrew Gomez stole from Gary Wayne Thompson and engaged in his
illegal conduct to support a lifestyle otherwise unavailable to him.
1.20
The thefts of Mark Andrew Gomez became so common that the illegal conduct
of Mark Andrew Gomez comprised a RICO Enterprise. To facilitate the operation of the
RICO Enterprise and to help cover for his wrongdoing, Mark Andrew Gomez
successfully solicited other members into the conspiracy of illegal conduct.
1.21
With no reflection intended to an assessment of the mental ability of the other
defendants, or compliment intended to the mental ability of Mark Andrew Gomez, it can
be correctly stated that Mark Andrew Gomez was the brain of the Racketeering
Enterprise.
1.22
Mark Andrew Gomez (or, “Racketeering Lawyer/former Guardian”) is, by far,
the most culpable defendant, the primary wrongdoer and the organizer of the criminal
conspiracy that forms the basis for this civil action against these defendants.
1.23
While the Racketeering Lawyer/former Guardian is, without question, the most
culpable defendant and was the primary instigator of the RICO Enterprise, this
Racketeering Lawyer/former Guardian was by no means the sole thief and exclusive
wrongdoing participant in the RICO Enterprise that deprived Gary Wayne Thompson of
hundreds of thousands of dollars, and necessary care and treatment that he was due.
1.24
While the other defendants’ conduct pales in comparison with the conduct of
the Racketeering Lawyer/former Guardian, the conduct of the other defendants is
reprehensible and can only charitably be classified as blatant thievery of the assets of an
