61
activity" under 18 U.S.C. Section 1961 (1)(A), (B), (C), and (D), which includes
violations of 18 U.S.C. Section 1341 (relating to mail fraud) and 18 U.S.C. Section
1343 (relating to wire fraud).but not as an exclusive statement of their wrongdoings,
the Racketeering Defendants have committed violations of O.C.G.A. § 16-4-4 and
engaged in Racketeering activity as identified by O.C.G.A. § 16-4-3, which statute (in
its ¶xxix) incorporates,“[a]ny conduct defined as “racketeering activity” under 18
U.S.C. § 1961 (1) (A), (B), (C), and (D)”.
10.2
The RICO Fraudulent Scheme
10.2.1
Mark Andrew Gomez became the guardian of Gary Wayne Thompson to
engage in the illegal conduct of stealing money from the incapacitated adult. Mark
Andrew Gomez used the assets of Gary Wayne Thompson as the banking account
for the RICO Enterprise.
10.2.2
Throughout the period during which Mark Andrew Gomez was the guardian
of Gary Wayne Thompson, the Racketeering Lawyer/former guardian engaged in a
scheme to defraud Gary Wayne Thompson of assets belonging to him.
10.2.3
The Racketeering Lawyer/former Guardian and the Other Racketeering
Defendants purchased items with the funds of Gary Wayne Thompson that were
used for the benefit of the Racketeering Lawyer/former Guardian and the Other
Racketeering Defendants, and not the benefit of Gary Wayne Thompson.
10.2.4
The Racketeering Lawyer/former Guardian and the Other Racketeering
Defendants were so heavily engaged in stealing from Gary Wayne Thompson and
the functions of the RICO Enterprise that they frequently violated the law in
