64
and, particularly, committed more than two acts of Racketeering Activity as
identified in O.C.G.A. §16-14-3 (9) (A) (xxix), which consisted of any conduct
defined as "racketeering 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)”.
10.4
The Pattern of Racketeering Activities
10.4.1
Each and every one of the Predicate Acts, comprising each of the violations
of the criminal laws of the United States and the violations of State criminal laws, is
related to the overall fraudulent scheme and conspiracy of and by the Racketeering
Lawyer/former Guardian and Other Racketeering Defendants to engage in a RICO
Enterprise.
10.5
The Continuity of Racketeering Activities
10.5.1
After Rhonda McClendon and the Office of the District Attorney made
known to the Racketeering Lawyer/former Guardian that they had knowledge of the
criminal conduct of the RICO Enterprise, the Racketeering Lawyer/former Guardian
attempted to conceal his conduct and encouraged some of the Other Racketeering
Defendants not to reveal their participation in the RICO Enterprise.
