65
10.6
The Injury to Gary Wayne Thompson
10.6.1
As a result of the acts identified in this Complaint and such other acts to be
shown by evidence, including the conspiracy among the Racketeering
Lawyer/former Guardian and Other Racketeering Defendants to commit fraudulent
acts and the further conspiracy to cover up those acts, Gary Wayne Thompson has
suffered injuries to his person, business and property in that the Racketeering
Lawyer/former Guardian and Other Racketeering Defendants have, as part of and in
furtherance of their fraudulent scheme and cover-up, caused Gary Wayne Thompson
to lose hundreds of thousands of dollars and suffer from the lack of personal care that
he was entitled to receive.
11.
SECOND CAUSE OF ACTION
[By Rhonda McClendon, as Guardian of Gary Wayne Thompson, an incapacitated
adult for the Actionable Conduct of a Conspiracy to Violate the RICO (Racketeer
Influenced and Corrupt Organizations) Act. O.C.G.A. § 16-14-1, et seq., 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]
11.1
As explained in detail in this Complaint, the acts of the Racketeering
Lawyer/former Guardian and Other Racketeering Defendants constitute a conspiracy to
conduct or participate in the affairs of a RICO Enterprise through a continuous and
ongoing pattern of racketeering activity, within the meaning of O.C.G.A. § 16-14-3,
O.C.G.A. § 16-14-4 and other Georgia laws.
