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12.
THIRD CAUSE OF ACTION
[By Rhonda McClendon, as Guardian of Gary Wayne Thompson, an incapacitated
adult for the Actionable Conduct of Aiding and Abetting Violations of 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]
12.1
As explained in detail in this Complaint, the acts of the Racketeering
Lawyer/former Guardian and Other Racketeering Defendants constitute the participation
in and the conduct of 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 (8) and other
Georgia laws, as well as a conspiracy to conduct or participate in such a violation within
the meaning of O.C.G.A. § 16-14-3 (9)(A) and under the laws of Georgia.
12.2
Additionally, the acts of the Racketeering Lawyer/former Guardian and Other
Racketeering Defendants constituted substantial participation in the various acts of the
Racketeering Lawyer/former Guardian and Other Racketeering Defendants, which
constituted violations of the provisions of RICO.
12.3
Each and every one of the Racketeering Lawyer/former Guardian and Other
Racketeering Defendants knew the nature of the acts to which they gave substantial
assistance.
12.4
Each and every one of the defendants therefore aided and abetted a violation of
RICO.
