68
12.5
Gary Wayne Thompson has been and continues to be harmed in his person or
property by such unlawful aiding and abetting by the Racketeering Lawyer/former
Guardian and Other Racketeering Defendants.
12.6
The Racketeering Lawyer/former Guardian and Other Racketeering Defendants
are therefore liable to Gary Wayne Thompson for such violations.
13.
FOURTH CAUSE OF ACTION
[By Rhonda McClendon, as Guardian of Gary Wayne Thompson, an incapacitated
adult for the Actionable Conduct of False Swearing, Fraud, Intentional
Misrepresentation and Negligent Misrepresentation
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 1, Jane Doe 2 and Jane Doe 3]
13.1
The Racketeering Lawyer/former Guardian and the Other Racketeering
Defendants engaged in a myriad of intentional false representation to induce the
Probate Court to act or refrain from acting, upon which the Probate Court justifiably
relied, resulting in damage to the Gary Wayne Thompson.
13.2
The Racketeering Lawyer/former Guardian and the Other Racketeering
Defendants concealed material facts that they were to communicate to the Probate
Court and representatives of Gary Wayne Thompson.
13.3
The Racketeering Lawyer/former Guardian and the Other Racketeering
Defendants made promises involving material facts without a present intent to
perform, which were intentional misrepresentation and a fraud upon the Probate
Court and Gary Wayne Thompson.
