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13.4
The Racketeering Lawyer/former Guardian suppressed material facts, which
they were under an obligation to communicate to the Probate Court and the
representatives of Gary Wayne Thompson.
13.5
The Racketeering Lawyer/former Guardian had an obligation to
communicate material facts about the administration of funds belonging to Gary
Wayne Thompson because of his fiduciary and confidential relations.
13.6
The Racketeering Lawyer/former Guardian and the Other Racketeering
Defendants engaged in willful misrepresentation of material facts, made to induce
the Probate Court to take an action or restrain from acting.
13.7
The above-identified conduct of the Racketeering Lawyer/former Guardian
and the Other Racketeering Defendants prevented the detection of their RICO
Enterprise and illegal conduct until Rhonda McClendon was appointed guardian of
Gary Wayne Thompson and obtained the records necessary to review the conduct of
the Racketeering Lawyer/former Guardian and the Other Racketeering Defendants.
13.8
All of the above-identified conduct amounted to fraud and other actionable
conduct that damaged Gary Wayne Thompson.
