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3.1.4
The Racketeering Lawyer/former Guardian and the Other Racketeering
Defendants engaged in conduct in violation of the laws of Georgia 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).
3.1.5
The Racketeering Lawyer/former Guardian and the Other Racketeering
Defendants engaged in conduct in violation of the laws of Georgia, and, particularly,
committed more than two acts of Racketeering Activity as identified in O.C.G.A.
§16-14-3, et seq.
3.1.6
The Racketeering Lawyer/former Guardian and the Other Racketeering
Defendants engaged in conduct, in violation of the O.C.G.A. §16-14-4 and the laws
of Georgia, which conduct was a pattern of racketeering activity that was more than
two violations of laws that comprise the prerequisite number of predicate acts for the
RICO causes of action in this Complaint.
3.1.7
The Racketeering Lawyer/former Guardian and the Other Racketeering
Defendants engaged in their illegal conduct in violation of the laws of Georgia as a
part of their modus operandi of committing acts designed to appear as contracts for
the legal necessities of Gary Wayne Thompson, when, in reality, the acts were only
thinly veiled covers for the thefts of assets of Gary Wayne Thompson. The
Racketeering Lawyer/former Guardian was so consumed in the goals of the RICO
