2
Influenced and Corrupt Organizations Act O.C.G.A. §16-14-1, et seq. (or, “RICO”) is the
primary basis for this Complaint. In addition to, and often in furtherance of, their RICO
conspiracy, some defendants engaged in other actionable conduct including, but not
limited to, false swearing, negligent misrepresentations, intentional misrepresentations
and other tortious conduct.
1.2
In Georgia, a RICO civil action is one of the most serious types of civil actions
that is specifically reserved for persons who have committed two or more designated
crimes and persons who have assisted in the commission of these crimes.
1.3
A RICO civil action, as is this action, is not an alternative or substitute for a
criminal action; it is a supplementary action that is designed to restore the losses of the
victims of a criminal enterprise and to answer to the needs of society in deterring this
type of conduct in the future by the participants. RICO civil actions are designed not only
to make crime unprofitable, but to insure that it is a bad financial investment for RICO
Enterprise participants.
1.4
Mark Andrew Gomez, Tina Barron, Leigh Ann Ware (formerly Leigh Ann
Robertson), James Bret Robertson, Jamie Robertson, Derwin Ware, and Nathaniel
Russell, collectively engaged in far more than two criminal acts designed to deprive Gary
Wayne Thompson, an incapacitated adult of money belonging to him. These individuals
are prime candidates for the relief provided by a RICO civil action such as this one.
1.5
The criminal conduct of these defendants had its origin in Mark Andrew Gomez
being able to become the guardian of Gary Wayne Thompson.
