NATIONAL PETITIONS INITIATED TO SUSPEND
FEDERAL FUNDING OF WASHINGTON STATE COURTS
By J.P. Zenger JPZengerMail@gmail.com
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Seattle, WA Dec. 31, 2022. “I will never be charged with a crime, because we have people in every part of government who will always protect me,” boasted serial criminal and sex offender John Pennington, Jr. to his ex-mother-in-law, Linda Laughlin.
As a result of that boasting, and over 15 years of effort by public interest attorneys and journalists, including hundreds of public records requests and thousands of pages of litigation, Mr. Pennington personally exposed what is likely the single largest criminal enterprise in U.S. history. An explanation of how is works is here.
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Today, Ninth Circuit Attorney John Scannell provided notice of a series of national Petitions to suspend Federal funding of Washington State courts. The Petitions will appear in the press, internet venues, and the courts. An advance draft follows:
National Petition
SUSPEND FEDERAL FUNDING OF WASHINGTON STATE COURTS

(Clockwise from Top Left) Valerie A. Villacin, Ian Cairns, Jonathan Collins, and
Howard M. Goodfriend, Allegedly Occupy a Central Role in a
Racketeering Enterprise That Denies Access to Justice to Washington State Citizens.
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John Scannell, a public interest advocate and lawyer in the Federal Ninth Circuit Court, started this Petition to the Department of Justice and others.
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SUMMARY OF THE PETITION
This Petition is for the citizens of Washington State – and all U.S. citizens – who don’t want their federal tax dollars to support a corrupt state court system. The goal of this Petition is to suspend Federal funding of Washington State Courts.
The citizens of Washington State are currently denied their Constitutional right to due process – a fair day in court – because of organized crime. The organized crime is called a RICO. The RICO, which operates openly, involves public officials and private attorneys.
The purpose of this Petition is to suspend Federal funding of the Washington State court system until the conclusion of Federal investigations. This Petition respectfully requests that Federal law enforcement based in Washington, D.C., the Department of Justice, Government Accountability Office (GAO), and Congress, investigate the allegations against specific people and legal cases. Those people and cases are listed in the “What We Are Asking” section below.
In addition to Washington State public officials, we ask for an investigation of the U.S. Attorney for the Western District, Nick Brown. Mr. Brown is fully aware of the RICO and is alleged to directly support the RICO by refusing to act against it. Prior to his position as U.S. Attorney, Mr. Brown was an attorney at a law firm that allegedly defends and supports the RICO according to legal scholars, researchers, and journalists.
In the Western District of the U.S. Attorney’s Office, Mr. Brown is the public’s last line of defense against public corruption. Because of that, Mr. Brown’s alleged knowing collaboration with the RICO, and inaction, is the most critical obstruction to public justice – his inaction protects and ensures the continued existence of the RICO.
This Petition calls for action by Washington, D.C. based Federal agencies to investigate the RICO. The first agency and contact is listed below, and several more will follow in the near future.
At the end of this Petition is a more detailed explanation that is titled “How the RICO Operates”
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WHO I AM
My name is John Scannell. I am a public interest advocate and appellate attorney in the Federal Ninth Circuit Court. Separately, I am a candidate for the Supreme Court of Washington State.
With decades of experience as a public interest attorney, I have worked on behalf of public justice with more than one hundred million dollars of impact, and which have resulted in constructive social change. I have seldom asked for any financial compensation for my work throughout my entire public interest career.
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WHY I AM SPONSORING THIS PETITION
Should your Federal tax dollars support Washington State courts which are controlled by extensively documented organized crime? This is why I am sponsoring this Petition.
I believe in the importance of due process, and that everyone should have a fair day in court. Millions of people have died for your Constitutional right to due process.
My personal motivation resulted from my discovery of the RICO, the racketeering enterprise. It includes judges, prosecutors, and lawyers who present themselves as representing public interest while in fact they betray their sworn duty under the Federal and State Constitutions.
By allowing well documented corruption in its courts, the State of Washington has violated its court funding contract with the Federal government. That contract requires the State to uphold the Federal Constitution and ensure the right of due process – a fair day in court.
Extensive corruption in Washington State courts is a reality. The question is, what are we willing to do about it? If we work together, we can make a difference.
Power is not taken from us. We give it through fear and inaction. Let’s act now.
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WHO IS FUNDING THIS PETITION, AND WHO IS BEHIND IT?
No one is funding this Petition, and I am its sole official sponsor.
Behind this Petition are several dozen public interest attorneys, legal scholars, journalists, and others who have been targeted for retaliation by the RICO. We have spent over 15 years filing hundreds of public records requests, reviewing thousands of pages of public documents, and engaging in public interest litigation – all at our own expense.
The summary of the RICO that follows this Petition is the result of all of our collective public records requests, research, testimony of government and corrupt law firm insiders, and public interest litigation.
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WHAT THIS PETITION IS ASKING
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IN CONCLUSION
We ask all Washington State citizens, Federal law enforcement organizations, legal advocacy groups, and every American citizen to join us in this Petition to suspend Federal funding for the Washington State court system until the conclusion of a Federal investigation of the named parties and cases.
The named parties, it is alleged, have betrayed their respective oaths of office and public trust to uphold the Constitution, betrayed the legal and ethical duty of the Washington State Court system to uphold the law, betrayed the trust of every federal taxpayer, and betrayed every Washington State citizen’s Constitutional inheritance: the right to due process – a fair day in court.
THIS PETITION WILL BE SENT TO: The Honorable Amy L. Solomon, who currently serves as Principal Deputy Assistant Attorney General of the U.S. Department of Justice (DOJ) Office of Justice Programs (OJP), and is the person who controls Federal funding of State courts.
Please also join us in directly contacting Principal Deputy Assistant Attorney General Solomon. Her phone number and address are listed on the screen below 202-514-2000; her mailing address is: Office of Justice Programs, U.S. Department of Justice, 810 7th Street NW, Washington, D.C.20001. Amy Solomon’s personal email address: absolomon5@gmail.com
Let’s keep the Constitution alive by working to suspend our Federal tax dollars from the Washington State court system today. Please contact us and let us know if you or your organization would like to join us.
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Petition Sponsor and Press Contact:
John Scannell, Appellate Attorney in the Ninth Circuit
zamboni_john@hotmail.com
Seattle/Pacific Time
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HOW THE RICO OPERATES
The courts of Washington State are currently controlled by organized crime.
This is a fact established by several public interest attorneys including me; national legal experts; and thousands of pages of evidence collected through hundreds of public records requests by journalists and legal academics at the award-winning publication, The Gold Bar Reporter.
The allegations in this Petition are the result of over 15 years’ public records requests, research, and litigation by the Gold Bar Reporter, its publisher, affiliated journalists, public interest lawyers, public records lawyers and experts, and several dozen concerned citizens.
The purpose of the alleged organized criminal activity – a racketeering enterprise called a RICO – is to control both the insurance market and financial losses for the insurance company Lloyd’s of London and its insurance partners, called syndicates. The RICO effects every citizen in Washington State.
A RICO is a complex fraud. Complexity is fraud’s best friend. Because complexity creates a kind of “sandstorm” of confusion. It allows the people who operate it, and the way that they operate it, to hide inside that storm. We have worked hard to deconstruct it.
An ongoing series of articles, “Seattle’s Epstein,” explains in more detail how the alleged RICO was exposed and operates. According to that series, in brief, this is a summary of how the RICO is structured, directed, and controlled:
1). Lloyd’s of London. The RICO is directed and controlled by the insurance company, Lloyd’s of London. In the U.S., the Lloyd’s RICO is directed and controlled by Cary Bond of Lloyd’s N.Y. office. Lloyd’s RICO is well documented in U.S. court cases like this one.
2). AWC. In the U.S., the RICO is operated on a state-by-state basis. In Washington State, the RICO is directed by Lloyd’s syndicate member, the Association of Washington Cities (“AWC”). Just days after his role in the RICO was exposed in the press, Peter King, the de facto CEO, hastily announced his retirement in an attempt to deceive Federal law enforcement.
3) The AG. The Co-Director of the Washington State unit of Lloyd’s RICO is State Attorney General (“AG”) Bob Ferguson. Mr. Ferguson was chosen and supported by Peter King to co-direct the RICO.
At the direction of Peter King, Washington State Attorney General Bob Ferguson controls the legal system and denies any Washington citizen, considered by the RICO to be a financial or political risk, their Constitutional right to a fair day in court in four main ways:
A). Public Records Officers. State public records officers, acting at the direction of Mr. Ferguson, routinely and illegally deny public records requests, destroy documents, and obstruct justice. The denial of public records prevents access to due process. These are criminal acts in violation of Federal law.
B) SAAGS. SAAGS are Special Assistant Attorney Generals. They are both private attorneys, and county prosecutors. A SAAG is basically “deputized” by Mr. Ferguson to act on his behalf as his own staff. This is illegal and unconstitutional: it places both attorneys and prosecutors in a conflict of interest with the people they have a legal duty to represent. When a prosecutor illegally accepts a SAAG contract from Mr. Ferguson, it allows Mr. Ferguson to assume the county prosecutor’s power of criminal prosecution, which is denied Mr. Ferguson under the Washington State Constitution. It also allows Mr. Ferguson to deny anyone he wants the right to due process under the Federal Constitution.
C) The Bar Assn. The private Washington State Bar Association is controlled by State Attorney General Bob Ferguson. Mr. Ferguson controls the Bar by illegally: 1) Giving the private Bar millions of dollars in free rent; 2) Hosting and controlling the Bar’s email and data servers; 3) Proving unlimited free legal services to the Bar – all at a cost of tens of millions of dollars to the taxpayers of Washington State; 4) Using the Bar and its State conferred disciplinary powers to target people chosen by Mr. Ferguson for liability control or political retaliation; and 5) Gifting every employee of the ‘private’ Washington State Bar tens of millions of dollars of taxpayer dollars through the State retirement system, called PERS;
In one case alone, Mr. Ferguson has spent over $30,000,000 of State taxpayer dollars to illegally disbar, harass with contract private security and cybercriminals, and engage in baseless litigation with dozens of attorneys against a single person, Anne Block, a court-recognized journalist, and former public interest lawyer.
D) Judges. Judges in Washington State are a key part of the RICO. They are routinely bribed in several known ways, including home refinancing where loans are paid by outside parties, “speaking engagements,” cash bribes, and promoted for their collusion and cooperation in the RICO. Corrupt judges are usually former employees of the staff of AG Bob Ferguson or were SAAGs – attorneys who were under contract by Bob Ferguson.
4). The U.S. Attorney in the Western District. For the public, the last line of defense against public corruption is U.S. Attorney for the Western District, Nick Brown. Until his appointment, aided by RICO co-director Bob Ferguson, Mr. Brown was an attorney with the SAAG law firm Pacifica Law Group. Pacifica law group allegedly has, and continues to protect, the RICO and its members.
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Seattle’s Epstein – Part Three
Seattle’s Epstein – Part Seven
Seattle’s Epstein – Part Eight
Seattle’s Epstein – Part Eight
J.P. Zenger appreciates the interest of the entertainment industry in the “Seattle’s Epstein” series, and is available to consult for story development and/or script writing. Mr. Zenger is also available to direct people who have been targeted by the RICO, including attorneys, to federal law enforcement agencies.
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Update, January 2020, Gold Bar’s new Mayor Bill Clem fired Ann Marie Soto ( as well as Kenyon Disend) and Shannon Ragonesi ( KBM Lawyers)
Snohomish County Prosecutors and attorneys tampering with FBI National Crime Information Center data
Ann Marie Soto Shannon Ragonesi
In November 2017, the City of Gold Bar’s attorneys Ann Marie Soto and Shannon Ragonesi decided to have a meeting with a federal witness Brandia Tamuu. Besides the obvious, tampering with a federal witness ( a felony in Washington), both entered into a bribery scheme to remove the witness’s criminal arrest warrant and criminal history from the National Crime Information Center’s (NCIC) criminal data base.
Public records from the City of Gold Bar, from November 21 to December 20, 2017, document that in November 2017, Shannon Ragonesi and Ann Marie Soto were contacted for a meeting by a convicted animal abuser. The woman was desperate for money, had in fact tried extort the Gold Bar Reporter for money/car, and had offered to meet up with Ragonesi and Soto at the Law Firm of Keating Bucklin McCormack Inc in downtown Seattle. Brandia Tammu needed money as she was being threatened with eviction from her home. In exchange for meeting with Ragonesi and Soto, the woman would get money and her City of Everett arrest warrant and conviction for animal abuse would be cleared. Tammu claimed to have dirt on the Gold Bar Reporter, but had nothing of value except speculation on why the Gold Bar Reporter moved West, and it was quite apparent from an insider at the law office that the woman is suffering from mental health issues.
According to the woman, Ragonesi and Soto agreed to clear her criminal arrest warrant and conviction from NCIC via ACCESS.
Ragonesi and Soto also told the woman that they could issue secret subpoenas for any document they so desired, and further offered to help the woman get a restraining order against the Gold Bar Reporter’s news reports. One witness said that the woman recorded their meeting, but we have no knowledge of whether this is true or not.
The Washington State Patrol turned over the woman’s criminal history one week before and a week after the Ragonesi and Soto November 2017 bribery meeting, and it is clear that just days after this meeting, the criminal conviction record and arrest warrant were wiped from NCIC via ACCESS. The person who cleared the woman’s ACCESS records was Michael Meyers, King County police officer.
The City of Gold Bar, at the bequest of Ann Marie Soto and Shannon Ragonesi, illegally claimed that the meeting records were exempt from public disclosure. Obviously, a lawsuit forcing disclosure is coming, and Ms. Soto and Ms. Ragonesi will be deposed.
In early 2018, Gold Bar’s new Mayor Bill Clem agreed to an interview with the Gold Bar Reporter and he said ” those people who are threatening you are now threatening me.”
NCIC was created to assist law enforcement track or apprehend persons that may be a danger to society or have outstanding criminal warrants. When a police officer stops a person driving or is a suspect, s/he should know whether the person has a criminal history. For this reason, ACCESS and NCIC are searched, hopefully alerting the officer a potential danger to them or outstanding court issues of the driver or suspect. Self protection according to the US Supreme Court.
But here in Washington State, the FBI NCIC database via ACCESS is being tampered with as political favors, bribery schemes, and to enhance criminal sentencing if a defendant is convicted of crime.
Over the past year, we found case after case where mainly prosecutors inside King and Snohomish County government are illegally removing criminal history from the NCIC.
Here’s just three cases that illustrate quite nicely three Snohomish County Prosecutors Mark Roe, Wallace Langbehn III and Sean Reay’s criminal racketeering acts exposed in public NCIC records.
Sno County Prosecutor Sean Reay, removing criminal history records from NCIC as political favors
In 2009, the City of Gold Bar’s Mayor, Crystal Hill ( nee Berg) attempted to have the Gold Bar Reporter charged with a crime for exposing her crimes against the City of Gold Bar taxpayers ( theft in excess of $200,000.00). Ms. Hill Berg was sleeping with several married men inside Snohomish County government, including but not limited to Snohomish County Executive Aaron Reardon and Emergency Management Director John E. Pennington.
Ms Hill Pennington ( nee Berg) and John E Pennington were stealing from Snohomish County Emergency Management and the County’s Emergency Housing Funds. Federal money distributed to the local government via a welfare block grant.
On July 5, 2008, Gold Bar’s water employee Karl Majerle was caught red handed stealing from the City of Gold Bar, and had in fact sabotaged the City’s Wells, # 3 and 4. Why, because Ms. Hill (Berg) was informed by Gold Bar council member Dorothy Croshaw that Majerle was stealing from the City. After Karl Majerle was caught stealing, he was fired, which he recorded via audio means, and then out of anger, he left City Hall and poured gravel down Gold Bar’s City wells # 3 and 4. Instead of reporting the federal crimes, as acts of domestic terrorism to Gold Bar’s water system, Ms. Hill (Berg) decided the best way to handle this was to ask Snohomish County Prosecutor Sean Reay for a favor i.e. help quash criminal charges against Majerle.
And Sean Reay did it.
Snohomish County Prosecutor Sean Reay received the criminal referral from Snohomish County Sheriff’s Officer Terry Handleman and Deputy Jeff Ross ( Brady Cops). Sean Reay received a phone call from Snohomish County Director John E Pennington and Executive Aaron Reardon asking for his help in quashing the criminal charges as “political courtesy.” Sean Reay called then Sheriff and both made an agreement to not prosecute Karl Majerle for sabotaging the City of Gold Bar’s water system.
Sean Reay, in an effort to make it look good, sent the Karl Majerle’s criminal complaint to his wife, Laura Twindale. Ms. Twinsdale is in charge of Snohomish County District Court, Evergreen Division.
Sean Reay never referred the case to the federal government as all crimes against water systems must be referred to the DOJ and FBI for investigation and/or prosecution. But instead, Sean Reay sent the criminal complaint against Gold Bar’s water employee to his wife, Laura Twinsdale. Ms. Twinsdale is only in charge of misdemeanor offenses and has no authority to issue felony charges nor prosecute federal crimes.
We later learned that Karl Majerle and Crystal Hill ( nee Berg) had entered into a bribery scheme. Why, because Karl Majerle knew what we didn’t know for five years until Snohomish County finally released a record it illegally withheld for almost 7 years now.
Simply put, Snohomish County Prosecutor Sean Reay is guilty of racketeering, quashing criminal charges as political favors. Perhaps Mr. Reay thought he and Aaron Reardon were going to the Governor’s Manson. So sad, but along came the Gold Bar Reporter, and Aaron Reardon was ousted for stealing public monies.
As a political favor, Sean Reay helped Crystal Hill ( nee Berg) remove her criminal conviction and arrest records from NCIC.
Not only did Prosecutor Sean Reay assist Ms. Hill ( nee Berg) remove her criminal history from NCIC, he also entered into a bribery scheme with Ms. Hill Pennington (nee Berg), to quash criminal charges after she violently assaulted a six year old child.
Our readers, and those Ms Hill Pennington ( nee Berg) stole from ( City of Gold Bar taxpayers) should be happy to know that she is now frauding the federal taxpayers working as a contractor at FEMA in Emittsburg Maryland. According to the Office of Inspector General, persons convicted of fraud are not eligible for federal employment or federal contracts of any nature.
FEMA’s Brock Long was made aware of Crystal Hill Pennington’s criminal history and has refused comment.
Snohomish County Prosecutor Wallace Langbehn III, putting false criminal history records inside NCIC. Why? To enhance criminal sentencing if the accused is found guilty. We also have ample evidence to also document that Wallace Langbehn also falsely placed criminal history inside NCIC to retaliate against persons who exposed Dawson Place as a fraudulent 501 (3) (C).
The Gold Bar Reporter was the first to expose Dawson Place as a fraudulent 501 (3) (c) with its sole purpose used by Snohomish County Sheriff’s Office and Prosecutors Office for purposes of domestic spying and siphoning over $27 Million dollars of Washington State and federal taxpayer monies.
Dawson Place uses the law firm of Anderson Hunter to funnel millions of public money just as G. Geoffrey Gibbs did with attorney Lin O’Dell inside the Snohomish County Housing Authority scam known as Whispering Pines. The scam that involved Dean Bellamy, a man murdered by Spokane County Sheriff’s Office. Mr. Bellamy was threatening to expose many Judges and Commissioners involved in the guardian scam with attorneys Joseph Nappi Jr, Lin O’Dell and James Spargetis in Spokane.
Click below to how Dawson Place is nothing more than a shrill set up by Snohomish County Judges, Prosecutors and attorneys siphoning off million of public dollars.
https://goldbarreporter.org/2018/08/
https://goldbarreporter.org/2018/09/
For those of my readers who have been following the County’s malicious prosecution of Lori Shavlik, it’s no surprise that Dawson Place’s Prosecutor Wallace Langbehn III was working inside Dawson Place when Snohomish County activist Lori Shavlik started piecing together the County Judges/Prosecutors/Attorneys sick little domestic spy ring also known now as Dawson Place.
Bigger question still remains unanswered: Where did the millions of public monies go?
In 2010, Snohomish County Prosecutors Mark Roe and Adam Cornell knew Lori Shavlik was getting close to exposing Dawson Place as a shrill to funnel public monies and spy on citizens. Mark Roe and Adam Cornell needed to shut Ms. Shavlik up as she was starting to unravel Dawson Place as a shadow agency owned and operated by Snohomish County government.
Mark Roe and Adam Cornell decided the best way to shut Ms. Shavlik up was to enlist the assistance of a known Brady Cop named David Fontenot. David Fontenot’s job was to find someone close to Ms. Shavlik to start a fire inside Ms. Shavlik’s tanning salon. Fontenot is as dirty as them, and had known all of the drug addicts, and one such drug addict Fontenot found worked inside Ms. Shavlik’s tanning salon. Rebecca Bradshaw was well know to David Fontenot, because Ms. Bradshaw was a drug informant on Snohomish County’s payroll.
While at the same time Rebecca Bradshaw is on Snohomish County’s payroll, Ms Bradshaw was working in and stealing from Ms. Shavlik’s tanning salon in the City of Snohomish. Brady Cop David Fontenot knew this, and enlisted Ms. Bradshaw assistance in starting a fire behind a dryer unitinside Ms. Shavlik’s tanning salon.
The false trumped up criminal charges Snohomish County set into action came only after Ms. Shavlik had exposed Dawson Place for fraud, and a government shrill to steal taxpayer monies without accountability.
In 2014, Snohomish County Prosecutors Office, known racketeering member, Franchasca Yahyavi tried Ms. Shavlik for first degree arson. Ms. Yahyavi, never disclosed that the lead detective David Fontenot was a Brady Cop, and that the County’s main witness Rebecca Bradshaw was a paid informant.
Thankfully for Ms. Shavlik one juror was a highly educated Engineer who later said ” this was bullshit. There was nothing here.” Those of you who know me, know I am partial to engineers not only because my engineer is my most loved treasure, but because persons that are trained in hard sciences are critical thinkers who analysis even small pieces of evidence.
That Engineer saved Ms. Shavlik’s life by holding out for days until the Judge called it a deadlock jury. Instead of the Prosecutors’ leaving well enough alone, Francesca Yadavvi recharged Ms. Shavlik in a second trial in February 2016.
The Gold Bar Reporter was in the audience watching as Brady Cop David Fontenot and Prosecutor Yahyavi paraded witness after witness on the stand to attest about what a bad business owner Ms. Shavlik was. One witness named Dolly even told the jury that she was told by the Prosecutors that she would get money for her testimony.
In March 2016, 12 jurors acquitted Lori Shavlik of arson.
Early this year, Ms. Shavlik started complaining that her insurance rates were over the roof. This prompted this question: have you looked at your criminal access searches and driving record from Washington State ?
When Lori Shavlik retrieved her driving record from the Washington State Department of Licensing she learned that Dawson Place Prosecutor Wallace Langbehn III had entered false information into Ms. Shavlik’s criminal history records, falsely claiming that she had plead guilty to contributing to the delinquency of a minor.
In a nutshell, Wallace Langbehn III entered into Ms. Shavlik’s criminal history records, via NCIC, that Ms. Shavlik had plead guilty to giving alcohol to minors. False.
Wallace Langbehn III falsely entered a conviction record into Ms. Shavlik’s NCIC records and he did so while assigned to Dawson Place, an alleged non-profit 501 (3) (c). A shrill money laundering company to further the efforts of Dawson Place and its racketeering members. Mainly Snohomish County Prosecutors and Judges and two mobsters and attorneys G. Geoffrey Gibbs and Michael Kenyon.
Does this fit the definition of racketeering crimes?
Source: https://www.cga.ct.gov/2006/rpt/2006-R-0484.htm
The federal Racketeer Influenced and Corrupt Organizations Act (RICO) (18 USC §§ 1961-1968) prohibits (1) acquiring, establishing, or operating an enterprise with illegally derived income, (2) acquiring or maintaining an interest in or control of an enterprise through illegal activity, and (3) using an enterprise to commit illegal acts (Extortion, Blackmail, Etc., 31A Am Jur 2d).
RICO defines “racketeering activity” as a long list of state and federal crimes. The federal crimes include bribery, various fraud offenses, gambling offenses, money laundering, a number of financial and economic crimes, obstructing justice or a criminal investigation, murder for hire, and sexual exploitation of children. The state crimes include murder, kidnapping, gambling, arson, robbery, bribery, extortion, dealing in obscene matter, and drug crimes.
It defines a “pattern of racketeering activity” as at least two acts of racketeering activity, one of which occurred after RICO became law and the last of which occurred within 10 years after the prior act.
“racketeering activity” means committing, attempting to commit, conspiring to commit, or intentionally aiding, soliciting, coercing, or intimidating another person to commit a specified list of felonies. These felonies include gambling activities, extortion, drug offenses, weapons offenses, murder, assault, prostitution, hazardous waste violations, securities violations, coercion, money laundering, arson, bribery, and forgery
“Pattern of racketeering activity” means engaging in at least two incidents of racketeering activity that (1) have the same or similar purposes, results, participants, victims, or methods of commission or otherwise are interrelated by distinguished characteristics; (2) are not isolated incidents; (3) include at least one incident that occurred after October 1, 1982; and (4) occurred within five years of a prior incident of racketeering activity (CGS § 53-394(e)).
“Collusion” is not defined in either RICO, although the word “collusion” is used in a number of state contracting statutes. The Black‘s Law Dictionary definition of “collusion” includes a “secret combination, conspiracy, or concert of action between two or more persons for fraudulent or deceitful purpose.” This type of conduct would appear to be covered by RICO
Wallace Langbehn III, Sean Reay, Mark Roe, Adam Cornell, Mike Kenyon, Shannon Ragonesi, Ann Marie Soto, and Snohomish County Judges were contacted and all declined comment.
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