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They engaged in "a pattern of racketeering activity, which included numerous acts of fraud," he wrote.
He noted that the plaintiffs were accusing the companies of "a pattern of racketeering activity" as defined in the law, including mail fraud and wire fraud.
The federal Racketeer Influenced Corrupt Organizations law allows civil lawsuits, seeking triple damages, against people accused of conducting an "enterprise's affairs through a pattern of racketeering activity".
Two Hobbs Act violations, in turn, can demonstrate a "pattern of racketeering activity" that entitles victims to triple damages under the federal racketeering law known as RICO.
The Hobbs Act question is important because the RICO law, which makes it illegal to conduct the "affairs" of an "enterprise" through a "pattern of racketeering activity," requires proof of at least two illegal acts.
Part of the Organized Crime Control Act of 1970, the Racketeer Influenced and Corrupt Organizations Act (RICO) makes it unlawful to acquire, operate, or receive income from an enterprise through a pattern of racketeering activity.
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Under RICO, it is a crime for an individual to belong to an "enterprise" that is involved in a pattern of racketeering, even if the racketeering was committed by other members.
By accusing the banks and Ms. Kohn of duping investors and using the fund's accounts, he arguably includes Mr. Madoff in the pattern of racketeering.
To establish liability of the defendants under RICO, the government had to prove that the companies engaged in a pattern of racketeering acts in a scheme to defraud.
He is accused of starting a "pattern of racketeering" shortly after taking office in 1985 to solicit bribes from executives in return for official favors.
Through court-ordered discovery in the U.S., however, it was revealed that Donziger and his team engaged in a pattern of racketeering, including fabricating evidence, bribing Ecuadorian judges and court officials, and even ghostwriting the final judgment against Chevron.
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Since I tried Ludwig back in 2017, I have been constantly using it in both editing and translation. Ever since, I suggest it to my translators at ProSciEditing.

Justyna Jupowicz-Kozak
CEO of Professional Science Editing for Scientists @ prosciediting.com