of the enterprise shall include the following information:
a. State the names of the individuals, partnerships,
corporations, associations, or other legal entities, which
allegedly constitute the enterprise;
b. Describe the structure, purpose, function and course of
conduct of the enterprise;
c. State whether any defendants are employees, officers or
directors of the alleged enterprise;
d. State whether any defendants are associated with the alleged
e. State whether you are alleging that the defendants are
individuals or entities separate from the alleged enterprise, or
that the defendants are the enterprise itself, or members of the
f. If any defendants are alleged to be the enterprise itself,
or members of the enterprise, explain whether such defendants are
perpetrators, passive instruments, or victims of the alleged
7. State and describe in detail whether you are alleging that
the pattern of racketeering activity and the enterprise are
separate or have merged into one entity.
8. Describe the alleged relationship between the activities of
the enterprise and the pattern of racketeering activity. Discuss
how the racketeering activity differs from the usual and daily
activities of the enterprise, if at all.
9. Describe what benefits, if any, the alleged enterprise
receives from the alleged pattern of racketeering.
10. Describe the effect of the activities of the enterprise on
interstate or foreign commerce.
11. If the complaint alleges a violation of > 18 U.S.C. S
1962(a), provide the following information:
a. State who received the income derived from the pattern of
racketeering activity or through the collection of an unlawful
b. Describe the use or investment of such income.
12. If the complaint alleges a violation of > 18 U.S.C. S
1962(b), describe in detail the acquisition or maintenance of any
interest in or control of the alleged enterprise.
13. If the complaint alleges a violation of > 18 U.S.C. S
1962(c), provide the following information:
a. State who is employed by or associated with the enterprise;
b. State whether the same entity is both the liable "person"
and the "enterprise" under S> 1962(c).
14. If the complaint alleges a violation of > 18 U.S.C. S
1962(d), describe in detail the alleged conspiracy.
15. Describe the alleged injury to business or property.
16. Describe the direct causal relationship between the alleged
injury and the violation of the RICO statute.
17. List the damages sustained for which each defendant is
18. List all other federal causes of action, if any, and
provide the relevant statute numbers.
19. List all pendent state claims, if any.
20. Provide any additional information that you feel would be
helpful to the court in processing your RICO claim.