Commercial Litigation and Arbitration

RICO — Conclusory Allegations of Pattern Inadequate — Good Quote

From Dalton v. City of Las Vegas, 2008 U.S. App. LEXIS 12522 (10th Cir. June 12, 2008):

Simply listing the litany of offenses allegedly committed by defendants, without any specification as to which acts (1) qualify as § 1961 predicate acts and (2) also occurred within the time frame required to satisfy § 1961(5), is insufficient to state a RICO claim.

The Court came to the same conclusion as to the complaint’s allegations of “enterprise.” The key: Twombly.

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