Racketeer Influenced and Corrupt Organization (RICO) Act Criteria;

1.     Person(s) receiving any income derived from a pattern of racketeering activity;

a.     At the very least, the NCMB is collecting fines from “improperly completed” licensure applications and renewals.  Additionally, the pattern of punishment reviewed in the last decade of actions by the NCMB cannot be explained by any rationale other than bribery/extortion.

2.     Enterprise;

a.     The NCMB qualifies as an enterprise; the willful disregard for state and federal statutes is not isolated to any single attorney of the NCMB.  There is a pervasive, systemic and systematic pattern of abuse.

3.     Conduct;

a.     Per the Supreme Court; “…in the ‘conduct’ of the enterprise extends only to those who have ‘some part in directing the enterprises affairs’…” The pattern of abuse originates at a level above any single attorney of the NCMB; it involves all of the attorneys of the organization.

4.     Pattern;

a.     The actions of the NCMB have affected large numbers of providers; over 100 providers in the past decade have been subjected to a complete disregard of;

                                                        i.     Due Process

                                                      ii.     Federal Statutory and Constitutional Rights

                                                     iii.     Protection by NC General Statutes Chapter 90 (among others)