compensatory damages of $20,000 from each Respondent in to deter the Respondents from continuing to engage in their unlawful and deceptive conduct. Plaintiff requests punitive damages in the amount of $10,000 from each Respondent and for any and all costs associated with this cause of action and reasonable attorney fees and for all other such relief as the judge may deem appropriate and proper. COUNT VIII Violation of the Racketeering Influenced and Corrupt Organization Act (RICO)10 18 U.S.C. 1961-1968 The allegations contained in Paragraphs 1 through 83 are incorporated by reference in this count as if fully restated herein. The Enterprise Respondents Nissan Motor Co. Nissan North American, Inc. Nissan Infiniti, Lt, Highland Park Motor Cars, Inc., Muller Nissan, Muller Auto Group, Carlos Ghosn, Nobao Araki, Roland Krueger, Michael Muller, Mark Muller, Rafal Chudoba et al at all relevant times are in violation of the Racketeering and Corrupt Organization Act. Respondents, their employees including their directors, lawyers, agents and vendors conducted the affairs associated in fact enterprise, as the term is defined. The Nissan Motor Co/Highland Park Motor Cars, Inc’s enterprise and the affairs of the Respondents affect commerce. The Nissan Motor Co/Highland Park Motor Cars, Inc’s enterprise is an ongoing and continuing group or unit of people and entities which are associated together for the common purpose of limiting costs and maximizing profits by engaging in deceptive trade practices, false Claimant’s Count VIII sounds in RICO. The Eleventh Circuit Court has interpreted RICO to reach any group of 10 individuals whose associations, however loose or informal, furnishes t vehicle for the commission of two or more
compensatory damages of $20,000 from each Respondent in to deter the Respondents from continuing to engage in their unlawful and deceptive conduct. Plaintiff requests punitive damages in the amount of $10,000 from each Respondent and for any and all costs associated with this cause of action and reasonable attorney fees and for all other such relief as the judge may deem appropriate and proper. COUNT VIII Violation of the Racketeering Influenced and Corrupt Organization Act (RICO)10 18 U.S.C. 1961-1968 The allegations contained in Paragraphs 1 through 83 are incorporated by reference in this count as if fully restated herein. The Enterprise Respondents Nissan Motor Co. Nissan North American, Inc. Nissan Infiniti, Lt, Highland Park Motor Cars, Inc., Muller Nissan, Muller Auto Group, Carlos Ghosn, Nobao Araki, Roland Krueger, Michael Muller, Mark Muller, Rafal Chudoba et al at all relevant times are in violation of the Racketeering and Corrupt Organization Act. Respondents, their employees including their directors, lawyers, agents and vendors conducted the affairs associated in fact enterprise, as the term is defined. The Nissan Motor Co/Highland Park Motor Cars, Inc’s enterprise and the affairs of the Respondents affect commerce. The Nissan Motor Co/Highland Park Motor Cars, Inc’s enterprise is an ongoing and continuing group or unit of people and entities which are associated together for the common purpose of limiting costs and maximizing profits by engaging in deceptive trade practices, false 10 Claimant’s Count VIII sounds in RICO. The Eleventh Circuit Court has interpreted RICO to reach any group of individuals whose associations, however loose or informal, furnishes t vehicle for the commission of two or more
complaint_10-15-2017.docx