3-4-17, Vii, Rico-Final, 117 Pages

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2 VOLUME II
3 TWO RICO CAUSES OF ACTION, 18 USC 1962 (c) and (d) and Prayer for Relief.
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Plaintiff Remington and the Burl Tree for its RICO complaint against the RICO defendants
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listed below, alleges as follows:
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INTRODUCTION
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800. Over the course of several years beginning around 2011-12, primary RICO defendant
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Russell Gans, his law partners, defendants and numerous co-conspirators have intentionally sought to
9 extort, defraud, maliciously crush and otherwise tortuously injure and destroy the land and
10 personal property of Remington and his solely owned business the Burl Tree. Originating in about
11 2007-8, as simple hyper- aggressive litigation by defendants, by 2012 those same defendants had
12 gradually conceived and evolved a criminal plot to unscrupulously WIN their frivolous retaliatory,
13 unmeritorious lawsuit against Remington, at all costs. Therefore they began converting their
14 defensive and offensive litigation strategies to rely upon progressively more unethical and illegal
evidence, mischaracterizations and falsifications, which have now by January 2017 substantially and
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exponentially escalated into a full-blown RICO enterprise, which meets all of the requirements of the
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state and federal statutes, and then some.
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801. By late 2015, Gans enterprises objectives that clearly manifested themselves into:
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Avoiding their lawful contamination cleanup costs; Appropriating all of Remingtons land which they
19 had encroached upon since 1998, which gradually increases as it moves down the mountain;
20 Avoiding all fines and criminal liability for their substantial crimes in 1998, and then those since
21 2012 involved in the massive cover-up; Making a huge amount of money for everyone involved in
22 the enterprise, bar none and especially for Gans, Plotz, Mathson and Lawrence; Fully defeating,
23 humiliating and crushing Remingtons family and business financially, emotionally and health-wise
24 because they were very angry that he stood up for himself and attempted to fight this vast
conspiracy merely to get his property justly cleaned-up, according to California law.
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802. Therefore, defendants have thus formed the Eureka, California-based associated-in-fact
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RICO enterprise which has and is substantially damaging Remingtons established, (solely) interstate
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commerce business, The Burl Tree.
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803. This RICO enterprise has always been led by Gans, however he is very closely assisted
by his fellow Mitchell firm law partners, Ryan Plotz, Paul Brisso, Nicholas Kloeppel and Julie
McBride, Gans Executive Assistant, plus the Mitchell firm itself is a sixth named defendant in this
PLAINTIFF REMINGTONS TWO RICO CAUSES OF ACTION-JANUARY 2017

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category. Other prominent charter members of this RICO enterprise are Rich Olson, Kyle Skillings,
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RAO Company, Inc and Larry Kluck, their attorney since 2014 (not yet believed to be fully involved
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in the criminal operation, so still un-named), for three total presently-named defendants; Jeff Nelson,
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the CEO of SHN Corporation; John Mathson, Remingtons neighbor and criminal vandal to the
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north; and last but certainly not least, Linda Lawrence, who is believed to still be the principal
6 financier of the entire enterprise, and therefore provides unlimited funding for any criminal scheme
7 that Gans conceives. As above, Kluck has so far very narrowly escaped obvious criminal culpability
8 so has not yet been named as a RICO defendant. The other ten (10) named individuals, plus RAO
9 Co, Inc and the Mitchell firm itself above, are therefore herein described as the RICO defendants, a
10 total of TWELVE (12) at this particular time.
11 804. As explained in the lengthy accompanying RICO statement, there are another 10-15
deeply involved, culpable RICO conspirators, some of which will undoubtably be named as
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additional RICO defendants in the first amended complaint (FAC). Substantial discovery has already
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begun here, and there are a known group of enterprise members who will now be forced to make
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false sworn statements on the federal discovery record, which are now required in order to be
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consistent with their numerous false state declarations and perjurious trial testimony. False affidavits,
16 perjured trial testimony, false responses to requests for admission and untruthful special interrogatory
17 responses, in the federal system, have very serious ramifications and punishments. Gans coached
18 perjury and mischaracterized trial and other written false and lying scripts, are also much more
19 likely to be taken very seriously and actually enforced under the more stringently maintained federal
20 ethical system than in the state system.
21 805. The above ten (10) named individual, plus two entities are all members of some sort of
a structured organization which is loosely affiliated with or employed by Gans enterprise, and
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paid by Ms. Lawrence of Allied insurance. Additionally, as explained, the Mitchell firm itself and
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RAO, Inc have also been named here, making a total of twelve (12) presently named RICO
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enterprise defendants.
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806. Those 10 named individuals are also members of the following groups: 1) the first five
26 are members of the Mitchell firm; 2) Olson and Skillings are employees and/ or owners of RAO
27 Corporation; Nelson is the CEO of SHN Corporation; John Mathson is an individual who leads an
28 unscrupulous Westgate Drive gang as described herein; and, Lawrence is believed to be the chief
insurance adjuster at Allied Casualty Insurance Company.
807. Presently unnamed primary RICO Associates. In addition to the above 10-named
RICO enterprise individual defendants (plus the Mitchell firm itself, RAO, Inc), and their as yet un-
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named associated attorney, Kluck, the other primary co-conspirators in Gans enterprise, as presently
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known before exhaustive discovery is done in this case, include the following individual members
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including the mostly small organizations, which they physically work for: Mark Ferriman, Brian
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Gwinn and their field soil tester from Blue Rock Environmental Co.; Michael Pulley from Points
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West Surveying Company; Liz Smith and Candy B from the file room, and Judge Reinholtsen of
6 Department Eight of the Humboldt County Superior Court; Mischa Schwartz of Winzler and Kelly;
7 Larry Lancaster, Melissa Martel, Peter Esko, Carolyn Hawkins, Paul Dalka, Mark Johnson and their
8 primary soil and water sampler, name unknown who all work (or worked) at the County of Humboldt
9 Environmental Health Division; Morgan Randall (of Piersons Hardware, plus other possible DOE
10 RICO associates); BOTH Kishpaughs and Gary Costa. RAO Corporation itself is not yet named as a
11 RICO defendant because they have not yet committed any known predicate acts as a corporation
Between 2012-2017, however there are other associates within RAO Corporation believed to have
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played an important role in some of these criminal activities over many years, which now warrant
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further investigation. See GANS RICO ENTERPRISE ORGANIZATIONAL CHART-2017.
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808. Additional presently more secondary RICO Associates. Other present members of
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Gans RICO enterprise who are not yet named (but several probably SOON Will be) in January
16 2017 as defendants include, without limitation, and in no particular order of priority: Marcie
17 Conn, Matthew Hillyard (of Farallon), Mike Retzloff (Retzloff Appraisal Services); Christopher Watt
18 (LACO Engineering); The Humboldt County Hazmat Divisions December 2011 tester technician,
19 whose name is presently unknown; Larry Kluck of Matthews, Kluck, Walsh and Wykle); RAOs
20 presently unknown insurer that pays Kluck; Joel Kiff of Kiff Analytical; Amanda Porter of Cal
21 Science Environmental Labs; Gary Evans; Harold Hilfiker; John Aveggios SHN January 2011 soil
testing technician; Mike Foget, SHN engineer; Boyd Davis, and the City of Eureka, are unnamed and
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un-implicated in the RICO enterprise to date, ETC.
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809. Other inferentially possible future, probably Secondary RICO enterprise members that
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are ignored here now, or until further discoveries are made would include without limitation: Mark
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Hubbard, Jason Eads (of Stokes, Hamer, Kaufman and Kirk, LLP, Miller Farms Nursery, etc.
26 810. The first 307 pages of Remingtons comprehensive 738-page RICO Statement
27 specifically describe all of the above names and what their known, believed and/or inferred
28 relationship to the RICO enterprise are. Additionally, there are several other enterprise codefendants
with known functions, but presently unknown names, which had a conspiratorial and complicit
involvement with several of the above organizations or small corporations, which we will learn more
about during discovery. Further investigation and discovery into all of the above names is now
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needed before any additional civil or criminal RICO culpability can be absolutely assigned or
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authoritatively and reasonably alleged within Gans RICO racketeering enterprise.
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811. Gans RICO enterprises five (5) major obvious goals and objectives have been
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comprehensively explained throughout Remingtons voluntary RICO statement. Today, they
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are all reasonably close to realization, except now that they are revealed and understood they must
6 eventually fail.
7 812. Gans ultimate RICO goal since 2012 is to create and apply enough pressure on
8 Remington, his family and the Burl Tree to extort and exact them into paying-off Gans and Mathson
9 in order to stop their painful corrupt campaign against the Burl Tree, to coerce Remington into
10 ending his just contamination lawsuit and ultimately just surrender all of the Burl Trees land to
11 defendants at no cost to themselves. In other words, Gans Enterprises ultimate aim is to create
enough pressure on Remington on these properties and in these lawsuits to extort him into paying to
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stop Gans campaign against him. The RICO defendants have also sought to inflict maximum
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damage to Remingtons finances, family and reputation in the neighborhood and to apply extreme
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personal psychological pressures on Remington and all his associated witnesses, and also to disrupt
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Remingtons relationships with and provoke County and state governmental investigations of every
16 conceivable kind from every governmental agency on the north coast, including about 40 in total to
17 date.
18 813. The general purposes of that pressure from Gans are to: Force Remington to drop his
19 successive action contamination lawsuits, which are intended only to clean-up the massive 1998
20 contamination by RAO and Mathson; to take possession and effective title to Remingtons land
21 which defendants have already improperly appropriated (stolen rent-free); and, to force Remington to
absorb the more than $350,000 of present overall real estate losses on the entire property value, if the
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Burl Trees property is even salable AT ALL, at any price as presently contaminated. Remingtons
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real estate sales consultant and expert Frank Scolari maintains that the Burl Trees property at 832
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Westgate Dr. is not salable at all today, by a reputable realtor, at any price.
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814.To implement and execute this plan, the RICO defendants and their co-conspirators initiated
26 an aggressive and frivolous defense based on the fraudulent testing and reports described herein, plus
27 they preemptively filed their own retaliatory lawsuit against Remington for purportedly causing a
28 visual nuisance from his residence, which was not completed quick enough to suit the Mathsons,
and from an inconspicuous fence between the properties in the middle of a redwood forest.
815. From its inception, the Gans- Mathson sham lawsuit in 2008, DR 080669, was always an
intimidation, fear-generating extortion tactic intended solely to prevent Remington from filing his
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just contamination action. Gans never had any monetary value associated with it and it was purely
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intended to offset Remingtons DR 080668 case and to make Remington an offer he couldnt
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refuse, and to settle his case cheap so that Mathson could keep all of Remingtons valuable
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encroached-upon land.
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816. Those facts are proven by the fact that before Remingtons preeminent expert Aveggio
6 prematurely died (from toxic exposures), unless he was killed, Gans offered Remington about
7 $100,000 to resolve an approximately $400,000 injury at that time. No monetary off-set value was
8 attached to DR 080669. After his unexpected federal summary judgment against Remington due to a
9 technical Rule 26 expert disclosure error, Gans reduced his settlement offer to zero. Now, after
10 another $150-$300,000 of expenses and damages, Gans and Remington are still no closer to
11 resolving this than in 2007, when Mathson and Remington did reach a handshake settlement.
817. Inferentially, Gans promised everyone in his enterprise especially Linda Lawrence, that he
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would have this 100% wrapped up in their favor five years ago. When that failed miserably, he has
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become very noticeably, increasingly desperate, unethical, hyper-aggressive and now employs a
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mafia-like organized crime extortion strategy, in order to achieve an unjust result against Remington
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and the Burl Tree and also the entire community both upwind and downstream.
16 818. Additional background. Gans litigation strategy began in January 2008 with a few
17 extortive and unreasonable letters and demands also survey, and then in July 2008 Gans commenced
18 a major war on three fronts:
19 819. A barrage of offensive and defensive litigation motions, including two special motions,
20 numerous demurrers, motions to strike, five different complex summary judgment motions,
21 countless technical objections to everything that Remington ever did were considered doing, and at
least 35 different requests for sanctions;
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820. An intense orchestrated series of bogus, frivolous and false complaints to more than 40
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different governmental organizations, whose subsequent letters, calls, appointments, investigations,
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reports and related distractions and anxiety caused Remington most of six months time in 2008-9. It
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was a full-time job responding to the agencies, and Gans motions and harassing letters and objections
26 and oppositions to Remingtons just lawsuit intended simply to get his land cleaned up;
27 821. Gans third front was Mathsons deer and bear Army, wherein Mathson severely
28 undermined and/or cut Remingtons fences, so that large deer could tunnel under them, or just
squeeze right through them. Mathson also squashed some of them down with logs so that animals
could to step over them. Mathsons primary tactic however was to lead his trained and hungry deer
army into Remingtons gardens in military-like assaults through his two (2) major secret doors,
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built into his fancy permanent wood fence. Mathson built his sturdy solid wood fence with clear
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intentional criminal intent, wherein he cleverly designed several concealed doors with tiny almost
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undetectable hinges on his side of the wall which he could open when Remington was away, and did
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so on a regular schedule captured on surveillance video. The Mathsons trained approximately 100
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local deer and then let 5-10 at a time through his secret doors into Remingtons gardens to ravage the
6 rare foliages, typically for 4-12 hours before he reopened up his doors again to let them out. Each
7 local mule deer could easily eat 7-8 pounds of roses and tender young struggling rosebuds and
8 typically did several thousand dollars of damages per incursion before Remington could locate
9 them and chase them out with paid dogs. Remington had and still has massive gardens with over
10 $200,000 of valuable plants in them. Gans and Mathson knew that, knew that Remington hated the
11 deer ruining his gardens worse than almost anything else and concluded that eventually Remington
would break and give in to the Enterprises objectives.
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822. From 2007 until 2011, Gans was a most obnoxious, unfair and unethical litigant, however
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because only John Mathson is believed to have initially committed state criminal vandalism and
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property destruction crimes, it is difficult to prove the existence of a RICO enterprise prior to 2012.
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Gans may have controlled Mathsons vandalisms as early as 2008, however we dont have any
16 conclusive proof of that yet, but will be attempting to discover some.
17 823. It now seems just as likely that Mathson committed his criminal acts from 2007-2011 just
18 for the pure sport of it, and out of his hate for Remington, and then when Gans heard about
19 Remingtons emotional irritation, time and energy losses, and how significant Remingtons
20 operations were disrupted and damaged, he may have urged Mathson to keep up the good work;
21 or, on the other hand, it is just as likely that vandalisms were Gans idea from the start, because the
first recorded continuous episodes occurred the very week before their complaint was filed, and
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thereafter at intervals of 2-3 per week. Whether it was the chicken or the egg, clearly Mathson and
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Gans have always had a symbiotic relationship with the common goal to hurt in defeat Remington as
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alleged herein. As complained of elsewhere, Gans always seemed to arrange for Mathsons criminal
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acts a few days before motion deadlines and related crucial filing dates, which finding, reporting and
26 chasing-deer-out severely compromised.
27 824. In other words, Remingtons RICO complaint herein did not fully and obviously matriculate
28 until the obvious exponential increase in Mathsons, and his local gangs, criminal vandalisms and
multiple varieties of property damage throughout 2016, and continuing on through December 2016
almost daily.

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825. Therefore, based on Remingtons considerable research thereon, this RICO complaint and
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its too specific causes of action under 1962 (c) & (d) began accruing with certainty by at least
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2012 with the monumental and extremely damaging Skillings, Olson and Mathson intimidation,
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coercion and extortion of Remingtons expert excavation and remediation contractor Bob Figas, from
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December 2012 December 2012 in the May 2013.
6 826. Gans 2011-2016 improper litigation practices have now escalated into full
7 criminality. In order to continue to exert unbearable litigation pressures on Remington and to keep
8 them escalating until his enterprise achieved its purposes:
9 A. Gans began fabricating evidence from his own client Mathsons properties and then falsely
10 equated it to Remingtons land;

11 B. To carry that out, Gans environmental experts Blue Rock Environmental conducted a
fraudulent series of soil and water test on Mathsons land in 2010 to acquaint the benign results there
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with what must also be true of the soil and water on Remingtons land, up to hundreds of feet
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away, and in no event equivalent;
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C. That fraudulent defensive strategy involved filing numerous frivolous and false writings in
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state and federal court repudiating Remington soil and water tests which Gans and defendants
16 experts all knew were valid from their own personal percipient investigations. Whenever defendants
17 experts visited Remingtons land they saw and smelled the contamination, so were afraid to ever do a
18 single boring roast take a single formal water sample on Remingtons land because the results were
19 obvious. Those obvious results were once confirmed when Gwen made a stupid error and stuck a
20 stick into a mucky waterhole and then hastily discarded it into the forest when it strongly smelled of
21 hydrocarbons;
D. Throughout 2010-2012 Gans made multiple false statements in all his motions, more than
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100 and his federal summary judgment alone, wrote perjured declarations himself plus drafted many
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others for all of his environmental experts and other witnesses, provably including, without
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limitation: Ferriman, Gwinn, Schwartz, John Mathson, Joy Mathson, Pulley, Kishpaugh, Skillings
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and Costa. Known false testimony has also been written for others, again including without
26 limitation: Hillyard, Randall, Nelson, Evans, Esko and Hilfiker, etc. due to trial delays however this
27 last group is not formally committed written or oral perjury but is expected to do so in federal
28 discovery imminently, which will therefore solidify many more colluding, conspiratorial enterprise
associates as formal chargeable RICO defendants, such that when anyone enterprise member is found
guilty of an imprisonable federal predicate acts, potentially they can all go down simultaneously due
to their assistance and associations. Under RICO, the Godfather does not have to commit a murder to
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be implicated for murders or related lesser crimes committed by his associates and enterprise
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soldiers. See Gans RICO Enterprise organizational chart-2017.
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E. Additionally, Gans has obfuscated and submitted multiple false discovery responses,
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colluded with his co-conspirators and fellow collaborators in the Superior Court file room, other
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alleged offices reaching into Department Eight, the Department of Health and beyond as inferred and
6 alleged in Remingtons detailed RICO statement, which makes some allegations from various
7 credible sources, but which are not yet corroborated.
8 F. Since all of Remingtons tests done by 6-7 different professional samplers and involving
9 soils, floating hydrocarbons in water and many other toxins including lead, asbestos and other metals
10 and bacteria, etc. proved to be positive in one way or another, in many locations but not in all, Gans
11 eventually wound-up with no defense at all against Remingtons contamination allegations.
G. Nothing has changed today, as Gans cannot refute the extreme toxicity of the soils and
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waters defendants deposited onto Remingtons property and buried, so they now must rely on
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frivolous technicalities such as bogus collateral estoppel, which was grossly misapplied and
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misinterpreted by Judge Reinholtsen in June 2016 from the federal summary judgment, wherein
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magistrate Vadas dismissed five federal statutory claims, without ruling on any of the underlying data
16 or testing.
17 H. That is the single largest contested issue in the companion federal success of action
18 environmental lawsuit which accompanies this RICO complaint. Remington still has a multiple
19 viable continuing nuisance and trespass even without contamination, hydrocarbon pollution and
20 asbestos, however for seating without those elements which in reality exist here on the site today
21 and every day, is absurd, illogical and unjust. When the gigantic concrete chunks and other
constantly shifting debris on these mountainsides, with every rain and earthquake, are removed, the
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main expense is going to be dealing with the asbestos by hand and it is logically absurd for Judge
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Reinholtsen to currently pretend that none of those hazardous waste exist here just because of some
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superficial, artificial and erroneously misapplied doctrine called collateral estoppel, which even
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Judge Reinholtsen himself has said on the record at least five times, that he may be wrong about. He
26 is wrong, and therefore a form of reconsideration and just application of the 2011-13 federal
27 judgment is requested herein, but if denied it will in any event be properly, reasonably and
28 presumably justly adjudicated in the first state appeal, after a possible negative verdict at the next
state trial, if needed.
I. As a result of all of the illicit behavior, unethical activity, false statements and perjurious oral
and written expert and percipient witness statements summarized above and fully delineated in the
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560+-page RICO statement, Gans has invited this RICO action.
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J. As one of Remingtons attorneys commented, if all of Gans unethical antics and illegal
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activities were fully disclosed as Remington has just barely begun to do here, the results could
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potentially be devastating, and might eventually send all of them to jail.
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827. When Gans knew that he had fully lost the DR080668 case on the merits because of
6 Remingtons primary environmental expert Aveggios dramatic and fully conclusive rebuttals of
7 Gans entire defense, which he asked Aveggios deposition point by point for several hours, Gans
8 immediately became desperate.
9 A. First, he fabricated the bogus Esko report a few months later in collusion with Melissa
10 Martel and other operatives in the health department, described in the RICO statement, in order to
11 attempt to fully rehabilitate and exonerate Mathson and improperly, unscientifically and illogically
defeat all of Remingtons testing in one stroke;
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B. Next Gans and Brisso exerted their entirely improper influence within the Health
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Department, because of Brissos frequent and constant role as County and city Counsel, according to
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Remingtons primary real estate appraisal witness, David Tidwell. Tidwell is on the inside of local
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government and understands many of the devious and corrupt practices which have taken place in
16 this case to date. Brisso therefore succeeded in delaying Maje Hoyos conclusive water and soil
17 hydrocarbon tests in Remingtons lower swamp area until late December 2011, which made them
18 much too late to be used in the DR 080668 proceedings. Judge Reinholtsen could have made
19 exceptions and been more lenient the way he was with Esko, who did all his incompetent work1
20 almost a year after discovery closed, yet that work was still allowed into the case, despite it being
21 irrelevant because it was done on another Different piece of property, not involved in Remingtons
contamination dispute.
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828. The bottom line here was that considerable influence and corrupt pressures were exerted
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upon several county government bureaucracies, which resulted in obviously improper, illogical and
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inconsistent decisions, because of actions taken by Gans enterprise. The only consistency is that all
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1. Eskos work was fully incompetent on every level of analysis possible. It was one-sided because
26 the county did not want any opposing views from our experts which we offered to them. The main
problem with Eskos conclusions were that they were based exclusively on Blue Rocks entirely
27 incompetent testing which John Aveggio conclusively proved was entirely fraudulent and without
28 any merit at all because the laboratory tests were done 6-8 weeks out of scientifically valid holding-
time, and in other words after all the hydrocarbons in their soil samples head fully volatilized down
in to different hot Southern California laboratories, while supposedly waiting to be tested.as a
result all of Gans soil and water test results were incompetent, worthless, presumed to be fraudulent
by our experts, enhance Esko's report was similarly fraudulent and incompetent because it was
based on knowingly and intentionally fraudulent raw data.
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of the above described in the many other related ones always benefit Gans enterprise and help it to
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achieve its objectives against Remington, as assisted by many of those named herein. Obviously,
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Remington is now attempting by these multiple actions to permanently undo some of those unjust
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and presumed to be corrupt decisions, and get his property cleaned up by the polluters.
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829. Finally, continuing with defendants fraudulent and incompetent testing of their own, and
6 their simultaneous pretenses that all of Remingtons tests were similarly unreliable, unprofessional or
7 in effect not to their liking, Gans came up with a new, purely extortion every tactic: Gans invented
8 Hillyard of Farallon. Hillyard was allegedly brought in very improperly to do unknown testing, at
9 unknown times, at unknown locations which were inside Remingtons fenced areas and therefore
10 were per se violations of No Trespassing, Violators will be Prosecuted signs.
11 830. No scientific purpose was accomplished by Hillyard because his tests, if any were not
admissible in any trials, and apparently Hillyard was intended to rehabilitate the discredited Blue
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Rock testers Ferriman and Gwinn. The only purpose Gans accomplished by threatening and
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inferring that Hillyard had done tests which refuted all of Remingtons experts testing, over several
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years in the swamp area, was extortion. Without providing any details, specifics or any scientifically
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valid locational information, Gans just asserted that Hillyard had refuted all of Remingtons tests,
16 especially Hoyos, so watch out in effect. All innuendo, fear, intimidation and coercion is an
17 excellent example of further Gans extortion on behalf of his enterprise. No other purpose was
18 accomplished, nothing scientific, but merely a fear tactic.
19 831. Meanwhile, Gans continued to keep up his derisive, improper and unethical motion
20 practices, and especially claiming in his March 2016 severance motion documents that none of
21 Remington tests were valid because Remington had contaminated his land himself by spilling
gasoline on the ground, and otherwise tampering with the evidence and creating artificial conditions
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on his property, etc.
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832. Remington estimates that what Gans began in 2008-10 as only 10% false statements and
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material factual mischaracterizations, had graduated to 35% by 2012, 50% by 2014-15 and was in the
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70% range by August 2016. Those very rapidly increasing, corrupt and disbarringly unethical Gans
26 material mischaracterizations and false unprovable accusations, were deliberate and fraudulent acts
27 of coercion and extortion, intended solely to reach the Enterprises improper and illegal objectives of
28 making Remington go away, while taking nothing in effect, PLUS paying the enterprise for their
deceptive and corrupt services. Obviously justice has nothing to do with Gans purposes, and none of
Gans irrational threats, allegations and unscientific dynamics are true or could ever be proven. The
TRUTH is that, Gans has no actual honest, relevant evidence to back up any of his false allegations
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and even if they were true as he has stated them, they are not scientifically valid and what he alleges
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that Remington has done, such as his Kuwait fire extinguishing experiments, could not possibly
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actually accomplish or produce the facts that are visible on the ground today.
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833. In other words, it is scientifically impossible that what Gans has alleged to have polluted
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Remingtons own property is correct, and therefore it is doubly impossible that Remingtons
6 minimalist activity could have contaminated Mathsons land 200 yards away, down a mountain,
7 underneath a creek, across a major gorge and then halfway up another mountain.
8 834. Additionally, Mathsons hazardous waste landfills have millions of pounds of toxic wastes
9 on both properties and there is absolutely no machinery access from Remingtons land. Does Gans
10 allege that Remington took 50,000 wheelbarrow loads across that above-referenced impassable
11 terrain with no paths or bridges, wheeled-them up a slope too steep and slippery to even walk on foot
and dumped 30,000 of them up on Mathsons land? What would be the purpose of that and where
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did Remington get 4000 yd. of hazardous wastes?
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835. Therefore, what Gans alleges is frivolous, stupid, nonsensical and knowingly
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fraudulent intended to deceive all applicable triers of fact. Furthermore, all of Gans defenses
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above are so ridiculous and inapplicable to any conditions or test results from any of these properties,
16 that they would clearly be inadmissible at any trial.
17 836. Gans evidence spoliation and false experts reports. By summer 2014, it had become
18 apparent that the Ninth Circuit appellate decision was not likely to seriously impact these successive
19 action lawsuits, and Remington drafted DR140426 for the three (3) years of environmental damages
20 from 2011-2014.
21 837. As a retaliation to those events, Gans began a new dramatic series of unethical and
criminal activities during 2015. Those included directing Mathson and his other principal soldiers to
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fabricate evidentiary photographs, remove or cover up virtually all incriminating contaminated waste
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which were visible at the ground surface, destroy Remingtons property and generally obstruct
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justice, distract and injure Remington and essentially force him to give up many more of his precious
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golden years.
26 838. During the extended 2016 pre-trial hearing Gans focused mostly on refuting all of
27 Remingtons photographs, scientific tests and experts testimonial evidence with various
28 falsifications and mischaracterizations on several hundred material issues, which eventually took
more than three months to sort through. Additionally, Gans and Plotz knowingly miscited and
misconstrued the controlling Supreme Court law in these cases, and especially confused Judge
Reinholtsen over the sophisticated principles of collateral estoppel regarding exactly what specific
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facts, if any, were determined from a magistrates diffuse technical dismissal of the case, wherein
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with no environmental expert on Remington side of the case, it was not possible to meet any of the
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elements of any of the statutory violations. Clearly there, the magistrate dismissed Remingtons
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federal case with the intention of preserving all of his state causes of action for state court wherein he
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had at least four experts already properly discovered and fully admitted into the cases. Defendants
6 however managed to confuse that issue and therefore it is requested for adjudication by this court in
7 the environmental section of this complaint.
8 839. Despite Remingtons extensive surveillance video recordings of Mathsons evidence
9 spoliation, removal and cover-up with redwood needles and other organic matter; Remingtons
10 overwhelming evidentiary support for his activities from 1998-2006 which prevented his discovery
11 of any of defendants contamination; and, Remingtons thorough photographic documentation of that
entire period, nevertheless Gans prevailed in the SOL trial by coaching all of his trial witnesses to lie
12
and misrepresent the known, true facts from John Mathson to Mike Pulley. Serial, consistent perjury
13
among five (5) colluding witnesses on what was essentially a simple yes or no question is hard, if not
14
impossible to defeat without advanced knowledge of that perjury and previous depositions of all of
15
the perjurers, which Remington did not have in this case. He will have it in the federal case and will
16 therefore defeat it.
17 840. Although slightly off topic perhaps, during that 2016. It became clear that Gans has lost
18 all of his environmental experts support. Gans had intended to call Ferriman if not Gwinn in the
19 2016 SOL trial, however it has now become apparent that Ferrimans credibility has been to deeply
20 damaged for him to appear at all, or to swear to anything under oath and perjury. Gans wrote a false
21 script for them back in 2011, which has now been fully discredited by Remingtons experts, and that
explains why Gans had to abandon all of Blue Rocks expertise, to resort to the desperate use of a
22
new, undamaged and charismatic expert Hillyard, however he is not even admissible in the
23
outstanding 2008 case. It is highly informative, that when Gans decided he wanted to extort
24
Remington and make him afraid going into 2016 trials that defendants could destroy Hoyos and
25
Aveggios testing in the swamp area, Gans neglected to turn to his established environmental
26 experts that had been in the case for six years, and turned to some young unknown expert from
27 Portland, Oregon. The inferences from that act are obvious and will be fully illuminated shortly.
28 841. The RICO defendants conduct violates the Racketeering Influenced and Corrupt
Organization Act, 28 USC 1961, et seq., with predicate acts of extortion, exaction, bribery, mail
and wire fraud, suborning perjury, money laundering, obstruction of justice, serial witness tampering,
retaliations against Remingtons witnesses and family, improper hauling of hazardous materials, and
12
1
deprivations of Remingtons and his businesss rights under 42 USC 1983, among other
2
transgressions all fully disclosed in the RICO statement.
3
842. Additionally, the RICO defendants conduct violated numerous state, county, federal and
4
common-law environmental and the other cited statutes, over which this court may take
5
supplemental jurisdiction, because they all arise out of the same controversy. Said controversy has
6 become worse every year, deeper and now involves numerous additional criminal acts in the
7 perpetuation of its present cover-ups, and corrupt and unjust attempts to utterly destroy and crush
8 Remington and the Burl Tree. Said above violations and crimes resulted in the numerous claims
9 listed herein, and with particularity in the environmental portion of this lawsuit, and include without
10 limitation:
11 843. Multiple acts of specific types of fraud, as fully explained in the more detailed RICO
statement; Unjust enrichment versus restitutionary relief, whereas Remington may recover the
12
greater amount of the two; Intentional and tortious interference with Remingtons contract with
13
SHN by Nelson and Gans, as fully explained in said RICO statement; Trespass to real property and
14
also to business chattels; Continuing public and private NUISANCE; Civil conspiracy; Assault;
15
Extensive, material and felonious spoliation of evidence; State court perjury, which soon must be
16 followed-up consistently with federal discovery and trial perjuries; More than 75 felony
17 vandalisms, other misdemeanor vandalisms and documented destructions of property; Conspiratorial
18 fraudulent concealment; Fraudulent misrepresentation; Fraudulent collusion; Aiding and abetting;
19 Intentional trespass and vandalism employing specifically tamed and trained destructive animals who
20 were intelligently and systematically trained to destroy Remingtons rare gardens and terrorize his
21 wife and grandkids; SCORES of egregious, actionable attorney ethics violations, which seemed very
serious in themselves, for several years, until they extended into and became grossly overshadowed
22
by Gans multiple penal code violations; Multiple fraudulent business practices (B & PC 17,200, et
23
seq.); Prevented and destroyed the Burl Trees right to free and unhampered business conduct, due to
24
Gans Enterprises extortion and RICO schemes.
25
26 PARTIES AND RELEVANT NON-PARTIES
27 A. Plaintiff
28 844. Plaintiff Bruce Remington is the sole owner of the Burl Tree business which owns more
than 90% of the land, personal property, gardens, produce, building, inventory, contents, burlwood,
fixtures, supplies, water rights, scrap iron, machinery, mill equipment, tools, patents, artwork and all

13
1
other possible items at issue which are located at 832 Westgate Drive, Eureka, CA. Remington is a
2
person under the law, and the Burl Tree is a licensed California business, since about 1972.
3
845. Remington and the Burl Trees central offices, workshops and all inventory are located at
4
832 Westgate Dr., but Remingtons personal residence and the mailing address for the Burl Tree is:
5
5149 Blackberry Lane, Eureka, California 95503. Suzanne Remington, Remingtons wife, is a part
6 owner of the subject property, however she has been permanently terrorized and traumatized by
7 Gans, Mathson had their numerous serious crimes and now refuses to visit the property or have
8 anything to do with it, because it upsets her, especially the amount of time these lawsuits have
9 wasted. Likewise, Remingtons three (3) granddaughters have been made afraid during August 2015
10 and 2016 by various wild and potentially vicious large bear and box maths and has forced into
11 Remingtons property where they essentially act as if they own the place and wait for little prey to
wander amongst the dense gardens, to startle them, which causes dangerous and unpredictable
12
behavior. Generally, the kids refuse to visit anymore despite the plethora of toys, and when they last
13
did visit, they ran in a panic from the gate to the house so they wouldnt get eaten by a bear or
14
speared by a deers horn, both of which are running rampant across the property after the SOL trial.
15
846. Remington and the Burl Tree are essentially one unit located at 832 Westgate and
16 henceforth are usually abbreviated as Remington, only.
17 847. The Burl Tree has been a highly successful redwood burl products logging,
18 manufacturing and retailing operation established in about 1970, and which still continues operations
19 in 2017 at a reduced scale. It was incorporated around 1982, and unincorporated during the 1990s.
20 The Burl Tree has always been the pacesetter and leader in the burl industry, and until the early
21 2000s always had the most sophisticated oral milling machinery and equipment, the best retail store
locations, delete professional salesman and numerous invaluable exclusive burl logging contracts
22
with all of the large timber companies on the north coast from 1975 until about 1990. Remington also
23
had enormous contracts with Cal-trans and their contractors; the Pelican Bay prison site grubbing
24
contractors; and the Redwood National Park bypass clearing and rubbing contractors.
25
848. The latter group of three contracts provided the Burl Tree with an essentially unlimited
26 quantity of redwood stumps and burls that was so lucrative, that Remington voluntarily gave up his
27 paid exclusive logging contracts with all of the major local area timber companies, during the 1970s
28 and 80s, because he had all of the low-priced burl that he could sell, especially from the Cal-Trans
and Pelican Bay sites. Even today, Remington still has nearly $1 million of Burrell slabs remaining
from the above burl logging activities from 25 years ago.

14
1
849. The Burl Tree and its major subsidiary called Paul Bunyans Burl stores had an average
2
of six retail stores, from Myers Flatt to Crescent city, throughout the late 1970s and until the early
3
1990s; generally had two sawmills, mostly in Eureka and Crescent city and employed up to about 30
4
full- time workers at a time, and as always had novel, patentable state of the art three-phase electric
5
and hydraulic burl chain and band-sawing and milling sawmills, all personally developed, built and
6 led by Remington who was for 90% of the relevant time period the CEO, chief Burl logger, chief
7 logging truck driver, head Burl Sawyer and millwright; sales manager and always among the top
8 salesman among a group of well-trained, brilliantly recruited, star professional salesman, before they
9 even came on board to learn to sell burl. Remingtons leadership, sales abilities and innovative
10 technological skills and creative concepts were important, plus he always had excellent store and at
11 least one sawmill manager concurrently.
850. Remington eventually consolidated his operations into the Burl Tree location at 3527
12
South Broadway St. in downtown Eureka and as the fad -like burl slab finished and unfinished table
13
sales declined substantially, Remington gradually became a one-man operation focused primarily on
14
turning blocks and related specialty burl wood products, which involved approximately 30 species of
15
California varieties of burlwoods. In 1998, Remington sold his very valuable real estate in Eureka to
16 Flying J gas station which had severely contaminated it, and move to this present a 32 Westgate Dr.
17 location still conducts an active interstate mail-order business and maintains an approximately $1
18 million burl inventory, both inside and out which features giant 6-inch thick slabs from Remingtons
19 Crescent City Pelican Bay milling operation, plus a huge collection of the rarest redwood lace burl
20 ever cut in California (or anywhere else), housed inside an approximately 6000 ft. of display space
21 with over 3000 linear feet of super-strong, wide, dry and heated shelving areas.
851. The Remingtons, the Burl Tree and their business property have been injured in the 20+
22
major ways described herein, and therefore virtually all of the complained of injuries are to an
23
interstate business. Defendants, Gans, Mathson et al caused 100% of the complained of injuries,
24
directly and without any intervening factors.
25
B. RICO defendants [See GANS RICO enterprise organizational chart-2017.]
26 852. The RICO defendants listed on pages 1-2 above, are all of the individuals presently
27 believed to comprise the leadership, nucleus and chief operating managers, and principal corrupt
28 soldiers of the alleged criminal enterprise. The next two years of intensive discovery, however, are
expected to add more RICO defendants, and likely not subtract any.
853. Led by their apparently well-liked, semi-charismatic, and NERD leader Gans, said
RICO defendants have conspired to engage in a pattern of racketeering activity. That means that each
15
1
named defendant has committed at least several criminal acts as part of their scheme to defraud, steal
2
from, extort and/or damage Remington and the Burl Tree. Each primary RICO defendant has
3
participated in the operation and/or management of the criminal enterprise to advance its objectives
4
and to facilitate the achievement of its goals.
5
854. Defendant Russell Gans (Gans) is currently and still the lead attorney representing the
6 Mathson/RAO pollution defendants and has been involved here since about 2006. John Mathson
7 personally told Remington definitively, matter-of-factly and without any equivocation on December
8 27, 2007 that: this (pollution) matter is out of my hands now, and we found out later that meant it
9 was 100% in the hands of, and under the absolute control of Gans, just as a ventriloquist controls his
10 dummy, or a marionettest absolutely controls 100% of his puppets movements and speech. If the
11 ventriloquist LIES, while keeping his mouth motionless, such that the words appear to come from
the dummy, then the dummy lies2, and in this case that would be John Mathson. Here, Mathson
12
now lies with words written for him by Gans, which he has which he has essentially memorized.
13
855. Gans will soon be deposed about all of this and especially about the minute details, very
14
specific issues and exactly what he taught his witnesses to say in such perfect unison ritual late to his
15
admitted coaching of all of his August 2016 SOL trial witnesses, to each individual 2016 and her
16 during Voir Dire. It will be interesting to learn what testimony was written, planted by and coached
17 by Gans, and which was spontaneous, if any. Will also be interesting to learn why Gans went to such
18 length to apologize to each individual juror and essentially got their permission and approval for his
19 writing the false scripts for all of his criminally conspiring RICO witnesses.
20 856. It was Gans, not Mathson who put together the enterprises large, aggressive professional
21 legal and expert team sworn to battle Remington to the death if necessary, while unconditionally
and hopefully destroying and/or were ruining Remington and the Burl Tree in the process. In his
22
deposition, Gans will likely claim that he gets his motivation, determination and anger from John and
23
Joy Mathson, however they are old and tired and not providing much if any direction, anger or
24
emotional leadership in 2016.
25
857. Increasingly, in 2016-17, it is exclusively Gans, the ventriloquist and marionettest who
26 masterminds all of the litigation and enterprise activities. He puts his younger and utterly
27 unscrupulous energy into the Mathsons sham defenses, while literally writing defaults and
28 perjurious scripts for his large group of marionettes and life -sized dummies, not one of which is
2. Ventriloquist acts were very popular and widespread 60-250 years ago, and although originating
3000 years ago, ventriloquist acts are now dying-out rapidly. Marionettes also date back at least 3000
years to Greece and according to Wikipedia, also date back 6000 years to Egypt. Gans puppetry works
the same way, and to date has applied very directly to virtually all of his trial witnesses.
16
1
believed to be a neutral, independent, honest or actual real objective person. Remington has observed
2
those specific corrupt dynamics everywhere that Gans goes, for example in Gans pluses to experts
3
property investigations of the Burl Tree land, he leads his experts around to see what he wants them
4
to see. The types of contamination that he is arguing do not exist on Remingtons land, he
5
deliberately prevents his experts from taking the paths where they would see that contamination, so
6 that at trial they can plausibly deny that no contamination exists. When Remington says, such as on
7 July 6, 2011, this is the path where we took numerous contaminated samples from a variety of
8 testing sites, Gans inexplicably and without comment takes a different path that avoids all
9 contamination. Simply put, their experts argument can now plausibly be that: they visited the
10 property repeatedly, they saw no contamination, and therefore it does not exist. All Gans experts
11 and percipient witnesses are similarly 100% controlled and scripted by Gans and hence all are
entirely vulnerable on cross-examination or at depositions to a frontal attack regarding the above and
12
any inevitable gross and material inconsistencies going forward. Gans is smart, clever and wily, but
13
his witnesses are much less corrupt, vicious, demonic or motivated and their collusive, consistent
14
perjurious chains have numerous weak links which we intend to attack and exploit.
15
858. Concisely put, Gans put together his crack enterprise team of experts, RAO
16 associated criminals, local Mathson friends who dislike or are envious of Remington, ETC; and, then
17 Gans personally trained them, thoroughly coached them to a totally improper extent, which gravely
18 crossed the line of altering and falsifying witnesses testimony, and then Gans further micro-
19 managed all of the enterprises related day-to-day scheduling, additional coaching sessions and
20 changes in the script which needed to be learned and memorized by all of the conspiratorial
21 witnesses on a given topic. See pages 10-94 and also pages 685-722, approximately, of
Remingtons RICO statement for more very specific details of Gans misconduct, and
22
regarding some of the predicate acts he is accused of committing, with more acts of mail fraud
23
discovered in the files every week or two.
24
859. Gans resides in Eureka, California, at a well-guarded, secret and protected location,
25
continues to hold a California law license, and has been an aspiring partner in Mitchell, Brisso,
26 Delaney and Vrieze for his entire 20-year career now. Gans attended St. Marys College and the
27 University of Oregon law school. Exercise of jurisdiction over Gans is thus reasonable and proper in
28 this district for the reasons set forth below under the category of Personal Jurisdiction.
860. Defendant Ryan Plotz is Gans young, inexperienced legal apprentice, just recently
out of San Jose State University and the Davis law school. Two years of close observations and
numerous written document exchanges prove that Plotz is very nave, learning to be a crooked
17
1
lawyer from a master at his craft, and also is totally under Gans corrupt document editing and final
2
proof-reading control, and rarely sends-out a written mail or wire (fraud) word that is not first edited
3
for proper angry, negative and racketeering spin and tone, by Gans. After all of these years, it is
4
quite easy to recognize which paragraphs or sentences in a document was written by or heavily
5
edited by Gans. Plotz never expresses any opinions of his own at oral hearings, sat like an
6 obedient dog beside Gans at approximately 75 consecutive hearings in 2016 alone, very rarely
7 speaking at all, but when he does speak it is only to explain some narrow area of the law which he
8 has partially researched, clearly never fully mastered, and it is always presented in an improper one-
9 sided, slanted entirely self-servingly manner, with most if not all of a Supreme Court cases teaching
10 which is favorable to Remingtons position, invariably omitted as if it did not exist. When Remington
11 calls attention to that fact, both Plotz and Gans just sit there without comment as though Remington
were crazy, and again the inference is that if they do not object to or refute Remingtons statements
12
then they must not be important enough to comment on. Judge Reinholtsen who almost never has the
13
time to read the source documents obviously leans heavily on his officers of the court for legal
14
guidance through the California case precedent law. That has been a big mistake, has led to many
15
errors by the court, which should easily be overturned on appeal. Similar to the above, and as
16 discussed in more detail below, exercise of jurisdiction over Ryan Plotzs reasonable, proper and just
17 as set forth below under personal jurisdiction.
18 861. Defendant Paul A. Brisso is another counsel of record in the various Remington v.
19 Mathson lawsuits and also in the former, retaliatory extortive sham lawsuit called Mathson v.
20 Remington which defendants dropped in early 2016 what it looked like it might actually go to trial, is
21 explained in detail in the RICO statement. Although deferring to Gans with respect to most operating
enterprise tactical, personnel and corrupt witness tampering and obstruction of justice trial decisions,
22
Brisso still plays a major and a very important role here, like a Chairman of the Board or Emeritus
23
advisor to the organization. Brisso also has deep influence within all departments of county
24
government, from the courts through the Health Department bureaucracies, enjoys wielding that
25
power as necessary to benefit Gans and his clients, as explained in detail in the RICO Statement.
26 Especially in 2008-2011, Brisso appeared at a lot of our state and federal case hearings and wrote
27 several hundred pages of largely, but not entirely, mischaracterized, false or otherwise misleading
28 motion documents corruptly supporting state case special motion attorney fees and falsely and
inconsistently arguing that Remingtons federal case should be dismissed because the state case was
earlier andBecause state issues predominated, which estopped positions were naturally improperly

18
1
reversed a few years later. Brisso is a proud HSU graduate and, a McGeorge law school graduate3,
2
and as above and below (see Personal jurisdiction section below), jurisdiction over Paul Brissos
3
reasonable and proper in this district because he resides in Eureka California.
4
862. Defendant Julie McBride, is Gans long-time personal secretary who has rapidly
5
advanced over many years to be his chief confidant, researcher, executive secretary and perhaps
6 much more. She is discussed further at pages 151-153 of Remingtons RICO statement, and as with
7 the above (and below, under Personal Jurisdiction), jurisdiction over her is reasonable and proper
8 in this district because she resides in Eureka, California. Discovery involving her knowledge and
9 involvement in this criminal racketeering enterprise is expected to be extremely revealing and
10 important.
11 863. Defendant Nicholas Kloeppel, is another Mitchell firm member, apparently of a
calmer, slower, LESS-BUSY or lower echelon, that fills-in at a lot of hearings for other attorneys
12
who are on vacation, and always seems to have time to fill-in for Gans, Brisso or Plotz in these cases,
13
as needed. [See Remingtons RICO statement at pages 159-62]
14
864. Kloeppel, although somewhat of a borderline figure here, is in January 2017 now
15
believed to be an active, knowledgeable and knowingly corrupt RICO enterprise member, partly
16
because he probably knows exactly what Gans is doing, KNOWS Gans is corrupt and unethical at
17 his innermost core, has actually aided and abetted Gans in doing many of his nefarious acts by
18 drafting at least several false special interrogatories in this case, and Kloeppel also must know how
19 Gans is deceitfully and corruptly conducting this complex racketeering enterprise.
20 865. Kloeppel has a rather ordinary, dull and innocent-seeming demeanor, however his name
21 has appeared in these case documents with some regularity since at least 2011, and If Kloppell really
does not know what Gans is presently doing, he should know, should have known, and he obviously
22
does know now after being served as a RICO defendant. If Remington was able to figure this out
23
from 6 miles away, Kloeppel could have figured it out more easily from 30 feet away. Kloeppel may
24
be a little slow, but he is not stupid, he has worked side-by-side with Gans for many years and is
25
believed to know about as much about this RICO enterprise as anyone not named Gans.
26
866. Kloeppel works there, he knows Gans very well, he socializes with Gans and probably
27 eats lunch with him several times a week. Therefore, he knows about Gans lack of ethics, laziness,
28
3. Four of the worst ABA ranked law schools in the US are in California. McGeorge escaped that
list and is only in the bottom 2.7% overall, and ranked 146 of 150 in the United States by Biz Journal.
Further according to Remingtons five minutes of research, McGeorge is expensive, apparently
located in the Sacramento area, only 73% of its graduates are employed and most shockingly only
64% ever pass the bar exam which is the worst of any known law school, etc.
19
1
false logic and overall mental and intellectual inability to function at the highest level of Californias
2
advocacy system. As an attorney with an office a few feet from Gans he is held to a higher standard
3
than most, and he will certainly be investigated for complicity and what he does know about this
4
racketeering enterprise or, as above, should have known, at a minimum. Since Remington is a
5
foremost scholar on Gans advocacy methods and records, therefore understands Gans very well,
6 and knows about all of his illicit criminal activity, pre-criminal activity and extremely unethical
7 behavior before that since October 2007, then it follows that it would be more than logical to assume
8 that Kloeppel also knows at least that much, by now. Maybe Kloeppel can convince civil or criminal
9 investigatory authorities that he is just dumb, naive, a bit slow, overly trusting and/or totally
10 innocent, however after a thorough analysis and consideration of specific deceptive and false
11 documents signed by Kloeppel since 2011, it seems obvious to Remington that Kloeppel should now
have to come forward with what he DOES know and exonerate himself, because right now he
12
appears to be guilty before he is proven innocent. He is an officer of the court, not Remington and
13
when discovery or investigations begin here, a non-Eureka lawyer might think that he should be
14
held to the high ethical standards envisioned in the California ethics laws including, without
15
limitation, CCP 128.7.
16 A. Similar to those above and below (see Personal Jurisdiction section below), jurisdiction
17 over Kloeppel is reasonable and proper in this district because he resides in Eureka California.
18 867. Defendant the law offices of Mitchell, Brisso, Delaney and Vrieze is believed to be a
19 California legal partnership, which according to their website (still) proudly serves the Northern
20 California community and ironically has a mission to adhere to the highest standards of
21 integrity and professional ethics to clients.. Apparently that was written long before the current
bunch was involved in a RICO enterprise, and eventually some of that bogus self-serving crap may
22
have to be edited.
23
868. In that regard, the founders of this firm in the 1940s, some of which Remington believes
24
he had contact with back in the early 1980s, were clearly a different much more ETHICAL breed
25
and they would not be pleased at all about having this enterprise centered in the inter-sanctums of
26 their modest offices at 814 7th St., PO drawer 1008, Eureka, CA 95502. At age 75, apparently
27 Remington is now of that former breed, and a strong built-in moral compass is kind of hard to
28 eliminate, however it is safe to say that the modern Mitchell firm has managed to overcome that
obstacle (of renouncing and then stomping on good old-fashioned ethics) very nicely.
869. Similarly, the Mitchell firm (above) is considered to be a citizen of this California
northern district and jurisdiction is therefore reasonable and proper, as further set forth a few pages
20
1
below under Personal Jurisdiction. Because probably 30-40% of the said Mitchell firm is likely
2
unaware of Gans corruption or the details of the Remington cases, it would appear to be up to
3
them, NOT Remington to determine the individual culpability of each member of the firm, when
4
fines or other sentences are ultimately levied.
5
870. Linda Lawrence is still believed to be a Western regional claims manager for Allied
6 Casualty and Insurance located at 1100 Locust St. Des Moines, Iowa, 50391. Her office is
7 believed to be located at or in the vicinity of 2251 Harvard St., Suite 200, Sacramento, CA 95815,
8 and she has handled the Gans/Mitchell/Mathson account for many years in the 2008-2012 range and
9 presumably she still does. If not, that will be discovered shortly, and whoever the new comparable
10 account executive should perhaps be substituted for Lawrence, although more likely, BOTH are
11 probably knowledgeable, culpable and corruptly guilty of the federal predicate acts alleged in the
RICO statement.
12
871. Lawrence, and/or her assistants, counterparts or subsequent replacement has paid for
13
every illicit scheme that Gans conjures up, and when Remington met her personally, she was young,
14
mildly attractive, smart, sophisticated, cocky and obviously personally motivated to save her
15
employer money at all costs, in order to accomplish their objectives of crushing the arrogant
16 Remington. Remington met her in about 2010, and she was very easy to size-up. Actually,
17 remembering the five-minute interaction she had with Remington in 2010 was where the idea of
18 CRUSHING Remington like a bug originated. She was entirely dismissive then, and obviously
19 assumed Remington had no chance to survive against their brilliant defense backed with infinite
20 financial resources. Maybe she was right, but maybe well see.
21 872. Ms. Lawrence is a smart and sophisticated manager who knows, should know, and also
should have known all along that Gans is as corrupt and unlawful as a $13 bill. However,
22
considerable written and then oral discovery will be needed to determine if she is a criminal herself
23
or just another innocent, too busy, naive, overly trusting of the great Gans, merely a pretty face
24
and well-meaning, very ambitious insurance executive, just paying all the bills submitted
25
automatically because she has absolute trust in Gans and the Mitchell firms ethics and integrity, so
26 does not give their analysts and criminal requests for reimbursements close scrutiny or any
27 understanding. Probably the latter will be her defensive posture, but will that fly credibly with
28 criminal investigators? After eight years of associations, Remington knows that she is no dumb
bimbo and in all probability is the overall corrupt mastermind behind their determined goal to
crush Remington indiscriminately, no matter what it takes. Remingtons impression of her in 2010
was that ethics, honesty and/or justice were not on her radar screen, nor much of a concern, if any.
21
1
873. As discussed in the RICO statement, she reminds Remington somewhat of Steven
2
Spielbergs secretary Bonnie Curtis who was a nice, kind, not unusual California high-energy type
3
woman, with a pretty face probably, but who actually was the brains of the Amblin Entertainment
4
and Spielberg operation, on many high-powered and significant issues. Eventually, within a few
5
years of Remingtons interactions with her she went on to produce her own hundred million dollar
6 budget films, which kind of inferred that she was never just a clerk-typist type from the beginning.
7 Lawrence resides in California and hence jurisdiction over her personally is reasonable and
8 proper as further specified below under the section entitled Personal Jurisdiction.
9 874. RAO Construction Company, Inc, has offices located at 5503 Walnut Dr. Cutten,
10 CA 95503, and owner Rich Olson also is believed to live in that immediate area, as part of a
11 vast residential complex he built around 2000.
875. Whether RAO and Olson are incorporated or not today is unknown, but they may well
12
have been in 1998 when these disputes originated, and inferentially, based on Klucks occasional
13
sporadic communications, they are still today. Immediate discovery will probe the present-day
14
structure of Olsons concrete and general construction company, and by the time of the FAC in this
15
case we will sue them properly, if there are any errors in their present designation. RAOs entity
16 number is C0725703. See further details about Olson and RAO around page 110 of Remingtons
17 RICO statement, and see also the next section below.
18 876. RAO was believed to be the acting entity in many of the crimes and transgressions alleged
19 herein, but whether it is actually separate in any significant legal respect from Rich Olson is
20 presently unknown, so for the time being we name both of them and sue them jointly, herein.
21 A. RAO, corp is considered to be a citizen of this California northern district and
jurisdiction over it, as well as over Olson and Skillings to follow, is therefore reasonable and proper
22
as further set forth a few pages below under Personal Jurisdiction.
23
877. Rich Olson, Owner of RAO Construction Company, described above.
24
Olson, along with his early partner John Mathson almost single-handedly created this mess
25
around 1998, which is just being fully discovered today, and has not yet been resolved at all.
26 878. Olson created an astoundingly large, flagrant industrial-sized illegal hazardous residential
27 waste dump, entirely for unlawful and unjust profits. Originally they dumped it on Massons
28 property but quickly there was so much of the hazardous debris which were too nasty for the
Mathsons to have under their lawns for their grandkids to play on top of, so early on Skillings began
meticulously sorting every adverse object with a huge loader, and put all of the worst toxins, which

22
1
today is provable by inspection, onto Remingtons property and buried them there, as per RICO
2
Statement, which obviously is fully incorporated herein and in all other paragraphs as required.
3
879. Olson resides in this California district and appears to have done so all of his life with no
4
Known plans to go anywhere else soon. He created and built a gigantic residential neighborhood of
5
fancy houses along Walnut Dr. with his illicit profits from his 1990s unlawful residential dumps,
6 which includes the above 5503 Walnut Dr. shop address, and he is believed to live within a few
7 hundred feet of that address in one of the six to ten recently built houses there, apparently mostly
8 owned by his extended family. Hence jurisdiction over Olson personally is reasonable and proper, as
9 further specified below under the section entitled Personal Jurisdiction.
10 880. Defendant Kyle Skillings about age 45-6 in 2017, has worked for RAO construction for
11 about 25 years and presently resides at 2401 Circle, Briarwood, Eureka, CA 95503-7510, See also
Remingtons RICO statement pages 163-171.
12
881.As discussed throughout these documents, Skillings is Olsons and Gans primary criminal
13
enforcer today, potentially the Luca Brassi (The Godfather films primary murderer and purveyor of
14
torture or other extreme violence) of this enterprise, although day-to-day John Mathson and his local
15
neighborhood Westgate gang are the main criminals, enforcers and lower-level extorter, working
16 directly under Gans leadership. Mathson, Kishpaugh, Evans, Costa, et al always operate
17 clandestinely, cowardly and commit their frequent criminal vandalistic, destructive and thieving acts
18 while they know Remington is asleep or away from the property; although, Remingtons cameras
19 never sleep these days, which fact will already eventually lead to the criminal conviction of John
20 Mathson.
21 882. Skillings is a mean-looking, physically tough, 250-pound linebacker type, serious and
heavy-weight extorter, previous violent offender and potentially very violent criminal. Bob Figas
22
is about as tough a logging boss and equipment operator as you could find in Humboldt County and
23
manages a crew of more than 100 men off in the remote eastern Trinity Alps mountains, for months
24
at a time. Men that do that type of work are about as tough as you can find in Humboldt County
25
these days.
26 883. All you really need to know about Skillings is that he has several times seriously scared,
27 intimidated, blackmailed and extorted Bob Figas to protect his, RAOs and Mathsons 1998-2000+
28 buried criminal secrets, and so far he has brilliantly succeeded. Skillings was extensively and well-
coached by Gans prior to the August 2016 SOL trial where he committed extensive perjury as
described in the RICO statement passages cited. That perjury was inexplicably allowed to stand by
Judge Reinholtsen in said SOL trial, but can be refuted in the federal trial now that we know what
23
1
his lies are, and what extensive conclusive 2003 photographic evidence we have that refutes said
2
perjury 100%. Skillings has committed federal predicate acts of extortion already, but has not yet
3
perjured himself or otherwise colluded to obstruct justice in this federal case, however that will be
4
calm a necessity immediately when he responds to Remingtons first written discovery request. By
5
the time of his deposition, Skillings for example will probably have violated at least a dozen federal
6 laws just within 2017 alone. Since Skillings resides in California and likely always has, therefore,
7 jurisdiction over him here is reasonable and proper as further described below under the section
8 called Personal Jurisdiction.
9 884. Defendant John Mathson, approximately age 70 is the secondary villain in the story,
10 FAR-BELOW Gans, but, at least as of March 1, 2017, far-above all of the other named defendants
11 in both portions of this lawsuit. Mathson has become a bitter, obsessed, constantly lurking evil
presence, exactly like Gollum in the Tolkien Trilogy, constantly watching Remington, peering and
12
peeping out of the shadows, from behind huge trees or through his multiple secret doors built into
13
his fence, and he has become much bolder, more brazen and much more desperate each year. What
14
he will do in 2017 is now of considerable dread and trepidation, even to Bruce Remington. As
15
to the rest of Remingtons closest family, Gans enterprise has already WON there and all of them
16 are essentially too afraid, uneasy or simply too terrified to get any enjoyment out of Remingtons
17 massive rose gardens, extensive toy inventory and endless paths to play on, so they dont come over.
18 Remington has most likely largest rose gardens north of Southern California, but thats not enough
19 to get his family over here. Gans has won! His extortion has succeeded in causing great fear and all
20 of Remingtons family, such that only Bruce Remington himself still has the courage to show-up at
21 832 Westgate Dr.
885. Mathson now as a matter of course, calmly and solemnly lies convincingly under oath,
22
which makes him by definition pathologically excellent liar. He is always watching Remingtons
23
property, lurking-around, occasionally taking surprise flash photographs in the semi-darkness and is
24
always watching for something prejudicial to attempt to use against Remington at a trial. In that
25
regard, Mathson continuously follows Remington around the property, endlessly and without
26 apparent purpose, somewhat reminiscent of a said-above pathological Gollum, gone bad. In August
27 2016, Mathson slipped-up and entirely contradicted his multiple lies, with a brief lapse into the
28 truth, all wall he was under oath, but Remington was unable to make it stick significantly with the
jury, the first time around. However, Remington expects to have many other opportunities to
conclusively develop and to prove the John Mathson is a serial vandal, burglar, local gang-leader,
drug dealer, massive perjurer and career criminal, who belongs in Pelican Bay prison right now.
24
1
886. Beyond the scope in this condensed document, Mathson is also a kleptomaniac with a
2
yard full of equipment, proudly stolen from his longtime former employer Samoa pulp mill.
3
Mathson is Remingtons northern neighbor who arguably single-handedly caused this entire
4
problem in dispute in 1998 with some assistance from Olson, Skillings and RAO construction.
5
887. Mathson has lived in Humboldt County all of his life still resides here at 778 Westgate
6 Dr., immediately north of Remington with whom we share a 330-foot long property boundary.
7 Hence, jurisdiction over him here is reasonable and proper as further described below under the
8 Personal Jurisdiction Section. [See Volume III, photo exhibits #54-55 for evidence removal]
9 888. RICO Defendant Jeff Nelson is the grisly old, nasty, generally-disliked CEO and one-
10 time civil engineer that leads SHN consulting, which is located at 812 West Wabash Ave., Eureka,
11 CA 95501 2138. Nelson directly employed and worked with Remingtons two foremost
environmental engineering consultants from 2009-2012. Then under enterprise duress, beginning in
12
2012, he sabotaged Remingtons entire litigation strategy by maliciously and deliberately breaching
13
our valid long-time contract by removing Mike Foget from Remingtons litigation support team, after
14
John Aveggios death. However, there was no direct connection between Aveggios death and Fogets
15
illegal and corrupt removal from Remingtons environmental trial expert team, because Foget was
16 employed here and paid by Remington for about two years before Nelson abruptly, unexpectedly and
17 summarily removed Foget from Remingtons case without any provocation or reason provided.
18 Clearly, as developed above and in the RICO statement, all incorporated by reference here, Gans and
19 his enterprise interceded and very prejudicially destroyed Remingtons entire environmental
20 litigation support team, almost costing him his entire environmental case. Nelson is an individual
21 residing at an unknown, secret location in Eureka, California, with the apparent intention of
remaining here indefinitely, and hence jurisdiction over him is reasonable and proper, as further
22
described in the Personal Jurisdiction section.
23
MAJOR NON-PARTY CO-CONSPIRATORS
24
889. Certain other non-party individuals, business entities and employees thereof played roles,
25
directly or indirectly, in Gans scheme to defraud, extort, steal from and destroy Remington, his
26 family and the Burl Tree. Foremost among those individuals and business entities, as based on the
27 enterprises cognizable operations over the last four years, but before any actual federal discovery
28 here, include without limitation the following4:
4. See number three (#3) of Remingtons RICO statement, dated January 2017 for a more complete
listing of so-far known additional wrongdoers, including various salient details about their
involvement, alleged criminal activity and the relationship to Remington and the Burl Trees damages.
See also footnotes 35-36 in the main environmental complaint for identification of all defendants.
25
1
890. Morgan Randall is a California resident and believed to be a present employee at
2
Peirsons Hardware Company. Randall once rented a house across the street from Remington in
3
approximately the early 1990s; Wherein, he vandalized Remingtons standing timber, stole firewood,
4
violated various neighborly promises and agreements that he made to Remington, while Remington
5
was away from the sites, and generally made himself an unwelcome pest on the street, as fully
6 explained in the RICO statement and complaints.
7 891. It now appears, that Mathson was his friend, even way back then, and Gans apparently
8 found him while looking for all of Mathsons friends who could provide any kind of additional false
9 testimony about any aspect of these lawsuits. Although Gans has not disclosed any aspect of what he
10 will testify about and also blocked Remingtons reasonable deposition request in May 2016,
11 Remington has inferred from discussions about him that he will provide additional false testimony, in
conjunction with Mathsons corrupt Westgate gang discussed herein, about his perception of
12
irrelevant conditions on Remingtons land hundreds of feet away from anything with any possible
13
material cause or effect on these lawsuits.
14
892. Additionally, Randall may have misinformation on the six-inch perforated or solid black
15
corrugated drainpipe which Gans apparently has bribed him to testify incompletely and/or falsely
16 about. Whether Randall may have sold Mathson, Olson or anyone 6-inch diameter perforated pipe in
17 1998 or any year has absolutely no scientific effect on the fact that the relevant and very important
18 pipe at issue, that is plainly visible in the ground today is solid by inspection. The significance of
19 this twin pipes issue and why Gans has written false and perjurious scripts for Mathson, Randall, all
20 of his environmental experts plus himself has been fully explained in the environmental complaint
21 and also in the RICO statement. There is no more important scientific, ethical or factual issue in
these cases than the verifiable fact visible in the ground at any time, that said twin pipes are solid and
22
not perforated. Hence they do not serve the purpose which Gans and his experts need and have sworn
23
to. Remington has a lot more to say on this issue, but will save it for Randalls, and others, written
24
discovery, depositions or cross-examinations under oath, where severe obstruction, witness
25
tampering and related lying under oath federal laws will be instantly violated during federal
26 discovery proceedings if any of the RICO enterprise members attempt to be consistent with their
27 false state testimony, as they now must be. Consequently, a federal prison term should now be the
28 price of following Gans perjury instructions and coaching on many of these issues involving
Randall, the twin pipes as well as several dozen related issues.
893. Randall was reputed by various Wilber sources and others to have been a prominent
member of Mathsons notorious, highly obnoxious, offensive and public nuisance-causing alcohol
26
1
and drug ring in the very early 1990s, which later morphed into and involved the MD Tree
2
Services owners methamphetamine ring described elsewhere. M.D rented a house directly across
3
from the Mathsons, and 3-4 houses down from Randall, for several years around and after 2000 and
4
caused many problems locally.
5
894. Defendants John and Mickee Kishpaugh have been named here previously, in October-
6 November drafts of this RICO complaint, but then were reasonably, properly and justly removed
7 because the only federal crimes we can prove so far involve state perjury, so we will firm-that-up in
8 federal discovery, easily convert it and their other crimes into a federal predicate act and then
9 undoubtably list them in the RICO FAC. Jon Kishpaugh remains as an environmental defendant
10 based on his environmental contamination and related activities described in the RICO statement.
11 The Kishpaughs are very close, long-time friends of the defendant Mathsons, who are willing to
commit perjury, and literally by actual proofs, say or do anything to support that friendship. They
12
have lied under oath already and previously lied to Remington about their extensive pollution
13
activities and dumping on his property prior to about 2003. We will develop their false narrative and
14
perjurious story about Remington and these properties during their federal deposition, or at the next
15
jury trial in any forum in such a manner that federal predicate acts will be violated next time.
16 Whether Mickee Kishpaugh intends to backup and support her husbands extensive and silly state
17 multiple trial perjuries remains to be seen, but she will soon have an opportunity to either tell the
18 truth or to become deeply implicated in the RICO conspiracy, where today she is not even an
19 ancillary enterprise member. See RICO statement for details about Mickees observed clandestine
20 guilty flights at twilight, and inferred thefts of something from the neighborhood that she was guiltily
21 and hurriedly carrying into her house in a large black plastic bag, which will be related to all of this
interrogation at the proper time.
22
895. Both Kishpaughs are desperately poor, need money in the worst way and will testify, for
23
money, to anything that Gans requests, as they did in August 2016, see RICO statement for additional
24
details, at 3D. Perjury means nothing to Jon, especially, and he has proved that over the years to
25
Remington at 5-6 year intervals. See Rico Statement 221-226/
26 896. Next time we examine Kishpaugh we will set the foundation to prove that he was one of
27 the major, long-time contaminators of Remingtons ravine and also Remington Creek, lied about that
28 and all of the other related facts in August 2016, including that he saw Remington not once but
TWICE talking to Mathson on his land in 1998, at least five (5) years before Remington went
anywhere near Mathsons yard in that manner sworn to. Next time Remington will have several more
years of sworn discovery to argue and prove that point with real evidence, not Kishpaughs BS, little
27
1
nervous laughs and big lies.
2
897. Next time, Remington faces Kishpaugh he will be facing federal criminal charges and
3
federal prison time if he attempts to repeat his false state trial in federal discovery, or trials, and
4
therefore he is expected to be more circumspect, less certain and a lot more truthful next time, and he
5
would also appear to be a likely candidate to reverse position and go straight with the DA in
6 Eureka, when he is imminently investigated. Potentially he or his wife could exonerate him, or both
7 of them, before they bury themselves in really serious imprisonable perjury. Is Mickee really going to
8 attempt to back-up ALL of Jons illogical and ridiculous (provable) lies and state perjury and also
9 subject herself to possible imprisonment if Gans entire house of cards or dominoes suddenly
10 collapses, as expected, imminent, and sooner rather than later?
11 898. Personally, Remington hopes they do so, and that they do not hopelessly dig their hole
deeper, and bury themselves further. The Kishpaughs are not bad people really, with their enviable
12
very close friendship with their wonderful friends the Mathsons, which is very touching.
13
Previously in 2016 they have both proven their dedicated willingness to do anything or say
14
anything to help Gans enterprise, especially if they can also kill two birds with one stone and
15
absolutely screw and preferably destroy their long-time hated enemy Remington. Their enmity was
16 simply caused by Remingtons eventual refusal to let them turn his Westgate property at the source of
17 Remington Creek into a toxic waste dump, because the Kishpaughs were too lazy and tight to
18 dump their trash and waste into the county disposal system. Remington merely refused to let them
19 dump their debris on his property and contaminate his Creek forever, after they had done it for route
20 15-years without his direct knowledge or permission, and apparently believed that it was their God-
21 given, estopped-right by some sort of easement to continue those illegal dumping acts forever, just
so they could avoid paying for an extra garbage can every couple of weeks. Kishpaugh lied about all
22
that in August 2016, and if he persists along that perjurious false Gans track with that total lying
23
BS in the federal case, he is going to face various witnesses which will eventually prove to the jury
24
that he lied under oath in a federal proceeding.
25
899. Although Remington did not really ever notice the rather inauspicious Kishpaughs
26 operation and yard, except for the neighborhood nuisance they caused for over 20 years, with all the
27 noisy old vehicles they continuously worked-on in their driveway, it is believed they moved here
28 about 22 years ago from out of the area, but are presumably California residents. Although their
house has been foreclosed for nonpayment and they owe about $65,000 on it, the fact that they are
still occupying it today infers that they are once again paying rent to someone, and will now probably
remain here indefinitely. As discussed above at number 893, the Kishpaughs are both believed to be
28
1
part of Mathsons and MDs old alcohol and drug ring, although Mathson claimed under oath that he
2
stopped drinking several years ago, but can you believe a psychopathic liar on that? Said
3
Kishpaughs also were a long time public nuisance when they had a highly obnoxious, amateur
4
country music band, with noisy, drunken, live-amplified instrument playing and bad singing at late
5
night hours, that seriously disturbed the neighborhood virtually every night for many years in the
6 1990s. Their constant and annoying starting and stopping, adjusting the volume of their amplifiers
7 and negative feedback noises were very exasperating going on for many hours in many continuous
8 nights, until they were eventually either fired from their gig, if they ever had one, or were closed
9 down by the county after multiple late night noise complaints, and never played for pay at all at some
10 local bar. We dont know what happened to that nasty, amateurish country racket, but in any event
11 that noisy-racket and talentless nuisance stopped several years ago, after an approximately 10-year
nuisance, which incidentally Remington never complained to the Sheriff about, for some
12
neighborly reason.
13
900. Likely future federal RICO defendant Joy Mathson, is well-established criminal
14
felon John Mathsons wife, and she is heavily implicated here because she knows every criminal act
15
which he commits, condones and applauds them. Joy is full of hate which helps to motivate Gans,
16
however, very significantly here now, she does have a certain degree of known trouble lying,
17 unlike virtually all of the others named herein. She was very clearly well-prepared to lie in August
18 2016, as explained in the RICO statement, however neither side actually called her as a witness, so
19 she got a gigantic break. For her, that was a HUGE blessing (from God?), so that now in her
20 imminent federal deposition she is not yet locked-in to all of the coached and collusive lies sworn to
21 by John Mathson and defendants other witnesses in August 2016. Maybe Gans will now write a
more truthful script for her, if she insists on it herself. More probably, she will now prudently attempt
22
to plead ignorance, and not be so positive that the wonderful John was absolutely correct and
23
truthful and that the obvious OGRE, that all her friends agree about, Remington, is in fact the
24
psychopathic liar, and not John. We all know that she is one of the principal masterminds here,
25
however alternatively, she may plead husband-wife privilege in order to try to shield herself from
26
federal perjury charges. Whatever she does, it will be complex because she will be deposed at great
27 length about a lot of things and how deeply she buries yourself and federal charges remains to be
28 seen and at this moment is entirely within her discretionary control. Personally, Remington hopes she
chooses wisely. Remington does not know if she is a religious person, which is very doubtful,
however if she is, she still has a chance to do the right thing here after all these years and after

29
1
causing all these problems, which she almost single-handedly precipitated in 2006, and then she
2
continued to fan the flames to keep things going here, 11 years later. See Rico Statement: 230-233.
3
901. In a federal trial or under local criminal investigation from the County DA, U.S.
4
Attorneys Office, or FBI, she is the most likely witness listed to turn states evidence and to not
5
get mired down in a never ending labyrinth of lies. She is just as dishonest and deceitful as all of the
6 others, except for one thing: She seems to think that she is honest for the most part. That somewhat
7 ambiguous personal perception in this situation caused her to be mostly truthful when examined by
8 Harvey Roberts, even when what she blurted-out was prejudicial to their case; and, if she is
9 delicately examined again by compassionate experienced trial counsel, she may be coaxed to tell
10 the truth so she does not have to worry about prison herself, if some other enterprise member
11 collapses, and tells the whole truth. Also, since she knows what the truth is in many cases and she
also knows that Remington absolutely knows the truth, it will be interesting to see if she would lie
12
directly to him. She did so in 2010 but will she do so when prison is an alternative? She has Also told
13
the truth to Remington previously, when it was inconvenient and directly violated a personal
14
friendship, with respect to the Kishpaughs, as explained in the RICO statement. She also made
15
numerous truthful admissions in her deposition which were overall very detrimental to the Mathsons
16 defense, including, without limitation: Joy swore that defendants primary objective in 1998 was to
17 completely fill-in the (Remingtons) ravine to make more land for themselves, usable land. In other
18 words, in 1998 they intended to appropriate a substantial amount of Remingtons land plus
19 Remington Creek and in fact they did so and have made it stick for the next 19-years and counting.
20 902. RAOs Insurer which pays Kluck, whomever it may be discovered to be. Said insurer
21 is now indemnifying a well-known major, Northcoast long-time, criminal polluter and Kluck has
been extremely passively representing him doing just enough improper advocacy to keep RAO just
22
barely out of default in 2014, in DR140426, not yet active. RAO, et al are named DOE defendants in
23
DR 080678, still in progress and the fact that Remington just ignores Kluck in that case because he
24
gets 100% of his motion documents directly from Gans, is direct proof of Kluck, RAOs and said
25
above insurers involvement with the RICO enterprise, if not directly implicated in its objectives and
26 day-to-day criminal functioning. Kluck is already alleged to have committed several preliminary
27 predicate acts in the RICO statement, but said above insurer has not, nor has any information yet
28 been discovered about them.
903. It is not yet even known for sure whether Kluck is actually paid by an insurance company
as opposed to Olson directly. However, very inferentially, since Kluck is always so beyond laid-back
and very obviously not worrying about whether he is going to get paid or not, Remington is
30
1
positive that there is yet another insurer involved here, with more to join-in shortly. Otherwise, we
2
would have seen Olson at least once in these proceedings, if he was paying for any of this, and there
3
would be some tiny semblance of a hint of urgency on the part of those RAO defendants. So far, as
4
explained above and elsewhere at length, Skillings who has been thus-far controlled only by Gans, is
5
the only one who has shown any emotion, exclusively hostility; or any fire or motivation to destroy
6 Remington completely, by whatever means he finds convenient.
7 904. Whether said above insurer and Kluck are now going to try to take over and tame the
8 tiger Skillings, and therefore be responsible for whatever criminal or murderous act he may commit
9 next, will be interesting to note. If nothing else, this RICO statement informs Kluck and whatever
10 insurance company that is paying him, that they are going to be deeply implicated in Gans RICO
11 racketeering enterprise almost instantly after this is filed and discovery begins, see also RICO
statement 3B. Also, they will certainly be fully responsible for any criminally violent acts committed
12
by Olson or Skillings going forward.
13
905. Ignorance is now no excuse. Not only should they have known, but they are
14
specifically and directly put on notice herein, such that they now do know exactly what is going on
15
here and where the path which Gans has been leading them on now for several years has been and
16 is rapidly going next, and also exactly where Klucks observed very close, friendly and personal
17 association with Gans, and all of the Mitchell firm members is now uncontrollably leading them all.
18 906. Near, but as yet unnamed RICO enterprise defendant Blue Rock Environmental is
19 Gans original environmental engineering expert firm. However, they are now so discredited with
20 respect to their dozens of false statements sworn to in numerous 2011 declarations and two different
21 lawsuits, which were obviously deceitfully written for them by nonscientist Gans, that it is presumed
that they have refused to testify further in these cases. That was all before this RICO lawsuit which
22
implicates them directly so now it would appear they would need to be suicidal to continue under
23
Gans corrupt racketeering leadership, through Federal discovery and a first substantive trial on the
24
merits. Theres no way that they can now gracefully talk their way out of their perjurers webs which
25
have been spun by Gans since 2010. Mark Ferriman is their chief worker with some small
26 semblance of integrity, and perhaps even justice, and now seems to Remington that it would be
27 impossible for him to come in now and testify under oath that he made no prior errors and that
28 therefore he should be fully or at all believed by a jury. He cant really do that and Remington
believes that therefore he wont. Therefore they hired a new young guy, Hillyard, to try to undo some
of the damage caused by Blue Rocks deceptions, however none of Hillyards work has been admitted
into evidence nor is it likely to ever be, so Gans is still stuck with Blue Rock for the indefinite future.
31
1
907. Similarly, Brian Gwinn has all of the educational and licensing credentials, because
2
Ferriman has zero, but he has proven himself to be entirely useless, inept, error-prone, corrupt and
3
like Ferriman, it may be inferred that there is no way he could ever overcome his stick test or his
4
deliberate and knowing, fraudulent volume of the fill errors, which are off by at least 800%. An 800%
5
error is really hard to do. Although his education is very marginal, as compared to Remingtons
6 experts, and his math background is negligible and presumably entirely nonexistent, nevertheless the
7 magnitude of his errors can only be caused by intentional fraud. Said fraud was undoubtably scripted
8 and demanded by Gans enterprise, however Gwinn is smart enough to understand how he was
9 misused by Gans, in Gans continuing successful corrupt attempts to defraud Remington and several
10 courts. The fact that Gwinns and Gans frauds succeeded in the federal magistrates court has
11 emboldened them, but certainly has not exonerated either of them in future discovery and in the next
trials, whether federal or state. See more at RICO statement 3C.
12
908. Matthew Hillyard from Farallon Corporation, out of Portland, Oregon is Gans
13
newest replacement expert for Blue Rocks above discredited environmental experts, and is at least
14
their fourth or fifth environmental consultant in these cases. Gans requires someone crooked,
15
unethical and someone who just basically is looking for a paycheck, who will sign-off on his illicit
16 theories and fraudulent dynamics, and inferentially Hillyard is just such a whore, however that will
17 not be fully confirmed until his deposition. Hillyard appears to look the part, which is Gans chief
18 objective, and if he also can sound like he knows what the hell hes doing then hes good to go.
19 However, if he is going to rely on Blue Rocks fraudulent out-of-time testing, and all of their other
20 numerous false statements on all case issues, sworn to in all of their declarations, too numerous to
21 outline here, but fully described in the RICO statement; then, Hillyard is going to have big problems
quickly after he disingenuously responds to his first federal discovery request, pursuant to Gans
22
false scripts which are based on Blue Rocks incompetent reports and false declarations. See RICO
23
statement number 3P, for much more on all of this, which is again incorporated by reference as if
24
fully set forth here.
25
909. Kiff Analytical laboratories of Davis California deliberately falsified the Blue Rock test
26 results from Mathsons land in 2010 to grossly understate the toxicity there, and very importantly to
27 therefore inferentially grossly understate the contamination existing on both properties. The simple
28 fraudulent method they used of running their scientific testing FAR out-of-holding time was fully
documented and demonstrated by John Aveggio during his deposition on July 1, 2011, at pages 86-92
to Gans great chagrin. Hopefully, Mr. Kiff will appear at one of our trials, by subpoena.
It is not rocket science that if you take hydrocarbon water or soil samples on Mathsons
32
1
property and then set them on a hot southern California shelf at 120-180 degrees Fahrenheit for 6-
2
8 weeks as defendants did in this case, then much if not all of the hydrocarbons will volatilize
3
during that time and the results submitted by the laboratory will show evidence of MUCH less
4
hydrocarbons than what were in the original samples taken on Mathsons property. We dont know
5
exactly how much less yet, but 100 to 500% less would be expected. In any event, none of
6 defendants minimal testing results on Mathsons land were competent, relevant or of any use in
7 these cases it all, and Esko fully relied upon them.
8 910. Cal-Science Environmental Laboratories, now called EuroFins Cal science, of Garden
9 Grove, California participated in executing the above fraudulent plot, by getting samples from
10 Eureka, Blue Rock and Kiff labs and then holding them improperly and scientifically fraudulently
11 until their hydrocarbon content had full volatilized and dissipated.
A. As explained above, that produces known to be substantially fraudulent and incompetent
12
results, which their experts absolutely knew about, yet they propounded them as part of the
13
Enterprises racketeering scheme and objectives for many years.
14
911.Two different courts plus Remington and his experts relied upon said above incompetent
15
Kiff-Cal-Science test results for about two years which was very damaging monetarily, scientifically
16 and timing-wise with respect to which tests we did, where and why. Therefore, as a direct result of
17 said above incompetent testing, Remington and SHN failed to timely test in certain areas until too
18 late in 2011 to be admissible into the DR 080668 trial, which is a highly prejudicial situation.
19 911. Gary Costa is a former retired, long-time fellow Samoa pulp mill union member and
20 very close-confidant and very long time friend of John Mathson. His false testimony in August 2016
21 was quite creatively crafted by Gans to implausibly and ridiculously involve a supposed, very
contrived, birthday 18-years ago that he recalls like it was yesterday, because he bought some
22
plant on that day. Remington has bought more than 10,000 such plants, many of which were BIG,
23
impressive and bought 3-10 at a time in the beginning, yet although he vaguely remembers some of
24
the blurred general circumstances about the environment in possibly 1 in 100 of those instances,
25
Remington certainly does not recall the day of the week or the month, or even the year to the nearest
26 3-5 years in any of the instances.
27 912. Costa obviously did not remember anything either, he just was able to proficiently present
28 his lines to the jury which Gans had scripted for him, and they fell for it. He seemed rather sheepish
and apologetic throughout his testimony, which was entirely false and Remington will never rest
until that perjury is somehow at least partially brought to justice.
913. Listening to him there, and unable to shake his slow honest-appearing demeanor, but also
33
1
understanding that he was absolutely lying about something that had never occurred ever on any
2
day, it became obvious to Remington that he will lie again, about anything, and everything as
3
needed. For example, if Remington is murdered, hell provide an alibi for the murderer and then tie it
4
also to a birthday, Christmas, anniversary, one of his kids birthdays, etc., or some other notable event
5
to prove that it was true. Conversely, if one of the defendants is injured or murdered, Costa would
6 be the first person they would call to swear that Remington committed the murder and Costa
7 absolutely saw him do it. Therefore, Costa provides this criminal enterprise with a valuable service
8 and he may be important going forward.
9 914. One of Remingtons witnesses Jim Wilber alleged that he is another part of the prominent
10 Westgate amphetamine, marijuana and related drug-ring centered at Mathsons residence over
11 various different years. As explained in the RICO statement, there was a large group of Mathsons
initially alcoholic drinking buddies in the 1990s, which included essentially all of their trial
12
witnesses including Gary Evans, Hilfiker, Randall and others that have been deposed and/or who
13
may or may not be called or involved with this drug and other substance abuse ring, over many
14
years. Many of whom, and probably most of whom, have since moved from this street and/or area.
15
The M.D. Tree Service family, explained in the RICO statement were prominent members of
16 that drug ring from about 1997-2005 approximately, focused on meth-amphetamines, and when they
17 left that rental house, the local drug activity, at least what was overtly public, has been reduced
18 somewhat, except for the conspicuous late-night comings and goings of swarthy, hyper- active,
19 and/or the opposite sluggish, generally spaced-out, non-local, out-of- place looking visitors at
20 the Kishpaughs residence, and also at the Mathsons to a lesser degree.
21 915. Melissa Martel has been the Director of the County of Humboldt, Environmental
Health Division for several years during these lawsuits and may still be today, however that is not
22
absolutely known.
23
916. As explained in considerable detail in the RICO statement at 3H, approximately pages
24
186-190, and not repeated again here, Ms. Martell has simply put, inexplicably obfuscated,
25
dragged-her feet and essentially has never taken Remingtons offensive cases here seriously since
26 about 2009, despite her several investigators assurances that the county would be highly concerned
27 about these contaminated sites and would be ordering their cleanup. That has never occurred or
28 even close to it.
917. As concluded at 3H, Ms. Martell has acted very strangely in these cases and certainly
appears to be entirely under the strong influence and total control of Brisso and Gans, perhaps

34
1
through their LAFCo associations, or similar behind-the-scenes collusion, which requires additional
2
probing.
3
A. In other words, we need substantial discovery next to determine why Brisso, Gans, Olson
4
and Mathson have received such an enormously favorable treatment from the county and conversely,
5
general diffidence to their massive industrial-scale hazardous waste dump, when much lesser
6 violators and less serious polluters such as Richard Miller have been aggressively prosecuted and
7 fined.
8 918. WHY have these serious, egregious contaminating defendants polluters, complained of
9 herein received an entirely free-pass so far, for far-worse violations, as compared to other local
10 contaminators, of literally 5-50 times the magnitude by weight, toxicity, unsuitability of location for
11 a Class I hazardous waste dump, and composition of hazardous materials, etc? We expect to find out
the answers to these questions over the next several years, and the public also has a right to know.
12
919. Peter Esko, odd, special environmental emissary designated to fully exonerate the
13
Gans/Brisso clients mass in an RAO. Esko is apparently affiliated with, but not employed by, the
14
Humboldt County Health Department, and he is an important corruptly-influenced figure here who
15
has been alluded to throughout these complaints, and is discussed in considerable detail at RICO
16 statement 3I, pages 242-245 at the time of the mid-January 2017.
17 920. Esko did not even work for the Health Department when he was strangely called out of
18 retirement to do one last favor for Martel, Brisso, and LAFCo which obviously no regular
19 investigatory employee in their department was willing to do, such as Mark Johnson, Maje Hoyos,
20 Larry Lancaster or Carolyn Hawkins. At that time Maje Hoyos was the sole investigator in charge of
21 both sites, yet she was inferentially passed-over and not consulted at all during the drafting of the
enigmatic Esko report, which exonerated Mathsons property completely from any present or future
22
liability to the county for cleanup. During discovery, we will determine whether she flatly refused to
23
perform Eskos corrupt and automatic approval of all defendants nefarious activities involving
24
both sites, or whether she was never given the opportunity to present her definite views, and if not
25
why not? Ms. Hoyos has been in a difficult situation for many years, and although Remington does
26 not want to get her into trouble in this RICO battle, she is obviously under great pressure from her
27 superiors and is already resisted that pressure when she turned her file on the Remington property
28 over to the California Waterboard, because the Martel-led County Health Department was not
interested in prosecuting it.
921. Remington did a special investigation on Esko during 2015, which information will be
used if he ever shows up as a trial witness for Gans as threatened. Strangely, Judge Reinholtsen has
35
1
allowed him to remain in the case despite the fact that his supposedly scientific information is
2
irrelevant, prejudicial and incompetent since it is based 100% on Blue Rocks above-described
3
fraudulent 143-page out-of-time testing. Esko and the Health Department declined Remingtons
4
request to submit rebuttal information to said above 143-page report, and therefore he has no
5
information about the Remington subject property at issue in these lawsuits. Even more
6 importantly, despite the fact that all of Eskos work was done approximately one year after discovery
7 closed, both of those crucially important sets of test by SHN and the County Health Department by
8 Hoyos, were intentionally disregarded by Esko, and also strangely and corruptly have been 100%
9 barred from the DR 080678 case, by Judge Reinholtsen. Remingtons two most important and
10 valuable sets of tests were completed long before Esko's completed his work or filed his report.
11 Why was that? Taken in its entirety, all of the above facts corruption, improper influence and deep
infiltrations into all power centers and humbled County by said RICO enterprise. We cant resolve all
12
that here and will need very extensive discovery regarding all of these related issues. Again,
13
everything about these decisions and all of those named above including Martel, Brisso, Esko and
14
Judge Reinholtsen are now under great suspicion, scrutiny and it will require extensive discovery
15
and/or criminal investigators to fully question, probe and investigate the causes and motivations for
16 all of the above unusual actions, pertinent to the above issues. All of said above actions essentially
17 severely prejudiced Remington and his cases and exonerated defendants and their RICO racketeering
18 leadership.
19 922. All of this smells very, very bad, when it is understood properly in the context of
20 what the county investigators told Remington from 2008-2011 that sooner or later the county
21 would be ordering the cleaning-up of both properties. However, as explained, but which is still a
mystery, somewhere during 2011 the influence of Brisso, Gans and Esko diametrically reversed the
22
earlier long-time stated policies pronounced by the Health Department investigators. Whether this
23
court perceives the above unusual and corrupt circumstances as extreme prejudice against
24
Remington and his contamination cases, or as extreme bias and highly improper and exceptionally
25
favorable treatment FOR Gans, Brisso and the Mitchell firm by all of the above, something is wrong
26 with these facts. None of it is logical. None of it is being handled objectively, fairly or justly by any
27 of these Humboldt County entities, which Remington infers as pervasive County-wide bias in favor
28 of Brisso, presumably resulting from his long-time roles as acting County Counsel. That position
wielded great power, awesome respect and fear, and obviously continues to do so today. Brisso now
has noticeable improper influence within all of the county power structures, relevant in this case,
presumably based-upon his long-time forged governmental relationships, plus the fearful possibility
36
1
that he might return at any time to take over and once again become the superior officer of said
2
involved bureaucrats. Presumably he hired and fired many of the current top leadership employees in
3
the county, especially in the District Attorneys Office, and in any event he clearly still has their total
4
respect and inferentially he still absolutely controls what they do as though he were still their boss
5
and able to fire them or adversely affect their career advancement. We have ample evidence and
6 witnesses to back all this up, some of which is in the RICO statement, but expect to discover much
7 more in the next two years because this is an important issue.
8 923. Liz Smith was a Humboldt County Superior Court file room employee during part of
9 the period at issue here and perhaps through all of it. She is discussed more extensively at RICO
10 statement 3J, approximately page 193+.There has definitely been a courthouse saboteur working
11 against Remington for many years, and the only question today is exactly who that sabotaging
criminal is. Liz Smith and Candy B, are Remingtons two very reasonably-likely suspects, since
12
about 2015, but extensive discovery in this case will be required to produce evidence of actual
13
federal predicate acts on behalf of the RICO enterprise.
14
924. As explained there, Remington has plenty of reasons to suspect her of all sorts of corrupt
15
activity, but no positive proof has yet been developed and the court executives who have done several
16 investigations about the file room crimes alleged herein have never caught anyone specifically in
17 the act that Remington is aware of, but they have scared some of the corrupt sabotaging perpetrators
18 for several months at a time, over many years, before the same kinds of untoward and seriously
19 criminal activity continued again, perhaps by the same or other bribed personnel. Also, if some of the
20 previous top court leadership did apprehend or fire someone over this are related crimes, Remington
21 would be the last to know about it, so his only guide is whether his properly filed documents are
sabotaged before or after they reach the proper court room.
22
925. Remington will soon be attempting to work with the County District Attorneys Office on
23
some of these issues herein, but today has a pessimistic and depressing feeling that until Brisso
24
leaves town, and other strong bombastic leadership takes over the county counsels office, nothing
25
much is going to come of anything which Remington initiates. Hopefully Remington is totally wrong
26 about that, and if so it will be presented here in the future.
27 A. Meanwhile, it seems like a smart and fortunate idea that Remington is attempting to obtain
28 justice from San Francisco courts and associated legal powers, because Humboldt County may be
totally and unjustly closed to anyone here that opposes Gans and Brissos RICO enterprise. In
fact, perhaps it reaches into the District Attorneys Office. We will attempt to ascertain that very
soon.
37
1
926. Whether Liz Smith is entirely innocent of any wrongdoing as alleged herein, or not
2
remains to be seen. Remington has no absolute proof of anything substantial that she did personally,
3
and no one at the courthouse has yet definitely implicated her, or anyone else either, however it is a
4
fact that is beyond dispute, that she obviously took several improper, biased and very prejudicial
5
actions against Remington, none of which were provably corrupt, as yet.
6 927.Whomever the courthouse saboteur eventually is proven to be, will have to be established
7 by investigators within that building, either with the district attorney or the Superior Court
8 supervisory staff. So far, there has not been strong enough incentive within the courts management
9 structure to really get to the bottom of these alleged crimes, and Remington does not have the
10 resources, incentive, intimate knowledge or financial power to bully his way into the courts and force
11 his own investigations, perhaps by way of a major lawsuit, and deposing half of the personnel in the
courthouse. Right now, that doesnt work economically, logically or perhaps any other way.
12
Ironically and obviously, if someone was sabotaging and shuffling-up the Mitchell firms filed
13
documents and preventing them from getting to the appropriate judges in a timely manner, there
14
would be hell to pay, heads would roll and it might well be, national media story. Whereas,
15
conversely when its just an obnoxious pro per that is harmed, the California justice system seems to
16 infer here that so what, it is just not that big a deal because Pro Pers shouldnt be involved here in
17 the first place.
18 928. Candy B, is one of the principal reasons why Liz Smith is merely a prime suspect, but
19 not the only very likely suspect, as viewed from a few miles away. Candy B is, or was a year or two
20 ago, also a Humboldt County Superior Court file clerk, who also grossly prejudiced Remington at
21 least twice several years ago. Her primary known provable infraction occurred when she
improperly and indiscriminately chose not to file several major crucial Remington documents, but
22
rather than just return them for some very minor superficial and unwarranted technical issue, she did
23
nothing and just sat on them for about 10 days and until one day before the hearing where they were
24
due. Then she called him to have them pick up the documents make some minor edit on a cover sheet
25
and then attempt to return them on the day of the hearing itself. Most egregiously she did not timely
26 alert Remington to his petty and minor failure, in her opinion, which caused her to arbitrarily
27 decide not to file the documents or get them to the court timely. She merely wanted some very simple
28 perfunctory corrections on the cover page, and the enormous prejudice to Remington occurred by
her not timely communicating with Remington, because her required corrections only required a
few minutes to do on the cover sheet of the motion, could have perfectly well been done by hand, if
said corrections needed doing at all, which clearly they did not. See Also RICO statement 3K.
38
1
929. Her actions were analogous or perhaps identical to the actions of the file room saboteur
2
who appears to be on Gans payroll, with the intention of getting Remingtons case dismissed for
3
failure to provide required opposition documents, usually, by the required filing dates.
4
930. On the other hand, what Candy B did, more than once, was public, signed, known and
5
although very unfair, prejudicial and improper, her actions were not necessarily illegal. Further, they
6 were not felonies and it did not appear that she was getting paid necessarily to ruin Remington and
7 some criminal manner, because what you did was signed and possibly thought she was doing the
8 right thing.
9 931. It is well-known that no file room court clerks like Remington or any Pro Pers and all
10 treat Remington perfunctorily and with mild irritation and ill-will, and very often borderline bad
11 faith. In other words, neither Candy B nor Liz Smith necessarily stand out from other file room
court clerks who like to pick on and prejudice Pro Per litigants, therefore much more discovery is
12
needed here. By way of contrast, during most of 2016, Remington was able to by-pass the file room
13
and directly file his numerous pre-trial documents directly in Department Eight to their courtroom
14
staff. From April through August 2016 Remington filed at least 100 individual documents including
15
5-6 per day on many occasions, all of which went perfectly, and without comment, criticism or any
16 mistakes of any kind, ever. To Remington that merely emphasizes the fact that there is a saboteur in
17 the Humboldt County Superior Court file room when he files documents through them. Additionally,
18 the latest example of this type of crime against Remington occurred after November 15, 2016
19 hearing wherein the Judge Reinholtsen court order was to send Remington a copy of the minutes so
20 he would know what the hell was going on in two different cases, with several different judges,
21 however, those minutes were never sent as ordered so Remington still does not fully understand who
the judges are in these cases or why.
22
932. As explained elsewhere, someone, over several years, went to huge trouble to sabotage
23
Remingtons documents, scatter-them widely around the courthouse, cancel hearings, remove
24
Remingtons name from the courts service list, withhold documents from judges and a wide and
25
diverse variety of other crimes.
26 933.Therefore, just as with Liz Smith above, professional investigators either within the county
27 or state court system or the District Attorneys Office will need to investigate these crimes, or more
28 probably just ignore them, and wait for Remington to go away. Remington still believes that most
probably Gans and Brisso, McBride or another Mitchell employee has a close relative or similar
confidant, lover or other confidential relationship with someone associated with the courts file room.
A relative or very close friend of one of the Mathsons, or their siblings, is also an option, and
39
1
deciding between the two above options is not realistically possible for Remington at this time and
2
again will depend upon discovery and whether Remington or his allies can locate another litigatory
3
adversary of Gans and Brisso and see if dirty tricks have been played upon them, TOO, or not. In any
4
case, without a third-party involved, it will be difficult to eliminate either above alternative.
5
Logically, it makes more sense for Gans RICO enterprise to do the corrupt activities which have
6 been done because they are intimately knowledgeable about the exact deadlines and the degree of
7 prejudice from sabotaging Remingtons documents at various times. As observed and written
8 elsewhere, Remington has noticed the very direct correlation between the number of animals and
9 destructive acts upon his property with the importance of various filing deadlines or court dates.
10 Gans knows precisely what Remingtons deadlines are, their importance, difficulty and hence the
11 amount of full concentration necessary in order to properly meet them. Therefore, theres no doubt in
Remingtons mind that the enterprise correlates many factors and at least two different saboteurs to
12
simultaneously attack Remington from within the courthouse and also from outside of his
13
fences, invariably one to two days before crucial deadlines. On the other hand, the Mathsons are
14
entirely crazed, desperate, have criminal mentalities and if they have a child or related zealot
15
anywhere near the courthouse file room, there is no doubt that they would induce that person with
16 money, sex, lavish praise or something of value to them, to try to technically destroy Remington in
17 his case, specifically by a failure to properly and timely file is documents. Therefore, the jury is
18 out on this issue and until the file room supervisor, court executives, Judge Reinholtsen or hopefully
19 the federal court takes a deadly serious and highly personal interest in this situation, it is obvious that
20 said file room saboteur will never be discovered, apprehended or brought to justice.
21 934. Judge Reinholtsen is still the sitting state judge in DR 080678, and therefore he cant
really be fully or properly dealt with herein. More details of his situation, Remingtons two attempts
22
to disqualify him after numerous prejudicial rulings and occurrences at the August 2016 trial, proved
23
he was hopelessly biased against Remington. Other probable inferences that Remington has drawn
24
about said court in 2016-17 is covered in RICO Statement 3L, as delicately as possible. On
25
February 17, 2017 we had a hearing on the status and next steps to be taken in DR 080678, and Judge
26 Reinholtsen conducted that status conference in an odd manner, when he solicited simultaneous
27 memorandums on the subject back in August 2016, And never allowed Remington to draft or file any
28 direct opposition to Gans post-trial brief. That situation today is very peculiar because the law is very
clear on what steps need to be taken next, as described in these documents elsewhere. Simply put it is
now up to defendants to prove to a jury that no continuing nuisances or trespass damages exist on
Remingtons land in any of his three-year time periods sued for. However, it appears at this time, that
40
1
even after Remingtons comprehensive 30-minute oral presentation summarizing all of the relevant
2
legal election and issues of fact to be determined only by a jury and not by the court or by Gans,
3
which are absolutely definitively mandated under Mangini II, etc., it inferentially appears to
4
Remington today that the court intends to prematurely dismiss DR 080678 to force this case next to
5
go to an appeal so that what it is one that can be returned to a different judge or after Judge
6 Reinholtsens imminent retirement, or both. All of that remains to be seen, and hopefully said judge
7 will take his usual 2-6 months to decide what to do next in that case and therefore allow this case to
8 move forward to a more expedited, efficient and reasonable conclusion in the federal system, for the
9 reasons explained throughout these documents.
10 935. Simply put, Remington has inferred for several months that Judge Reinholtsen is
11 somehow influenced by this RICO enterprise presumably through his good friend and longtime
former law partner and associate, Brisso. Said judge is a kind, empathetic man, a super-hard worker,
12
probably seven days per week, 9-12 hours per day, and although ill-suited to this particular case
13
intellectually, temperamentally and scientifically, he is our judge here. Apparently he wants to remain
14
that, and why he is so motivated to continue on here in such a time-consuming and onerously
15
detailed case in an area of the law he is unfamiliar with, is not immediately obvious, and how he
16 adapts to being named as a possible future RICO enterprise associate or defendant after considerable
17 additional discovery, remains to be seen. Presumably he will not appreciate these inferences,
18 however as fully set forth in the RICO Statement, during 2016, Judge Reinholtsen made too many
19 odd and prejudicial decisions against Remington to be entirely random or neutral, in Remingtons
20 opinion. Remington also expressed his candid opinions in the two disqualification motions, so the
21 cats out of the bag so to speak. Early in the May 2016 pre-trial hearings judge Reinholtsen said in
so many words that he was in effect not sensitive to what Remington was thinking about him, and
22
did not care if Remington did not like his decisions or thought he would have to appeal erroneous
23
rulings, and he said that in so many words. That said directly that he did not care what Remington
24
felt or eventually did with regards to opposing his orders or appealing his decisions. At the time,
25
obviously, Remington ignored all that and did his best to capitulate, convince him about what was
26 right and generally to get along with him because he had been an excellent judge in Remingtons
27 opinion for about seven years in these cases. Specifically, between an erroneous special motion
28 decision in 2009 were Gans deceived, confused and just conned-him, to be blunt about it, and his
erroneous collateral estoppel decision in June 2016, Judge Reinholtsen was an excellent and
exemplary judge who was on track to justly resolve these cases. However, in Remingtons opinion,
he went bad and fell under Gans and the Enterprises intellectual (at a minimum) influence in June
41
1
2016 and continued to bungle and make a variety of erroneous, and Remingtons opinion, legal
2
decisions and orders thereafter. As alluded to above, one more of such errors is now expected, but if
3
so it will be very easily appealable because it goes blatantly against many controlling Supreme Court
4
opinions in the contaminated nuisance/trespass area of the law.
5
936. Possibly said Judge was not influenced, intimidated, threatened with exposure and further
6 complaints (regarding his own recent felonious activities), or offered a wonderful lifetime of
7 common part-time retirement working indefinitely again as a partner at the Mitchell firm. However,
8 we dont really know that and Remington cannot just take his declaration at face value against the
9 background of approximately 50 consecutive totally biased, crucially important decisions adverse to
10 Remingtons interests in his 2016 pretrial and trial rulings, some of which are listed in the RICO
11 statement. Obviously, Remington will take an interest in all this now for years, especially after he
retires, to see if Judge Reinholtsen immediately winds-up at the Mitchell firm, as expected.
12
937. Therefore, Judge Reinholtsen is delicate, unfortunate and how we will gather the
13
necessary required discovery regarding his possible RICO associations, if any, remains difficult and
14
in doubt. Inferentially, if he is totally innocent and all of Remingtons inferences of possible
15
improper allegations or corruption are unfounded, then he will calmly respond to all questions and
16 indicate with his demeanor and answers that Remington is wrong. That is certainly possible, and just
17 as said Judge admitted that he might very well be wrong in this collateral estoppel decisions,
18 Remington willingly admits that it is theoretically possible that it judge could make 20-30
19 unbalanced or possibly prejudicial decisions against one litigant without being corruptly influenced,
20 and just did it because he believes that one side is guilty and the other is not. At a minimum, Judge
21 Reinholtsen has obviously concluded that Gans and Mathson are the good guys here that have been
totally abused herein for the last 10 years by a vindictive and falsely accusing Remington.
22
938. Possibly Judge Reinholtsen will be influenced or impressed by this RICO lawsuit, which if
23
he ever read this carefully might very well alter his overall impression of who is the good, and the
24
bad in these cases. However, said judge no longer reads Remingtons documents carefully, if he
25
ever did and therefore will never know what is alleged herein. Probably now he will merely be
26 angered, but as speculated above, Remington infers and feels that Judge Reinholtsen has had
27 enough of this case and has made-up his mind to capitulate to the RICO enterprise and send this case
28 to the appellate court where wiser minds can resolve many of these difficult issues. Probably that is
good, because again, without being unfair or nasty about it, Judge Reinholtsen now seems to
Remington to be intellectually incapable of grasping or properly resolving or applying the rather
simple law of these cases, at this point in this career, if one takes the time to carefully read it, which
42
1
He has not and Remington believes is never going to do. As explained above, he relies on his former
2
law partners and officers of the court to read and interpret the law for him and He has refused to
3
accept Remingtons constant clamor and constantly proven allegations that said Mitchell firm
4
attorneys are intentionally, successfully unethically and actually fraudulently deceiving Judge
5
Reinholtsen on the applicable Supreme Court law, and also on all the case facts as alleged in all of
6 these documents.
7 939. Mischa Schwartz of Winzler and Kelly, is Gans asbestos expert who has been
8 improperly used, untimely designated in any of the cases so far, did all of his work, if any, long after
9 discovery had closed in every case where he has written declarations; and, he has not even visited
10 Remingtons property where all of the asbestos has been recovered, nor has he timely investigated
11 the subject properties, according to Gans evasive and deceptive comments to the court during May
2016, about the dates of Schwartzs work.
12
940. His declarations to date are mostly wrong factually, unscientifically and non-objectively
13
slanted as though written by Gans, and mostly inaccurate, but not yet fraudulent or overtly
14
corrupted, but give him time. He has just started working for Gans. What Schwartz does next and
15
what he testifies to at the next state contamination trial or in federal court will be of great interest. So
16 far he has followed Ferrimans fraudulent and discredited narrative about their being only one piece
17 of pipe on both sites that may not even be asbestos, and he has entirely ignored clear, important and
18 blatantly dangerous chrysotile sampling results.
19 942. Presumably in future cases including this one, he will want to walk the sites, especially
20 Remingtons site where most of the asbestos and chrysotile have been recovered and is still located
21 today, conspicuously sticking-out of the ground in many places. Even after Mathson has removed
most of the visible asbestos or buried it under various types of organic debris, there are still a lot
22
more than just one piece of asbestos pipe visible and they are unmistakably asbestos, to any asbestos
23
specialist.
24
943. Michael Pulley of Points West surveying. Pulley is merely Gans surveyor who drove
25
some stakes in the ground along the joint property line between Mathson and Remingtons
26 properties. Gans has attempted to use his impressive voice and physical presence in front of a jury in
27 other corrupt and deceptive ways, such as to make Pulley their default volume of the fill expert,
28 however Remington caught on to that fraudulent attempt and at the August 2016 trial Pulley
acknowledged that he knew nothing about the extent or volume of the fill and that Gans had dictated
what the false parameters of the fill were and he had nothing to do with scientifically determining
where the fill was but merely drafted-in what Gans told him to do. At the August 2016 trial he was
43
1
just attempting to be honest and did not deny the obvious under cross-examination, that his crude
2
sketch of the purported toe of the fill was not an informed scientific geological opinion, was not
3
his own original work, but was merely a diagram depicting what Gans and Mathson disingenuously
4
and inaccurately told him to put on his chart. Gans would have misled us with the inference that
5
Pulley had determined how far the fill went on to Remingtons land or did not go, however that
6 crucial quasi-volume estimate parameter had nothing to do with Pulleys careful research. That
7 erroneous line was a further MAJOR, crucial, material misrepresentation by Gans intended to
8 deceive Remington, his experts and all courts involved in these cases. Failed as to Remington but
9 likely succeeded in deceiving the court and jury There is no other issue in these cases any more
10 important than what the encroaching volume on Remingtons land is as calculated by Remingtons
11 solid geometry-based additive, volumetric prismatic-solid methods. Simply put, without the accurate
and competent underlying field dimensions of the correct length, width and depth of the
12
contaminated fill, said toe of the fill line fraudulently ordered by Gans be put onto Pulleys big trial
13
chart, does nothing less than understate the fill AREA by at least 400%, by itself alone. When
14
combined and magnified by Gwinns depth errors of another 3-600%, Pulleys chart merely
15
graphically represented all of Gans false fraudulent statements of all three parameters of the fill in
16 one place. That false information was originally propounded under Gwinns uninformed signature,
17 wherein he misstated the first two variables of the three variable volume calculation (L x W x D), by
18 the above-referenced 400%, BUT after Gwinns fraudulent depths were added to the massive
19 erroneous mess for another 2-400% error in each additive reference prism, defendants knowingly
20 erroneous and fraudulent result was an understatement of a total multiplicative volume error of
21 between 800-1600%, overall! At any level of elementary school, high school or above Gans and his
RICO defendants would get an F minus for that work, plus an affair system, a suspension and/or jail
22
term.
23
944. The damaging significance of those errors in US dollars, if Gans numbers were to be
24
believed or applied here, would be an understatement of the cost to remove Mathsons encroaching
25
wastes by a factor of 8-16 times! In other words, if believed, a jury might award Remington $20,000,
26 when the correct amount was 8-12 times that amount, say TEN (10) times, or over $200,000!! that is
27 why both sides of this dispute regard the volume calculation is so important.
28 945. Therefore, Pulleys chart involves arguably the most crucial damages issue in the
cases, and so far he has been honest and accurate in his testimony. Maybe that wont change. SEE
3O, for additional details regarding Pulley and Remingtons RICO statement.

44
1
946. This issue will be fully litigated under the pendant state claims of: intentional fraudulent
2
misrepresentation, concealment, conspiratorial collusion and on-going conspiracy and will be
3
charged against Gans in the RICO action under attempted extortion, witness tampering and attempted
4
obstruction of justice including intentional fraudulent and unlawful manipulation of material trial
5
evidence. Complete proofs of all of those allegations already exist today and are described in the
6 RICO Statement and elsewhere herein.
7 947. Meanwhile, summarizing as to Pulley, none of the above is really his fault, at least
8 initially. It would appear that he was just doing his job, following Gans orders and hoping that
9 Remington would be too stupid to notice Pulleys important deceptions or to realize the significance
10 thereof. Now however, Pulley has been put on notice as to how Gans is attempting to abuse his
11 integrity and the forthright honest impression made to a jury. If he allows that to continue going
forward, he will very quickly become an important enterprise member, which he is not today. In fact,
12
as alleged elsewhere, Pulley is one of the only known enterprises straight and ordinary business
13
people who are now being caught-up in the corrupt wheels of Gans enterprises machine, and
14
Pulley is in further danger of becoming hopelessly tangled in the disingenuous, corrupt webs
15
which Gans has ingeniously, deceptively and increasingly stretched-across all issues of these cases,.
16 948. As relating to other sophisticated philosophical questions raised and answered in the
17 RICO statement, Pulley is a perfect example of an enterprise member or a person on the fringes of
18 becoming one who is not dishonest 100% of the time, if at all. He was ordered to draw an inaccurate
19 and very significant line on his map, which in all probability he did not fully understand the
20 significance of. Now he does. If he continues to promote that knowingly FALSE line, which attempts
21 to deceive the trier of fact and defraud Remington from a just recovery here, as being legitimate or
accurate in any respect at all, then he will rapidly become complicit in the attempt to defraud
22
Remington out of at least 90% of the just recovery which would be necessary to remove defendants
23
hazardous waste from his property. Bottom line: Today it would be unfair and totally unreasonable to
24
implicate Pulley in Gans and Mathsons long-time intensive and integrated RICO racketeering
25
enterprise and have him risk serving prison time by his association with those criminals plus the
26 others named herein.
27 949. Marcy L. Conn is a Eureka court reporter who made Remingtons 2010 deposition so
28 unintelligible, at least partially knowingly and intentionally, that Gans could interpret it any way that
he wanted to. That type of a super-BAD transcription, to wrong and incomplete to edit, in the hands
of a corrupt, criminal advocate is a very valuable service, indeed. Although she was under great
duress that day it appears, and is obviously an inept stenographer at best, she should have understood
45
1
the debacle that she was creating by missing approximately 50% of the words Remington swore to
2
that day, without ever acknowledging that she was missing anything, or ever requesting that he slow
3
down or repeat something, despite that question coming-up repeatedly as to whether she was getting
4
everything okay. Therefore, everyones default inference, throughout the several hours of that
5
deposition, was that she had fully transcribed every golden, important word, and subtle nuance, when
6 the reality was the opposite.
7 950. Contemporaneously, Remington refused to sign that deposition after writing out 30-40
8 pages of corrections which eventually became too onerous, too detailed an subjective to submit as
9 corrections. Remingtons attorney objected to said deposition, declared it as being unusable and also
10 requested that Gans retake the deposition, back in 2010, but defendants ignored our requests
11 inferring that they agreed with them. Again in 2016, Remington requested that Gans and Conn again
certify under the appropriate statute, see RICO statement 3R for details and CCP citations, that said
12
deposition was an accurate transcription of Gans questions and Remingtons answers, and of course
13
they refused to do that. Gans likes mangled unusable depositions. Because said deposition was a
14
mangled and unusable mess, that perfectly suited Gans corrupt advocacy style where he could
15
interpret Remingtons incompletely transcribed answers in any way that he wanted, which of course
16 was always antithetical to Remingtons true answers or the facts from 2010.
17 951. In Remingtons opinion, Conn works for Gans regularly because having an unusable
18 deposition like that works magic in the hands of a deceptive advocate like Gans, whose defensive
19 strategies always depend upon deception, subterfuge and mischaracterization. Maybe she was paid
20 extra to make it so bad, and maybe not, but we intend to try and find out.
21 952. Despite these explanations, written memorandum and that outrageously bad copy of a
transcription being in the courtroom, Judge Reinholtsen inexplicably allowed Gans to ask questions
22
from it, never asked to see a copy of it personally, so he could review it for accuracy, prejudice or
23
fraud. Why said court insensitively and unjustly ruled the way he did on that issue and many others
24
is still a big mystery in these cases which needs to be discovered.
25
953. Therefore Gans used said useless deposition, where any answer required more than about
26 five words, anyway, despite realizing that it was unjust, wrong and very prejudicial to Remington.
27 Said court entirely ignored Remingtons valid objections, but Gans himself realized that Remingtons
28 position was well taken and therefore stopped using it after only 3-4 questions, because he saw that it
was potentially going to cause more trouble than benefit, especially during the appellate process,
where there had already been dozens of similar errors committed by said court, in Remingtons
personal opinion.
46
1
954. Additionally, in Remingtons humble estimation, until proven otherwise, Ms. Conn is part
2
of Gans enterprise, probably works for him very regularly, but is but a small cog in this enterprise,
3
but with a potentially rather important role in this case in regards to discrediting Remington and
4
making him look like an ass, or in any other future case which Gans illicitly conducts in this
5
matter. Discovery is needed to attempt to determine whether Conn has done this sort of deliberately
6 sloppy and potentially fraudulent transcription for Gans in other cases, because potentially having a
7 corrupt stenographer who will word process a false version of an important answer or two, as
8 requested by puppet-master Gans, could turn an entire case on one apparently insignificant sentence,
9 at least insignificant to anyone but Gans, who almost always has an illicit purpose an ulterior corrupt
10 motive in every action that he takes.
11 955. Paul Dalka. Dalka was a former investigator from the Waterboard and County Health
Department, whom Remington had met several times while he was investigating the Flying J cases,
12
which oil company had contaminated the groundwater under the Burl Tree. In 1999, Dalka very
13
strangely and briefly investigated Remingtons 832 Westgate property based on some diesel smells
14
which he had noticed while inexplicably standing over on John Mathsons property in 1998 only
15
days or weeks after their project was completed. Maybe he was smelling some of the diesel from
16 Massons contaminated dump, but rather than investigate that he decided to laboriously come over on
17 the Remingtons land, because there was some odd, unfounded suspicion at that time from the
18 Waterboard that perhaps some of Flying Js contaminated soils had found their way up to
19 Remingtons property when he moved the Burl Tree there. That whole situation is extremely odd
20 when you consider the fact that Dalka was standing on remediated Flying J debris, when he decided
21 to come over and attempt to implicate Remington in that exact crime. As described in some detail in
the RICO statement, Remington has inferred from all of these unusual and suspicious details that
22
Paul Dalka was most likely bribed by RAO, to acquiesce to the Mathson-RAO contaminated dump
23
and distract from all that by frivolously investigating Remington. Dalkas silly investigation of
24
Remington led to absolutely nothing, but meanwhile the Waterboards attention was TOTALLY and
25
sadly distracted from the real problem which was over on Mathsons land, which problems we are
26 still dealing with today in this lawsuit, but which shouldve been handled back in 1998 by Dalka.
27 956. What Dalka was doing there, talking casually to Mathson apparently, and why he did not
28 notice or stop defendants from dumping 4000 yards of hazardous debris on both properties as
alleged in detail at RICO statement 3S, is presently unknown, and it is also a very big mystery. Why
did Dalka waste time on such an insignificant and meaningless test of a few drops of diesel 2-inches
deep under a hand-filled diesel tank on Remingtons property, far-away from defendants massive
47
1
contaminated Class I landfill, when he was standing at that very moment on arguably the largest
2
residential hazardous waste dump in Humboldt County history? When we learn the answer to that
3
question during discovery, we may have the key to much of these cases.
4
957. Concisely put: present evidence shows that Mathson and RAO must have bribed Dalka to
5
make them look the other way about their project, which he was standing right in the middle of while
6 it was underway! Then why go over and distract and intimidate Remington unless it was to extort
7 him to keep his mind and eyes off of Mathsons land, which was already unnecessary in late 1998,
8 because Remington never had any interest in Mathsons land or projects, and in fact knew nothing
9 about them at all until the mid-2000s. Dalka could be a star witness if we can find him, although he
10 likely has criminal culpability here, however he appears to have left the area or to be deceased,
11 however we will attempt to confirm both of those possibilities as this case progresses.
958. Jason Eads of the law firm of Stokes, Hammer, Kaufman, etc. represents Jeff Nelson
12
of SHN, who gravely needs representation now that he has been implicated in Gans enterprise, see
13
3V of Remington RICO statement at pages 236-7, for more background and details. Had Nelson
14
properly offered Remington a full refund plus substantial compensation for all of Remingtons lost
15
and wasted time; substantially wasted testing and planning costs; deep anxieties and intentional
16 extreme emotional upset, due to Nelsons illegal and tortuous interference with contract and its
17 breach, then Remington would never have discovered the Gans RICO connection, which has now
18 been proven by knowledgeable witnesses. Treble damages are now sought with regards to any RICO
19 enterprises involvement in removing Foget and sabotaging all of Remingtons other potential Eureka
20 environmental experts, at LACO, et al.
21 959. Eads Will now be representing Nelson and how he conducts himself going forward will
determine whether he becomes personally implicatedIn this RICO enterprise, and whether he falls
22
under Gans immoral and unethical influences, charisma and corrupt schemes and objective, as
23
would be expected. As above, Nelson is already implicated but Eads himself personally, is not, yet,
24
until he falls under Gans spells and gets all of his in accurate and corrupt case history from the
25
Mitchell firms offices. In other words, Eads is now only on the fringes of the enterprise, and
26 probably will gradually become an active, enthusiastic, named RICO defendant, but only
27 in the 2017-18 FAC, at least as of March 2017.
28 960. Harold Hilfiker of Eureka. Hilfiker is believed to be involved in Mathsons local
drinking and drug gang, is in their personal social circle and apparently has been scheduled by Gans
to falsely testify about anything that Gans nefariously wants another 2-3 people to back-up. What
exact topic that will be at this point is presently unknown. He has never been on Remingtons land
48
1
nor has Remington ever met him. Gans and Mathson both have an impressive capability of
2
befriending local itinerants and unhappy misfits, possibly by offering them alcohol, drugs, an/or
3
benign, supposed friendship, under the guise of legal protection and Hilfikers name has
4
appeared on all Gans witness list since about 2010, without ever explaining his testimony.
5
961. Meanwhile, when or/if Hilfiker ever does testify about something, it will inevitably be a
6 scripted partially false scenario, and if so at that time hellLikely endeavor to become a full-fledged
7 enterprise member by making a false statement in a federal proceeding; however, today he is only on
8 the fringes with no known, specifically assigned task, or yet known violated RICO predicate acts.
9 962. Mike Foget of SHN was hired, trained and paid, all by Remington during 2012, as the
10 prematurely deceased John Aveggios replacement to act as Remingtons sole independent

11 environmental expert. Foget was very excited at the opportunity on many levels to take over new
challenging and exciting responsibilities and to further, continue and/or complete the impressive
12
scientific work and legacies of his very good friend and fellow expert John Aveggio.
13
963. However, during the Ninth Circuits appeal, Gans got to Nelson with some sort of
14
presently unknown unethical and improper influence, bribes or extortion and succeeded in getting
15
Nelson to remove Foget from Remingtons trial team, crippling Remingtons case instantly and
16 nearly ending it.
17 964. As explained throughout these documents and specifically at 3X, currently page 238 of
18 the Rico Statement, Remington has evidence that Gans caused Nelson to remove Foget, causing
19 catastrophic damages to Remingtons trial case, but future discovery, i.e, Fogets deposition, is now
20 needed to sort-out all details of the corruption involved.
21 965. Chris Watt is the CEO of LACO engineering, who has oddly become involved in this
case again due to the complex influences and extortions from Gans, Nelson, and some of the others
22
cited herein, mostly allegedly exercised through Ferriman, Gwinn and their testing associates. The
23
exact dynamics among the various members of the Eureka environmental testing community,
24
including LACO, Nelson, Blue Rock and Gans enterprise is not fully understood today, but is
25
partially described at 3Y of Remingtons RICO statement, pages 238-9.
26 966. Extensive additional discovery is needed within the entire Eureka environmental
27 engineering and testing community, and it will be undertaken during 2017-19, as needed.
28 967. Gans enterprise has pervasive influences and effects in Eureka and its tentacles reach
across the entire city. Watt of LACO is presently believed to be only an indirect participant in the
collusion and conspiracy against Remington and his environmental cases at this time, however he is
known to have close contacts with Gans and to have caused deleterious impacts on Remingtons
49
1
relations with SHN, which therefore gravely prejudiced Remingtons environmental cases
2
monetarily. The specific dynamics, interrelationships, dates and correlation with the aforementioned
3
RICO enterprise membership is yet to be fully developed and understood.
4
968. Mike Retzloff is allegedly Gans residential real estate appraiser, who Gans apparently
5
hired to attempt to contradict and counteract Remingtons prominent and preeminent local real estate
6 appraisers and consultants Tidwell, Scolari and Matt Nielsen. Presumably Retzloff has agreed to
7 dispute Remingtons experts and frivolously and probably falsely argue that contaminated property is
8 not ruined and can easily be cleaned up, and therefore is still valuable and that this whole
9 contamination thing is not that big a deal. Actually, until Retzloff writes an expert disclosure
10 statement in this case it would appear that anything he would say would be foolish, wrong and
11 indefensible against our experts and their numerical studies and research. Retzloff has not made any
known appearances or substantive statements in these cases yet, so it is presently unknown whether
12
he is qualified or motivated to analyze all the factors involved here and to determine the types and
13
amounts of hazardous materials existing here, and their effects on Remington or Mathsons real
14
estate values.
15
969. Maybe Retzloff will confound expectations and never join Gans RICO rackets. Gans
16 cannot succeed in corrupting 100% of his witnesses, but of course he can try. He selects them
17 carefully based on malleability, financial need, questionable integrity and simply put, some kind of
18 weakness in their ethical structures or compasses, and also somewhat by their reputation, no doubt;
19 however, Gans cannot be perfect in his selections. He probably makes some mistakes, such as Pulley
20 and Hubbard (Mathsons unfortunate choice, not Gans) come to mind, and some of his experts
21 may not agree to LIE for them, as needed, as per the several possible or presently only hypothetical
examples provided herein. Actually two of Gans present weakest links, or both of the Mathsons for
22
the reasons fully outlined in these documents, which will become much clearer during their next
23
depositions.
24
970. In other words, it is conceivable that Retzloff wont lie, deceive or misrepresent under
25
oath, or when he inevitably will be asked to do so, conceivably he will refuse. We just dont know
26 anything about him today. Therefore, he is not a present RICO enterprise member, associate, or even
27 presently necessarily expected to join the enterprise, until we see exactly what he is planning to say in
28 these cases, what that is based upon, and what hes willing to actually swear to at a trial, or during
federal discovery where prison terms are the possible price to pay for perjured, fraudulent and false
testimony written by Gans, with no regard for truth. Gans is rather like Trump in his belief in
alternate facts. Remington rejects that philosophy and will endeavor to prove that in this case there
50
1
are true honest facts, falsehoods and lies, and perhaps some gray areas in between the two, which if
2
so they must be supported by other real facts, honest and correct logic and good-faith explanations as
3
opposed to fraud and deception. Therefore, today we just dont know what any of his positions are,
4
truthful or clearly their opposite, so he would not be named as a RICO enterprise member, until the
5
FAC at the earliest, and hopefully never. See 3Z For additional details.
6 971. Gary Evans of Eureka is believed to be another local Mathson drinking buddy,
7 fellow user, possibly another ex-pulp mill union worker, who would probably give his life to
8 Mathson to make sure that he wins this case. Evans apparently lived somewhere along Westgate
9 Drive at one time, and reportedly watched Remington work with the Mathsons, from their hillside
10 lawn chairs, while drinking beer and smoking dope in the evenings, presumably after working at
11 their soft pulp mill jobs. In other words, just relaxing, and having fun while Remington risked his life
on the dangerous, opposite mountainside developing his property. Evans was originally supposed to
12
testify regarding when Remington did various developments, including grading his land and building
13
an agreed fence along the properties approximate boundary lines, as understood by both parties. He
14
has been designated to testify about that and nothing more, however Remington will now be shocked
15
if he doesnt multiply that disclosure by about 100 times.
16 972. After the August 2016 trial, the problem with Evans is that he appears to be 110% under
17 John Mathsons and Gans control and influence and is therefore believed willing to swear to literally
18 anything Gans conceives, writes-up for him and coaches him enough, so that he memorizes it. As
19 long as it is favorable to Mathson, detrimental to Remington and generally mischaracterizes the true
20 facts here, then it is ready for a Gans-produced and directed performance in front of the jury. See
21 Remingtons RICO statement at 3Z-1 for a few additional details
973. Today, Evans has no known function or cognizable testimonial purpose known to
22
Remington, but Gans undoubtably has other ideas, so we will attempt to discover what those are with
23
motions to compel, because Gans has never revealed any useful, helpful or Discovery-required
24
details about anything, unless forced to do so by a court, or by fear of said court.
25
974. RICO conspiracy, agency and relationships. At all relevant times, each and every non-
26 party RICO defendant named in the paragraphs above was acting in concert with, as an agent for, or
27 as a direct instrument or independent contractor for, or employee of, one or more of the above-named
28 RICO defendants; and, further as described in more detail below and in the accompanying RICO
statement, conspired with one or more of the other primary RICO defendants to perform the acts
averred herein. The same would apply to the named RICO defendants with respect to Gans, and each
other, as would be obviously inferred from their relationships and functions for which they were
51
1
hired, by Gans. Gans did not take control over this litigation and massive cover-up until 2006-2007,
2
so earlier than that the environmental defendants masterminded and executed their own different
3
criminal conspiracies as fully outlined herein, and did a fine job on their own without Gans
4
leadership. As explained, Gans deceptive and unethical defensive litigation practices did not become
5
a RICO extortion racketeering enterprise until Mathson and his mens property destructive crimes
6 had become well-established and successful, and Remington has estimated that did not occur until
7 its obviously criminal groups began in about 2011 to March, 2013, and thereafter flourished through
8 spring 2013.
9 975. Most, but not all of both types of RICO defendants above worked directly for Gans and
10 followed his express specific directions, however there are a variety of obvious exceptions,
11 especially where intermediaries such as Brisso, Plotz or McBride issued the specific orders in
question directly to the RICO racketeering members and soldiers, but which orders were originated
12
by Gans and his top RICO brain trust. See RICO Statement for more on all, plus See GANS RICO
13
ENTERPRISE ORGANIZATIONAL CHART-2017.
14
15
SUBJECT MATTER JURISDICTION AND VENUE
16 976. This court has subject matter jurisdiction over Remingtons claims under 28 USC
17 1331 and under 18 USC 1964 (c). Remingtons first claim for relief arises under 18 USC 1961 et
18 seq., as hereinafter more fully appears. There is also minor diversity of citizenship between the
19 parties, and the amount in controversy exceeds $75,000, exclusive of interest and costs. Remingtons
20 RICO, state, county contamination law claims all arise out of the same case or controversy as its
21 federal law claims, as all claims in this action ultimately arise out of a common nucleus of operative
facts originating around 1998, but thereafter have morphed into successive continuing action
22
claims. Thus, this court also has supplemental jurisdiction over Remington state law claims under 28
23
USC 1367.
24
977. Venue is proper in this district under 28 USC 1391 (a)-(c), as All of the property that
25
is the subject of these actions is located in Humboldt County and the Federal Northern District; a
26 substantial number of the events and related issues giving rise to this action occurred in this district;
27 and, because all principal defendants and/or subordinate or likely defendants are residents of
28 Humboldt County, California; and also under 18 USC 1965.

52
1
PERSONAL JURISDICTION
2
978. Exercise of jurisdiction over Defendant Gans is reasonable and proper in this
3
district because: Gans is a citizen of the state of California and because he conducts extensive
4
business activities within the state. Gans is believed to be a partner or quasi-partner, although
5
unnamed in the partnerships heading of principal partners, in the above described Mitchell law firm,
6 which is located in and does business in Eureka, California, part of the federal Northern District of
7 California, headquartered in San Francisco. Through his activities in California, Gans has served as
8 the ringleader of this enterprise to defraud, extort, impoverish and ruin the health of Remington (at a
9 minimum), as explained throughout these documents, especially under objectives and damages, at
10 5D in the RICO statement. Analogously to a Mafia Godfather, Gans always works very closely with
11 his other RICO defendants and/or the others mentioned herein in this action, and most of the corrupt
activities of the enterprise are carried out by the Enterprises soldiers under direct orders, instructions
12
and/or individualized special situations coaching from their leader.
13
Furthermore, Remingtons exercise of RICO jurisdiction over Gans for his violations of 18
14
USC 1962 and related California state laws is proper pursuant to 18 USC 1965 (a) and 28 USC
15
1367.
16 979. Exercise of jurisdiction over defendants Brisso, Plotz, Kloeppel and McBride is
17 reasonable and proper in this district because they are ALL citizens of the United States, permanent
18 residents of California and because they conduct very extensive business activities within the state.
19 Both Brisso and Plotz are important, influential confidants, advisers to and direct helpers for Gans
20 as needed, and they both do considerable motion writing, in both make frequent hearing appearances,
21 all of which requires intimate knowledge of and complete familiarity with the enterprises corrupt
purposes and objectives, including all operating details masterminded by Gans, and substantially
22
executed in 2016 by Plotz and others. McBrides crucial and pivotal role was fully explained at
23
RICO statement 2J, around pages 162-4. Kloeppels less significant, but still pivotal, role was also
24
explained with particularity at pages 164-6, to the extent that it has been discovered to date.
25
980. Hence, Brisso and Plotz are equally responsible and culpable here in initiating and
26 knowingly carrying-out the Enterprises specifically described racketeering objectives against
27 Remington. They both engaged in intentional, wrongful, illegal and/or tortuous acts which they knew
28 or should have known, would severely and deleteriously impact Remington and his entire family, the
Burl Tree and eliminate any possible semblance of justice here in these cases. That is what the
enterprise requires and needs in order to prevail in accordance with their objectives. The same
especially applies to McBride, since she is totally on the inside as much as anyone could possibly
53
1
be, but also applies to Kloeppel because he is in actuality a sophisticated attorney who really knows
2
whats going on, despite possible appearances to the contrary, as well as he obviously should
3
know, for the numerous reasons provided above and also herein.
4
981. Therefore, for Remingtons RICO claims against all named Mitchell attorneys, and
5
McBride for violations of 18 USC 1962 and California state laws, exercise of jurisdiction over
6 Brisso, Kloeppel, McBride and Plotz is proper pursuant to 18 USC 1965 (a) and 28 USC 1367.
7 982. For the exact same reasons enumerated in the two previous sections above, exercise
8 of jurisdiction over defendant The Mitchell firm, which LLP law firm entity is defined above,
9 is similarly reasonable and proper under the authority of 18 USC 1962, the relevant California
10 state laws and Humboldt County regulations cited, and under 28 USC 1367.
11 983. Exercise of jurisdiction over RAO, Olson, Skillings, and more than likely Larry Kluck
imminently and almost certainly going forward, in the upcoming FAC, is similarly reasonable and
12
proper under 18 USC 1962 and 28 USC 1367, in this District because they are all long-time
13
citizens and residents of Humboldt County in California, and because they all conduct extensive, and
14
probably all of their, business activities in this California Federal Northern District, or at least Cutten,
15
California is the center of their operations in the event that they invest their unjust profits out of state.
16 984. The above cited group in collusion with the Mathsons, started this whole controversy
17 around 1998, and now are the chief co-conspirators along with Gans, sworn amongst themselves to
18 absolutely guarantee that their dirty, criminal, buried secrets stay buried permanently and away from
19 any scrutiny, discovery or view by anyone, especially by Governmental regulators or the hated
20 Remington.
21 985. It is a proven and unfortunate fact that defendants buried various toxic, dark ugly secret
hazardous wastes in their dump on both properties, many of which, but certainly not all, have been
22
identified and complained about. Whether said secrets involve any human skeletons, biological or
23
radioactive hazardous wastes, or are merely very unlawful leaking, rusted 55-gallon drums of
24
hydrocarbon saturated soils removed from the gas station remediation projects along Broadway in
25
1998, and clandestinely trucked to Mathsons property, for the extremely profitable reasons described
26 above, has yet to be conclusively and finally determined.
27 986. All of the above named RICO enterprise members, RAO, Olson, Skillings and also
28 Kluck, have engaged in multiple intentional, wrongful, illegal, tortious (and also torturous) and/or
RICO predicate acts which they knew or should have known would severely scare Remington,
damage him and generally cause grave harm to his estate and especially to the business property and
inventory, owned by the Burl Tree.
54
1
987. Said RICO enterprise members have acted independently since 2012-13, through their
2
co-conspirators and under Gans direction, as Gans (only) receives all served lawsuit documents,
3
schedules, court decisions and communications with Remington and then provides them directly to
4
Kluck, the other RAO defendants and to all the other named and unnamed defendants in both
5
portions of this lawsuit. The precise activities over the last four (4) years of Olson, Skillings and the
6 other inferred RAO DOE defendants will shortly be discovered, to determine the relative proportions
7 of their independent corrupt acts, as compared to exactly which criminal activities were directly
8 ordered by Gans in his Mitchell firm associated RICO leadership.
9 988. Exercise of jurisdiction over Jeff Nelson as an individual is reasonable and proper in
10 this district because he is a long-time resident of the Northern District of California, and he is
11 expected to remain so. As above, 18 USC 1962 and 28 USC 1367 apply to Nelson.
A. As rather thoroughly explained above and at 2I, beginning in 2012, after John Aveggios
12
untimely death, Nelson has successfully attempted to make Remingtons life a living nightmare by
13
first allowing his replacement Mike Foget to get fully and totally involved here as Remingtons
14
environmental expert, and then suddenly breaching our contract and removing him for no legal or
15
reasonable reason. Foget Was very excited by the work and the new challenges of learning the
16 intricacies of litigation support and Nelson further encouraged Remington to get excited by Fogets
17 new ideas and enthusiasm, over the period of about two years. Foget alone wasted much more than
18 $15,000 of Remingtons time which Remington had spent, without limitation: In the consolidation,
19 condensing and reviewing of Aveggios work for relevance, significance, continuity and future
20 continuations; Determining where Foget was seriously deficient as to testifying at depositions and
21 trials in a proficient and exemplary manner, and identifying where he needed major remedial
training; Determining exactly which specific parts and passages of all Aveggios numerous written
22
documents and depositions needed to be studied, and almost memorized by Foget for trial and his
23
deposition, WHY, and what we could do to improve upon that testimony; determining what kinds of
24
books, YouTube videos, and personal practice sessions Foget NEEDED in order to get up-to-speed
25
on trial and deposition tactics for environmental expert witnesses, and how to appropriately testify in
26 front of a local jury; and in the planning and scheduling of more visits, future testing whenever that
27 might be allowed and what OTHER toxins we would still like to test for; planning what to do about
28 the contaminated water with regards to capturing and treatment methods, where that would be done
who would design the systems and at what costs; and, probably more time-consuming than anything
else were Remingtons complex and lengthy at least 3-4 different, vehemently contested, Foget-
related trial motions, to substitute him into the cases and then to request additional testing of his own,
55
1
which requests as to additional testing were essentially denied by Judge Reinholtsen, and therefore
2
had to be reiterated and reinitiated several different times, increasing the complexity and convolution
3
of Fogets brief and highly wasteful foray into these cases, exponentially, etc. Gans battled against
4
Fogets entry into the case like it was the Battle of Gettysburg, knowing that if he could block
5
Remington from having any environmental expert at all, the case would instantly be over. In other
6 words, Nelsons tortious breach and abrogation of our litigation support contract with SHN caused
7 extreme damages, far beyond what Nelson pretends to understand at this point, but which Gans
8 understands all too well, and eventually so will a federal jury.
9 989. As outlined above, from 2012-2014, Nelson was conspiratorially and corruptly involved
10 with Gans and improperly influenced by his enterprise, as explained. Gans had been fully defeated
11 by Aveggio and understood that if he could not get rid of Foget, just as Aveggio was lost, then
Remington would have to give up his entire defense. Intimidating, extorting, bribing or otherwise
12
improperly influencing Nelson was a stroke of genius by Gans and was extremely effective. It greatly
13
damaged Remington and the Burl Tree by apparently eliminating Remingtons last possible credible
14
environmental expert in this area which although not yet fully successful as explained above,
15
nevertheless Gans collusion with Nelson had very predictably adverse effects and impacts on the
16 prosecution of Remingtons lawsuit, and caused Remington grave anxiety during the substitutions of
17 Foget and Dr. McEdwards, and all those surrounding problems, which caused the numerous types of
18 damages explained above, and throughout these documents, many of which emotional, consequential
19 and special damages are continuing and not yet fully recovered from, as will be determined and
20 summed up at a trial.
21 990. Even today, Gans is still attempting to bar any and all of Aveggios brilliant work from
the next trial in any form, and he has now successfully prevented Aveggios good friend Foget from
22
communicating with Remington and from interpreting and authenticating Aveggios work plans or
23
even identifying his handwriting. Nelson has strangely backed-up Gans and thwarted both
24
Remington and Fogets emotional and related just and reasonable desires to vindicate Aveggio and
25
all of his work and make sure that he did not die in vain, essentially. Some of the last and best work
26 that Aveggio did in his lifetime was at the Remington project in 2011. Nelson now fully controls
27 Foget like a Negro slave, and extensive discovery is now going to probe that relationship and to what
28 extent Gans was responsible for it, because in either case, it was and still is very damaging to the
Burl Tree, as explained. Now, going forward, under federal law, if either Gans or Nelson denies
under oath in their special interrogatories that they did not have the above alleged interactions, they
will open-themselves-up to severe federal penalties, as fully described in the RICO Statement. We
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1
expect to be able to prove a lot of the truth here, early-on, with some of the lower echelon witnesses
2
involved here, who are not yet sufficiently implicated here that they would be afraid of prison if they
3
decided to tell the truth from the beginning. There are about a dozen such witnesses at this time,
4
some of whom have been described in these RICO documents, and others are likely to unexpectedly
5
come forward.
6 991. Finally, as alluded to above, serious damages have been incurred here in this SHN fraud
7 and expert witness disaster, but so far are probably only in the mid-five figures range, however were
8 Remington and the Burl Tree to lose any of these contamination cases and then be subjected to and
9 lose malicious prosecution and punitive damages of some sort, plus legal fees, Remingtons losses
10 and provable damages against SHN in particular, could easily rise into the 6-7 figure range,
11 according to proofs to a San Francisco jury. Therefore, as stated above, exercise of jurisdiction over
Nelson is reasonable and proper in this district.
12
992. Exercise of jurisdiction over the vandalistic, psychopathic felon John Mathson is
13
reasonable and proper because he is a California resident who is believed to have never been
14
substantially out of the state or past Oregon. As above, 18 USC 1962 and 28 USC 1367 apply to
15
his jurisdictional culpability.
16 993. John Mathsons serious continuous criminal activity and collusion with the entire
17 racketeering organization, especially the experts and his fellow perjuring drinking buddies and
18 alleged users has been emphasized here, throughout these documents.
19 994. In summary, Mathson has for many years, continuing into 2017, engaged in more than
20 150 intentional, deliberate, wrongful, illegal, tortious, extortive, intimidating, slanderous, exactive,
21 etc and/or blatantly RICO predicate acts, which he and his wife both know would justifiably scare,
anger and hurt Remington, his wife and grandkids, emotionally, physically and also irreparably
22
damage the Remingtons image and reputation in this community.
23
995. Those same acts which damage Remingtons family as described also injure the Burl
24
Trees land, gardens, fences, large residential offices and structural-complex, and his entire estate
25
accordingly.
26 996. Eventually Mathsons and defendants contaminated soils, water, asbestos, etc. will be
27 removed at their expense, but stigma and damages to the estate itself and its eventual marketability
28 may have been in alterable he and irreparably damaged, probably permanently. Mathsons soils and
poisonous waters can be removed, cleaned-up and remediated, whereas the damages to Remington
and the Burl Tree business in the community, due to defendants corruption, bad faith, slanderous and
libelous public statements and lies that all Remingtons burls are contaminated, along with the entire
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1
estate, broadcasted bad feelings, and similar nasty untrue accusations in the community etc, can
2
probably never be fully undone, at least in Remingtons lifetime. Since 1998, defendants, and all of
3
them, have accused Remington of poisoning, damaging and otherwise threatening the health of the
4
community with his contaminated burls, when hypocritically, and in reality, it is the Mathsons that
5
are poisoning all nearby residents with the asbestos, toxic vapors and contaminated waters discussed
6 at length, herein.
7 997. Exercise of jurisdiction over defendant Linda Lawrence is applicable, reasonable and
8 proper for the same reasons as for those above. She is believed to be a long-time and continuous
9 resident of California, and therefore she, or any possible replacement, is also liable and sue-able
10 under 18 USC 1962 and 28 USC 1367.
11 998. More details about what we know about Linda Lawrence are discussed at 2B around
pages 94-108. Although we need vastly more discovery from her, at this point it is obvious that she
12
is intimately involved with plotting and executing Gans strategy and according to Gans (see RICO
13
Statement) her only serious reservations about these lawsuits are that it is costing her too much, and
14
taking the enterprise too long to defeat Remington, to suit her. Gans has probably conned-her and
15
duped her about many facets of these cases, however as explained, she is a highly sophisticated
16 executive and clearly knows about almost all of Gans corrupt, nefarious RICO acts in Eureka,
17 and otherwise she obviously should know and should have known about everything.
18 999. Gans has only one interest in these cases and that is to keep getting highly paid himself
19 for as long as possible, while likely presumably attempting to get the best possible result for the
20 Mathsons.
21 Lawrence is, and has been for many years, engaged in intentional, wrongful, illegal, tortious
and RICO federal predicate acts of mail and wire fraud, money laundering, obstruction of justice,
22
accessory to multiple related felonies, and the other acts alleged throughout these documents, which
23
acts continue through January 2017 as discussed in much more detail at RICO Statement, 2B.
24
25
FACTUAL BASIS FOR CLAIMS
26 A. Background
27 1000. One sentence summary of RICO case. This RICO portion of Remingtons 2017
28 federal complaint details how since about 2012, Gans, defendants and their cadre of ordinary,
innocent-looking corrupt defense lawyers, environmental experts and technicians have perverted
this states legal system to defraud, extort, intimidate, bankrupt and thereafter destroy Remington, his
family and the Burl Tree (as explained in detail herein), in order to steal his land, avoid all back-
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1
rent, retaining wall and cleanup costs, as well as force the Remingtons to drop their just
2
contamination cases to avoid total, devastating financial ruin or possibly physical violence.
3
Proofs of many of the quotations and/or other evidence included herein were capturedAnd
4
contemporaneously documented in many ways including, without limitation: On hundreds of hours
5
of surveillance camera videos; micro audio during about 100 days of 2016 pretrial proceedings and
6 related corridor interactions; Recorded in the Burl Trees extensive chronological, daily business
7 records; derived directly from more than 1000 deposition pages from the parties and experts from
8 both sides over seven (7) years; reconstructed from many thousands of words of expert declarations,
9 again from both sides; quoted from word-processed 2016 hearing transcripts; and, also copied
10 directly from about 20,000 pages of defendants own motion documents, emails, letters,
11 transcriptions from verbal statements from numerous hearings, phone calls, personal meetings or
defendants witnesses trial testimony; and from numerous other material trial evidence, many
12
thousands of photos, more than 100 sophisticated and scientifically accurate expert-testimony trial
13
charts, other documents, other informed percipient witness, electronic sources plus extensive
14
information on the above from the internet.
15
1001. Short history. Almost 10 years of litigating this dispute has produced the cited
16 evidence and predicate acts, condensed into these presently-filed 1000 or so pages, however
17 considerable additional discovery has now begun in order to further define all of the relationships
18 between the defendants and associates named herein. Until August 2016 these cases were on track
19 for a just resolution by a jury, but now Gans blatantly corrupt Mafia-like intimidations, bribery,
20 intimidation, inferred improper influence of a Superior Court judge, and absolutely known and
21 provable suborning of perjury among five coordinated witnesses, pursuant to his carefully crafted
scripts, well-coached and memorized false narratives of all important 2016 SOL case issues, has
22
dropped defendants Gans and Plotz led defense to an all time dark, dirty and criminal LOW level.
23
1002. That Gans approach, new path and now unavoidable method of resolution is not to
24
Remingtons choosing or liking, as he prefers the most beautiful, honest and highest forms of art,
25
music, literature, and the ideals of legal justice, decency and fair play, which are unfortunately
26 entirely unknown to defendants RICO enterprise and their nefarious objectives which now go far-
27 beyond just defeating Remingtons just contamination cases. However, now that Remington has
28 been mercilessly, ruthlessly and preemptively attacked, like at Pearl Harbor, only with invisible
nerve gas as defendants primary weapon of choice, now we must put-on our expensive gas masks
and total breathing and 100% skin-protective apparatus, suitable for a spacewalk, and then wallow

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1
with the pigs, in Gans horrors, Skillings and Mathsons ruthless, violent, continuous property
2
damage (or worse), and the constant fear of same for all of Remingtons family.
3
Today, it is more likely that after 10-15 years these cases will be resolved through physical,
4
violent retaliations against Remington to shut-him-up, incapacitate him and block most truthful
5
evidence, at the expense of any legal justice for Remington and the Burl Tree.
6 1003. Defendants predicate acts, and corrupt objectives are fully set-forth in detail
7 in the 738-page RICO Statement at the pages set forth on the next page, and herein.
8 A. Gans and defendants detailed ruthless and corrupt campaigns to win all of these cases
9 unconditionally through the use of extortion racketeering tactics are very fully detailed in the RICO
10 statement, which is herein incorporated by reference in its entirety, although written over several
11 months of changing and constantDiscovery of new previously partially forgotten facts and deepening
understandings of Gans racketeering conspiracies.
12
1004. Specifically, see pages 324-356, for a 32-page generalized statement of the types
13
and categories of crimes committed by Gans enterprise and generally who committed them,
14
drafted several months ago, but only partially superseded.
15
A. Next, see separate 132-page stand-alone document from November 2016 entitled:
16
Chronological Pattern Of Predicate Acts From 2012-16, Dates And Background,
17
at pages 356-488, as of January 2017.
18
1005. That latter 132-page document is still the best chronological history of the RICO
19 enterprises corrupt activities over the last four years, although it too has been partially superseded
20 as additional new corrupt facts, details and events occur or are discovered virtually every day. NEW
21 corrupt and fraudulent facts and additional examples of federal mail fraud especially, as they are
22 discovered in the files, have been provided elsewhere, herein, and particularly in the higher page
23 numbers in the RICO Statement drafted in December 2016-January 2017, as they were discovered
5
24 and/or remembered .
1006. Said particularized RICO statement, incorporated by reference into this
25
paragraph, specifies many of Gans Enterprises corrupt transgressions, including without
26
5. Due to the obnoxious propensity of the long RICO statement to crash approximately every five
27 minutes, under the specialized programs Remington employs and the almost automatic crashes when
28 Remington attempts to toggle rapidly through the document at 50-100 pages per second to insert a
new fact or incident in the proper consistent position with respect to the defendant involved or the
subject category, Remington has eventually had to do his last final updates in early March 2017 in
the last pages of the RICO statement and not scattered throughout, which wouldve been preferred,
and perhaps a superior and clearer organization. It is just not possible to use these highly specialized
programs that way so Remington was unwillingly forced to do it the way it appears herein.
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limitation: Numerous lies to the courts, both orally and written, including declarations,
2
promulgated as to all issues; MAIL and wire frauds; the obstructions of justice specified; the specific
3
instances of extortion against Remington, Figas, Tidwell and other Remington witnesses; extensive
4
and pervasive, serial perjury and suborning of perjury; intimidation, coercion, exaction and fear
5
promoted; witness tampering, involving all of their witnesses and several of Remingtons; serial,
6 repetitive and continuous felony vandalisms; extensive theft and destruction of Burl Tree property;
7 material evidence spoliation throughout Remingtons property; money laundering; sale of controlled
8 materials; destroying most of Remingtons relevant civil rights, etc.
9 1007. RICO objectives reiterated. The clearly articulated, strongly inferred and ALL fully
10 and provably acted-upon purposes and objectives of Gans RICO racketeering enterprise, pursuant
11 to Remingtons RICO statement 5 (d), are:
1) Defendants illegal hazardous waste dump can and MUST remain on Remingtons land;
12
2) Defendants will not incur any costs for its removal;
13
3) Defendants will therefore get all of, i.e STEAL Remingtons encroached-upon land free,
14
without ever paying any present or back RENT, and without ever being forced to buy said
15
land which they use, and have heavily used, as if they had owned it for the last 30 years;
16 4) As a result of defendants massive encroachment and major land theft of crucial land needed
17 to stabilize Mathsons entire property, they will avoid all criminal culpability for such theft and
18 not have to go to jail for their present RICO criminal coverups;
19 5) All of the RICO enterprise leaders and soldiers will continue to make high salaries and have
20 all of their lavish expenses met at Remingtons expense eventually and indefinitely;
21 6) Above all, the enterprise is dedicated to eventually entirely crushing and ruining
Remingtons family personally, and driving them forever from this area simply out of spite,
22
because he stood up to them for what is right;
23
7) After Remington gives-up and is driven away, then defendants intend to sue him for
24
malicious prosecution and the recovery of all of their costs, expenses and attorneys fees in
25
these cases since 2008, for the insult of standing-up to the bully, for what is right.
26 1008. Gans basic method of operation. Under the pretense of legality, Gans defense has
27 become entirely corruptly based in focus, as described in extensive detail in the 570+-page RICO
28 statement. As fully explained there, Gans enterprise does not operate 100% with criminal acts, But
possibly only 20% severe illegality. They mislead, pretend to be mostly following the law, which
mostly they are even if deceptively, deceitfully and unethically; meanwhile they continuously distract
and deceive Remington and the courts from noticing and proving that a large percentage of their
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1
overall activity is corrupt and in specific violation of the federal predicate acts cited herein. That
2
entirely pervasive defensive fraud and corruption practiced-in and illicitly condoned-by the state
3
court caused Remington to remove these cases the federal court in order to get honest, ethical,
4
focused and more intelligent adjudication. See also GANS RICO enterprise organizational chart-
5
2017.
6 Gans, Skillings, Mathson, Plotz, Brisso, and Kluck, et al, have all systematically extorted
7 Remington especially in 2016, by numerous specific threats and destructive acts, intended to
8 continue their reign of terror forever, and reach their objectives just re-summarized at number
9 1007, above. As stated there, Gans enterprise will absolutely not rest until: Remington gives up his
10 cases; settles for nothing beyond avoiding the pain and expense of Gans future threats of malicious
11 prosecution and punitive damages; permanently and with his blessings gives-up all of his very
valuable, owned land north of Remington Creek to defendants, purchase and rent free; forgives 19
12
years of back rent worth $228,000 and increasing; stops demanding that defendants clean-up their
13
dumped hazardous materials on Remingtons land, plus their own; and eventually moves from the
14
street, so defendants lawless, hedonistic, lower-class gangs can control the community, without
15
upward mobility pressures.
16 1009. Injuries and harm. Remington and his business the Burl Tree which owns virtually all
17 property at 832 Westgate Dr., have suffered substantial damages as a result of defendants RICO
18 conspiracy, which damages continue daily.I
19 A. Specifically, see the categories of relief requested at the end of this complaint, and at the
20 end of the RICO causes of action and in the RICO statement at 15, 16 and 17, about pages 501-513.
21 1010. Overview of federal civil RICO law. What are the necessary salient elements common to
all RICO violations, do they exist here and has Remington properly alleged them?
22
1011. Congress passed the Racketeer Influenced And Corrupt Organizations Act (RICO) as Title
23
IX of the Organized Crime Control Act of 1970, a comprehensive legislative package aimed at
24
combating the influence of organized crime on interstate commerce. The broad scope of the RICO
25
statute however, has allowed it to be applied far-beyond conventional organized crime to reach
26 nearly any circumstance that involves long-term criminal or fraudulent conduct, including the types
27 of circumstances alleged herein.
28 1012. Section 1962 of RICO generally outlaws four types of conduct involving a pattern of
racketeering activity, only two of which are presently alleged herein until the extensive discovery
now underway has been completed. The two now alleged here, are under 1962 (c) and (d). Section
1962 (c) prohibits a person from knowingly operating or managing the affairs of a separate enterprise
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1
through a pattern of racketeering activity. Section 1962 (d) prohibits a person from conspiring to
2
participate in an endeavor or scheme that, if completed, would constitute a violation of sections 1962
3
(a), (b) or (c). Gans, and his Mitchell firms operative criminal leadership have and continue to
4
operate an extortive racketeering enterprise collusively conspiring to achieve total victory over
5
Remington in these environmental lawsuits, in violation of 1962 (c), while destroying him
6 personally, financially and emotionally in the process.
7 1013. This civil RICO claim is brought primarily under section 1962 (c) which requires that
8 Remington prove by a preponderance of the evidence that: 1) the defendant is a culpable person
9 who willfully or knowingly; 2) operated or manage the affairs of an enterprise or association-in-
10 fact enterprise; 3) to commit a pattern of: 4) racketeering activity.
11 1014. Additionally, under section 1964 (c), a civil plaintiff may recover triple damages for injury
to his business or property by reason of of violations of sections 1962 (a), (b), (c) or (d). The
12
plaintiff must bring its RICO claim within four (4) years from when it discovers, or with reasonable
13
diligence should have discovered, his injury. These elements and issues are discussed in more detail
14
below and in much more detail in the RICO statement. Remington herein alleges that said RICO
15
defendants violated sections (c) and (d) of 1962 with the substantial portion of their defensive
16 litigatory activity which was clearly and provably in violation of the state and federal laws cited
17 herein.
18 1015. The Culpable Person Requirement. A plaintiff cannot prove a RICO violation merely
19 by lumping all of the defendants together as a group and claiming that said group collectively
20 violated RICO. Instead the plaintiff must establish by a preponderance of the evidence that each
21 individual offender qualifies as a culpable person who willfully or with actual knowledge violated
or conspired to violate the RICO statutes as fully and specifically designated. Section 1961 (3)
22
defines a culpable person as an entity capable of holding a legal or beneficial interest in
23
property, which definition would apply to all of the currently named 12 RICO defendants.
24
1016. Russell Gans is the undisputed leader, but he is far from being alone in his willful and
25
knowing criminal activity, as he has many other thoughtful top management Mitchell firm attorneys
26 and executives assisting him plus the leaders of or responsible employees of many additional
27 prominent local Eureka businesses, which have been variously named under defendants, other
28 wrongdoers and various near defendants or anticipated future defendants, when they begin their
deceitful defense which now must be consistent with their state case precedents, numerous errors and
very extensive perjury and Gans objectives, all of which sworn testimony and false facts are too late
to change now.
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1
1017. Each of the currently named 12 individual defendants, which includes one legal
2
partnership association, and one alleged Corporation (RAO) is an entity capable of holding a legal
3
or beneficial interest in property as defined in 18 USC 1961 (3), and therefore can be sued under
4
the RICO statutes cited.
5
1018. Each named defendant is an individual alleged RICO culpable person, however Gans
6 overall 40+-man illicit sham legal machine, which is in reality a RICO racketeering organization,
7 is not the culpable person or a real entity capable of owning land, or doing anything much as a large
8 group. The enterprise never acts in concert like an invading army, but merely chips-away at justice,
9 one or two acts, motions, opposition or perjuries at a time. Each culpable person and defendant,
10 operated or manage the affairs of this association-in-fact enterprise as they worked to achieve the
11 objectives of the enterprise by committing a pattern of racketeering activity, by committing
multiple 1961 unlawful federal and state predicate acts. A RICO racketeering enterprise is similar
12
to an individual in that a criminal can perform 500 consecutive honest acts in society and then
13
commit one arson, burglary, kidnapping or violent extortive act. At that time, that individual or
14
organization becomes a criminal and all of the good other acts are probably irrelevant to that
15
designation. Further, and analogously, obviously if an individual or organization commits 50 or more
16 extortive racketeering and additional criminal acts (over 4 years), performing 2000 noncriminal
17 administrative acts will not erase any of the criminal acts, or be a defense against being a RICO
18 criminal racketeering enterprise. Such is our situation here.
19 1019. For example, the Godfathers Mafia organization is an enterprise, but not a culpable
20 person. Individual criminal RICO enterprise family members must be analyzed in detail, one by
21 one, crime by crime, which has been done here now for the past six (6) solid months, and continues.
That process is quite complicated, time-consuming and can continue during March-April 2017 based
22
on the dozens of instances of federal mail and wire fraud alone, which are already in the files, but
23
soon are expected to multiply by at least 3-5, when written discovery commences to a large number
24
of enterprise members, associates and witnesses. More than 50 serious federal predicate acts already
25
exist in this case, however, during 2017, for the obvious reasons thoroughly discussed herein, MANY
26 more federal predicate acts of the worst magnitude are expected immediately, which presumably will
27 essentially dominate the FAC in this case around early 2018.
28 1020. Gans alleged RICO enterprise defined, as paraphrased from the RICO statement.
Gans extortion racketeering enterprise is a group of individuals associated in fact in the
manner prescribed by 18 USCA 1961 (4), as explained directly below.

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1
A. In Remingtons detailed RICO statement, he alleged in detail that each named defendant
2
participated in the operation of or management of a separate entity, portion of, or associated group
3
that qualifies as a RICO associated in fact enterprise.
4
1021. For a group to qualify as an association-in-fact enterprise, courts generally require; 1)
5
Some commonly shared purpose or purposes among the members of the group, which here have
6 been very specifically delineated and called the Enterprises purposes and objectives; 2) a continuity
7 of structure and personnel; and 3) an ascertainable structure6 distinct from merely joining together to
8 commit the pattern of racketeering. As argued and explained in specific detail in said RICO
9 statement, each defendant is distinct and different from the overall 40+ man enterprise entity. In other
10 words, each person and defendant is distinct from the enterprise itself. Gans is leading a group of
11 separate businesses and people to commit the overall pattern of racketeering, one crime of the time.
For example, the Mitchell firm itself is not necessarily the wrongdoer, but collectively most of the
12
important Enterprises leadership work at the Mitchell firm, to the extent that the firm itself
13
probably knows and certainly should know and should have known what was going on there.
14
Whether the entire firm ever meets in a single group is unknown and unimportant, and if it did meet
15
it is unlikely that Gans criminal RICO activities against Remington would be a topic of discussion.
16 On the other hand, it is unlikely that any Mitchell firm members would be completely oblivious of
17 this RICO enterprise, however it is possible and irrelevant to whether the Mitchell firms leadership
18 or most of its significant members were knowledgeable and active RICO members. In any event,
19 future discovery will reveal more about who knew what and when, but meanwhile it is self-evident
20 that most lawyers and other workers at the Mitchell firm WERE and still ARE known RICO
21 members, and since all other Mitchell firm members were intimately and continuously exposed to
all aspects of the RICO enterprises associates and specific nefarious work activities, it therefore
22
follows that ALL who worked in the Mitchell firms offices, could have known and probably should
23
have known, inferentially and in all probability based on a preponderance of the evidence, DID
24
KNOW about said RICO enterprise, but not under that name obviously. Ultimately it will be up to a
25
judge and jury to determine to what extent the Mitchell firm itself is liable separately from the
26
6. Gans Enterprises structure here is very clear and was described in detail at 6 (a-d) in the RICO
27 Statement. Other than the core leadership in the Mitchell firm, the enterprise consists primarily of
28 part-time consultants assisting Gans, as he specifically requests, see US v. Turkette, 452 US 576,
583 (1981). Remington has drawn-up 3-4 RICO Enterprise organization charts, authority flow
diagrams and one federal predicate acts circular diagram which shows how the integral RICO
leadership of Gans, Lawrence, Mathson, Skillings, Brisso, Olson, Plotz and sometimes others commit
specific crimes which immediately damage Remington and his business property as shown. Some
of those charts are attached with the photographs in volume III, and others will be available for trial.
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1
individual members of its obvious integral leadership, which has been fully discussed. Hence they
2
are also named as a defendant, however they are not the enterprise itself. In this example, The
3
Enterprise is like an independent monster which lives and sleeps in the Mitchell firm building, uses
4
its electricity, toilets and heat, but is not identical to the building itself, or its ownership for that
5
matter.
6 1022. Besides establishing the existence of a separate enterprise, a RICO plaintiff must prove
7 that each defendant participated in the operation or management of the enterprise. Simply
8 performing services for the enterprise, even with knowledge of the illicit activity, usually is not
9 enough to establish liability under section 1962 (c); rather, a RICO plaintiff must prove that each
10 defendant actually intellectually participated in the operation or management of the enterprise, see
11 Reves v. Ernest, 507 US 170, 185 (1993). That has already been done in the RICO statement and will
continue to be further developed during discovery.
12
1023. The key element: The Pattern Requirement
13
To prove his RICO claim, Remington also must prove that each defendant used, or worked
14
within the enterprise, to commit a pattern of racketeering. To prove a pattern of racketeering here,
15
Remington must show that each defendant engaged in long-term criminal conduct, as defined under
16 the criminal acts listed under 1961, that was both related and continuous. If those criteria are met,
17 then the next important characteristic to determine is whether the asserted pattern of racketeering
18 activity has sufficient closed-ended or open-ended continuity, HJ v. Northwestern, 492 US 229,
19 242 (1989). We have consistently alleged herein that Gans RICO racketeering enterprise has
20 exhibited a clear and presently continuing pattern of open-ended continuity.
21 1024. A closed-ended pattern is one in which a long-term series of predicate acts have
concluded. Whereas an open-ended pattern is one in which a lawsuit is brought before a long-term,
22
closed-ended sequence of acts can be shown, but where the plaintiff can prove that the scheme poses
23
a threat of continuity7, is also presumably then on-going, and that by its nature projects into the
24
future with the threat of repetition, ID, 241.
25
1025. In our case, we have four (4) years of provable predicate acts, with a sorted background
26 of related unethical and improper advocacy that goes back further, and precedes the RICO enterprise.
27 7. To determine whether defendants conduct constitutes a close-ended or open-ended pattern of
28 racketeering activity, a trier of fact may consider a variety of factors, including: 1) length of time
over which the predicate acts were committed; 2) the number of predicate acts; 3) with a variety of
predicate acts; 4) the number of participants; 5) the number of victims; 6) the presence of separate
schemes; and 7) the occurrence of distinct injuries, GICC v. Tech, 67 F. 3d 463, 466-68 (2nd 1995).
Of those factors, the duration of the conduct is probably the most important and courts repeatedly
reject RICO claims for the span of criminal acts is less than a year (cite).
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1
The present open-ended continuity is very much still in progress today and shows every indication
2
of continuing-on until all appeals are ended here, or Bruce Remington and his lawyer daughter are
3
dead. Originally drafted in September-October 2016, defendants pattern of racketeering activity
4
continued unabated another five months throughout the winter, and certainly through the end of
5
February, 2017 when this sentence is actually being written. As explained, Gans enterprise now
6 only knows one false direction, one corrupt, unethical deceptive, bad-faith litigatory style and one
7 criminal, unjust gear to get there; and, now to remain consistent with their prior 10-years of false
8 sworn facts and evidence, they literally have no choice but to continue their criminal predicate acts
9 until these cases or Remington end, one way or another.
10 1026. Racketeering Activity committed by defendants under the direction of Gans, and
11 his corrupt associates.

A. RICO plaintiff Remington most eventually prove by a preponderance of the evidence that
12
each defendant willfully or with actual knowledge of their corrupt acts committed a pattern of
13
racketeering activity as defined under Section 1961. 1961 (1) defines racketeering activity to
14
include a long list of state and federal crimes as potential RICO predicate acts.
15
1027. The first six (6) pages of Remingtons RICO statement discuss defendants specifically
16 and in detail alleged 16 specific categories of predicate acts ( 1515 is definitions), explained with
17 particularity, in the 738-page statement with respect to the exact dates, specific circumstances (place)
18 and the alleged specific defendants involved in each individual specific alleged criminal, illicit or
19 corrupt act.
20 1028. It is impossible for Remington to concisely summarize the criminal acts which
21 defendants have committed here in the last four years, and as is now apparent, it took him almost
550-pages to explain them. However, if forced to provide an attempted one sentence summary of
22
the general continuity of the primary defendants harmful acts it would be, something like: Gans
23
attempted extortion, exaction, improper influence, fraud and unlawful intimidation of Remington,
24
while Mathson, Skillings and the numerous other enterprise soldiers applied continuous, daily, major,
25
literally unbearable destructive pressures on the Burl Trees property and Remingtons time and
26 waiting energies, involved most fundamentally Gans actually stated, to Remington in so many
27 words, quid pro quo that: THEY are very angry with you and therefore obviously they will
28 relentlessly continue to harass, extort and destroy all of your development, until you unconditionally
surrender and give-up these lawsuits on our terms, with all of the rest directly implied, as
explained under the Enterprises objectives.
1029. Mail and Wire Fraud in violation of 18 U.S.C. 1341 and 1343.
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There have already been numerous acts of mail and wire fraud alleged herein already with
2
another 20-40 or more anticipated to be easily recovered from the tens of thousands of pages of case
3
documents, when time permits, or if necessary. Remington does not expect to spend another several
4
hundred hours doing so automatically yet, because it is very clear that federal production of
5
documents, after several years of motions to compel, will produce many more MAIL FRAUD8,
6 smoking guns which are more important than anything yet existing in the files today. A RICO
7 racketeering law firm is above-all careful in what they write and obviously they are not going to
8 voluntarily release any documents at all which inferentially might send someone to prison. Hence,
9 90% of this lawsuit over the next several years will probably involve attempting to locate
10 incriminating documents from ancillary participants, before the major named defendants are able to
11 collusively purge their phone, email and filing records, and essentially attempt to conspiratorially
destroy all written documents, which would be incriminating. Therefore, since incriminating emails,
12
letters and written plans will be obviously hard to come by, extensive depositions of all RICO
13
members, while forcing them to bring and produce all of their relevant documents that they have
14
received from and sent to the enterprise leadership, will of course be important. Forcing criminals to
15
talk and reveal or keep from destroying documents which may send them to prison is not
16 Remingtons primary strength or interest, hence he does anticipate employing an attorney that likes
17 kicking ass and explaining to witnesses why it will probably be more in their interests to tell the
18 truth than to lie. Also, obviously having the right tough federal judge overseeing all this will be
19 crucial. Defendants need to fear someone here, and that clearly has not been Remington, as should be
20 obvious in these hundreds of pages. On the bright side, however, from Remingtons perspective is
21 that Gans now has a literally impossible task of keeping all of his false facts and untruthful witness
statements consistent and exempt from now becoming additional imprisonable federal predicate acts,
22
so now it is just a matter of time and perseverance for Remington to complete the puzzle and
23
conversely to simultaneously to point-out and prove that even though Gans is frantically re-cutting
24
8. To prove a RICO claim based on mail or wire fraud in violation of 18 U.S.C. 1341 and 1343, a
25
RICO plaintiff must prove that each defendant intentionally engaged in a scheme to defraud and
26 used the interstate mails or wires to further that scheme. A scheme to defraud encompasses "acts of
artifice or deceit which are intended to deprive an owner of his property or money," (Vicom cited).
27 When pled as RICO predicate acts, the elements of mail or wire fraud have been identified as 1) a
28 plan or scheme to defraud; 2) intent to defraud; 3) reasonable foreseeability that the mail or wires
will be used; and 4) actual use of the mail or wires to further the scheme, Wisdom cite. The mailings
and wire communications need not be fraudulent in and of themselves; as innocuous or "innocent"
mailings and wirings are sufficient RICO predicates as long as they further a fraudulent scheme,
Tabas cited. This is because the crux of mail and wire fraud is a scheme to defraud, and the mails or
wires need only be used to carry out Gans (here) scheme.
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1
and repainting his hundreds of disparate puzzle pieces, they will never fit into the real picture here or
2
anything other than a great picture of a man standing behind the bars of a jail.
3
1030. Fraudulent Collusion and Conspiracy is alleged here under section 1962 (d) as well
4
as numerous state laws, under the environmental portions of this complaint.
5
A. Under 1962 (d), see also RICO Statement 14, page 655-656, RICO plaintiff Remington
6 intends to prove by a preponderance of the evidence that each culpable defendant knowingly agreed
7 to facilitate or participate in an endeavor or scheme that, if completed, would constitute a violation of
8 the RICO statute, see Salinas, 522 US 52, 65-66 (1997). In our case, many subordinate RICO
9 schemes have already been completed, and also many have been attempted, which are still in
10 progress.
11 1031. Each named RICO defendant, and each listed, named other prominent enterprise
member who eventually probably will be or may be named as financially responsible culpable future
12
defendants by the time of trial, need to have both agreed to participate in the alleged RICO
13
conspiracy with some knowledge of the essential nature of that scheme. It is not necessary that some
14
of the named defendants or minor possible defendants did not know all of the details of the scheme
15
or commit any of the criminal acts alleged, in furtherance of the scheme, Salinas, ID. Rather, it is
16 only necessary that a defendant must knowingly agreed to facilitate the activities of those who
17 operate or managed the criminal enterprise, the latter of which could be Gans, Brisso, Plotz,
18 McBride or potentially about a dozen others.
19 1032. Gans enterprise gravely injured Remingtons business the Burl Tree as alleged
20 herein and specifically in the RICO Statement 15-17, at pages 656-670. As further alleged, and
21 proven and all of these documents, as based on available discovered information to date, Gans
racketeering enterprise was the proximate cause of the Burl Trees injuries, and specifically as a
22
result of the numerous alleged violations of section 1962 (c). At RICO statement number 14, page
23
501, Remington also alleges that the overall RICO racketeering conspiratorial acts also contributed
24
to those Burl Tree damages, as apportioned in the following 12-13 pages9.
25
1033. Furthermore, for Remington to have the required standing under section 1962 (c), under
26 Holmes v. Securities, 503 US 258, 268-69 (1992), the Supreme Court ruled that the Burl Trees
27 injuries must be by reason of the defendants commission of the alleged RICO predicate act (s).
28 Additionally, that by reason of language requires that Remington show but for causation and
9. Simply put here, the Burl Tree owns all of the land, gardens and development at 832 Westgate Dr.
involved in this lawsuit and also owns about 95% (by value) of all of the extensive inventory and
large amount of personal, business, architectural and building materials, etc property on this site.
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proximate cause which depends primarily on the directness and foreseeability of the injury, and its
2
causal relationship to the injurious conduct alleged, ID.
3
1034. Reliance. Although Remington has an unfortunate, difficult to break habit of relying on
4
proper, legal or official-looking documents, letters and motions from Gans, the Mitchell firm and the
5
Humboldt County Superior Court, he has gradually learned, and by 2016 probably knows that
6 nothing from either source can be fully or always reasonably relied upon. As has been alleged here,
7 and as fully documented in these 1000 or so pages, based-upon the presently reasonably discovered
8 facts, Remington has recently become totally skeptical and suspicious of any document from said
9 above sources, and particularly from Gans enterprise. Fortunately, however reasonable reliance by
10 plaintiff on defendants fraudulent unlawful and criminal RICO conduct is not required to sue for
11 damages under RICO, see Bridge v. Phoenix, 128 S. Ct 2131 (2008), and also Holmes, Anza, etc.
1035. There has unfortunately been substantial detrimental reliance by others on Gans
12
RICO enterprise deceptions, material falsifications and perjury which damaged Remington, and
13
his business, however, and they would include without limitation: Judge Reinholtsen, Judge Watson,
14
the visiting Judge (Bream) that improperly allowed Esko into the case; The County Health
15
Department, numerous (35-40) other Northcoast governmental agencies, ranging from State Fish and
16 Game to the County Planning and Zoning Commission; and, last but certainly not least, the August
17 2016 SOL trial jury and about a dozen associated court staff members. Said associated court clerks,
18 guards and related staff all helped to improperly influence each other and the jury with respect to the
19 perceived but false veracity of defendants entire case and all of their positions, as well as to
20 successfully disguise and conceal the corruption and rampant, smelly criminality of their RICO
21 enterprise, which conducted the entire SOL trial, plus more than 100-previous days of largely
corrupted pretrial hearings. Specific examples of Gans most recent examples of blocking Superior
22
Court orders from being sent to Remington as ordered, and his even more blatantly corrupt, flagrant
23
mischaracterizations of California Supreme Court contamination law, which occurred on the
24
stenographic record on February 17, 2017, was described and complained about elsewhere in these
25
documents.
26 1036. Substantial amounts of interstate commerce were negatively affected and entirely
27 eliminated by Gans Enterprises injuries to Remington and the Burl Tree.
28 A. As established elsewhere, the Burl Tree is Remington and vice versa. Remingtons forced
defense of Gans frivolous retaliatory and preemptive lawsuit, and Gans scores of motions, hundreds
of other issues which all required huge daily expenditures of strenuously debilitating time to
defense; having to deal with John Mathsons and his criminal gangs continuous daily vandalistic and
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very destructive acts, requiring even more strenuous physical exertions; plus Remingtons partially
2
voluntary offensive lawsuits, effectively took all of Remingtons time for about 10-years and
3
counting, which was another major, extremely costly damage in addition to the numerous
4
complained of direct real and personal property destructions.
5
1037. Eventually, a jury will also be asked to determine whether any of Remingtons legal
6 time, money and energies was really voluntary when he was merely seeking the absolutely just
7 removal of defendants encroaching poisonous wastes which had to be removed to salvage the health
8 and most likely the very life of Remington and the community, plus (only) partially restore
9 Remingtons property value, which can now never fully recover due to real estate stigma. Stigma
10 will now require one last lawsuit after the property has been sold, if it must be sold below expertly
11 appraised value, as determined by 4-5 of the best local experts.
1038. The Burl Tree has lost an enormous amount of sales since the discovery of defendants
12
pollution in 2006. During 2006 and in the prior 20 years Burl Tree sales averaged approximately
13
$100,000 per year, and have been as much as $400,000 in a year. Today, and since about 2008, sales
14
have been roughly in the $4000 per year range. That is a drop of about $96,000 per year
15
attributable to these lawsuits, and Remingtons participation therein. Currently, Remingtons profit
16 margin is approximately 90% of gross sales, since he has zero logging, manufacturing, utilities,
17 personnel or overhead costs, but exact damages will be calculated during a trial and not 10 different
18 other times before that.
19 1039. As stated above and thoroughly established elsewhere, because the Burl Tree IS Bruce
20 Remington, and because Remingtons time has been 100-110% occupied full-time for at least 5-6 of
21 Remingtons recent man-years here, Remington attributes about $45,000 per year in lost sales to the
necessity to defend against Gans lawsuits alone over the past eight years. Although, arguably all
22
of Remingtons litigation time spent defending the Burl Trees property interests should be
23
recoverable, as well as loss Burl Tree profits, there are other assumptions which can now be made,
24
below.
25
1040. If only Remingtons time spent defending against Gans frivolous motions and lawsuit are
26 recoverable here, Remington would now argue, and rounding-down in defendants favor, that 8-10
27 years of diminished profits of almost $90,000 per year, would be calculated at about $720,000; then,
28 if that is divided by two to recover only defensive time but not offense case time, then only $360,000
in lost profits would be recoverable. Whether Remingtons paralegal or secretarial time is added onto
that number would be a matter for the trier of fact to determine at some later appropriate time, such
as during a federal trial.
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1041. According to those above calculations then, Gans enterprise directly reduced Burl Tree
2
retail profits by about $360,000 and wholesale profits by a total of more than $500,000, for a total
3
loss of sales PROFITS of $860,000, according to proofs. About $850,000 of that loss would have
4
been interstate commerce losses applicable here. Under the doctrine of RICOs treble damages, that
5
would be over a $2 million business loss alone. Not an enormous drop for the US or world economy,
6 yet catastrophic for Remington, the Burl Tree and his affected customers.
7 A. Clearly, Remington and the Burl Tree have sustained major injuries caused by Gans RICO
8 racketeering enterprise.
9 1042. Does plaintiff Remington meet RICOs standing requirements? [YES]
10 To establish standing for a civil RICO claim, Remington must satisfy four factors: 1) He
11 must be a person, which is apparent based upon the discussions in the RICO statement and
especially at 4, pages 305-307, describing the business victims, Remington, his family and the Burl
12
Tree; 2) who sustains injury, 3) to his business or property (or both in this case), 4) by reason
13
of defendants violation of 1962. Remington has conclusively argued herein that Gans
14
enterprise directly caused 100% of the complained of Burl Trees injuries from the direct causal
15
effects of their dozens of federal and state predicate acts, as described herein, with clearly no
16 material intervening factors.
17 1043. Further, as explained above, and in the RICO statement at page 656 and beyond, the
18 additional Burl Tree injuries sustained from the overt acts of the enterprise committed in
19 furtherance of their conspiracy, are a violation of 1962 (d) and are recoverable thereunder.
20 1044. Remington and the Burl Tree sustained a concrete measurable financial loss caused
21 by the enterprise. It is ascertainable, defined and includes Remingtons present inability to fully use
or transfer any of his property at all, because it is all impacted by Gans enterprise. Under the law,
22
Remington has a right to conduct business relations unhampered by the corrupt schemes
23
perpetrated by Gans organization, which are prohibited by the RICO predicate act statutes,
24
Mendoza v. Zirkly, 301 F 3d 1163, 1168 (9th C 2002).
25
Statute of Limitations.
26 1045. The US Supreme Court has established a four-year statute of limitations for RICO
27 actions such as this one. Here, four years is easily met and conforms with the worst and
28 independently verifiable predicate acts alleged in this case. Remington can and previously has pled
facts showing that the defendants fraudulently, cleverly, very well-concealed vital information
needed to bring this RICO claim any earlier, and Remington could not have discovered those facts
sooner, despite the exercise of reasonable diligence plus constant scrutiny.
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1
1046. That principle applies to various aspects of Remingtons asbestos claims and to its
2
burial, concealment, its dismissal as insignificant by Schwartz and Ferriman, and the fraudulent
3
out-of-time Blue Rock tests, to cite only two of the earlier frauds from 2008-2011, which presently
4
are not needed here to support a RICO cause of action. See the comprehensive RICO statement
5
which shows most presently recognized predicate acts organized by individual perpetrator,
6 chronology and several other organizational methods. Study of that document proves that there are
7 no statute of limitation issues here and this RICO action is timely under the controlling US
8 Supreme Court doctrine on the subject.
9 1047. OTHER relevant, important, gate-keeping RICO variables and considerations
10 needed to put Remingtons RICO claim into perspective, and to determine its validity, veracity and
11 justification for proceeding forward.
1048. Culpability. As explained throughout these documents and especially in the RICO
12
statement pages 10-94, Gans is the main culpable leader and acting-CEO of this enterprise, and like
13
the Godfather of a Mafia family he is ultimately responsible for every issued order and for every
14
criminal act conducted on his behalf, or in the name of the enterprise, by any of the 35-40 RICO
15
racketeering members. Since Gans issued the orders and condoned the criminal behaviors
16 complained of herein, then he might just as well have pulled the trigger, burned-down the building
17 or destroyed the Burl Trees business property himself, personally. See also GANS RICO
18 ENTERPRISE ORGANIZATIONAL CHART-2017.
19 1049. In the event of a federal civil or federal indictment, all of Gans top named assistants,
20 leaders, complicit law partners and associates, corrupt managers and violent enforcers would also
21 be implicated and charged, and each is separate from Gans enterprise, whether acting
independently or under specific orders. The Godfather, say Gans Corleone, is not the family or
22
the entire enterprise, just its leader. He is arguably the most guilty and worthy of the worst
23
punishment, because planning, financing and solving all necessary problems, in order to facilitate
24
the execution of serious criminal acts is required to activate the criminal organization to do
25
anything. Without the leader, many of the enterprise soldiers would languish into depression,
26 lethargic inactivity and then probably be forced by their wives or children to seek honest and
27 legitimate work. The enterprise leader motivates his men, feeds them, organizes them, teaches
28 them, sparks-them and essentially starts-them-up like an automotive ignition or ignition key.
Without getting overly philosophical, is the ignition key more important than the motor in the
criminal bank robbers getaway car? Probably not, but both are absolutely necessary and work
together just as this RICO organization divides up their labor and activities for maximum effect.
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Additionally, arguably, it is not the evil and criminal car or its key that commits the wrong, but in
2
actuality it is the human driver that has the evil intent.
3
1050. Consequently, here Gans Enterprise is like a car which Linda Lawrence paid for
4
initially, and now Gans, with a huge amount of help from his inner top leadership, gases-it-up,
5
makes sure the battery is charged, the ignition is good and then HE PERSONALLY turns-the key,
6 activating the corrupt RICO engine and vehicle, numerous times a day so that said car can do its
7 destructive and criminal acts against Remington. Arguably, the key, ignition, gasoline and engine
8 are not really criminally corrupt in a bank robbers getaway car, and it is really a criminal person
9 who activates all of those mechanisms which should go to prison, and not the car itself. Here, Gans
10 has plenty of human, high-powered attorney and scientific expert advice, and the other 11-named
11 defendants are not the enterprise either, without the brain and evil motivation of their leader. They
are just working within it, sometimes independently, but usually under direct orders from Gans, his
12
top assistants in the Mitchell firm, or from each other, as needed, under the hierarchical and
13
organizational plans graphically portrayed in Volume III of this document. Enterprise orders or
14
wishes are usually executed with some amount of individual discretion, because the majority of
15
the members are intelligent professionals capable of acting on their own volition, although 10-20 or
16 more of the lower soldiers do absolutely nothing on their own and get specific orders from Gans,
17 whom he usually intensely coaches, as all Gans enterprise members must carefully and
18 meticulously rehearse their testimony or planned actions with him, and then memorize his orders
19 and suggestions for proper regurgitation as needed, because just telling the truth is absolutely not
20 an option for any member of Gans enterprise. Several people, as named have been fired by
21 Gans for attempting to be forthright, and to tell the truth in good faith, but that does not work with
Gans, and inferentially right now there have been as many as 5-6 former enterprise members in
22
good-standing that have either resigned or been fired for refusing to commit federal crimes or
23
perjury under Gans orders.
24
Mental State, and The Intentionality of The RICO defendants Criminal Actions.
25
1050. Remington has pleaded herein, described and fully established the preliminary facts
26 that each defendant did knowingly engage in the corrupt conduct alleged and all defendants had
27 sufficient actual big picture knowledge of the overall illegal, corrupt objectives and illicit
28 activities of the enterprise, to fully establish culpability.
1051. Many of the lower-level operatives and even some of the more sophisticated
environmental experts and perjurious percipient witnesses may possibly not have been fully
apprised of all of the enterprises objectives as clearly as they are defined herein, however that is
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not fatal to a RICO cause of action here. Factually, it is well-known that most, and probably all of
2
the RICO defendants knew at least two of Gans most important objectives: 1) Make as much
3
money for themselves and Gans as possible, and 2) Do whatever it took, irregardless of what was
4
known to be the true facts and any oaths were said witnesses swore to tell the truth, in direct or
5
cross-examination, or in depositions and declarations, to professionally and discreetly, but
6 conclusively hurt Remingtons personal credibility, destroy his experts proofs and tests of the facts
7 which exist on the contaminated sites, all with the single-minded objective of damaging and
8 preferably destroying Remingtons entire case, irrespective of the fact that it was obviously just and
9 there is a massive amount of ultra-hazardous contaminated debris to remove. In many known cases,
10 but not in 100% of all cases that we have full knowledge about now, the total financial and personal
11 destruction, or annihilation of Remington, was deliberately intended and believed to be likely.
Obvious examples of that are fully explained in detail in the RICO statement, and would include
12
John Mathson, Skillings, Costa and Kishpaugh, and their absolutely known to be flagrantly false
13
sworn testimony. On the other hand, Pulleys trial testimony was somewhat more ambiguous,
14
truthful, unrehearsed and not clearly directed by the RICO enterprises corrupt leadership to fulfill
15
their objectives. Whether Gans explained all of his objectives to Pulley was not fully obvious and
16 also appears to be very unlikely from his fact-based testimony, which did not directly attack
17 Remington necessarily. As noted elsewhere, it was very wrong overall, however Pulley honestly
18 acknowledged what his work was and who gave him the wrong information, which he did not
19 attempt to defend because he had no independent verification thereof. As a result of Pulleys clear,
20 intentional attempts to stick to the honest facts, he has not yet been named as a RICO defendant,
21 and is the only Gans witness from the 2016 SOL trial to achieve that status.The above group of
four (4) bad faith perjurers, eight lines above, were all smart enough to know that Remington was
22
displeased with their testimony, and there false sworn testimony was very intentional, deliberate
23
and intended to unconditionally, unethically and wrongfully to win Gans case right then and there.
24
Therefore, Gans was thrilled with it and also knew that it was obvious that, although known by
25
themselves, and ALL of them to be factually untrue, nevertheless, if it was accepted by the jury,
26 then it would destroy Remingtons case potentially. Since said above defendants knew that their
27 testimony was either entirely false or partially false, that imputes intentionality to fulfill the
28 enterprises corrupt objectives, in Remingtons estimation. In other words, all four (4) of the above
named defendants and/or near-defendants can be inferred to have committed intentional unlawful
predicate acts, but of varying severity.

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1052. As of January 2017, most of the enterprise members have not YET been fully-coached
2
to testify, and therefore may possibly not yet be fully aware of the enterprises corrupt objectives,
3
or fully within its corrupt clutches and criminal influences. Therefore, they all are now placed
4
specifically on notice of the criminality of Gans trial strategy and the unlawful and improper
5
nature of all of his RICO Enterprises objectives, and also a reminder that perjury under oath in a
6 federal court room is seriously against the law, even if it is widespread and acquiesced to in state
7 trials. Therefore, as we go forward hear with federal document requests, special interrogatory
8 discovery and requests for admission, no one involved in Gans enterprise should be in doubt about
9 their RICO criminality involved here, especially as Gans tries to make his federal trial evidence
10 and testimony consistent with his false state evidence. Therefore, by the definitions and
11 discussions above, any anticipated further or future unlawful acts and additional untruthful
testimony going forward from Gans enterprise members, will be definitely intentional, fully
12
understood to be corrupt and there for subject to the RICO penalty statutes and predicate act
13
statutes cited. Similarly, all future trial-coaching and detailed scripts written by Gans for the next
14
state or federal trial, plus Gans anticipated detailed preparations for future depositions, and the
15
above written-discovery responses will be henceforth closely scrutinized, propounded and opposed
16 on the actual true provable facts, and additional violations of federal law will be noted and
17 prosecuted civilly, and/or criminally, if warranted. Gans believes in false reality and fake news
18 and to him there is no truth or accurate facts available from these dumpsites, despite the fact that
19 we have conducted over a dozen major tests, by numerous experts with totally consistent
20 inconclusive results which are true on contestable facts here and not subject to Gans sophism, false
21 reality and alternate facts. Again, there is no such thing as alternate facts in this lawsuit there is
only truth, actual facts, and actual falsehoods, fraud and perjured knowingly false versions of
22
obvious and provable reality.
23
Future discovery will be extraordinarily important, comprehensive, probative of all the
24
facts and allegations contained herein and will likely take several years.
25
1053. If Remington and his attorneys can enlist the interest and cooperation of the County
26 district attorney that would expedite these procedures, obviously streamline the process, increase
27 the motivation of all witnesses to be truthful going forward, and probably enableOr at least
28 facilitate the exposure of the specific Humboldt County state courthouse and judiciary corruption
alleged herein. However, also as alleged, Brisso has extreme influence in this town and long and
strong tentacles that reach deep into all phases of county government and well-beyond, in this
entire area, stretching into several other small towns and communities within 20 miles of Eureka.
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IS anybody in the city more powerful, more feared and hence more influential and intimidating
2
than Paul Brisso? That question will now be raised in this lawsuit, at every deposition, and every
3
written discovery request and also in the local media, where defendants pass for more than 10
4
years has finally come to an and. Witnesses and inferences presently exist, however final
5
conclusive factual proof sufficient for a jury to understand and convict BRISSO on will still need
6 to be discovered.
7 1054. Ideally, we will end this case sooner instead of later, because if one district attorney
8 will get cursorily involved here, they should have an easy time breaking about one third of the
9 named RICO enterprise members. McBride, Plotz, Costa, Kishpaugh, Kloeppel and even Joy
10 Mathson immediately come to mind because they are still probably not quite deeply criminally
11 involved here enough to deliberately picture weight there RICO involvement and increase their risk
exponentially. Some of them now or analogous to a snowball, which could either gently and
12
quietly melt away into oblivion, or continue rolling down the slope and rapidly gather much more
13
serious criminal intentionality as Gans tries to write perjured testimony for his witnesses
14
signature or oral lies, consistent with his state fraudulent, conspiratorial deceptions. In other words,
15
any witnesses who now participate in this federal lawsuit to try to be consistent with their fault
16 state representations are going to immediately commit one or more additional, actual and provable
17 federal predicate acts going forward. All federal crimes are serious, so someone is nearly certain to
18 want to bail-out of Gans corrupt family here, without having to over-think these acts, and
19 whether they are punishable only by fine, imprisonment or perhaps by both.
20 1055. Today, Remington would put his money on one of the above outsmarting Gans,
21 John Mathson, Olson, Kluck, Nelson and Skillings, et al, and not placing themselves fully at the
mercy of that criminal bunch, all of which can easily be implicated and convicted here, bringing-
22
down all of the others who have assisted or corruptly fraternized with, or otherwise facilitated their
23
RICO crimes in any respect. Did they knowingly assist? If so, when, how, was it intentional or
24
just innocent error, and what would be the proof thereof?
25
1056. To plaintiff, it would seem that anything that any of the enterprise members does
26 intentionally going-forward, after reading these documents, which is based upon the numerous
27 corrupt and unlawful Gans orders, would be knowing assistance to a criminal enterprise, and
28 thereafter everyone named here is now basically on notice and on their own. In other words, it is
now going to be hard for someone like BOTH Kishpaughs, Costa or say Joy Mathson to be able to
plead ignorance or insanity about what was and IS really going on here. Maybe some or all of these
members will have to satisfy district attorney, FBI, Remingtons attorney investigators or other
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1
scrutiny, or maybe not. If not, Remington is perfectly content to proceed logically and
2
comprehensively with sworn discovery and sworn trial testimony, to eventually ferret-out the truth
3
and implicate the perjurers who conflict with the truth and who are unable to consistently recall all
4
of Gans false coaching points for a period of several years. For example, Costa was so calm and
5
well-rehearsed with his false and contrived recalls a very insignificant detail from a birthday 20
6 years ago! That worked great when the element of surprise was present but thats now been lost and
7 if he persists with that he could wind-up doing jail time, when Remington proves he was out of
8 town on the date of Costas allegedly birthday. Costa is a practiced, excellent and calm perjurer
9 who would be hard to break, but what will happen when Joy Mathson, Plotz and/or both
10 Kishpaughs decide to tell the entire and whole truth? Where will that leave Costa and his
11 ridiculous fabricated stories that totally defy credulity?
1057. Further, and importantly, the equally or more important environmental component of
12
these litigations is entirely scientifically based, and sufficient tests now exist in the files from
13
numerous independent, competent and entirely reliable testing professionals. As discussed above,
14
Gans cannot make up the accurate scientific facts here, which are real and irrefutable. Gans cannot
15
make-up his own facts, here, there are just actual facts and actual fictions, deceptions and false
16 facts. Gans raises numerous prejudicial doubts and complaints, however he has absolutely zero
17 factual evidence that refutes any of Remingtons actual facts, because Gans did not intentionally do
18 even one test on Remingtons land, therefore he cannot be heard to complain about Remingtons
19 testing, when he could have done his own, for 10 years. Therefore, it is now mostly a simple matter
20 of overturning Gans frivolously, erroneously and/or alleged possibly corruptly obtained collateral
21 estoppel, and thereafter going-on to additional trials here or in DR140426, based on the inviolable
and irrefutable 2011 scientific testing, essentially. Collateral estoppel is improper here, but it
22
may now take a state appellate court to determine that, or preferably this court, which was the
23
initial and primary reason for bringing this lawsuit, before additional study proved that the reason
24
these cases had persisted this long was because Remington was essentially facing a Mafia-like
25
crime family, operating out of the offices of a local law firm.
26 1058. As we have argued throughout these documents, Gans RICO enterprise is now still
27 trying in real time to greedily and illicitly obtain, among many other things, all of Remingtons
28 northern Burl Tree property free, without any testing or rental costs, cleanup expenses or any of the
numerous other damages requested herein. Then, as repetitively explained, the RICO gang intend
to make Remington pay very dearly for that privilege of being robbed, extorted and humiliated in
the community for years to come, and there-after ruined and bankrupted financially via deadly
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serious, although legally entirely frivolous, malicious prosecution, punitive damage, costs and
2
attorney fee suits, some of which have already been drafted and/or filed.
3
1059. Some of the above-named, presently perceived probable weakest links in the RICO
4
enterprise, for the reasons espoused above, are fully aware of said above Gans unethical and
5
corrupt plans, purposes and objectives, which include in part only: to fraudulently and illegally
6 obtain Remingtons money and property by means of frivolous lawsuits, materially false and
7 fraudulent pretenses, known fraudulent and incompetent scientific representations, obstruction of
8 justice, witness tampering, suborning perjury, evidence spoliation, money laundering, deprivations
9 of Remingtons civil and common law rights, etc., as specifically delineated in the RICO statement,
10 fully included by reference in this paragraph. Take McBride and Plotz, for example:
11 1060. Both understand better than Remington does, exactly what Gans was, has been and
still is plotting going forward; and, what he actually has done and now intends to do going-forward
12
here in 2017-20, now that he has such a high-powered and sophisticated finely-tuned RICO
13
machine barreling forward with tremendous nearly unstoppable momentum. Both also fully
14
understand and appreciate the threat that Remington poses, and therefore exactly how the
15
enterprise expects to illicitly when these cases no matter what crime that entails and what specific
16 methods and personnel they intend to use to either destroy or possibly kill Remington in the years
17 to come, and the sooner all of that occurs, the cheaper it will be to Lawrence and her superiors who
18 undoubtably are displeased with sGans and her performances, to date.
19 1061. Since at least fall 2015, if not 2013, it would have been impossible for thoughtful,
20 intelligent direct assistants to a Mafia Godfather (such as McBride, Plotz, Kloeppel, Ferriman,
21 Kluck, ETC.) to have had a genuine, good-faith belief that Gans and they were operating ethically
and legally in any respect with regards to Remington. Just getting very well-paid and claiming that
22
they are merely following vague orders that they did not understand at all, just to avoid being fired,
23
and to just keep harmoniously getting along in the enterprise, and keeping their inflated
24
paychecks coming, is not an acceptable excuse when committing federal crimes. That type of
25
excuse did not work for Hitlers inner circle and its little better for Gans similarly conspiring
26 leaders, if on a smaller and less grandiose or violent scale, so far. The above accessories to these
27 conspiratorial crimes are all very thoughtful and sophisticated people, who all fully understood
28 what they were doing or should have known that they were gravely and unjustly damaging
Remington by conspiring to commit unlawful acts against him.
1062. Therefore, at a bare minimum, none of the above have any defense at all to mail and
wire fraud, which are presently the chief allegations against most of them, with likely much more
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1
to follow. Ferriman also has made numerous egregious scientific errors and falsely sworn that they
2
are true, which will become very serious in the new federal lawsuit, when he repeats them under
3
oath once again. Kluck also is somewhat different from the others above, with one alleged act of
4
extortive intimidation, one act of state obstruction of justice in his pursuit of a bogus overturning of
5
a lawfully required default judgment by means of making confusing and false representations to
6 judge Reinholtsen, which said court could have verified were false, but does not want to be seen as
7 taking the side of a hated pro per against a long-time friend and 40-year long, highly respected, at
8 least at one time, officer of the court.
9 Extortion is the primary predicate act alleged herein.
10 1063. Said extortion is primarily of Bruce Remington, but also involves several of his
11 witnesses, especially Figas, as explained individually above, and in the RICO statement, which is
the primary topic from pages 305-489.
12
A. Gans, Mathsons and defendants efforts here have always been intended to
13
aggressively take full effective legal control, and to fully and HEAVILY use the over acre of
14
Remingtons land directly adjacent to their property, where they established their dump in 1998-
15
2001 and effectively fully appropriated that land at the time of that encroachment. That acre,
16 has effectively been a part of Mathsons backyard and its foundation since 1998, and said
17 contaminated waste dumps also have effectively damaged or destroyed a total of more than acre
18 of Remingtons most fertile, sunny and productive land on the north side of Remington Creek.
19 SEE #1069 Below, for a more thorough discussion of this crucial land theft and critical fact that
20 said stolen land now supports Mathsons entire estate from falling into the ravine issue which is
21 actually the real motivational basis for all of these lawsuits, from defendants side especially.
Until the significance and importance of these issues are fully understood, and the very substantial
22
structural, monetary and related damage components involving the required removal of
23
defendants contaminated debris from Remingtons land and the overall economic ramifications to
24
both sides of that remediation are understood, no court or trier of fact can really resolve anything
25
here.
26 1064. By 2017, extortion under the various pertinent US Supreme Court, and following
27 precedents seems to be the correct generalized term for Gans enterprises attempts to fully and
28 legally obtain most of Remingtons property by inherently wrongful means, which here
involved many years of violent and deliberate property destruction, as per Gillman v. Thomas, 490
F. 3d 791, 799 (10th C. 2007).

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1
1065. In 2016-17, Gans Enterprise graduated to nearly pure corrupt, vandalisticly-based
2
destruction of Remingtons Burl Tree property, caused by dozens of federal criminal acts each year.
3
Mathson and his gang now conduct almost continuous and continuing major vandalisms, property
4
destruction and have effectively maintained and overall reign of terror (RICO statement: 258-
5
390)For several years, undertaken by his union, fellow retired-workers and drug users, intended to
6 break Remingtons will, destroy the Burl Tree and drive both from this area.
7 1066. As described throughout and perhaps more clearly below at number 1069, Gans,
8 Mathson and defendants RICO enterprise have already stolen the portion of Remingtons land
9 which they desperately and urgently need, and all of their criminal extortion now is about making
10 Remington afraid, breaking-him in order to make their theft stick. They refuse to allow their
11 crime to be undone by payments for cleanups, or by forcing Mathson and/or the other
environmental defendants to put up a strong, engineered, tall retaining wall either after or before
12
Remington removes the 15-foot deep, highly toxic and hazardous materials at the Pulley property
13
line, which of course supports Mathsons entire dump above, and property based upon said dump.
14
1067. Gans and Allied today owe Remington between $450,000 and several million dollars
15
total damages, as alleged, justified and explained throughout these documents, in addition to
16 surrendering his stolen land, building a retaining wall, etc. However, they have refused and still
17 refuse to do so.
18 1068. As alleged herein, they are only willing to spend money on the aggrandizement of
19 their members, especially Gans and Lawrence. To date, Allied has spent an estimated $400,000
20 now, just trying to make an originally estimated $200,000 contamination clean-up impossible.
21 Now, according to Gans June 2016 extortive threats to Remington in the courthouse, Lawrence
and their enterprise will not stop under any circumstances, because they are so very angry now.
22
Lawrence was portrayed by Gans as being like a kid throwing a tantrum. However, to any honest
23
or neutral observer, it is obviously Remington who was the long-time severely harmed victim
24
here. Apparently, all of the defendants in these cases are just angry with Remington because he
25
has resisted their wanton land theft and fought-back here against overwhelming and nearly
26 insurmountable forces. First, the environmental defendants, today strongly backed by the RICO
27 enterprise, effectively stole a large proportion of Remingtons best land, refused to clean-up either
28 parcel or the environment, despite the incriminating fact that their clients and policyholders,
Mathson and RAO admitted to dumping hazardous wastes on Remingtons land, and burying
them, as early as 2010! Presumably, if they admit dumping some contaminants on Remingtons
land, it could be inferred that all of the other contaminants mixed-in with those were also dumped
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by the same defendants, since they are the only ones with any access to that area! The RICO
2
defendants other objectives such as making huge amounts of money for themselves, avoiding
3
punishment, culpability and prison; driving Remington into bankruptcy and then suing him after
4
that for their costs, irritation, the insult and their attorneys fees because of his allegedly frivolous
5
lawsuits, and continuing that relentless assault until his death, have all been very fully explained
6 before.
7 1069. Given: Gans RICO enterprise and their affiliated separate (but overlapping)
8 environmental defendants STOLE about acre of Remingtons best land, are now using it
9 without any compensation, are desperately trying to make their criminal theft legal through a
10 complex variety of frivolous oppositions and related legal maneuvers, and therefore owe
11 Remington more than $500,000 for that illegal use, plus a small part of his associated costs
and damages. Gans present extortion campaign is now simply an effective attempt to make
12
that substantial land theft stick, by perpetuating a massive expert-based pseudo-
13
contamination-law based legal defense. Gans is also importantly attempting to avoid prison and
14
remediation costs for themselves and all involved; and, also as described herein is a criminal
15
extortion attempt to force Remington to give-up entirely on obtaining justice here, and to
16 immediately and cowardly drop his fully justified lawsuits, and try to give away his million-
17 dollar now unsalable estate.
18 1070.The contaminated hazardous waste dump which defendants established on
19 Remingtons land without permission or Remingtons knowledge, is about 15-feet deep along
20 Mathsons property line, lavish backyard lawns and sheds, and since 1998 that land has always
21 been needed to support Mathsons vast upper property and lawn expansions.
1071. Defendants should have purchased that land from Remington or paid rent on it since
22
1998, and both options have been discussed over the years, demanded and then ultimately laughed-
23
at by Gans all-powerful RICO enterprise. In other words, since 2008, defendants have effectively
24
or tacitly said no as to the issue raised here of reasonably compensating Remington for the very
25
heavy but continuing use of that land, which is totally invaluable to Mathson. Without Remingtons
26 supporting land, Mathsons entire property would be reduced in value by 75-90%. If Mathsons
27 yard and structures were clean and salable (which they are not in either case), they might arguably
28 be worth $435,000, however if Remington removes Mathsons encroaching materials and reclaims
his property without defendants constructing the crucial retaining wall discussed in these
documents, over several years Mathsons land could and inevitably would rapidly collapse into the
ravine, and in a few years would have little or no value, except as a rental for a trailer.
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1072. Therefore, defendants need to purchase their encroached-upon land and pay rent
2
going- forward, plus back rents, or alternatively they must very quickly build a retaining wall to
3
support their upper land and structures, BEFORE notAfter Remingtons remediation, and also still
4
pay Remington back-rent for their 18-20 years of free and extorted uses.
5
1073. Gans enterprise has always intended to steal the said above -acre of encroached-
6 upon land which supports Mathsons entire residential development. These lawsuits are essentially
7 a distraction, cover and extortion attempt intended to force Remington to leave that crucial
8 stolen quarter acre alone, which supports Mathsons entire estate, and then also to destroy
9 Remington entirely, in every way possible, as fully explained above. For example, in August 2011,
10 before there was the thought of or desperate need for a formal RICO enterprise, Gans and
11 Lawrence offered Remington approximately $100,000 in settlement to remediate portions of his
land, however no provision was made then, or since, for a retaining wall or for the contingency of
12
Remington removing 15-feet deep of supporting foundational structure on the side of that 60
13
mountainside. Removing that deep, solid and important support, which must be done to remove the
14
hazardous materials defendants deposited and buried 15-feet deep on Remingtons land, would
15
have the obvious effect of collapsing most of Mathsons mountaintop development in heavy rains
16 or earthquakes. The problem for both parties is however, that defendants foundational support was
17 piled onto stolen Remingtons land without his knowledge or permission and as discussed
18 repetitively above, theyve never offered rent or payment for the $400,000+ or more value they
19 have appropriated to date. These lawsuits are all substantially about that foundational support issue
20 above.
21 1074. Remington is under no obligation to provide his land free to artificially support
defendants entire property with 15-feet deep of hazardous toxic wastes piled on his land, which
22
makes him sick and contaminate the entire environment. In fact, he has refused to do so now for at
23
least eight years, and until defendants build a retaining wall, with their money, as discussed herein,
24
and provide Remington with the funds to remove the hazardous waste from his land, plus pay back
25
rent and the other damages and costs requested herein, these lawsuits will go on indefinitely.
26 1075. The death of Remington will not end anything here, because Remingtons heirs,
27 including two highly successful London/US lawyers, will also need to clear title and resolve
28 these issues, which now diminish the value of Remingtons estate by nearly $1 million, and when it
is fully developed in the next several years, potentially the loss of a sale because of this
contamination could be much more than that, due to the fear of future regulatory punitive actions,
stigma and the fear of additional or returning contamination emanating from Mathsons dump
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1
above. See several sections near the end of each accompanying document, on harm, damages and
2
injuries, some of which environmental damages may be augmented with general damages under
3
the law, and treble RICO property damages can also be properly granted in a proper case.
4
1076. Therefore, if these cases cannot be resolved in federal or state court during
5
Remingtons lifetime, many viable causes of action still remain under the state and federal
6 continuing trespass and nuisance statutes, and eventually Remington or his heirs will find receptive
7 triers of fact, at some level of the judicial hierarchy, willing to justly resolve the numerous and
8 ever-increasing issues surrounding these contaminated sites, and lawfully return to Remington his
9 presently appropriated valuable lands.
10 1077. Gans RICO enterprise has violated federal law in committing more than 30
11 discrete instances of mail and wire fraud, just since 2012.

As preliminarily alleged in the comprehensive RICO statement, Section 5., after page 356
12
A-N, and elsewhere, through and beyond the extortive and abusive 2016 fence agreement, Gans
13
enterprise has already committed numerous instances of mail and wire fraud, however we have
14
barely begun reviewing the more than 20,000 page file here, nor alleged more than the tip of the
15
iceberg, so far. We cited above, more than 20 fraudulent instances but did not have the time yet to
16 research and analyze the other 20-30 more, that are known to exist in Remingtons files now alone.
17 Just during the drafting of these documents alone, about two more were discovered every week.
18 Much more serious civil or criminal mail and wire frauds are positively guaranteed from
19 defendants imminent document discovery requests, because they now must be consistent with
20 literally scores of state case frauds, experts errors and multiple perjuries from all witnesses
21 appearing for Gans to date. Because defendants core leadership attorneys are obviously very sly,
slippery, smart, corrupt and knowledgeable and clearly will not reveal any of their many hundreds
22
of incriminating documents without gigantic battles to the death, which will make it difficult for
23
Remington to positively corroborate that said documents even exist at all, it is now an absolutely
24
certain fact that many motions to compel discovery responses will be required in this case. As
25
alleged herein, violating state or federal laws and daily corrupt activities of all types are second
26 nature and commonplace and automatic with Gans enterprise, so it is a certainty that he would
27 rather argue and LIE that miscellaneous incriminating documents never existed at all, an attempt to
28 shred anything adverse to the enterprise, than to reveal them.
1078. There is no doubt at all that Gans, et al, will deny the existence of, withhold anything
of use and clearly destroy anything that is at all incriminating, unless we can prove the existence of
said incriminating documents independently, or some of the enterprises witnesses inadvertently
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1
disclose them at a deposition. Therefore, odd copies in the hands of unexpected people and/or
2
backup copies on computer hard drives, will need to be searched and hopefully the interest of civil
3
or criminal investigatory authorities will be available to assist with searching defendants
4
computers, etc. since all Gans witnesses and Associates smoothly lie and perjure themselves as a
5
matter of course, learning to recognize that and break through it to the truth is a constant challenge.
6 1079. Crucial to the apprehension of Gans and his inner circle of top RICO
7 management will be the truthful testimony of one or more minor enterprise soldiers or
8 participants that have not yet committed imprisonable offenses, and hope to keep it that way.
9 In other words, independent corroboration, of what we already absolutely know to be the true facts
10 in these cases, with live witnesses who are not yet guilty enough to swing for the RICO
11 enterprise here, should be possible, expected and are needed. That eventuality is nearly certain with
this diverse group, which has been so deeply corrupted already in the state proceedings. Gans has a
12
rather large number of RICO members to herd and coach here, and the likelihood of several of
13
them deciding that Gans, Mathson, Skillings, Olson and/or the other criminal gang members here
14
are not really worth going to prison over, when you stop and think about it for a while, is extremely
15
high. Therefore, by the time of the FAC in this case, many more incriminating documents and
16 probably a few additional smoking guns will surely be available for emphasis at a trial in this
17 matter.
18 1080. Multiple Civil and criminal mail and wire frauds or alleged to have been
19 committed by Gans RICO enterprise and they continue rampantly today. This case has many
20 provable examples, which all involve:
21 (1) A scheme based on an intent to defraud; and
(2) The use of the mails, internet or phone to further that scheme.
22
Those criteria are easily met here because Gans certainly had numerous schemes over the
23
years and has committed serious frauds for years especially since 2012, as documented. Virtually
24
everything that Gans does or says involves a specific and calculated scheme or artifice to defraud
25
Remington, either directly in one false sentence which misconstrues a Supreme Court case
26 teaching, or as the ultimate result or objective of a lengthy 10-page document. Other earlier frauds,
27 misrepresentations, deceptions and schemes by Gans have been alleged here since 2008, and ethics
28 charges based primarily on the 2009 federal case were filed previously in 2014 by Remington, and
similar CCP 128.7 complaints will be filed again, as more provable criminal activity is

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uncovered, both in this case and in his others 10. A criminal conviction on one or more of the
2
provable federal civil RICO predicate acts alleged herein, should be sufficient to receive an
3
admonishment from the state ethics board, and/or presumably disbarment by same or the state
4
Superior Court.
5
1081. Meantime, perhaps Gans will decide to now help Remington herein, by now, once
6 again, alleging a statute of limitations defense, and that he committed many other, egregious actual
7 federal predicate acts prior to 2012, and hence is exonerated here! If so, Remington will look at
8 them and add them to what he has already reported previously and said additional and earlier
9 federal crimes will presumably be of use in the first imminent appeal of DR080678 and also in the
10 anticipated reopening of the 2009 federal case CV 09 4547 NJV, both of which appeals are heavily
11 based on the serial Gans led and coached frauds and trial perjuries alleged herein, which have been
rampant and troublesome, since about 2011-12, and several occurred before that, in Gans frivolous
12
second special motion argued to Judge Reinholtsen, and in all of the fraudulent, 2009 padded
13
attorney fee and cost requests made to Judge Miles. SHE did not put it in those exact words, but
14
that view could be inferred from her courtroom demeanor, the hearing transcripts and the fact that
15
she ultimately reduced the Mitchell firms $15,000 attorney fee request, which was rising at least
16 $1000 a week, down to $5200, which couldve easily gone to zero, since she was angry. But, rather
17 than totally trash Brisso and his law firm, she relented and gave them something.
18 1082. The elements of mail or wire fraud were all met during the last four years in dozens of
19 instances by Gans RICO enterprise, and are:
20 A. A plan or scheme to defraud, which we have repetitively alleged that Gans obviously
21 has here, both macro and with numerous subordinate micro-schemes, artifices and frauds;
B. The intent to defraud someone, such as Remington, his attorneys Harvey Roberts, Hans
22
Herb or William Verick, plus every judge that hears these cases. Can there be any doubt of that
23
here?
24
C. Reasonable foreseeability that the mail or wires will be or were used. That is all that
25
they use, and then repeated again orally at hearings and trials;
26 D. Actual provable use of the mail or wires to further that scheme. Here, Gans uses his
27 phone a great deal with his enterprise members, and has sent at least 20 to 30,000 pages to
28
10. Remington now already has some evidence, before weve even seriously started to gather it,
that this RICO enterprise is not Gans first rodeo. We have already found other disgruntled and
very angry former adversaries willing to backup Remingtons charges of unethical and criminal
acts. When these lengthy and comprehensive documents are filed, Remington will get much more
serious about pursuing this and numerous other relevant, related lines of investigative inquiry.
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1
Remington and many courts, probably 20% of which was substantially fraudulent and at least 10%
2
is now provably so. If 10% of a 10-page motion document is entirely false and fraudulent, is the
3
entire document fraudulent or only part of it? There appears to be no simple cursory answer to that
4
philosophical question, as it would appear to vary, possibly according to its introduction and the
5
objective essential purpose of the document, as being whether to further truth or fraudulent
6 deception. As to the incriminating communications between the RICO racketeering members,
7 clearly ALL relevant phone records, dates and records of, and recollections of, those calls will now
8 be VERY crucial, although what are the chances that 98% of the incriminating records and
9 documentation thereof will NOT be systematically destroyed and then denied? Also, records of all
10 internet searches and all relevant period email records from all enterprise defendants, and All other
11 named ancillary or fringe members will now he sought. But, one of the odds of Remington in Pro
per or with an aggressive attorney actually getting many are any of those important records? That is
12
why enlisting the FBI, US attorneys or local district attorneys will ultimately be crucial to our
13
investigations, and therefore will be focus upon.
14
1083. Interstate commerce. As explained above, the Burl Tree is the victim here that owns
15
the land and property damage by defendants. Today, and since the mid-1990s the Burl Tree does
16 about 95-99% of its business in interstate commerce. In that regard, it is the exact type of victim
17 which the RICO laws were intended to protect and compensate. That would break down to about
18 99% of all its sales over the last 25 years, and currently were and are to points outside of
19 California. Additionally, about 70% of its overall purchases since 2000 or so have also been out of
20 state, and especially his $150-200,000 of wholesale plants were imported, mostly from Oregon and
21 east of the Mississippi. In other words, Remington and the Burl Tree easily meet that criteria and
all prerequisites for a bona fide RICO enterprise lawsuit. What are some of the other numerous
22
critical factors and essential requirements?
23
1084. Relatedness.
24
A. Clearly, all alleged predicate acts here plainly and logically relate to the furtherance
25
and continuation of Gans purposes and the enterprises crystal-clear objectives as plainly stated by
26 Gans and unambiguously written over several years. All of that will be easy to prove in this court
27 or at any trial from present records, but obviously MUCH more is available, discoverable and also
28 plainly present or induced from the written and stenographic records here, and as summarized
above or fully set-forth in several different places herein, including pages 390-410 of the RICO
statement.

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B. In fact, once you clearly understand the enterprises objectives and what activities they
2
conduct almost daily to reach those objectives, it follows that all of the alleged predicate acts
3
herein were specifically intended to reach those objectives, and to accomplish nothing else, and
4
ultimately to end these lawsuits as soon as possible and exclusively on defendants terms, while
5
grinding, wearing-down and damaging Remingtons health, business and financial sustainability as
6 much as possible.
7 C. For example Gans suborned perjury in August 2016 was solely intended to destroy all of
8 Remingtons contamination cases entirely, by falsely characterizing all relevant California
9 contamination and discovery rule law, and then blatantly lying about virtually all of the known
10 facts, which real facts were that Remington did not reasonably discover Mathsons contamination
11 until 2006. Their chief perjurer John Mathson said the opposite, and then they had four other
witnesses to verify that some conversations took place in 1998 but they dont know what they
12
were. Therefore, although NO conversations at all occur between Remington and John Mathson in
13
1998, ultimately the entire case came down to Remingtons truthful word against Mathsons, and
14
Gans succeeded in tricking a jury into believing the latter. By fraudulently and falsely portraying
15
the true facts differently, Gans succeeded in knocking-out Remingtons discovery rule exception
16 and inferentially and falsely established that Remington should have discovered the contamination
17 sooner and acted upon it. As explained elsewhere, Remington believes he can work around that
18 unfortunate erroneous jury verdict, based entirely on fraud and four (4) witness's assessory perjury,
19 however that entire situation and trial was a perfect example of the enterprises purposes and
20 objectives in action, and established and proved the precedent that the enterprise is entirely
21 ruthless, has no ethics or scruples and will commit virtually any criminal acts in order to WIN. In
America, win at all cost is not supposed to be applicable anywhere, because there are rules in
22
every game, every venue and especially in the legal venue. The fact that Gans has discarded all
23
major rules as being inapplicable to him in his case, except where convenient and where he needs
24
cover and the pretense of legality, proves overall the fact that he is desperate, he has no better
25
morals than a mafia godfather, and likely less. So far, he has not needed to commit any direct acts
26 of violence on any people, but if he ever loses a few motions or anything else significant, then there
27 is no predicting what he might do. Accordingly, Remington has vastly increased security measures
28 around his personal safety. All of the above criminal state perjury, etc., was all related to Gans
RICO enterprises objectives, and since this is a federal action, they will have to repeat the above
perjured obstructions of justice in order to produce more RICO criminal violations, and there is no
doubt that they will do exactly that if they choose to frivolously defend this indefensible RICO suit
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and risk Gans, Lawrence, et al going to prison. When that occurs, that will be one happy day, and
2
at least partially justify several of the lost months here, if not the lost 10 years.
3
D. All of the enterprises corrupt and criminal participants here are substantially the same
4
in the commission of all predicate acts to date, especially since 2012, and are therefore well-
5
known, consistent over the years and therefore obviously related by definition and simple
6 inspection and comparison. Substantially identical and overlapping criminal perpetrators who
7 conspire against Remington, and injure him according to a common plan which they all share, are
8 logically and philosophically related,and although there have been approximately ten (10)
9 distinct types of crimes committed against Remington and the Burl Tree by defendants, under
10 RICO, they would all be related because of the overlapping and identical perpetrators all directed
11 towards the exact same enterprises objectives and purposes.
1085. Likewise, the victims and intended HARMS here, in 100% of Gans soldiers
12
intentional criminal acts, are all exactly the same in every single deliberately targeted discrete
13
predicate act, as already explained in painful detail. Remington is the chief nemesis of the
14
enterprise and he WAS and still is the direct target and primary intended victim of most, and
15
presumably ALL11, of the predicate acts, however in reality it is the Burl Tree, and to a lesser
16 degree Remingtons family, which are the primary entities affected by and permanently and
17 irreparably damaged by the RICO enterprise, for the reasons explained.
18
19 11. There are obvious exceptions to every rule, under certain circumstances and that applies to
20 every generality made in all of these documents. Remington and certainly defendants will always be
able to cite one or two exceptions to anything. Here for example, it could be argued that Bob Figas
21 is a partial exception as he was also damaged personally and financially by the RICO enterprises
extortion of him personally. Therefore, it could be argued that the RICO enterprise was targeting
22
him here and not Remington. However, probably neither would be true and they were merely
23 protecting themselves and trying to stay out of prison for another few years. That extortion was
intended to drive Figas away and also to harm Remington, but not only to harm Remington. RAO, et
24 als other purpose, just as fundamentally was clearly intended to protect RAO, Skillings, Olson, and
even the Mathsons , to a lesser extent, from their conspiratorial criminal actions which will be
25
proven during any serious remediation. Any excavated remediation on Remingtons land (or
26 Mathsons) will inevitably uncover the horrors, skeletons, and quite obviously the terrible and
criminal contents which defendants buried on both properties in 1998, and which they are expected
27 to consider murder, in order to now protect themselves from substantial prison terms or worse. The
28 amazing extent of defendants crazed paranoia over Remington and Figas (and Marshs, and
the others who eventually will dig here) uncovering what those cutthroat, merciless RICO
pirates buried in the various dump areas on both properties, proves that some horrible crimes were
committed here, which eventually we and the authorities will determine in all details, whether they
be dead bodies of Olsons competitors, Skillings numerous mortal enemies, nerve gas, radioactive
wastes or infectious diseases.
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1086. There are many other lesser victims affected here including Remingtons close
2
family, his three very young grand-daughters and daughter who live in England and visit for about
3
one month per year, and his wife, Suzanne, that is now afraid and too uncomfortable to ever visit
4
here, except in bona fide emergencies.
5
1087. The additional victims cited in the environmental complaint especially involves an
6 adjacent community up-wind to the east from invisible asbestos, benzene and other hydrocarbon
7 vapors and several varieties of fine carcinogenic silica and asphalt dusts. Obviously all users of any
8 waters, or ingesters of shellfish or anything living in those waters, downstream towards Elk River,
9 Humboldt Bay and the surrounding National Wildlife Preserves in that region are also adversely
10 affected.
11 1088. Therefore, upon a very detailed analysis, which philosophically would go beyond the
limits of these writings, it is clear that all of the cited predicate acts here are totally related in all the
12
above variables, but furthermore, the concept of relatedness is generally-speaking not that
13
difficult to meet in the first place, and as a result, this issue is seldom contested or litigated, see
14
Medallion v. SelectTV, 833 F. 2d 1360, 1363 (9th C. 1987).
15
1089. Are Gans Enterprises crimes and activities serious enough here to sue them for
16 and then successfully recover treble damages? In answering that question, courts may consider
17 all relevant facts, and apply the following several types of objective and quite subjective tests,
18 including, without limitations:
19 1090. The know it when you see it test.
20 A. Every court evaluates and analyzes these facts differently, and determining whether a
21 RICO lawsuit is valid and appropriate is still quite subjective in most practical applications.
B. Even a bona fide Mafia organization can be difficult to nail and convict under
22
RICO, especially without one credible informant, several prominent inside witnesses telling the
23
truth, or without several kidnappings, witnessed strong-arm extortion attempts, brutal violence
24
and/or several witnesses to serious bribery, counterfeiting, provable monetary swindling crimes,
25
etc. Usually, Any well-financed and creative offending criminal can almost always raise a spirited
26 defense, deny all and accuse the other side of being biased, crazy, wrong or here, just in Pro Per,
27 so What do you expect? In this case, we are not wrong, but our road is difficult, because even if
28 the enterprise murders Remington, that is not a guarantee of victory for his heirs, because murder
surprisingly not an instant federal predicate act, in itself!
1091. The multiple facts test is one of the other many tests which a court may or is
expected to use to determine if a RICO case can continue towards justice, or not. Here, in the
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event of the or not, then Remington will very quickly file this RICO action in state court, after
2
suitable state modifications and rather crippling limitations.
3
Said multiple facts test analyzes:
4
(A) The number of predicate acts and their severity. Here we have many in number, some
5
that are severe, in overall a very serious and damaging pattern of harm to Remingtons business
6 interests;
7 (B) The variety of predicate acts. Again, here we have identified so far at least 17 different
8 types, even before substantial discovery, which discovery is expected to increase the variety of
9 criminal acts somewhat, as well as to multiply the number of said crimes in those 17 categories, by
10 at least two;
11 (C) The length of time over which said predicate acts were committed. Here, the term is at
least four years, with their rotten roots and precedent corrupt, evil and unethical acts going back
12
further;
13
(D) The number of victims. Here, we have five or six primary ones, but thousands of them
14
within a few miles of the contaminated sites, where airborne and waterborne contaminants can
15
reach;
16 (E) The existence of separate, creative corrupt devices and disingenuous schemes. As
17 discussed above, Gans RICO racketeering enterprise operates in many diverse ways, including
18 performing many perfectly legal, routine and ordinary ministerial advocacy acts, filing, document
19 copying, ETC., plus conducting and pursuing their vast amount of corrupt illegal schemes and
20 artifices with clear and logical illicit, improper and fraudulent actions, also being undertaken
21 essentially daily, in furtherance of said corrupt, disbarable and/or imprisonable schemes. Here,
Gans employs at least 40 knowingly and a few probably unknowingly corrupt RICO soldiers to
22
further Gans constant major disingenuous activities and corrupt, unethical sub-routines of his
23
overall RICO disingenuous scams and plans, which ultimately have severely mischaracterized and
24
misrepresented every single known material issue in these cases. In other words, Gans has many
25
dozens of corrupt mechanisms, illegitimate devices and methods of always attempting to arrive at
26 the same RICO objective, which as alleged many times above is still to win by any ruthless and
27 extralegal means necessary, and almost equally important, to trample and/or leave Remington for
28 dead in the process, as he has laughingly and boasted for years that he will do;
(F) The occurrence of distinct, actual, real and measurable injuries. Here, the severe harm
done to the Burl Tree and to Remington, whether personally, financially, emotionally and in all of

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the other ways cited, has been adequately documented herein, see e.g. Morgan v. Beck, 804 F. 2d
2
970 (7th C. 1986)
3
1092. Without repeating excessively all of that analysis here, It should be clear by now
4
when these documents are studied, that THIS RICO action ranks very high in all of those
5
criteria.
6 1093. Remington, his family and the Burl Tree may be the primary victims, but his part-
7 time employees in California and Oregon, hundreds of customers and other associates are also
8 adversely affected, as is the entire up-wind neighborhood and obviously also the downstream
9 fisheries as alleged above. Cumulatively, there are numerous Humboldt County and beyond victims
10 of Gans enterprise, not merely Remingtons family and business as cited above. As alluded to
11 previously, further an additional discovery is planned in this area, because there is little doubt that
if Remingtons former excellent health has been nearly extinguished, there are almost certainly
12
many other elderly, young or frail local residents and animals which have also been and continue to
13
be adversely affected. If Mathsons, Gans and RAOs contaminants have killed all native living
14
things from all kingdoms (from amphibians and birds to plants and insects) in the Remington
15
Creek Valley, then it is expected that others in all directions from the hazardous landfills will have
16 also been deleteriously affected, so its now just a question of taking the substantial time to knock-
17 on a few hundred local doors and eliciting some candid raw data facts and anecdotes.
18 1094. The threat of future repetition is not hypothetical here (i.e., open-ended
19 continuity), but it is happening right now, nearly every day, as this was written in November 2016
20 until March 2017. Today is March 1, 2017 and the last noticed criminal vandalistic act by Gans
21 enterprise was about three days ago. There were more later. Remington has complained and railed
about the threat of future repetition of defendants criminal RICO acts every few days since
22
September 2016, and every time said acts continued and were repeated. There have probably been
23
at least 50 successive repetitions of defendants predicate acts since the concept of open-ended
24
continuity was first discovered and then theorized here, a full six months ago. Although it is not an
25
absolute certainty, Remington concludes now that we will see some and probably MANY more
26 defendants acts of vandalism until these cases are over, and Remington has departed from this
27 scene. In fact, Remington has purchased numerous additional surveillance cameras and is
28 counting-on that virtual certainty! Harassing Remington and destroying his property and ability to
focus on these legal documents, such as THIS one, is Mathson and his friends recreation and only
known hobby, outside of substance abuse. Vandalism is Gans and John Mathsons gangs
extortive modus operandi. As thoroughly explained throughout these documents, Mathson and his
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local gang damage and cut Remingtons fences several times per week and send-in, or lure and
2
HERD, huge ravenous deer, bear, big dogs and/or even human vagrants from along Ridgewood
3
Drive to come-into Remingtons tightly and impenetrably-fenced major estate and unique
4
(anywhere in the world) gardens through those holes in Reming long Ridgewood Dr., John
5
Mathson and his fellow defendants also let those same destructive invasive animals in through his
6 various secret doors in his solid 8-foot wooden fence, which she specifically clandestinely
7 designed and meticulously concealedIn his solid wood fence built around 2008-9, specifically to
8 destroy Remington and his property. Took him a few years to work out all the details, but
9 eventually by 2012 he fully succeeded in his Gans-directed RICO objectives. Remington has
10 several human witnesses and extensive surveillance video to prove those facts.
11 1095. Gans RICO defendants are very excellent at doing their criminal vandalistic
work, because they love doing it, especially John Mathson. Remington has carefully observed,
12
actually, at numerous opportunities that Gans loves hearing about it, and then smiling superiorly
13
and condescendingly at Remington as they laugh and discuss it, especially when its the day of
14
important hearings which involved 20-100 pages of new filings, and major destructive activity just
15
happened during the previous day, and then continued into the day of the hearing and was known
16 by all to be taking place simultaneously with Remingtons attempts to focus on serious hearing
17 legal issues and philosophies. Obviously, Gans and his RICO men were carefully watching
18 Remington on those days to see if he was nearing the breaking-point and hoping that there
19 extortion was finally about to succeed. Although Remington has about a dozen security cameras, it
20 is impossible to fully view at least 4000 linear feet of his fencing when each camera covers only
21 50-60 linear feet. Night watchman in certain seasons, has also been an option however when it
takes 45 minutes to walk the perimeter that is also not foolproof, because Mathson often uses his
22
own secret doors and also varies the location and character of his attacks creatively and frequently.
23
Primarily however, having human personnel for any purpose, when these litigations require
24
absolute and complete focus by Remington, is not desirable or reasonably possible, because any
25
supervisory function and management tends to require about half as much of Remingtons time as
26 the worker himself spends doing his work. Here, Remington has zero time to spare on management
27 and therefore has had to accept the nearly permanent destruction of many of his most rare and
28 valuable plant species. Perhaps in the future, there will be more stability here and Remington can
eventually replace the $100,000, or so gigantic gaps of destroyed foliage, all over his gardens.
1096. John Mathson has been committing these destructive, emotionally hostile acts of
theft and vandalism for many years and enjoys it so much that it apparently has become
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addictive. Clearly it is his favorite activity in the world and often terrorizing and torturing
2
Remington appears to be his only enjoyable activity, aside from sitting passively next to Gans in
3
about 100 consecutive hearings during 2016. Even when he is winning in the litigation and does
4
not need to apply extortive pressures he still does it out of pure enjoyment and probably sadism.
5
Inferentially, Mathson will never stop his attacks until either he or Remington is dead,or until he is
6 in jail and unable to patrol Remingtons perimeter. Possibly also, if he succeeds in reaching the
7 enterprises objectives and totally crushes Remington into financial oblivion, whereupon Remington
8 is forced to leave the area, it may now be inferred that Mathson and his gang might ease-off any
9 subsequent purchasers of Remingtons estate. Without being able to torment Remington, the
10 Enterprises violent racketeering activity would become without meaning, and at some point would
11 become too dangerous and risky to continue.
1097. Alternatively, were Remington to win some minor, major or any victory here, which
12
forced the Mathsons to payout a few dollars for something, for the land they stole, their witnesses
13
or for anything at all, that would be so traumatic for them that there would be hell to pay. Arson
14
would be the most likely expected attack from Mathson but murder, sabotage of his vehicles or
15
something else drastic thereafter would be almost immediately anticipated.
16 A. Remington still has serious, real, pre-cancerous scars on his back and occasional pain
17 from Mathsons last arson about eight years ago, which very serious fire inside his huge structure
18 nearly enveloped and destroyed it. Happily, Remington was much younger and much much
19 stronger at that time and managed to single-handedly put-out that fire himself, because he had (and
20 has) an active 5/8 garden hose right there in the entryway, running inside the house for just such a
21 fire suppression purpose, leading to very near where the fire was started. During that fire, and the
10-minutes Remington fought it alone with a hose and related means, some large heavy plastic
22
ornaments 15-feet above where Remington was fighting the fire melted and dripped a 6 inch
23
diameter burning molten blob of polyethylene onto Remingtons back, burning through all shirts in
24
a second, and then it seriously stuck there to the skin on his back for about 10 seconds, in a difficult
25
to reach location, causing severe third-degree burns.
26 1098. Mathson has continuous 24-7 access to Remingtons yard, property and
27 residential structure through his at least two secret doors, and has had such since at least two
28 years before said arson. He can and does use those secret doors during daylight without being
seen, except for the one time when my wife saw him peering through a crack in the door. That
completely freaked-her-out, and shes only been back one time that Remington recalls about five
years after that incident, to look hastily for some old Christmas ornaments, stored inside the house.
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The evidence now shows that he stealthily came over, while Remington was entirely buried
2
behind three different doors in another part of the house, and kindled the fire with a match in some
3
highly flammable materials, about 1-foot inside Remingtons unlocked plywood front door, and
4
then he quickly ran back the 250 feet to his own yard, entirely and 100% obscured from neighbors
5
view by a 25 foot tall 10-15 foot thick privet hedge. However, he was seen later watching with
6 great interest from the street side of said hedge, while the fire department engines were there a bit
7 later. More data about that will be provided at his next deposition. That extreme act of arson and
8 arguably attempted murder, is expected to be repeated someday, especially in the event of his
9 inevitable loss here, sometime in the distant future.
10 1099. As a result of that particular danger, plus the numerous other cited serious property
11 vandalisms involving numerous randomly cracked or smashed large expensive six-foot tall
Anderson dual-pane windows by Mathsons rocks, plus the other personal property complained
12
about, Remington has had to maintain an excessive amount of Homeowners insurance to enable a
13
complete rebuild and a full-replacement of the several hundreds of thousands of dollars of valuable
14
items inside. He also has to keep electronic backup copies of all documents and records outside of
15
the structure, and be very wary and cognizant of where he stores various valuables. For example,
16 right now today, Remington has approximately 1000 pages of un-filed federal complaint
17 documents, which could be destroyed in two minutes by another arson fire. Therefore, tonight like
18 every other night, Remington will save todays thousands of words of additional word processing
19 to a portable digital Cruzer storage device, so that he can carry all of these old and new federal and
20 state legal documents out of here daily, in order to be protected in the event of that next fire
21 occurring tonight.
1100. What is the standard of proof required in a civil RICO action?
22
Since Sedima v. Imrex, 473 US 479, 491 (1985) every Court of Appeals that has addressed
23
the subject has held that the preponderance standard applies to civil RICO actions, see Wilcox v.
24
First, 815 F 2d 522, 531 (9th C.1987).
25
1101. Attorneys fees are recoverable by the prevailing prosecuting plaintiff, but not by
26 the accused defendants. Presumably, some of Remingtons legal costs and time will be recovered
27 at least at the rate of a paralegal, if this court or jury determines that Remingtons writing and
28 research in these various environmental and RICO areas has any merit. In any case, at the
appropriate time, such as under the sections about harms caused and damages requested,
Remington will request compensation for some of those 10-20,000 hours of legal time spent here,

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because it is probably the most important and significant detriment cause thereby defendants
2
RICO enterprise.
3
1102. Remington himself is not a licensed attorney, however he does expect to employ one
4
or more in this RICO action, as needed, probably partially on some form of contingency recovery,
5
plus expenses.
6 A. The Ninth Circuit has held that 1964 (c) permits only prevailing plaintiffs to recover
7 attorneys fees and not defendants, such as Gans enterprises core group of racketeering attorneys
8 and support staff. Obviously, that will also apply to the attorneys of the other numerous alleged
9 RICO defendants and near-defendants, plus those others who are expected to be charged, either
10 civilly, criminally or both, when the additionally discovered evidence permits, Chang v. Chen, 95 F
th
11 3d 27, 28 (9 C. 1996).
1103. Rule 11 (b) (3) sanctions.
12
Plaintiff Remington believes, and knows, under penalty of perjury, in most, and probably all
13
cases, alleged herein, as appropriately qualified and the specific sections, that the accusations and
14
facts contained herein and as described in the entire company RICO statement are true, correct,
15
valid, factual, have very substantial evidentiary (including photographic and human witness)
16 support under federal law and are sufficient to expose, bring-down and otherwise convict and
17 destroy Gans RICO extortion racketeering enterprise, explained herein. In other words, sufficient
18 evidence exists today to allow these two RICO causes of action below to proceed here in federal
19 court, and without question after two years of federal discovery we will have another 2-5 times
20 worth of useful material evidence in this RICO case.
21 1104. However, virtually no actual additional discovery as such has been done in any of
these cases for about six (6) years. A huge amount of related older information was gathered,
22
reformatted, charted in Photoshop and recorded from more than 100 continuous days of pretrial
23
hearings in 2016+12 week trial of half days, but it was sharply limited by Gans objections and
24
numerous judge Reinholtsen protective rulings. Gans cleverly and successfully stonewalled most
25
evidentiary issues and sat silently for hours at a time, during spring and summer 2016, as
26 Remington made literally dozens of serious provable accusations, which Gans and Plotz mostly
27 neither confirmed nor denied on the stenographic record.
28 1105. Additionally, Gans for primary perjuring witnesses in August 2016 swore to their
coached and well-rehearsed, unflappable testimony, which the court inexplicably allowed, despite
its apparent or at least inferred ability to sense who was telling the truth or not, which failed
miserably here. If that court did or does have any ability to determine, just from listening and
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attempting to intuit, sense, feel and/or judge what testimony was truthful or not, it sure did not
2
show any indication of that ability for two weeks of trial, and thoroughly and 100% lost the
3
confidence of Remington, with that glaring inability, etc. In other words, said Judge failed to detect
4
who was telling the truth and who was lying, not just once but in at least a dozen important than
5
material instances. Probably that was Gans fault, as his honest -appearing deceptions and frauds
6 are exceptionally skilled and apparently difficult, and in August 2016, impossible, for his former
7 law partner to detect or punish in any event.
8 1106. Therefore, we now have a huge amount of solid information to proceed on, but still
9 need several years of further comprehensive investigations in this complex case which will
10 obviously reveal and fully document much more solid support for these RICO contentions before a
11 trial. The known obvious pervasive mail and wire fraud evidence between the enterprise members
alone will obviously greatly multiply the incriminating evidence against hands and the other
12
enterprise members, especially when thoughtfully targeted and combined with strategic
13
depositions, which expense Remington will need to incur this time.
14
1107. Now that Remington understands the extreme and potentially unlimited depths of
15
corruption, violence (which is actually very disconcerting) and perjury that Gans and his enterprise
16 members are going to indulge in, Remington can carefully prepare for the worst case scenario. That
17 discovery plan, already in preparation would of course involve properly sequenced depositions,
18 well-targeted special interrogatory and document requests designed to consistently elicit the state
19 court perjury by all testifying witnesses (except Pulley, as noted), plus plenty of motions to compel
20 responses, which are expected to be urgently required to back-up probably every well-targeted
21 request. That would rather obviously be because, as noted above, revealing any of the truthful
information which Remington will be requesting will inferentially potentially send someone to
22
prison on one federal violation or another, most likely, and consequently, since ultimately that is
23
most likely to quite quickly implicate Gans, HE will therefore fight every single request by
24
Remington, as though his life depended on it.
25
26
RICO CLAIMS FOR RELIEF
27
FIRST CLAIM FOR RELIEF
28
(Violations of RICO, 18 USC 1962 (c),
Against All Ten (10) Presently Designated Defendants)

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1108. Remington re-alleges and incorporates herein by reference each and every foregoing
2
and subsequent paragraph of BOTH portions of this federal complaint, i.e, Volumes I & II,
3
including the pertinent facts in the RICO statement and ALL photographs and trial charts in
4
Volume III, as if all relevant allegations were consistently set forth in full here.
5
1109. Remington further specifically incorporates by reference all relevant facts contained
6 within the entire 738-page RICO Statement, which although drafted over a lengthy period of nearly
7 6 months of continuing changes, revisions and material edits, nevertheless is still accurate,
8 complete and if it is inconsistent with some of the earlier versions, the broadest possible corrupt
9 interpretation should ordinarily be construed, as well as some of the last addendums point after
10 about page 672.
11 1110. At all relevant times, Remington and the Burl Tree is a person within the meaning of 18
USC 1961 (3) and 1962 (c).
12
1112. Likewise, at all relevant times, each of the presently 12, but gradually increasing
13
number of RICO defendants below, is also a person within the meaning of 18 USC 1961 (3)
14
and 1962 (c).
15
1113. This count is against all twelve (12) presently named-defendants, hereinafter the
16 Count one defendants. It is now expected that several more borderline enterprise members will
17 be added for sure in the FAC, after minimal additional discovery is completed, to add one or more
18 federal predicate acts, where today perhaps only one exists. As described above, the rampant and
19 flagrant state fraud and perjury perpetrated upon plaintiff by several presently unnamed RICO
20 defendants, merely needs to be repeated for about five minutes of deposition time in this federal
21 forum, to instantly add several more RICO defendants. See GANS RICO ENTERPRISE
ORGANIZATIONAL CHART-2017.
22
1114. This alleged Gans and Mitchell firm-led RICO racketeering enterprise involves and
23
affects some interstate commerce, however the real and central effects on interstate commerce are
24
due to the enterprises deleterious impact on the Burl Tree business. Said Burl Tree burl logging,
25
milling, manufacturing, extensive finishing, sales and distribution business, today operates
26 exclusively and 100% as an interstate commerce business, hence Gans enterprise severely disrupts
27 and damages a fairly major North Coast interstate burl business. Formerly, the largest, and
28 provably most successful, anywhere. In other words, for the last 15-20 years the Burl Trees sales
have been mostly 100% out-of-state, and always at least 95%. Additionally, although the Burl Tree
has bought 10-20% of its purchased materials and supplies within California in some isolated

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years, on the average and definitely overall it has purchased more than 90% of its necessary
2
purchases in interstate commerce, also.
3
A. In other words, at all relevant times Gans enterprise affected interstate and foreign
4
commerce within the meaning of 18 USC 1962 (c).
5
1115. The RICO defendants and their co-conspirators are a group of persons associated
6 together in fact for the common purpose of carrying-out an ongoing, intentionally criminal
7 enterprise, as amply described in the foregoing paragraphs of this complaint; Specifically, it
8 operates through a multifaceted campaign of lies, extensive and pervasive perjury, fraud, extortion,
9 intimidation, exaction, threats and miscellaneous other corruption, in order to coerce Remington
10 into dropping his obviously just contamination clean-up demands and also to extort him to forgo
11 the several hundreds of thousands of dollars of damages defendants now clearly owe to Remington.
Gans RICO defendants and their co-conspirators have organized their operation into a cogent and
12
cohesive group led from within the plush offices of the Mitchell firm, with specific assigned
13
responsibilities and a discrete hierarchy, clearly defined organization and command structure,
14
which operates overall throughout the Eureka California area, but as explained, appears to only
15
function as a true RICO enterprise when the Remington case files are opened. Discovery, however
16 will attempt to determine whether Gans RICO enterprise goes beyond Remington to involve other
17 plaintiffs and other criminal acts, which in any case would probably technically be a separate RICO
18 enterprise, even if many of the same participants were involved in a different conspiracy. Over the
19 past 4-8 years the afore-complained of RICO conspirators, have adapted their scheme to changing
20 facts, circumstances and interim court decisions, recruiting new members to their operation and
21 expanding their objectives and scope, while ever-deepening the corruption of their activities,
overall. While the organization of their criminal enterprise has evolved somewhat over time, as
22
different issues, facts, witnesses and court decisions arise, Gans criminal enterprise has generally
23
been structured to operate as the concise unit it still is today, in order to accomplish their criminal
24
goals, as very briefly summarized below in the next paragraph. Obviously, see the RICO statement
25
for all of the complete, presently-discovered allegations against these above-designated 12 RICO
26 defendants.
27 1116. Briefly the named-defendants in this RICO count are:
28 a. Defendant Russell Gans, Esq. has been responsible for opposing Remington in these
multiple litigations since about 2007, and what HE began as an overly-aggressive and unethical
advocacy, gradually became a pure criminal RICO enterprise by about 2012-13, because honest

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tactics in accordance with the Code of Civil Procedure, have never worked very effectively for
2
long for Gans in this case.
3
b. Therefore, since the RICO enterprises inception, Gans has always been primarily
4
responsible for its overall planning, execution, its NUMEROUS calculated, artifices, tricks and
5
schemes to defraud, vandalize, damage, defeat and extort Remington, and to direct his co-
6 conspirators to take whatever actions were necessary to accomplish the overall aims and objectives
7 of the criminal enterprise as explained above. Very succinctly put, those include, without
8 limitation: Manufacturing perjured and other contrived, unscientific and impossible evidence
9 inferring Remingtons liability for all contamination of both relevant sites; Manufacturing
10 fraudulent defensive evidence and then using it to fraudulently influence Health Department
11 regulators; Fraudulently slandering and deriding Remingtons professional testing results,
especially after Aveggios death and inability to defend his integrity and results; Physically
12
removing, spoiling, altering and intentionally (concealing with redwood needles) the actual factual
13
evidence which exists on both sites; Promoting sham visual nuisance, frivolous trespassing
14
allegations (against Remington) and bogus fence location, and related insignificant (small nails
15
driven into 4 inch thick bark) allegations against Remington to distract and attempt to offset the
16 real damages here; Conducting a major local public-pressure campaign to spread false, slanderous
17 and generally misleading, prejudicial information about Remington and his lawsuits in the
18 community; and, Obstructing and totally blocking Remingtons efforts to present honest, real
19 material evidence at numerous state court proceedings. Overall, it takes over 70-pages to list Gans
20 federal predicate acts, and those are only the ones that have been discovered to date, and to explain
21 them with particularity, see e.g. Gans alleged extortion, bribery, mail fraud, multiple kinds of wire
fraud, obstruction of justice, obstruction of law enforcement, witness tampering, retaliation against
22
witnesses, money laundering allegations, inferred drug involvement with his using co-
23
conspirators, and miscellaneous deprivations of Remingtons rights, etc.
24
1117. Defendants Plotz, Brisso, Kloeppel, McBride and the Mitchell firm operate
25
primarily in a supporting role for Gans, entirely under his exclusive personal direction, and they
26 have been seen to assist in the planning and execution of his fraudulent and illegal schemes to
27 corruptly harm Remington. It takes about 12-15 pages to explain the individual roles as best they
28 are known to date, and those details are generally found between pages 324, of the RICO
Statement, after each individual name. All four (4) above-named individuals there have had
extremely important and powerful roles at times during the history of this enterprise, all of which
still continue into March 2017. Today, Plotz and McBride would be the primary individuals,
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1
continuously involved in all daily RICO decisions, planning, the intentional execution of fraudulent
2
and corrupt schemes, and perhaps most importantly they would have the ability to put a stop to
3
Gans corrupt activity in minutes, if they chose to do so, which at the moment they do not. Maybe
4
they will now choose to do so.
5
1118. It is also always foolish to disregard Brisso, who is arguably the most powerful
6 behind-the-scenes illicit manipulator of all authority figures in the courthouse, especially in the
7 County Health Department, and far beyond that into the outlying municipalities at a minimum.
8 Brissos power is obviously overwhelming and not fully understood without considerable
9 discovery. As explained in the RICO statement, he is the Godfather, emeritus who does not need
10 to participate in the ordinary day-to-day corrupt details of drafting and coaching perjured trial
11 testimony, because he is too busy planning overall big picture agendas and how to use the
powerful commission and Council members, judges and other local leaders, whom he irrefutably
12
and detrimentally for Remington has great influence over, one way or another. Whether he will
13
now allow or assist the RICO enterprise to become violent, dangerous and ruthless against
14
Remington, to in effect shut-him-up in order to protect his known and demonstrated
15
overwhelming power and influence within the District Attorneys Office, probably in Department
16 Eight, and with other judges of the Humboldt County Superior Court, and demonstrably and
17 provably in the various County Council and City Attorneys office around the area, is presently
18 unknown, but not for long. Remington has at least two witnesses to the above allegations, and
19 expects to develop more without too much difficulty as investigatory time permits.
20 1119. Plotz and McBride are the day-to-day workers, gophers, legal researchers, drafters and
21 motion-writing drafters, for Gans express approval, who during active periods of these multiple
litigations spent full-time on these cases cranking-out dozens of nicely-processed, sloppily
22
researched, newly crafted and/or fabricated pages every day. However, for the last several years
23
virtually everything they have done, on behalf of their RICO enterprise, involves, for example:
24
Prosecuting their sham defensive litigation against Remingtons 2-3 cases, with such technical and
25
essentially frivolous drivel which included: numerous Motions to Strike, Demurrers, Objections to
26 all Remingtons experts, motions to amend his complaint and a dozen other topics, and ALWAYS
27 with incessant, inflated and obviously frivolous requests for sanctions for literally everything
28 which Remington requests or opposes. 100% of which have been denied since 2011. Dozens of
other types of bogus or entirely sham and/or knowingly false documents with little or no
merit included, without limitation, Gans severance motion opposition documents and their
numerous MIL #20 motions, some of which frivolous, improper or false, badly-researched
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1
requests, such as related to their collateral estoppel work, seriously confused Judge Reinholtsen
2
and resulted in the severe disruption of these cases, which continues. Remington cited dozens of
3
other similar unethical and worse intentionally corrupt examples of the enterprises documents in
4
the RICO statements.
5
1120. More than 20-pages of meticulous detail and specific proofs of the above exist in the
6 RICO statement, and Remington expects to add at least 200 more, so far discovered pages, alleging
7 new mail fraud essentially, which are already in progress to follow in the FAC or the state version of
8 this RICO action if required; however, for now, said above they (including Kloeppel and Brisso,
9 where appropriate and just), are Gans right-hand men. Thus, Gans has plenty of able
10 brainpower and administrative researchers and legal writers to make his life very easy.
11 Cumulatively, they all also help to manage Gans private army of experts, corrupt witnesses and
property-destroying vandals and soldiers, while exerting improper influence, passing along
12
fraudulent and corrupt orders, and otherwise colluding and communicating with and among the
13
RICO conspirators. Again, as in all other cases, see RICO statement for at least 5-6 times more
14
detail, about all of these allegations.
15
1121. John Mathson is one of the original defendants in the contamination lawsuits, and
16 now serves as Gans chief criminal enforcer. As noted, he is one of the fundamental core
17 members of the RICO enterprise, whereas his wife Joy Mathson has happily not yet
18 implicated herself here into this bottomless whirlpool of proven very serious federal
19 potentially imprisonable violations, YET.
20 1122. John Mathson is discussed fully at RICO statement pages 108-136 and his impact on
21 Remington, the Burl Tree and these cases cannot be properly condensed, here. As discussed above
and also below under pattern of racketeering activity, Mathson has arguably personally
22
committed more federal predicate crimes than anyone else involved here, even Gans. Gans ordered
23
these extortive acts in general terms and sometimes on specific dates, however John Mathson loves
24
torturing and tormenting Remington so much, that he improvises and does a little extra, because
25
thats the primary focus of his entire life, as we will prove during the next round of discovery.
26 However additionally, as also argued above, since John Mathson is essentially a marionette and a
27 handheld puppet, he is fully controlled by Gans in the broadest possible sense. Therefore, he is like
28 a soldier in Hitlers army: Guilty of more than 100 serious crimes in literally 15 different
categories. He is as guilty as a cowardly, traitorous torturer can be, and if not deserving of
execution, he deserves some very serious punishment. But is he more guilty and worthy of
punishment than Hitler himself? Probably, we will get his opinion during discovery, but ultimately,
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1
that will be up to a trier of fact here, after Remington expresses his extremely strong but perhaps
2
non-objective opinion during closing arguments. Remington has extensive incriminating
3
surveillance footage on John Mathson, e. g. Photo #54.
4
1123. Rich Olson and Kyle Skillings of RAO Construction. Those two criminal
5
excavation contractors and truckers are fully discussed at pages 163-176 of the RICO statement.
6 They have both coordinated the extortion and intimidation of Remingtons remediation expert Bob
7 Figas, which was one of the first egregious and damaging criminal acts caused by this enterprise,
8 Subsequently, Skillings in particular has had a strong influence on these cases, and maintains a very
9 conspicuous and dangerous profile here. He has now fully proven himself to be an established
10 serial perjurer, as well as a brutal and violent soldier to be greatly feared by everyone on
11 Remington side of the case. Inferentially, that is the intended frightening effect that Gans intends
for him to have. He is a salaried employee of Olson and RAO, neither of whom have yet made an
12
appearance in these lawsuits, and also works for Kluck. Skillings is strongly expected to prove that
13
he is a violent force to be feared and capitulated to in these cases, and presumably he will prove his
14
worth and manhood by attempting some violent acts against the Remington family before long. As
15
soon as written discovery begins in this case he will be forced to repeat his perjured state testimony
16 in federal written discovery of all types, which will totally implicate him instantly, since that
17 perjury by all of them is easily provable in the next trial, where a proper foundation can be
18 established this time. Olson is a known, long-time well-established ruthless concrete contractor and
19 local criminal, as outlined above, but we will need extensive discovery and numerous witnesses
20 from within his concrete construction organization, from his subcontractors, plus some of his
21 customers, to prove his generally unsavory and unreliable ethical reputation in the community, and
his reputed frequent contamination and unlawful dumping, over many years at other local sites.
22
1124. Linda Lawrence, believed to still be a chief insurance adjuster, handling the
23
Mitchell firm and RICO accounts at the Sacramento office of Allied Insurance Company, in Des
24
Moines, Iowa, who is here sued as an individual, because she knew about, intended or should have
25
known about all of Gans progressively more criminal activities. She financed it gladly,
26 enthusiastically, maliciously and presumably will continue to do so until Remington is dead and
27 gone from the scene. She is discussed in more detail, at pages 94-108 of the RICO statement,
28 which describes some of the presently known specific predicate acts she has already committed,
and is soon expected to double or triple that number, once discovery commences in this case.
1125. Jeff Nelson is the enigmatic, grizzly old CEO of SHN Engineering and Consulting
who was the supervisor and boss of Remingtons two primary local environmental experts,
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1
Aveggio and Foget. To Remington he is best-known for his shocking, perfunctory, unfeeling
2
tortious contract-breaching act of removing expert contamination engineer Foget, from his case a
3
mere few weeks before a prospective trial date. At that time, Foget was the foundation of
4
Remingtons entire trial presentation, analogous to the leadoff man and anchor leg of a mile relay
5
team.
6 1126. Remingtons preeminent environmental expert Aveggio died of purported natural
7 causes, obviously worsened by his exposure to the infectious toxic wastes on these sites, which
8 have also nearly killed Remington several times recently, as complained of elsewhere.
9 Subsequently, Foget was hired, trained and paid to replace Aveggio with Nelsons full-knowledge,
10 participation and approval, but approximately two years later was corruptly removed by the
11 tortious breach of contract explained for 15 pages at 2I, see approximately pages 187-205.
Remington has reliable information which implicates both Gans and Nelson in a collusive
12
racketeering relationship, intended to damage or destroy Remington and benefit themselves,
13
proportionately. Discovery, including depositions, from the middle and lower levels of both of
14
these organizations, especially the secretarial staff, such as McBride and her SHN counterparts,
15
will be useful and important to prove all of the links that have been alleged here.
16 1127. Nelson has been involved in the numerous illicit state predicate acts, one serious
17 tortious, VERY damaging contract breach, and a few federal crimes to date. During federal
18 discovery, like many of the others, he is expected to bury the knife in deeper, federally, as he lies
19 to justify, rationalize and exonerate himself. He has already severely extorted and intimidated
20 Remington on behalf of Gans, assisted with witness tampering with Foget, committed numerous
21 acts of mail and wire fraud while simultaneously obstructing justice, and retaliated against
Remingtons primary environmental expert witness Foget. Foget was very excited and intensely
22
interested in becoming Remingtons environmental testifying trial expert, so Nelson not only
23
damaged Remington but also Fogets career and treated him like a robotic slave. That is allowable
24
in a professional working relationship, however Remington was not the only one damaged by the
25
RICO enterprise over this issue. Finally, Nelson violated federal law, 1952 with regard to
26 interstate travel with illicitly laundered funds derived from these RICO relationships.
27 Since the allegations against Nelson are somewhat convoluted, complex and lengthy and take
28 about 15-pages to explain, Remington essentially defers to those pages.
Pattern Of Racketeering Activity
1128. The count one defendants agreed to conduct and did knowingly participate in the
conduct of the enterprises obviously partially corrupt affairs through the clear pattern of
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1
racketeering activity described and for the unlawful purpose of intentionally defrauding plaintiff
2
through bogus scientific and legal subterfuge, to reach their stated objectives. Until Remington
3
actually came to understand the significance and extreme illegality of Gans unusual, creative and
4
incredibly unexpected pattern, beginning in fall 2016, Gans RICO extortion racket against
5
Remington was flawlessly and magnificently successful. It is also still working today, but less so
6 going forward.
7 1129. At this point, it really is necessary to summarize or specify each instance where each
8 individual defendant conducted and participated in the conduct of the affairs of the enterprise,
9 through a pattern of racketeering activity. Simply put that means what were the individual
10 criminal acts allegedly committed by each named defendant and what was the exact time, specific
11 place and what were all relevant details surrounding those specific acts?
A. That is a problem here, because we already have 700+ pages or more devoted to those
12
facts. To specifically list again the several hundred fraudulent, improper and unlawful acts
13
associated with the 11-named defendants, which we have already fully- alleged based on our
14
present discovered information, would be redundant, excessive, onerous, counterproductive and
15
therefore Remington declines to do so again here.
16 1130. Irritating and unlikely as it may be for the court, or some of the other readers to now
17 seek out the details, if any are desired at this point, by way of references to the approximately
18 738-page RICO statement, plus indexes and the photos in Volume III, nevertheless that is what
19 Remington will now suggest. All required details are there, easily found from the indexes, and page
20 numbers and therefore some of those are now provided.
21 A. Pages one through approximately 208 discuss in detail the alleged predicate act
violations of all of the named defendants, including sufficient details to allow this complaint to go
22
forward.
23
B. The next 107 pages provide a summary of essential details about the additional
24
wrongdoers which is #3 of the accompanying RICO Case Statement Standing Order Form.
25
C. All of the information which might ideally be included here now at #1128 (The detailed
26 pattern of racketeering activity by this allegedly RICO enterprise) is consolidated and included at
27 5. (a) and (b), on pages 307-488 on the day this paragraph was written.
28 In the RICO statement and index that category is shown as: 5. (page 246)
1131. Describe In Detail The Pattern Of Racketeering Activity:

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1
All of the best summary discussions of these issues are presented between about
2
pages 246-390 is listed in the index and as characterized as:
3
A. (a) & (b). Introduction: 17 categories of predicate acts violated here by Gans RICO
4
enterprise, Diagrams, Organizational chart, See GANS RICO ENTERPRISE
5
ORGANIZATIONAL CHART-2017, used in several places;
6
B. November 2016, 30-page document (324-356), Description of Enterprise;
7 C. 132-page November document of Chronological Predicate Acts from
8 2012-2016, pages 356-488 (with a Summary at 484-488);
D. Table One is shown several places in the RICO statement, including in Volume III,
9
after photos & charts and page 107 BELOW, showing the relevant Predicate Acts complained of
10 here so far, without federal discovery yet.
This is all important summary material and for the court or defendants wishing to
11
know what charges are alleged against them, this summary section as identified above is
12
important and arguably crucial to read and fully understand.
13
1132. Defendants alleged racketeering activity. Pursuant to and in furtherance of their
14
fraudulent schemes, defendants committed multiple related acts which were a clear pattern of
15
racketeering activity from 2012-2017 that form the basis of the RICO claim. See also #1136 below
16
for the specific statutes in general categories of violated federal predicate acts common to all RICO
17 defendants violations.
18 1133. In the above- reference November 2016, 132-page document entitled Chronological
19 Predicate Acts From 2012-2017, which is fully set forth in Remingtons definitive
20
RICO statement, already incorporated herein by reference, at pages 356-488, the alleged
21 chronological pattern of criminal activity by date and individual violator (s) are fully set forth, and
22 thats where the information is right now. As above, Remington does not believe it would be helpful
23 to re-summarize, reorganize and repeat for a third or fourth time that same information, and so it is
24 not been done here.
25 A. In other words, please refer to the RICO statement now, pages 356-488 for a
26 chronological listing and discussion of Defendants corrupt RICO enterprises activities over
27 the last four years.
1134. Additionally: For individual discussions of each named RICO defendant, their
28
misconduct and the alleged federal statutes violated and predicate acts committed for the unlawful
purpose of intentionally defrauding plaintiff, see Remingtons 738-page RICO statement at the

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1
pages designated, which still were accurate as of March, 2017, but do vary gradually during editing
2
and revisions:
3
4 2A. Russell Gans, pages 10-94;
5 2B. Linda Lawrence, pages 94-108;

6 2C. John Mathson, pages 108-136;
7
2D. Rich Olson, pages 136-163;
8
2E. Kyle Skillings, pages 163-171;
9
10 2F. Ryan Plotz, pages 171-176;
11 2G. Paul Brisso, pages 176-182;

12
2H. The Mitchell firm, LLP, pages 182-187;
13
2I. Jeff Nelson, pages 187-205;
14
15 2J. Julie McBride, pages 205-208;
16 2K. Nicholas Kloeppel, pages 208-211.

17 1135. SUMMARY: The above cited RICO Statement pages, 6-167 specifically consider some
18 of the presently known instances, without limitation, where each specific defendant conducted and
19 participated in the conduct of the affairs of the enterprise through a pattern of racketeering activity.
20 More instances of racketeering activity are expected to be discovered imminently, and some are
21 disorganized and not neatly categorized under each named defendant, but are found elsewhere in the
approximately 1000 pages of ALL the documents comprising this federal complaint in Volumes one
22
(I), environmental portion; two (II), RICO portion; and three (III), photos pertinent to the entire case.
23
1136. Predicate Acts used in 2016-17 RICO Cause of Action, which
24
25 were cumulatively violated by all named defendants, as indicated above.
26
1. 18 USC 1951, Hobbs Act. EXTORTION, deliberately causing great FEAR in Remington;
27
2. 18 USC 201. BRIBERY, at least a dozen incidents of varying severity are alleged;
28
3. 18 USC 1341. Mail Fraud (overlaps with violations of California B & PC 17, 200, et seq);
4. 18 USC 1343. Wire Fraud, including internet, email and phone;
5. 18 USC 1503. Obstruction of Justice. Gans has no honest scruples or ethics;

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1
6. 18 USC 1511. Obstruction of law enforcement, as to a gambling endeavor;
2
7. 18 USC 1512. WITNESS TAMPERING. This is a BIG ONE. Arguably Gans favorite;
3
8. 18 USC 1513. Retaliation Against Witness;
4
5 9. 18 USC 1515 (a) (1,3 & 6) and (b), applicable definitions, such as Making false statements,
6 omitting information, intentionally concealing facts and destroying material evidence.
7 18 USC 1952. Barring interstate travel with racketeering or gambling income, applicable here;
8 10. 18 USC 1956. Money laundering uses are illegal, and ALL RICO Defendants are guilty;
9 11. 18 USC 1957. Specifically bars property sales or purchases with laundered dirty money;
10 12. 18 USC 1961-4, et seq. Money laundering: barring illegal profit investments in businesses;
11 13. 49 USC 5101, et seq,. Improper safety and permitting for hauling hazardous wastes;
12 14. 15 USC 2607, 2614-15 and 2642. Violations of many hazardous materials hauling laws;
13 15. 42 USC 1983, Miscellaneous actionable deprivations of Remingtons rights by defendants.
14 16. 42 USC 102, Selling, using and dealing in various, named controlled substances.
15 Those specific federal predicate acts set forth above constitute an actionable pattern of
16 racketeering activity by Gans RICO racketeering defendants, pursuant to 18 USC 1961 (5).
17 1137. Additional details. The Count One (I) RICO defendants have directly and indirectly
18 conducted and participated in the conduct of the enterprises affairs through the above described
19 pattern of racketeering and related litigatory activity, in violation of 18 USC 1962 (c).
20 1138. The above-cited RICO defendants have engineered and launched a wide-ranging
21 campaign against Remington and Humboldt County Superior Court, the Health Department and in
22 the local community, entirely based on false and misleading statements, known incompetent testing,
23 frivolous investigations by governmental agencies, ongoing harassment, disruptions and destruction
of Remingtons business operations and Gans is essentially demanded a tribute from Remington
24
involving him dropping more than $500,000 of costs and just damages before they will stop
25
tormenting and damaging Remington and his family.
26
1139. All of the above and all of the acts contained within these filed documents were done
27
with the intent and effect of causing the reasonable fear in Remington that defendants enterprise
28
would continue to cause greater and greater losses and damages forever, within our lifetimes, or
well- beyond, if necessary.

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1
1140. To execute the above corrupt practices and violations of federal law, Gans enterprise
2
mostly manufactured false evidence including testing, photographs and suborning oral trial
3
perjury in all of their witnesses testimony. Gans committed unlawful witness tampering under
4
1512 with Costa, Skillings, John Mathson, Kishpaugh, Pulley and Joy Mathson, in other words with
5
all their testifying witnesses. Gans entire trial presentation was based on misleading conduct,
6 mischaracterizations, serious unethical and impermissible coaching and training of all his
7 witnesses and then coaching them into memorized too-consistent scripts with each other, and in
8 summary correctly persuaded all of his witnesses to lie in order to destroy Remingtons discovery
9 rule exception. It worked, and Gans won the August 2016 trial, by fraud, deceit and criminal acts,
10 but that was just one small battle amidst a major war.
11 1141. Gans personally wrote the scripts, improperly and unlawfully ( 1512) coached the
witnesses and then led them through their false facts and knowingly corrupt material testimony.
12
Defendants RICO enterprise have deceived the courts with false declarations, irrelevant out-of-
13
time photographs and hydrocarbon testing data, where their evidence was spoiled, altered, removed
14
and/or where all relevant conditions were intentionally fraudulently changed to fit their overall
15
entirely false narrative that they never contaminated anything, but rather Remington did it himself,
16
despite the impossibility of doing so.
17 1142. Accordingly, the RICO defendants have unlawfully obstructed, delayed, affected, and
18 also attempted to obstruct, delay and affect commerce, as that term is defined in 18 USC 1951, the
19 movement of the Burl Trees articles and commodities in interstate commerce, by extortion, (as
20 defined in 1951), in that the RICO defendants attempted to induce Remington to consent to freely
21 giving and abandoning his property to the Mathsons, through the wrongful use of actual and
22 threatened force, vandalism, violence, and fear-including the fear of real actual occurring economic
23 harm.
1143. Multiple instances of mail and wire fraud have been committed by defendants, as
24
cited throughout the RICO statement, which violations of 1341 and 1343 continue and are also
25
expected to be multiplied by 3-10 times shortly, for the obvious reasons indicated above. See e.g.
26
RICO statement throughout, for nearly continuous examples of mail and wire fraud, and about 20
27
total, which is not a full-listing of all of those alleged herein.
28
1144. As described in those above-cited pages, in furtherance of their scheme, the RICO
defendants transmitted or cause to be transmitted by means of wire communication in interstate
commerce, writings, pictures, maps and documents, and caused those things to be placed in various

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1
post office boxes or similar authorized depositories and also made multiple phone calls and sent
2
electronic messages via Suddenlink Internet cable. Those mailed documents and wired emails
3
included, but were not limited to, the following: Emails and mailings related to all of their experts
4
false and misleading declarations and reports, including those sent to the Humboldt County Health
5
Department and filed with state and federal courts; wirings and related mailings between and among
6 the RICO defendants concerning the preparation of all of their numerous false expert reports,
7 devious deposition strategies, concealment and evidence spoliation activities, and communications
8 involving the scheduling of, coaching (meeting dates with Gans and his co-conspirators and related
9 details), and the substance of all defendants trial witnessess perjured trial testimony;
10 Communications directed towards the various state court judges here, especially Judge Reinholtsen,
11 which incorporated false and misleading statements regarding all of Remingtons testing and trial
related activities as well as Gans deceitful and corrupt defensive evidence and overall strategies;
12
use of the mails to send or wire transfer monetary funds from Linda Lawrence to Gans, the Mitchell
13
firm and then to all of the RICO defendants, all of which are paid well, to promote and effectively
14
bribe all RICO defendants in order for them to continue to happily carry out all of their
15
aforementioned criminal activities. With no pay, very few will play; The electronic and paper filing
16 and service of thousands of pages of federal and state court papers virtually all of which contain
17 false and misleading statements intended to illicitly destroy Remingtons case and to deceive
18 and otherwise obstruct the operation of those courts.
19 1145. As alleged throughout, but stated slightly differently here, Gans RICO racketeering
20 enterprises ultimate objective is to coerce Remington into making and also forgoing substantial six-
21 figure dollar monetary payments, which several hundred thousand dollars is presently, and is also
22 intended in the future to directly benefit all individual and organizational defendants, especially
23 Linda Lawrence and her employers, and of course Gans.
1146. As explained above, Gans also used the ruse of an independent expert Esko to deceive
24
the county and the courts with false and misleading testimony that cans new to be incompetent and
25
false. Eskos report was essentially fraud based on knowingly fraudulent incompetent test results.
26
Esko only considered one Biased side, that of the enterprise and then successfully deceived two
27
different Superior Court judges with that false narrative, Breen and Reinholtsen, which fraud was so
28
significant that it eventually could damage Remington to the extent of losing one or more of these
cases.

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1
1147. As background to GE above, Gans and his enterprise soldiers, including Ferriman and
2
Gwinn, fraudulently disseminated Blue Rock Environmentals knowingly incompetent report in fall
3
2011 to Melissa Martel at the Health Department, knowing it to be false and misleading and that it
4
would lead to their objective, which was to get Eskos influential but fraudulently, scientifically
5
wrong report.
6
1148. As complaining above, 2011 and subsequently Plotz and Gans circulated on behalf of
7 the enterprise, the false expert declarations from all of their experts with knowledge of their
8 falsity. For example, as cited in the RICO statement, in 2016 defendants used and deceived the
9 court with a large 12-inch high pile of those false expert declarations, fraudulent 143-page 2010
10 Blue Rock report and related documents in order to procure their erroneous MIL #20 decision.
11 That act of both mail and internet wire fraud was also an obstruction of justice violating
predicate act 1503. Many of the cited RICO predicate acts above, violate 3-4 laws
12
simultaneously.
13
1149. Finally, we now need immediate discovery directly from the enterprise itself by
14
proceedings under Rule 26 (a), (f), etc which authorizes and requires the enterprise to immediately
15
submit their most incriminating documents, which when they refuse to do so, we can commence
16
motions to compel quickly. Just as they have done in prior court proceedings, the enterprise is
17 expected to consistently avoid discovery and refuse to reveal the truth about anything. The
18 enterprise specializes in obfuscation, quibbling and frivolous objections to discovery requests,
19 which is expected to continue immediately in this federal forum.
20
21
1150. DAMAGES.
22
23 As a direct and proximate result of the Count One defendants racketeering
24 activities and violations of 18 USC 1962 (c), plaintiffs Remington, et al and the Burl
25 Tree have been seriously injured in their business and property in that they incurred
26 the thoroughly discussed approximate damages in the RICO statement from about
27 pages 656-670, and elsewhere, which are substantially paraphrased, without limitation
28 or detailed cross referencing, in the next paragraph below. Most of these damages were
calculated during winter 2016, and some but not all have been upgraded into February 2017,
but since most of them change somewhat every month, the final calculations will not be
made until during a trial of these actions.
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1
2 1. Permanently lost iron sales attributable to the Figas extortions: At least $28,000
3 2. Overall lost Burl Tree profits due to the Wayne Marsh extortions: $18,000+
4 3. Defendants orchestrated vandalism of Remingtons fences, FELONY: $94,000
5 leading to garden foliage damage and killed roses and trees: Misdemeanor: $53,000
6 4. Increased homeowners insurance premiums, approximation to date: $9000
7 5. Increased environmental experts costs: $25,000, and continuing
8 6. Legal fees, projected going forward, probably with a RICO attorney: Potentially $50,000
9 7. Lower slide damages, below dumps since 2012, increasing annually: $6000
10 8. Upper slide damages, attributable to Randall, Figas and Marsh extortions: $22,000+
11 9. OTHER Property destruction, thefts, arson, equipment vandalisms (windows, tanks
12 irrigation systems, vehicles, etc., attributable to Mathson and his gang of hoodlums: $15,000
13 10. Additional Remington paralegal time and costs, $25/hour x 2000: $50,000
14 11. Increased administrative costs, supplies, printers, computers, remote storage: $17,000
15 12. Greatly enhanced security measures of all types as previously outlined: $9000
16 13. Lost ANNUAL water sales from Remington Creek (3 years), if captured and pumped
17 for $50,000, and then delivered to Garberville for drinking and irrigation: 3 X $400,000
18 14. Lost sale value of the 1/3 acre encroached upon and appropriated by the Mathsons,
19 which arguably could be applied as a partial offset to 16 below, at a trial: $150,000
20 15. Additional deteriorated value of the other half-acre north of Remington Creek,
21 and/or the cost to restore it to its original pristine condition: $75,000
22 16. Rental value of Remingtons land fully occupied by the Mathsons since 1998,
23 at 19 years times $1000 per month times 12: $228,000+
24 17. Estimated present value of the reduction in value of the entire estate (2017): $400,000
25 18. Cost of engineered retaining wall prior to Remingtons remediation, estimate: $25,000
26 19. Estimated permanent Burl Tree inventory depreciation due to Gans enterprise and
27 permanently lost Jagger, et al, interstate and international wholesale sales: $150,000
28 20. Permanently lost Burl Tree sales, and subsequent inventory deterioration and
permanent devaluation, as calculated in the RICO statement: $368,000

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1
2 1151. The above damages are mostly purely RICO injuries with treble damages being
3 appropriately applied as per the judgment of the court and the trier of fact. They are not added-up
4 here because they are subject to major changes every year; to the application of Renz time frames
5 going all the way through trial and appeals, or not, in the discretion of the court; and also they
6 ignore the vast majority of the environmental contamination lawsuit costs, general, special and
7 punitive damages that have been requested and presumably are recoverable. After the next trial, or
8 during it, as appropriate, Remington will add-up all appropriately recoverable damages, as has been
9 done in various summary documents many times before, without any tangible result to date.
10 1152. Each of the RICO defendants has engaged in multiple predicate acts, as described
11 through-out the RICO statement, and above, supra. Likewise, the conduct of each of the individual
12 RICO defendants described in said above paragraphs, constitutes a pattern of racketeering activity
13 within the meaning of 18 U.S.C. 1961 (5).
14 A. Since Remington equals the Burl Tree, and vice versa, he is the ultimate victim of the RICO
15 defendants unlawful enterprise. Remington has been for years and will continue to be injured, more
16 each day, in his business, LOL, and overall quality of life, as specifically requested in the
17 environmental harm sections of these complaints, in an amount to be determined at trial.
18 1153. Pursuant to 18 U.S.C. 1964 (c), Remington is entitled to recover treble damages
19 plus costs and attorneys fees from the RICO defendants on the appropriate damages claimed herein,
20 as determined by the court in the special jury instructions.
21 1154. As alleged above and throughout all of these RICO documents, Remington and the
22 Burl Tree were injured in their business and property by reason of the RICO defendants
23 alleged violations of 18 U.S.C. 1962 (c). Those injuries to the Burl Tree caused by reason of the
24 violations of 18 U.S.C. 1962 (c) include, in addition to the 20 specific damages and categories
25 above, at #1150, include, but are not limited to: Damage to Remingtons and the Burl Trees
26 credibility, reputation in the community and far-beyond, and there former business goodwill; The
27 impairment of Remingtons interest in executed contracts, including the SHN contracts, the
28 Farmers extorted $20,000 settlement and release with Mathson (beneficial to them, and all of
them, and damaging to Remington) and increases in Remingtons homeowners insurance, etc.; The
attorneys fees and all costs including Remingtons time to defend himself and his business against

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2 Gans objectively baseless and improperly motivated sham litigation in DR 080669+ his at least
3 equally frivolous defense in DR 080668, DR140426 and CV 094547 NJV; All of Remingtons
4 anticipated deposition, discovery, transportation, including airfare, lodging, parking, eating costs
5 and fees IN SAN FRANCISCO, associated with exposing these RICO defendants pervasive frauds
6 in these Federal RICO proceedings, to an unbiased and sufficiently qualified court. In short,
7 Remington hereby requests all damages not specifically prescribed, requested and/or recovered in
8 the contamination portion of these lawsuits, plus all of the additional costs for past and future
9 experts depositions, filing fees, stenographic trial transcripts and all past recoverable costs
10 associated with this lawsuit, plus all of the numerous unforeseen future 2017-2020 recoverable
11 litigation costs.
12 1155. Finally, Remington is further entitled to, and should be awarded, a preliminary
13 and permanent injunction that enjoins defendants and anyone else acting in concert with them,
14 including the Mitchell law firm, Klucks law firm and the Stokes law firm from commencing,
15 prosecuting, or advancing in any way, both directly or indirectly, any attempt to recognize or
16 enforce the ostensibly fraudulent SOL trial verdict from August 2016, until this court determines the
17 merits of this RICO action and either enters judgment on Remingtons claims against the
18 defendants in this action, or otherwise dismisses this lawsuit for further prosecution in state court.
19 1156. WHEREFORE, Plaintiff prays for judgment as set forth below and throughout these
20 documents, and requests that this court entered judgment against the Count I defendants as
21 described in the RICO statement, and as is appropriate under law including actual damages, all
22 appropriately recoverable other types of damages requested throughout these documents, treble
23 damages and attorneys fees, as warranted and where properly supported.
24
25 Count II-Second Claim for Relief
26 (conspiracy to violate RICO, 18 USC 1962 (d), against all RICO defendants)
27 1157. The allegations of all 1156 paragraphs above, PLUS all pages attached of the 570+
28 page RICO statement, dated in January 2017, as well as all pertinent, non-duplicative, relevant
sections from the federal environmental complaint, plus the photographs of volume III, are hereby
incorporated by reference herein into this paragraph, as if set forth in full, all 1200+, or so pages.

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2 1158. The aforementioned eleven (11) presently designated RICO defendants have all
3 unlawfully, knowingly and willfully combined, conspired, confederated and agreed together with
4 the other enterprise members to violate 18 USC 1962 (c) as described above, in violation of 18
5 USC 1962 (d), in order to conduct and participate in the conduct of the affairs of the enterprise
6 through a pattern of corrupt racketeering activity.
7 1159. In other words, the Count II defendants have intentionally conspired and agreed to
8 directly and indirectly conduct and to participate in the conduct of the affairs of a RICO enterprise
9 through a pattern of racketeering activity, at a minimum. Additionally, after and according to
10 discovery, it is very likely that said defendants have also used, invested, reinvested and therefore
11 multiplied derivative illegal funds from illicit laundered income (such as was knowingly invested by
12 Olson after, and probably before 1998), that was also knowingly derived from a pattern of
13 racketeering activity in an interstate enterprise and acquired, maintained and subsequently enhanced
14 the interests in and of the enterprise through a presently continuing pattern of racketeering activity.
15 The illicit conspiratorial RICO criminal activity complained about here occurred subsequent to
16 2012, but all of the dates, investments and history of all corrupt transgressions, if any, first need to
17 be determined. Perhaps during discovery, Mathson and RAO will want to try to prove that they
18 engaged in criminal conspiratorial activity prior to 2012, but that seems unlikely, although some of
19 the precursors and poisonous roots were likely present earlier.
20 1160. At a minimum, the present Count II defendants, irrespective of any pre-statute of
21 limitation additional violations by Olson, knew that their predicate acts from 2012-2016 were
22 unethical, unjust, illegal and hence part of a pattern of extortive racketeering activity, and
23 defendants agreed to the commission of those acts to further the schemes described above.
24 A. Simply put, all any of the defendants appeared to care about was getting well-paid,
25 advancing their careers, receiving Gans approval and future work and few knew Remington at all
26 when they first got involved. Therefore the crushing Remington objectives of the enterprise were
27 primarily confined to the top Mitchell firm, Lawrence and Mathsons gang leadership, and was
28 probably not central, or specifically known with the clarity presented herein, to about half of the
enterprise members. All enterprise members could presumably see and understand exactly what was

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2 happening overall, however undoubtably they did not discuss it in detail or laugh about it during
3 their rehearsals, lectures and improper coaching sessions.
4 1161. That above specifically described illicit conduct in their above-described agreed
5 (together and with others), confederated and secret conspiratorial RICO plans to corruptly conduct
6 partially unlawful and deliberately harmful litigatory actions against Remington, over several years
7 including during state and federal trials, and pretrial proceedings, constitutes a conspiracy to violate
8 18 U.S.C.A. 1962 (c), in such a manner as to further violate 18 U.S.C. 1962 (d). As above,
9 whether 1962 (a) or (b) were also violated seems very likely, but is presently unknown, and
10 presently lacks directly implicating specific evidence, or at least is not yet provable within the last
11 four years.
12 1162. As a direct and proximate result of the Count II defendants conspiracy, the overt
13 acts taken in furtherance of that harmful, illegal conspiracy, and their provable violations of 18 USC
14 1962 (d), plaintiff Remington, his business and business property have been injured, as previously
15 described at #1150 above, under Count I.
16 1163. Upon information and belief, it is clear that most of and likely all of the RICO
17 defendants knew that they were engaged in a conspiracy to commit the alleged predicate acts,
18 and they knew and/or certainly should have known, that their predicate acts were part of such
19 racketeering activity, and the participation and intentional agreement of each of them was necessary
20 to allow and further the commission of this pattern of racketeering activity. Defendants conduct
21 was therefore intentional, and said conduct also constituted a conspiracy to violate 18 USC 1962
22 (c), in violation of 18 USC 1962 (d).
23 1164. Gans RICO enterprises management and operation. Further, upon information and
24 belief, the alleged RICO defendants agreed to conduct or participate, directly or indirectly, in the
25 conduct of, management, or operation of the Enterprises affairs through a pattern of racketeering
26 activity in violation of 18 USC 1962 (d). Remington has carefully observed the majority of these
27 RICO enterprise defendants, soldiers and other involved participants for about 8-9 years, and has
28 gathered sufficient information as consolidated in the RICO statement to support these allegations.
1165. Each named RICO defendant knew about and willingly and enthusiastically agreed
to facilitate the Enterprises scheme to obtain property illicitly from Remington. It was part of

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1
2 the conspiracy that the RICO defendants and their co-conspirators would commit a pattern of
3 racketeering activity in the conduct of the affairs of the enterprise, including the acts of racketeering
4 set-forth in all of the above paragraphs and in the RICO statement.
5 1166. As a direct and proximate result of the RICO defendants conspiracy, the acts of
6 racketeering activity of the enterprise, the overt acts taken in furtherance of that conspiracy, and the
7 violations of 18 USC 1962 (d), Remington has been injured in his business and property as was
8 specifically set forth in the paragraphs directly above, and in greater detail in the RICO statement
9 1167. Defendants have engaged in the malicious, willful, and fraudulent commission of
10 the wrongful acts set forth above; and, because of the reprehensible and outrageous nature of
11 many of those acts, Remington is entitled to, should be awarded, and hereby requests punitive
12 damages against each of the named defendants above, in whatever reasonable amounts the court or
13 jury determines.
14 1168. WHEREFORE, plaintiff requests that this court enter judgment against the Count
15 II defendants as requested specifically under Count One (I) at #1150, more generally in the
16 Prayer For Relief section which follows next, and also in association with the independent
17 and/or partially overlapping damages reasonably requested in the environmental action
18 presented in Volume I, by way of appropriate additions, without any double recoveries.
19 PRAYER FOR RELIEF
20 1169. Remington requests:
21 A. General, special and actual damages according to proof at trial, the application of the
22 Renz time frame which would calculate and add-up all damages through trial and all appeals, trebled
23 as appropriate, according to statute, 18 USC 1964 (c);
24 B. Prejudgment interest according to statute;
25 C. Remingtons reasonable attorneys fees, personal time expenditures at paralegal rates (or
26 greater), expert, administrative, purchasing and all other appropriate costs according to statute, 18
27 USC 1964 (c);
28 D. For equitable relief as appropriate pursuant to applicable law, not duplicative with the
damages requested in the environmental portion of this lawsuit, including a preliminary and
permanent injunction that bars defendants and any of them, including specifically the Mitchell,

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1
2 Mathews and Stokes law firms from further intimidation, extortion, threatened lawsuits,
3 harassments and other anticipated retaliatory actions in both state or federal courts, until this court
4 determines the merits and enters judgment on one or more Remingtons claims against the
5 defendants in this action;
6 E. Monetary or other remuneration for such other legal and equitable relief as is requested in
7 the FAC or which the court may deem Remington is entitled to receive.
8
9 Date: March 31, 2017 By: __________________________________
10
11 Bruce Remington, in pro se, and co-counsel.
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PLAINTIFF REMINGTONS TWO RICO CAUSES OF ACTION-JANUARY 2017

PLAINTIFF REMINGTONS TWO RICO CAUSES OF ACTION-JANUARY 2017

10 equated it to Remingtons land;

PLAINTIFF REMINGTONS TWO RICO CAUSES OF ACTION-JANUARY 2017

PLAINTIFF REMINGTONS TWO RICO CAUSES OF ACTION-JANUARY 2017

PLAINTIFF REMINGTONS TWO RICO CAUSES OF ACTION-JANUARY 2017

PLAINTIFF REMINGTONS TWO RICO CAUSES OF ACTION-JANUARY 2017

PLAINTIFF REMINGTONS TWO RICO CAUSES OF ACTION-JANUARY 2017

PLAINTIFF REMINGTONS TWO RICO CAUSES OF ACTION-JANUARY 2017

PLAINTIFF REMINGTONS TWO RICO CAUSES OF ACTION-JANUARY 2017

10 prematurely deceased John Aveggios replacement to act as Remingtons sole independent

PLAINTIFF REMINGTONS TWO RICO CAUSES OF ACTION-JANUARY 2017

PLAINTIFF REMINGTONS TWO RICO CAUSES OF ACTION-JANUARY 2017

PLAINTIFF REMINGTONS TWO RICO CAUSES OF ACTION-JANUARY 2017

11 his corrupt associates.

PLAINTIFF REMINGTONS TWO RICO CAUSES OF ACTION-JANUARY 2017

PLAINTIFF REMINGTONS TWO RICO CAUSES OF ACTION-JANUARY 2017

11 discrete instances of mail and wire fraud, just since 2012.

PLAINTIFF REMINGTONS TWO RICO CAUSES OF ACTION-JANUARY 2017

PLAINTIFF REMINGTONS TWO RICO CAUSES OF ACTION-JANUARY 2017

PLAINTIFF REMINGTONS TWO RICO CAUSES OF ACTION-JANUARY 2017

PLAINTIFF REMINGTONS TWO RICO CAUSES OF ACTION-JANUARY 2017

PLAINTIFF REMINGTONS TWO RICO CAUSES OF ACTION-JANUARY 2017

PLAINTIFF REMINGTONS TWO RICO CAUSES OF ACTION-JANUARY 2017

PLAINTIFF REMINGTONS TWO RICO CAUSES OF ACTION-JANUARY 2017

PLAINTIFF REMINGTONS TWO RICO CAUSES OF ACTION-JANUARY 2017

PLAINTIFF REMINGTONS TWO RICO CAUSES OF ACTION-JANUARY 2017

5 2B. Linda Lawrence, pages 94-108;

11 2G. Paul Brisso, pages 176-182;

16 2K. Nicholas Kloeppel, pages 208-211.

PLAINTIFF REMINGTONS TWO RICO CAUSES OF ACTION-JANUARY 2017

6 omitting information, intentionally concealing facts and destroying material evidence.

PLAINTIFF REMINGTONS TWO RICO CAUSES OF ACTION-JANUARY 2017

PLAINTIFF REMINGTONS TWO RICO CAUSES OF ACTION-JANUARY 2017

PLAINTIFF REMINGTONS TWO RICO CAUSES OF ACTION-JANUARY 2017

PLAINTIFF REMINGTONS TWO RICO CAUSES OF ACTION-JANUARY 2017

PLAINTIFF REMINGTONS TWO RICO CAUSES OF ACTION-JANUARY 2017

PLAINTIFF REMINGTONS TWO RICO CAUSES OF ACTION-JANUARY 2017

PLAINTIFF REMINGTONS TWO RICO CAUSES OF ACTION-JANUARY 2017

PLAINTIFF REMINGTONS TWO RICO CAUSES OF ACTION-JANUARY 2017

PLAINTIFF REMINGTONS TWO RICO CAUSES OF ACTION-JANUARY 2017

PLAINTIFF REMINGTONS TWO RICO CAUSES OF ACTION-JANUARY 2017

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