• Introduction

• Scheme to infiltrate and control "Valley of Lakes"

• Land Development Scheme

• Lake Algonquin Scheme

• Building Fees Scheme

• Real Estate Scheme

• Sewage System Schemes

• Arnold Palmer Golf Course Scheme

• Bank's scheme to conceal insolvency of CBG Ltd.

• Scheme to continue Racketeering using Chapter 11 Bankruptcy protection

• Bank's Scheme to operate and manage the Racketeering Enterprise

• Scheme to conceal Racketeering Activity prior to merger and to continue Pattern of Racketeering Indefinitely

• Enterpise

• Pattern of Unlawful Racketeering Activity

• Summary of each defendant's association with and participation in the pattern of Racketeering Activity

• Summary of each plaintiff's injury to Business or Property

• Count II: Interstate Land Sales Full Disclosure Act

• Count III: Civil Rights Violations

• Count IV: N.J. Real Estate Sales Full Disclosure Act

• Count V: Common Law Fraud and Deceit

398. Plaintiffs repeat and reallege the allegations contained in COUNT I of this complaint as fully as if set forth here.

399. Count V of this complaint is brought by all plaintiffs as a class action against defendant FIRST EASTERN BANK, MLA, CBG, FRANK CEDRONE, VALLEY UTILITIES CO., INC., and ONEIDA WATER CO. for common law fraud and deceit.

400. The court has jurisdiction of this state claim under the doctrine of pendent jurisdiction.

401. Defendant's acts, schemes, misrepresentation, etc., constitute common law fraud under the law of the State of New Jersey.

402. Defendant's acted intentionally, willfully, wantonly, maliciously, for profit, and without just cause or excuse.

403. Plaintiffs suffered damages as a result of defendants wrongful actions.

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