Is There Probable Cause for a Grand Jury to Indict Governor David Ige for Racketeering in the TMT Crisis?

Is There Probable Cause for a Grand Jury to Indict TMT Advocate David Ige for Racketeering?

by

Dr. Leonard G. Horowitz and Sherri Kane

9-17-19 (updated 9-20)

In 2014 these authors published a book and film evidencing the military connections to the world’s most powerful telescopes on the highest mountain on earth—the sacred Mauna Kea. These works featured the proposed “dual purpose” Thirty Meter Telescope (TMT). 

Very few people knew of the dual purpose of the TMT. The media concealed this and misrepresented the important military involvements proven by documents such as this contract. The generally unaware public was seduced by fraud, censorship, and corruption that accompanied the “astronomy project.”

Everyone wanted to believe the proponents. They said there was plenty of room on the Mauna to license the project for science and spirituality. After all, Hawaiians’ ancestors were great navigators. They looked to the stars for guidance and Akua. There should, therefore, be no opposition to the TMT that is dedicated to advancing astronomy, children’s education, and the Hawaiian culture. The corporate parties even agreed to establish a council honoring elders to oversee any disputes.

That promise never materialized, and the illusion of “no military involvement whatsoever” advertised on the TMT’s official website has remained.

The TMT opponents never fully grasped this fraud. The military contracts and dual usage promised commercial research and developments of space based weapons systems and more. The ‘CCID’ “eye of the telescope” was, for example, produced and contracted to be tested at the TMT by the U.S. Air force and its agents in collaboration with MIT’s Lincoln Labs. The Starfire Optical Range at Kirtland AFB in New Mexico was awaiting the data.

The naïve public and private decision-makers never learned of this fraud; never gave their ‘informed consent,’ and this corruption was material and substantive to the Univ. of Hawaii’s involvement and DLNR licensing agreements.

Hawaiians’ rights to “due process” were seriously deprived by a virtual “racketeering enterprise.” This article evidences this racket.  

Government and TMT officials arguably administered land theft ‘under color of law’ by fraud, omissions, and misrepresentations concerning the military’s collaboration. Fraudulent concealment of conflicting interests by local officials combined with their ‘predicate acts’ to satisfy the elements of a ‘RICO claim’ under federal law 18 USC § 1961.

“Civil remedies” were always available but not affordable for the Natives. Whistleblowers too lacked resources to take on what local attorneys general neglected by willful blindness. The law of 18 U.S. Code § 1964 is not commonly exercised by victims.

Other options were neglected too. Citizens were encouraged and enabled by 42 USC 1988–the Private Attorney General’s Act–to bring a private lawsuit or class action to circumvent state and federal prosecutors who appeared complicit and/or neglected their duties.

There was also the promised ‘administrative remedy.’ The Comprehensive Management Plan (CMP) included a “Grievance Mechanism Design Committee, per Section OI-4 . . .  Open to Kanaka Maoli and all Hawaiian Peoples.”

But none of the aforementioned options were exercised. So the controversy has continued to the present day.

Over the years, these matters and emotions have been ‘heating up.’

A few months ago, officials and the media were given explosive new evidence discovered by members of the Facebook group ʻOnipaʻa Kākou. The newly-revealed public records compounded evidence of governmental fraud and special interest crimes. The group’s documents especially incriminated Gov. David Ige. JudicialCorruptionNews.com exclusively heralded these documents. All other news sources disregarded them. 

In previous articles, such as here, here, and here, we addressed these concerns. We reviewed much of the evidence of corruption, received threats from the wrongdoers, heard from lawyers who argued our analysis was “meritless,” and others who told us “there is insufficient ‘probable cause’ for a grand jury indictment against the governor and the state.

In this article, we refute naysayers and notice troublemakers. We consider these very serious matters in the context of Hawaii case law. We raise and answer the question, “Is there sufficient ‘probable cause’ to persuade a grand jury to indict Gov. Ige and complicit officials on charges of TMT-related racketeering?” We contend that there is.

In summary,

1) The Pacific International Realty, Inc. was the agent for Ige, and this was the only time they were agents for anyone as evidenced by public records;
2) That agency created the David and Dawn Ige Enterprises at the same time as the $3m payment was made to Private Security Group, co-owned by the same agent for both Pacific and Ige Enterprises.
3) The $3m seems disproportionate to any probable services rendered on a vacant lot at the top of freezing cold Manua Kea.

These facts provide enough ‘probable cause’ to investigate whether there was any transfer of money between the agents to the governor beyond what would have been demanded by so called “house rental fees.”

Here we lay out our evidence for the Court of Public Opinion to rule, and also satisfy the ‘probable cause’ requirement for a grand jury investigation.

We hold that the proposed TMT military “astronomy” construction and land conversion plan should be scrubbed before someone is killed in the wake of media recklessness, official malfeasance, and instigated violence only benefiting the wrongdoers.

 

Introduction

“Can anyone help me?” asked a listener of Rock-the-Boat-Hawaii, our weekly radio show featuring our “in your face” style of activism.

Legal Standards of Review

See Footnote #1 below.

 

Argument: A History of Genocide in the Making

Since the overthrow of the Kingdom of Hawaii in the late 1800s by insidious corruption, Hawaiian families have been forced to suffer the devastation of land thievery, genocide, and cultural exploitation.

Racketeering officials involved in this wrongdoing gave no empathy or justice for the oppressed and dispossessed victims of their white collar crimes. They simply made tens of thousands of Hawaiians homeless. Natives were forced to deal with institutionalized devil-doing.

The damages to society were shocking. Hawaiian male incarcerations rose disproportionately. Most inmates were transferred to the mainland from their homeland.

This reflected the genocide likewise suffered by natives worldwide. Native Americans lost similarly before conscientious objectors administered a reprieve. Congressional representatives today call for “reparations” to be made to African Americans whose ancestors were enslaved by white men. Some were enslaved to labor in Hawaii in the sugar and pineapple plantations.

Similar overdue justice remains for the generally neglected native Hawaiians.

This history of trauma and barbaric abuse has left its mark on the hearts and minds of the Kanaka Maoli. Millions of their supporters worldwide have voiced outrage. Public perceptions and opinions oppose the abuse of Hawaiians’ civil rights, property rights, and spiritual culture.

It was for this reason that TMT officials pledged to include the Kanaka Maoli in the project.

This effort began with Gordon Moore, the Silicon Valley billionaire behind Intel supplying computer chips for military technology worldwide. Moore’s “non-profit”– The Gordon and Betty Moore Foundation – hired Peter S. Adler and Janesse Brewer to poll citizens to assess the social impacts of the proposed TMT on Mauna Kea.

The polling and behavioral surveys resulted in planned strategies to socially-engineer the public’s acceptance of the project we see today.  In other words, the political, behavioral, and media strategies for conditioning people to accept the TMT were bought-and-paid-for by Moore in favor of his commercial, scientific, and military interests.

Early officials and administrators of the Comprehensive Master Plan (CMP) for the TMT’s construction on the Mauna solidly determined the need to involve the Kanaka Maoli at every level of the “science project.” They published paperwork to secure this result.

But these agreements have gone largely neglected, in some cases violated.

Two most egregious breaches of the public’s trust include:

(1) the fraudulent concealment of the “dual usage” military and scientific contracts foundational to the TMT project; and

(2) the conflicting interests of certain officials prejudicing and corrupting the Kanaka Maoli’s involvement in proceedings required by law and the CMP. This injustice was especially noted during the contested case hearings.

Reflecting on history, for example, at the November 27, 2007 meeting of the Mauna Kea Management Board (MKMB), there were seven members of the community who were nominated by the UH Hilo Chancellor, and approved by the UH Board of Regents. At that meeting, UH legal counsel Darolyn Lendio failed to provide truthful, open, and honest disclosure regarding the consultants appointed by UH to develop the CMP.

The two consultants with conflicting interests were ho’akea (dba ku’iwalu) and PB America. The UH counsel falsely stated that: a) Hoakea was a community consultant; and b) PB America was the planning consultant. No further information was provided.

What the UH attorney Lendio failed to disclose at the 11.27.07 meeting was that a year earlier both Hoakea and PB America were working on the “Rail Project.”

The Honolulu Authority for Rapid Transportation (HART) had formed a generally-neglected political campaign alliance with Pacific Resource Partnership (PRP), advertised as “the backbone of Hawaii’s construction industry, representing the Hawaii Regional Council of Carpenters and more than 240 of the state’s top contractors.

“PRP is one of the most vocal and powerful champions for the further development of Mauna Kea,” Kanaka Maoli representatives protested to no avail.

The statements and/or omissions by Lendio were a breach of contract. This violated CMP Sec. 4.2 for failing to disclose potential bias and conflicts of interest.

The CMP per Sec. 4.2 required adherence to the following Principals: “Trust or Hilina’i- As with any relationship, trust is fundamental. The University of Hawaii recognized and committed to being truthful, open, and honest in the development of the TMT’s CMP.”

Some officials did balk over the violations. They wrote that, “Increased effort at community consultation is needed, to address concerns by some in the community that the decision-making process is not transparent and that they have not been involved. (CMP 7-21) The University must restore its trust and confidence with the community.”

Further appraising related history, quoting Civil Beat, the devil-doers at PRP represented “an advocacy group for the Hawaii Carpenters Union and local contractors.” They spent more than $3 million through their political action committee in 2012 to methodically dismantle [Honolulu mayoral candidate Ben] Cayetano’s campaign.

The black budget was spent to keep “Honolulu’s $5.26 billion rail project” on track.

Today, seven years later, the project is still delayed, and costs administered by this same derelict enterprise is reported to be “$8.165 billion.” Media reports indicating that after financing costs are included it will be over $10 billion,” noted Wikipedia.

It took a long time for rail-opponent and mayoral candidate Ben Cayetano to fully grasp PRP’s strategy to dismantle his candidacy. “Cayetano was running on an anti-rail platform, which made him a target for PRP from the first day he announced his candidacy,” Civil Beat wrote. “Both of his opponents, incumbent Peter Carlisle and Caldwell, were outspoken proponents of the project.”

“That degree of sophistication and coordination are made possible by large black pools of money,” Cayetano’s attorney, Jim Bickerton, announced. “It’s not a mom-and-pop organization that’s using these hired guns. They can poll test their ads. They can fine-tune them. They can spend hours and hours moving one word here and one word there to get the impact they’re looking for.”

The TMT and CMP were similarly mismanaged and misrepresented, contrary to the  Comprehensive Management Plan (CMP) that included (as mentioned) a “Grievance Mechanism Design Committee, per Section OI-4 . . .  Open to Kanaka Maoli and all Hawaiian Peoples.”

This agreement required the principles to “not only [be] responsive to community involvement, but also . . . establish a meaningful relationship between the University and the community.”

“As with any relationship, shared commitments and values are central to its health and longevity,” officials wrote. “The true test of the effectiveness of the CMP will lie with its implementation [of community involvement] and the extent to which the University and its subsidiary agencies can continue to embrace the values outlined in Section 4.2” ( CMP page 4-7).”

Unfortunately, these agreements were never actualized by reason of corruption, fraud and insider profiteering, extending into the current administration.

 

Voiding  of Previous Agreements and Proceedings Due to Fraud

Between 2009 and the present time we have been similarly victimized by land thievery and racketeering aided-and-abetted by corrupted government officials and Hawaii’s willfully blind courts. One of our cases is currently before the Supreme Court of Hawaii, where we anticipate the same malfeasance that enslaved us in unconscionable litigations and fraudulent prosecutions committed for our ‘attrition,’ just as Queen Liliokalani was forced to endure at the hands of her Anglo persecutors.

In 2014, sorely aware of the widespread political and judicial corruption in Hawaii, and concerned about the covert military presence and Halliburton vehicles in our neighborhood visiting Puna Geothermal, we published a book called Space Pearl Harbor that very few people read.

If they had, there is a high probability that many people on both sides of the TMT controversy would have saved a lot of time, money and aggravation.

Most importantly we concluded that the TMT’s permit was secured in violation of the terms of their permit application and was void.

The permit required truthful disclosures regarding who was building the project. This was not done.  

TMT knowingly failed to disclose their partnership with the US Air Force (USAF).

While there is nothing wrong with partnering with the USAF, failure to disclose this fact impacted the narrative that the telescope would only be used for astronomy. That too was not true.

That fraud by omission and misrepresentation was intentional. It concealed the fact that a dual use military and science project was not allowable in the Mauna Kea Scientific Reserve Area.

Because of the TMT’s fraud by omitting and misrepresenting these truths, the University of Hawaii and the public were never afforded their fair and full opportunity to understand the nature of the project.

Therefore, no lawful consent or permit approval could have been given.

Consequently, whatever has transgressed since the earliest stages of TMT proceedings are null and void by law, according to Hawaii case law. Every contract or agreement that violates HRS Section 480 protecting the rights of citizens against damage by unfair and deceptive trade practices, especially by fraudulent advertisements resulting in property transactions, is absolutely void and is not enforceable at law or in equity. (See, for example, Ai v. Frank Huff Agency, Ltd., 607 P. 2d 1304 – Haw: Supreme Court 1980. That precludes ‘severability’ of all portions of the contract that are ‘legitimate’ when the basis for the entire agreement is fraudulent, as in the case of the TMT.)

Fortunately, as mentioned, an administrative remedy exists (short of going to court again and again to end up here). The Comprehensive Management Plan (CMP)  included a “Grievance Mechanism Design Committee, per Section OI-4 . . .  Open to Kanaka Maoli and all Hawaiian Peoples” embracing the values outlined in Section 4.2” ( CMP page 4-7).”

Unfortunately here as well, the government and university officials promised but neglected to actualize a spiritual and scientific council to govern the proceedings on the Mauna. This was to have been formed to settle disputes. This group never actualized by reason of corruption, fraud and profiteering as aforementioned and further detailed below.

 

The State of Facts Blocking Remedies

Governor Ige, and his associates, have claimed that their alleged wrongdoing is “without merit.”

Dr. Horowitz previously replied to that defense by  Gov. Ige and the Longs.  The doctor argued that the evidence discovered and published by The Protectors raises reasonable suspicions. The public records show the $3 million payment to the Longs’ Private Security Group in 2015 by the TMT is questionable because:

1) Melanie Long’s Pacific International Realty, Inc. acted as the legal filing agent for David and Dawn Ige Enterprises, and this was the only time Pacific International Realty, Inc acted as agent for anyone as evidenced by public records;
2) That agency created the David and Dawn Ige Enterprises at the same time as the $3m payment was made to Private Security Group; and
3) The $3m seems disproportionate to any probable services rendered on a vacant lot at the top of freezing cold Manua Kea.

Reflecting on the now determined kinship between Dawn Amano-Ige and Riki May Amano, these additional facts raise reasonable questions regarding the overall legitimacy of the contested case hearing and extent of the governor’s “enterprise.”

Do these facts, and related discoveries, provide ”probable cause’ for a grand jury investigation and indictment of the governor and his agents?

Here we argue in the affirmative in accordance with State v. Chung, 75 Haw. 398, 409-10, 862 P.2d 1063, 1070 (1993). That case states: “Probable cause is established by a state of facts as would lead a person of ordinary caution or prudence to believe and conscientiously entertain a strong suspicion of the guilt of the accused.’” 

A “state of facts” means “the statement made by any one of his version of the facts.”

Thus, Governor Ige and the Long’s attorney, Michael Green’s, defenses are “without merit.”

The Protectors have every right to present their ‘state of facts’ on Facebook, or in a court of law. These are not actionable “rumors” as Mr. Green and Hawaii News Now threatened.

The Protectors provided ample facts that “would lead a person of ordinary caution or prudence to believe and conscientiously entertain a strong suspicion of the guilt of” Governor Ige in activities that have aided-and-abetted the fraud, fraudulent concealment(s), omissions and misrepresentations of the military and other special interests advancing the TMT. Fellow suspects in the apparent racketeering enterprise include the Pacific Resource Partnership Super-Pac for the Carpenter’s Union (renamed Be Change Now).

As you can see from the adjacent table, the TMT-related construction industry represented four-out-of-five “Top contributors” to Gov. Ige’s 2014 campaign. Mr. Hilton Hiroshi Unemori is among them.

Mr. Unemori “worked at Lockheed Missiles & Space Co. and Avco Everett Research Labs as a data analyst engineer. He formed an electrical engineering consulting firm based in Hilo, which specialized in Power engineering and served the Department of Defense in the Pacific Rim.

In 2012-13, anticipating the massive income from Puna Geothermal’s expansion in producing hydrogen fuel for military drones, as well as TMT work, Power Engineer (PE) company purchased Mr. Unemori’s company and ongoing labor.  (PE is a world leading engineering firm specializing in geothermal and solar advances, drone geospacial operations, and power delivery systems.)

The “insiders” were well aware of the Univ. of Hawaii’s and Deep State’s “Roadmap for the Way Forward.” The 2008 Analysis of Geothermally Produced Hydrogen on the Big Island of Hawaii predated the TMT’s initial investments by one year. This was the way to go.

And if these campaign financing and commercial military associations proving conflicting financial interests with the University of Hawaii’s Natural Energy Institute (HNEI), the State of Hawaii Department of Business, Economic Development and Tourism (DBEDT), plus the aforementioned TMT conflicts are insufficient to cause “a person of ordinary caution or prudence to believe and conscientiously entertain a strong suspicion of the guilt of the accused” then there is more. . . .

Consider Gov. Ige’s other alleged predicate acts within this alleged racketeering enterprise that has threatened The Protectors, and deprived native Hawaiians of their civil rights to due process; and also deprived them of their real and personal properties as the alleged theft of books and more showed during the dismantling of the children’s library on Mauna Kea on Sept. 7, 2019.

The ‘state of facts’ in question now, beyond the fraudulent concealment of military connections, and neglect of the promised spiritual-science commission to mediate disputes, include the following facts presented by The Protectors:

A. EVIDENCE OF FRAUD, FRAUDULENT CONCEALMENT, and BRIBERY

The aforementioned evidence of kinship between Judge Amano and the governor’s wife compounds the evidence of racketeering involving bribery previously published by The Protectors and these authors.

This ‘state of facts’ included public records showing the formation in 2015 of David and Dawn Ige Enterprises (DDIE), legally established by agent and owner of Pacific International Realty, Inc. (PIRI), Melanie Long, who also maintained a criminal record for methamphetamine trafficking, and also acted as co-owner with her husband Charles of Private Security Group, Inc. (PSGI) that gained $3 million from TMT officials that same year.

And for what was this $3 million paid? For “professional services” seemingly unrelated to actual “security services,” because it is apparent that no security services were required to secure a vacant lot at the top of Mauna Kea where no construction was taking place.

Mrs. Long and the governor claim the two entities were used legally to collect and transfer funds to the Iges’ partnership from alleged “house rentals.”

These parties claimed there were no conflicting interests to be found in these facts, despite the fact that the Ige Enterprises was formed in 2015, and only operated legally for a short time contemporaneously with that $3 million payment by TMT officials to, presumably, Melanie and Charles Long’s “Private Security Group, Inc.”

Consequently, Governor Ige’s and the Longs’ claims that these facts are “without merit” insults reasonable intelligence.

 

The Selection of Judge Riki May Amano Compounds Evidence of Public Corruption and Racketeering

The selection of Judge Riki Amano to oversee the contested case hearing was opposed by Attorney Richard Naiwieha Wurdeman for the wrong reasons made known here.

Attorney Wurdeman objected on grounds that the selection represented a conflict of interest because Amano and her husband were members of the Imiloa Astronomy Center.

That facility is part of the University of Hawaii, which lists TMT as a corporate sponsor on its website. That objection was over-ruled by the Board of Land and Natural Resources (BLNR).

OBJECTION: The Chairwoman of that BLNR was Suzanne Case, who was appointed by Gov. Ige in April, 2015–the same year the “professional services” payment of $3 million was made by TMT to ‘secure’ the project.

Wurdeman and his clients in opposition to the TMT were not made aware that both Case and Amano, the two most influential parties in the contested case hearings, maintained conflicting interests with the governor.

The date of Suzanne Case’s appointment by the governor was also contemporaneous with Melanie Long’s action for the governor to set up David and Dawn Ige Enterprises (DDIE).

Consequently, substantial compounding evidence establishes probable cause to view several insiders surrounding Governor Ige as agents in a racketeering enterprise paid to influence the advancement of the TMT.

These facts involving the Iges, Amano, Case, and the Longs, give the impression of fraud, fraudulent concealment, and give probable cause to consider bribery of the governor through the Longs, resulting in enterprise agents who prejudiced the contested case hearings in favor of their concealed racketeering enterprise.

 

The Contested Case Hearings Are Void

If that “impression of impropriety” is not staggering enough, compound it with the third most influential voice favoring the TMT license during those hearings–attorney Stanley H. Roehrig of Roehrig, Roehrig, Wilson & Hara in Hilo.

Heavily advocating for the TMT as a DLNR board member under Suzanne Case was former Governor Abercrombie’s appointee, Stanley Roehrig. A clip of Roehrig’s response to a testifier at one hearing was circulated in the social media. Roehrig repeatedly stated that he is “on the side of law and order.” But documents neglected by the DLNR evidenced otherwise.

As an attorney, Roehrig had intimate knowledge of “the side of law and order” and his rules of professional conduct discouraging conflicting interests and lacking candor.

Roehrig concealed his directorship of Keaukaha One Youth Development program. According to the Hawai‘i Community Foundation (HCF), closely allied with the Carpenter’s Union, Keaukaha One Youth Development was a grant recipient of its THINK fund.

But according to the TMT organization, “[T]he Thirty Meter Telescope (TMT) launched THINK (The Hawaii Island New Knowledge) Fund to better prepare Hawaii Island students to master STEM (Science, Technology, Engineering and Math) and to become the workforce for higher paying science and technology jobs in Hawaii’s 21st century economy. TMT’s founding gift of $1 million marks the beginning of the construction phase of astronomy’s next-generation telescope on Mauna Kea, Hawaii,” their propaganda promoted.

We stop here examining possible additional conflicting interests in the BLNR officials who administered like a ‘kangaroo court’ the proceedings that were steeped in conflicting interests, fraud, and alleged crimes including evidence tampering, witness tampering, obstruction of justice, hampering an official proceeding, obstruction of governmental operations, bribery, complicity in thievery, and more.

–End–

 

CLICK HERE to Read the Mauna Kea Science Reserve Master Plan

 

Footnotes:

(1) In this section we review the legal standard applied in Hawaii courts regarding the bar of ‘probable cause’ required for a grand jury to indict, in this case, Governor Ige and complicit state agents and agencies advancing the TMT project by fraud, fraudulent concealments, theft of land and personal property, such as when the governor’s appointee, William Aila, Jr., approved the destruction and taking of the “unpermitted” library construction on the Mauna, and racketeering activities, including evidence of bribery.

In State v. Atwood, 301 P. 3d 1255 – Haw: Supreme Court 2013, the sufficiency of evidenced needed to support a grand jury indictment was discussed.

State v. Ontai, 84 Hawai`i 56, 63, 929 P.2d 69, 76 (1996).

Regarding the issue of “first degree theft,” which is the claim of “The Protectors” of the Mauna, the Hawaii Supreme Court added in State v. Atwood:

[I]n order for the grand jury to have found probable cause to support Taylor’s indictment for first degree theft, the State must have produced evidence of each essential element of the offense. See Ontai, 84 Hawai`i at 64, 929 P.2d at 77. This court has held that there are three material elements for theft in the first degree under HRS §§ 708-830(1) and 708-830.5(1)(a): that “the defendant intended to: (2) deprive the other of his or her property; and (3) deprive another of property that exceeds $20,000 in value.” State v. Duncan, 101 Hawai`i 269, 279, 67 P.3d 768, 778 (2003).

In the TMT’s Contested Case Hearing officiated by Judge Amano, many Protectors claimed that the State, the Department of Land and Natural Resources (DLNR), the Department of Hawaiian Home Lands (DHHL), UH officials, and others representing Gov. Ige’s administration and his advocacy for the proposed construction, (1) intentionally acted; (2) to deprive Hawaiians of their holy land; and (3) deprive them of priceless property (obviously valued in excess of $20,000).

Furthermore, as reviewed in Tanaka v. First Hawaiian Bank, 104 F. Supp. 2d 1243 – Dist. Court, D. Hawaii 2000, “A civil RICO claim requires (1) conduct (2) of an “enterprise” (3) through a “pattern” (4) of racketeering activity (or “predicate acts”) (5) causing injury to the plaintiffs “business or property.” See, e.g., Grimmett v. Brown, 75 F.3d 506, 510 (9th Cir.1996) (citations omitted).

A “pattern” for RICO purposes requires “at least two acts of racketeering activity … the last of which occurred within ten years … after a prior act of racketeering activity.” 18 U.S.C. § 1961(5). RICO’s “predicate acts” or “racketeering activity” include violations of certain federal statutes, many of which prohibit various types of fraud. See 18 U.S.C. § 1962. . . .

Applicable RICO predicate acts that may be raised as claims in the TMT matter include:

(A) a threat involving alleged bribery of the governor by TMT officials administered through David Ige’s agent, Melanie Long and her partner, Charles Long; (B) the following acts which are indictable under the following provisions of title 18, United States Code: Section 201 (relating to bribery), section 1341 (relating to mail fraud), section 1343 (relating to wire fraud), section 1351 (relating to fraud in foreign labor contracting), section 1503 (relating to obstruction of justice), section 1510 (relating to obstruction of criminal investigations), section 1511 (relating to the obstruction of State or local law enforcement), section 1512 (relating to tampering with a witness, victim, or an informant), section 1513 (relating to retaliating against a witness, victim, or an informant), section 1951 (relating to interference with commerce), section 1952 (relating to racketeering), section 1957 (relating to engaging in monetary transactions in property derived from specified unlawful activity).

 

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