The following excerpt is from Hon. Otto J. Reich, Otto Reich Assocs., LLC v. Lopez, Docket No. 16-510-cv (2nd Cir. 2017):
the energy business; it is not a narcotics ring or an organized crime family. See United States v. Aulicino, 44 F.3d 1102, 1111 (2d Cir. 1995) (noting that open-ended continuity does not exist when predicate acts are "in furtherance of endeavors that are not inherently unlawful, such as frauds in the sale of property"); United States v. Pizzonia, 577 F.3d 455, 465 (2d Cir. 2009) (holding, in the context of continuity, that "long-term criminal associations plainly include those traditionally grouped under the phrase 'organized crime'" (internal quotation marks omitted)).
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