What are the elements of "a pattern" and "racketeering activity"?

federal, United States of America

The following excerpt is from Nordeen v. Bank of Am., N.A. (In re Nordeen), Adv. No. 11-01076-LED, BAP No. NV-12-1441-DKiCo, Bk. No. 09-21273-LED (B.A.P. 9th Cir. 2013):

For purposes of this appeal, we focus on the two elements of "a pattern" and "racketeering activity." A "pattern" "requires at least two acts of racketeering activity." 18 U.S.C. 1961(5). "Racketeering activity" encompasses "any act indictable under several provisions of Title 18 of the United States Code, and includes the predicate acts of mail fraud, wire fraud and obstruction of justice." Turner v. Cook, 362 F.3d 1219, 1229 (9th Cir. 2004). A claimant may seek civil relief for any RICO violation(s) resulting in injury to his or her business or property. 18 U.S.C. 1964(c).

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