FBI Special Agent In Charge June 9, 2007
Federal Bureau of Investigation
600 State Street, New Haven, Connecticut 06511
It occurs to me that in light of my reference to the Cross Motion for the Entry of Judgment dated 8-15-05 in the (non-legalese) RICO Litigation Summary I was asked to forward to former FBI Agent Barndollar and more recently to your New Haven Office, that you may not have as yet retrieved said Cross Motion from either Ron or your office (to whom copies have been previously sent) and as such, I have enclosed the same herewith. Moreover, I have enclosed some additional delivery confirmation receipts to the New Haven Office, etc., I was able to “dig out” (with the exception of the central pleadings for copies/transmission/filing, viz., RICO Verified Complaint, RICO Statement, Affidavit - courtesy copies to Chief Judges Chatigny, Dist.Ct., and Dabrowski, Bk.Ct., most of my things are packed in boxes and ready to move.). The Cross Motion succinctly sets forth the factual/legal scenario, as well as Coan’s testimony before Judge Chatigny which culminated in Judge Chatigny’s ruling against Coan in Coan’s action to prevent me from suing him (he knew what he had done and I had to fly out there for the hearing). Consistent with the cover-up, fraud connected with a case under Title 11 U.S.C., obstruction of justice, etc., federal judges have ignored Judge Chatigny’s ruling.
This is not a complex matter. Indeed, from the investigative perspectives of motive, means, and opportunity, this case has always been quite simple. This is particularly so with regard to defendant Coan’s liability at this juncture for which there is applicable insurance/surety coverage and no legitimate defense (RICO encompasses predicate acts, part of a pattern over a 10 year period as I’m sure you know. Moreover, it is a fundamental principle of RICO law that RICO standing requires only harm resulting proximately from the predicate offenses. It does not also require that this harm give rise to a civil claim based upon those predicate offenses. Holmes v. Securities Investor Protection Corp., 503 U.S. 258 (1992). Additionally, the RICO plaintiff need not have suffered harm from each predicate offense comprising the pattern. H.J. Inc. v Northwestern Bell Tel. Co., 492 U.S. 229, 242 (1989). See, e.g., Ford Motor Co. v. Summit Motor Prods., Inc., 930 F.2d 277 (3d Cir.), cert. denied, 502 U.S. 939 (1991) (permitting a RICO claim based on violation of a court order to which plaintiff was not a party: the “standing inquiry in any civil RICO case depends solely on demonstrating injury to business or property, and not on satisfying any standing requirement attached to the predicate act”)).
While I realize this once again comes at a well deserved difficult time for the Department of Justice in light of the pervasive corruption endemic to American legal/judicial, etc., processes today of which there is greater awareness domestically and internationally, there is no legitimate reason that this matter not be resolved consistent with a meaningful rule of law as, ie., set forth in the summary and consistent with the Cross motion as annexed hereto (58 pages total). Please let me know if there is difficulty retrieving documents from Ron or if for any reason the files are incomplete inasmuch as I have copies of everything and can forward same on notice.
hoping to speak with you within a reasonable time, I am
Very Truly Yours,
Albert L. Peia (213) 219-7649