Rico Case Standing Order §§1961-1968; Use of Generative Artificial Intelligence

=== Rico Case Standing Order §§1961-1968 ===

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF OHIO EASTERN DIVISION Plaintiff, vs. Defendant. Case No. JUDGE GRAHAM RICO CASE STANDING ORDER 18 U.S.C. §§1961-1968 The above-captioned case contains a civil RICO claim, which has been filed in this Court pursuant to 18 U.S.C. §§1961-1968. This Standing Order has been designed to establish a uniform and efficient procedure for processing this case. The plaintiff shall file, within twenty (20) days hereof, a RICO case statement. This statement shall include the facts the plaintiff is relying upon to initiate this RICO complaint as a result of the "reasonable inquiry" required by Fed. R. Civ. P. 11. In particular, this statement shall be in a form which uses the numbers and letters as set forth below, and shall state in detail and with specificity the following information. 1. State whether the alleged unlawful conduct is in violation of 18 U.S.C. §§1962(a), (b), (c), and/or (d). 2. List each defendant and state the alleged misconduct and basis of liability of each defendant. 3. List the alleged wrongdoers, other than the defendants listed above, and state the alleged misconduct of each wrongdoer. 4. List the alleged victims and state how each victim was allegedly injured. 5. Describe in detail the pattern of racketeering activity or collection of unlawful debts alleged for each RICO claim. A description of the pattern of racketeering shall include the following information: a. List the alleged predicate acts and the specific statutes which were allegedly violated; b. Provide the dates of the predicate acts, the participants in the predicate acts, and a description of the facts surrounding the predicate acts; c. If the RICO claim is based on the predicate offenses of wire fraud, mail fraud, or fraud in the sale of securities, the "circumstances constituting fraud or mistake shall be stated with particularity." Fed. R. Civ. P. 9(b). Identify the time, place and contents of the alleged misrepresentations, and the identity of persons to whom and by whom the alleged misrepresentations were made; d. Describe how the predicate acts form a "pattern of racketeering activity"; e. Describe how the alleged predicate acts relate to each other; and f. Describe how the alleged predicate acts amount to, or otherwise constitute a threat of, continuing racketeering activity. 6. Describe in detail the alleged enterprise for each RICO claim. A description of the enterprise shall include the following information: a. State the names of the individuals, partnerships, corporations, associations, or other legal entities, which allegedly constitute the enterprise; b. Describe the structure, purpose, function and course of conduct of the enterprise; c. State whether any defendants are employees, officers or directors of the alleged enterprise; d. State whether any defendants are associated with the alleged enterprise; e. State whether you are alleging that the defendants are individuals or entities separate from the alleged enterprise, or that the defendants are the enterprise itself, or members of the enterprise; and f. If any defendants are alleged to be the enterprise itself, or members of the enterprise, explain whether such defendants are perpetrators, passive instruments, or victims of the alleged racketeering activity. 7. State and describe in detail whether you are alleging that the pattern of racketeering activity and the enterprise are separate or have merged into one entity. 8. Describe the alleged relationship between the activities of the enterprise and the pattern of racketeering activity. Discuss how the racketeering activity differs from the usual and daily activities of the enterprise, if at all. 9. Describe what benefits, if any, the alleged enterprise received from the alleged pattern of racketeering. 10. Describe the effect of the activities of the enterprise on interstate or foreign commerce. 11. If the complaint alleges a violation of 18 U.S.C. §1962(a), provide the following information: a. State who received the income derived from the pattern of racketeering activity or through the collection of an unlawful debt; and b. Describe the use or investment of such income. 12. If the complaint alleges a violation of 18 U.S.C. §1962(b), describe in detail the acquisition or maintenance of any interest in or control of the alleged enterprise. 13. If the complaint alleges a violation of 18 U.S.C. §1962(c), provide the following information: a. State who was employed by or associated with the enterprise. b. State whether the same entity is both the liable "person" and the "enterprise" under §1962(c). 14. If the complaint alleges a violation of 18 U.S.C. §1962(d), describe in detail the alleged conspiracy. 15. Describe the alleged injury to business or property. 16. Describe the direct causal relationship between the alleged injury and the violation of the RICO statute. 17. List the damages sustained by reason of the violation of §1962, indicating the amount for which each defendant is allegedly liable. 18. List all other federal causes of action, if any, and provide the relevant statute numbers. 19. List all pendent state claims, if any. 20. Provide any additional information that you feel would be helpful to the Court in processing your RICO claim. It is so ORDERED. JAMES L. GRAHAM United States District Judge

=== Use of Generative Artificial Intelligence ===

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO EASTERN DIVISION OCT 21 2025 11:52A OCT 21 2025 11:52A STANDING ORDER ON THE USE OF GENERATIVE ARTIFICAL INTELLIGENCE The use of generative Artificial Intelligence (“AI”) by attorneys and pro se litigants to prepare pleadings, motions, briefs, and other documents has raised concerns over the reliability, accuracy, and volume of filings in this Court. Rule 11(b) of the Federal Rules of Civil Procedure provides that by submitting a pleading, motion, brief, or other paper to the Court, an attorney or pro se litigant certifies that their claims, defenses, and other legal contentions are warranted by existing law and that their factual contentions have evidentiary support. It is hereby ORDERED that any party, including a pro se litigant, who uses generative AI to help generate the content of any portion of a pleading, motion, brief, or other document must submit a declaration disclosing the use of generative AI. The declaration shall be captioned “Disclosure of the Use of Generative AI.” The declaration must identify the content (by page, section, or paragraph number) which was prepared with the assistance of generative AI and state the platform used (ChatGPT, Gemini, etc.). In the declaration, the attorney or pro se litigant must CERTIFY that they have reviewed the relevant source material and have verified that all submissions to the Court are accurate, and that they have complied with their obligations under Rule 11(b). An attorney or pro se litigant who signs a pleading, motion, brief, or other document submitted to the Court is responsible for the contents of that filing under Rule 11, regardless of whether they used generative AI to generate any portion of that filing. The failure to comply with Rule 11(b) may result in sanctions under Rule 11(c). IT IS SO ORDERED. October 21, 2025 s/ James L. Graham James L. Graham United States District Judge