(6) Describe how the predicate acts form a “pattern of racketeering activity”;

The predicate acts form a “pattern of racketeering” because they are all part of a common criminal plan, beginning no later than 1997 and continuing through the current date, to control a substantial portion of the Russian oil industry through criminal conduct and to secret the profits of this scheme from taxes. All of the predicate acts relate to one another because they represent a common scheme to control a substantial portion of the Russian oil industry through acts of racketeering, including bribery, extortion, mail and wire fraud, money laundering, illegal transactions in monetary instruments, and violations of the Travel Act.

The predicate acts progressed in a logical fashion, first directed at taking over TNK in the Corrupt 1997 Privatization, obtaining complete control over TNK in the Corrupt 1997 Privatization, stripping assets from Chernogorneft, NNG, and Kondpetroleum in the Corrupt Chernogorneft, NNG, and Kondpetroleum legal proceedings, and then taking over Yugraneft in the Illegal Seizure. The predicate acts were designed to create a “slush fund” of monies illegally diverted from TNK and other Russian oil companies through Crown and ultimately to the Slush Fund Companies. The related predicate acts of mail and wire fraud, money laundering, illegal transactions in monetary instruments, and violations of the Travel Act were designed to create this secret fund in order to provide funds for bribing Russian government officials and paying secret salaries and bonus payments to members of the Conspiracy, as part of the Massive Tax Fraud.

The predicate acts reflect conduct over a five year period (1997 through 2002) and the threat of continuing wrongful activity. The extensiveness of the predicate acts is manifest; while Plaintiff cannot establish every predicate act absent discovery, it has alleged bribery in relation to the Corrupt 1997 and 1999 Privatization, corruption of the Russian judicial system in relation to the Chernogorneft, Kondpetroleum, and NNG legal proceedings, corruption in regard to the legal proceedings concerning Yugraneft, numerous instances of mail and wire fraud, money laundering, and illegal transactions in monetary instruments, as evidenced by the numerous wires to the Slush Fund Companies; and continued violation of the Travel Act.

The number of victims, again while not fully known, impact hundreds, if not thousands of persons, including the Russian government, the British Government, and the United States government in relation to the Massive Tax Fraud; many shareholders, including Americans, and many creditors of Chernogorneft, Kondpetroleum, and NNG, as well as the shareholders of Sidanko, including American interests, in relation to the Corrupt Chernogorneft, Kondpetroleum, and NNG proceedings; Plaintiff in regard to the Illegal Seizure; and all of the above victims in regard to the bribery, mail and wire fraud, money laundering, illegal transactions in monetary instruments, and Travel Act violations by which Defendants diverted profits from TNK and other Russian oil companies in order to create the Slush Fund which provided funds for bribes and secret salaries and bonus payment.