Flatten

BACKGROUND

I. The Original Complaint

19 On August 9, 2021, plaintiffs Ezekial Flatten, William Knight, Ann Marie Borges, and Chris 20 Gurr filed this lawsuit against defendants Bruce Smith and Steven White in the Superior Court for 21 the County of Mendocino. On September 10, 2021, Smith removed the case to this Court, asserting 22 federal question jurisdiction. 23 The original complaint asserted a single cause of action under the Racketeer Influenced and 24 Corrupt Organizations Act, 18 U.S.C. §§ 1961-1968 (“RICO”), and alleged that Smith and White 25 were members of: 26 [A] longstanding and continuing RICO conspiracy involving law enforcement officers in Mendocino County and surrounding jurisdictions conducting the affairs activity consisting of extortion to obtain marijuana, guns and cash from victims in possession of marijuana by unlawfully searching their residences, stopping, detaining Plaintiffs and hundreds of other victims, committing robbery, obstruction of justice, money laundering, tax evasion, and structuring currency transactions to evade the currency transaction reporting requirement. 3 Compl. ¶ 5 (Dkt. No. 1). …