One World, LLC v. Onoufriadis

2 Citing cases

  1. Wade Park Land Holdings, LLC v. Kalikow

    589 F. Supp. 3d 335 (S.D.N.Y. 2022)   Cited 30 times   1 Legal Analyses
    Finding RICO “excludes from the definition of unlawful debt the ‘occasional usurious transactions by one not in the business of loan sharking” (quoting Durante, 755 F.2d at 250)

    The Second Circuit "has never held a period of less than two years to constitute a ‘substantial period of time.’ " Cofacredit, S.A. v. Windsor Plumbing Supply Co. , 187 F.3d 229, 242 (2d Cir. 1999) ; see alsoSpool v. World Child Int'l Adoption Agency , 520 F.3d 178, 184 (2d Cir. 2008) (same); One World, LLC v. Onoufriadis , 2021 WL 4452070, at *2 (2d Cir. Sept. 29, 2021) (summary order) (same). Although the two-year time frame is not "a bright-line requirement," the Second Circuit has stated "it will be rare that conduct persisting for a shorter period of time [will] establish[ ] closed-ended continuity, particularly where ... the activities alleged involved only a handful of participants and do not involve a complex, multifaceted conspiracy."

  2. Oyarzun v. President/CEO of Exch. Place Pres. Partners

    3:21-cv-1230 (JAM) (D. Conn. Dec. 31, 2021)   Cited 1 times

    In order to prove her RICO claim, Oyarzun must allege facts to show a “pattern of racketeering activity.” 18 U.S.C. § 1962; One World, LLC v. Onoufriadis, 2021 WL 4452070, at *1 (2d Cir. 2021). This means she must allege two or more federal crimes from the list of crimes set forth in 18 U.S.C. § 1961.