Saturday, July 18, 2015 7:07:25 AM
are natural persons and, as such, each is a “person” within the meaning of 18 U.S.C. § 1961(3)(the “RICO Individual Defendants”).
120. Defendants Hudson Gray, Studio AG, and Mixed Company, Inc., are business
entities and, as such, each a “person” within the meaning 18 U.S.C. § 1961(3). Hudson Gray,
Studio AG, and Mixed Company, Inc. are collectively referred to as the “RICO Entity
Defendants.”
121. The above RICO Individual Defendants and RICO Entity Defendants are
collectively referred to as the “RICO Defendants.”
122. The RICO Defendants engaged in activities affecting interstate or foreign
commerce. Among other things, XA (New York) engaged in extensive email and telephone
communication with XA’s Chicago office, on essentially a daily basis. Andereck, Gudin,
Lomma, and Day were located in New York and Wagner, Wilson and Pizzo were located in
Chicago and, on information, all travelled between the two offices and spent substantial time and
did business in New York. Their communications were extensive, as Schedule A indicates.
Studio AG, located in Chicago, did extensive business in New York, including nominally
working (but actually stealing) XA’s NBCUniversal work.
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