2 § 1962(a-c), conspiracy to violate Title 18 U.S.C. § 1962(a-c), and common law conspiracy.

I. INTRODUCTION

1. This is a case about active, coordinated and ongoing corruption, fraud and obstruction of justice by Fusion GPS, its founder, Glenn Simpson, and the CfA. 2. The Defendants are persons associated in fact (a RICO enterprise) who engage in interstate commerce by the use of one or more instrumentalities, including, but not limited to, the I nternet, computers, telephones, mails and facsimile. In 2018, the Defendants received income derived, directly or indirectly, from a pattern of racketeering activity and have used or invested such income, directly or indirectly, in the establishment or operation of an enterprise engaged in, or the activities of which affect, interstate commerce. Through a pattern of racketeering activity, involving a cts of wir e fraud in violation of Title 18 U.S.C. § 1343 and acts of obstruction of justice in violation of Title 18 U.S.C. §§ 1503(a), 1512(b), 1512(d) and 1513(e), the Defendants have maintained, directly or indirectly, an interest in or control of an enterprise which is engaged in, or the activities of which affect, inter state commerce. While associated with such enterpris e, the Defendants conducted or participated, directly or indirectly, in the conduct of such enterprise’s af fairs through a pattern of racketeering activity. Between 2018 and the present, the Defendants have engaged in activity that is prohibited by Title 18 U.S.C. §§ 1962(a), 1962(b), and 1962(c). 3. The Defendants’ ongoing and continuous racketeering activities are part of a joint and systematic effort to intimidate, harass, threaten, influence, interfere with, impede, and ultimately to derail Plaintiff’s congressional investigation into Russian