Sent to my Attorney - Copy:
J P Stadtmueller, presiding
Date filed: 02/25/2014
Date terminated: 10/21/2015
Date of last filing: 10/21/2015
John Dickert, Gary E. Becker, Kurt S. Wahlen, James Kaplan, Gregory T. Helding, David L.
Maack, Aron M. Wisneski, Robert E. Mozol, Marl K. Levine and Joseph G. LeGath
(collectively, “Municipal Defendants”), to produce all relevant, responsive, non-duplicative
electronically stored information (“ESI”) located on the City of Racine’s archive tapes. In
support thereof, Plaintiffs state as follows:
rights violations and engaged in a pattern of racketeering in violation of the Civil RICO statute.
Plaintiffs’ claims are set forth in detail in their Amended Complaint (Doc. No. 61). Stated as
simply as possible, Plaintiffs allege that the Municipal Defendants conspired to gain control of
the Racine city government through of a pattern of racketeering activity, which they then used to
unlawfully discriminate against minority-owned establishments with minority clientele.