NATURE OF THE SUIT
The MICCOSUKEE TRIBE brings this suit for racketeering, conspiracy tocommit racketeering, fraud, aiding and abetting fraud, embezzlement, civil theft, and breachof fiduciary duty against Defendants, who conspired with each other and specifically withDefendant CYPRESS to aid, abet, create, advance and perpetrate an enormous fraud andtheft scheme through which Defendant CYPRESS and the other Defendants eitherparticipated, facilitated and/or assisted in stealing, diverting, converting, using, andmisappropriating millions of dollars that belonged to the MICCOSUKEE TRIBE and theMICCOSUKEE PEOPLE and which were in the care, possession, control, and supervision of the Defendants.
JURISDICTION AND VENUE
This Court has jurisdiction over the subject matter of this suit by virtue of:a.
Federal question jurisdiction pursuant to 28 U.S.C. § 1331, involving anaction pursuant to 18 U.S.C. §§ 1964(a) and (c), the Federal RacketeerInfluenced and Corrupt Organizations Act (RICO);b.
Supplemental jurisdiction pursuant to 28 U.S.C. § 1367(a), involving
claims that are so related to claims in the action within the Court’s original
jurisdiction that they form part of the same case or controversy underArticle III of the United States; and,3.
This Court has jurisdiction over the Defendants because:a.
Each defendant either resides or transacts business within this judicialdistrict; and,
Case 1:12-cv-22439-MGC Document 1 Entered on FLSD Docket 07/01/2012 Page 2 of 78