08-3187 Volume Appendix15.pdf - Medical Supply Chain

560. Plaintiff is entitled to recover their actual damages in the amount of in excess of $500,000,000.00
for their actions resulting in the loss of trust accounts, and actual damages in the amount of in excess of
$500,000,000.00 for their actions resulting in the loss of the lease sale together with the costs of suit, and
attorney fees.
561. Defendants’ actions were willful, wanton, malicious and oppressive.
562. Plaintiff is also entitled to recover punitive damages in an amount in excess of $10,000.00.
563. Plaintiff realleges paragraphs 1 through 562.
COUNT XIV
DAMAGES FOR PRIMA FACIE TORT
564. To whatever extent said activities of Defendants may not violate antitrust laws or tortuously
interfere with contract or business expectancy, said acts and activities of Defendants are still unlawful and
fraudulent.
565. Said activities were intended by Defendants and performed by Defendants.
566. Said activities were intended by Defendants to cause injury to Plaintiff.
567. Said activities did directly and proximately cause injury to Plaintiff.
568. Said activities were and are unjustified.
569. Plaintiff is entitled to recover their actual damages in the amount of in excess of $500,000,000.00
for their actions resulting in the loss of trust accounts, and actual damages in the amount of in excess of
$500,000,000.00 for their actions resulting in the loss of the lease sale together with the costs of suit, and
attorney fees.
570. Defendants’ actions were willful, wanton, malicious and oppressive.
571. Plaintiff is also entitled to recover punitive damages in an amount in excess of $10,000.00.
COUNT XV
DAMAGES FOR RACKETEERING
INFLUENCED CORRUPT ORGANIZATION (RICO) CONDUCT
(18 U.S.C. § 1962(c), 18 U.S.C. § 1962(d))
572. Plaintiff realleges paragraph 1 through 571.
573. On January 21, 2005 Medical Supply discovered the Defendants’ pattern of inflicting injuries on
the plaintiff to obstruct its entry into the market for hospital supplies and hospital supplies in e-commerce.
An important component of the Defendants’ scheme was to interdict capital required by Medical Supply to
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