RICO ENTERPRISE

The pleaded enterprise is an association-in-fact under 18 U.S.C. § 1961(4).

Two Sisters Dairy LLC and Anastasia Anne Thiele are the injured business and property holders.

The associate-by-associate record, the dated instrument record, and the recorded-instrument trail appear in the tables below.

The asserted common purpose was pursued through complementary functions:

1. controlling company information, books, accounts, revenue, and governance;
2. increasing and enforcing the operating-line balance of $6,146,401.90;
3. expanding and enforcing real-property and business collateral;
4. imposing forbearance fees, paydown requirements, transaction deadlines, and consent conditions;
5. preparing the buyer entity, appraisal, possession rights, and purchase structure;
6. disposing of the herd, land, equipment, and operating assets;
7. routing sale, closing, exchange, and creditor-pool proceeds;
8. financing the Martins-affiliated acquisition; and
9. refinancing and maintaining the acquired position.

2013 | OPERATING AND COLLATERAL RELATIONSHIPS

The record identifies the dairy-operation, creditor, account, real-property collateral, and accounting relationships through which the business and its assets were operated and financed.

2019 | DOCUMENTED CROSS-BANK COLLATERAL DEALINGS

Bank of the West requested AgTexas’s execution of the proposed Consent to Easement.

AgTexas denied the request. The instrument was not issued or executed.

Twenty-eight days later, Bank of the West recorded Deed of Trust No. 2019-05501, including road-easement and related covenant rights across the Hoover/Murphree collateral identified in the unsigned consent materials.

2021–2024 | TRANSFEREE FINANCING, POSSESSION & ACQUISITION

AgTexas financed Martins-affiliated entities beginning September 16, 2021.

The transaction record then proceeds through:

• buyer-entity formation;
• appraisal;
• exclusive transaction arrangements;
• possession effective April 7, 2023;
• July 26, 2024 acquisition;
• and BMO acquisition financing.

2025–MAY 5, 2026 | REFINANCING & RELEASE

AgTexas refinanced the acquired position for $33,000,000 on November 26, 2025; a further $7,000,000 note on April 14, 2026 brought the position to $40,000,000.

BMO terminated its UCC and released its deeds of trust. The recorded Martins-affiliated facility later totaled $118,696,740.50 across ten notes and five cross-guaranteed entities.

ENTERPRISE PERIOD ASSERTED — 2013–MAY 5, 2026

The enterprise showing rests on:

• the identified common purpose;
• direct relationships among the associates;
• recurring and complementary functions;
• repeated use of the same collateral, accounts, property, transferee, and transaction channels;
• and longevity sufficient to prepare, execute, finance, and maintain the transferred position.

GOVERNING STANDARD

18 U.S.C. § 1961(4)

Boyle v. United States, 556 U.S. 938, 944–48 (2009)

CLAIMANT AND ENTERPRISE SEPARATION

TWO SISTERS DAIRY LLC — Injured operating business and property holder.

ANASTASIA ANNE THIELE — Injured individual property holder and sole member.

CONTROLLING AUTHORITY

St. Paul Mercury Insurance Co. v. Williamson, 224 F.3d 425, 445–47 (5th Cir. 2000)

Cedric Kushner Promotions, Ltd. v. King, 533 U.S. 158, 161–64 (2001)

The enterprise’s activities affected interstate commerce through identified banking, wire, carrier, lending, auction, escrow, and commercial channels, including:

• a proceeds assignment connecting a Texas dairy operation, an Alabama counterparty address, and a California bank lockbox;
• electronic transfer of dairy proceeds;
• Fedwire transfers from Texas to Florida;
• interstate delivery carriers and tracking records;
• a California auctioneer’s herd-disposition contract;
• federally regulated banking and Farm Credit institutions;
• Idaho borrower entities;
• and a Dairy Producer Milk Supply Agreement with Borden Dairy Company, identified in the agreement as a Delaware company.

The commerce showing rests on the interstate counterparties, financial institutions, electronic transfers, carriers, contractual channels, and transaction instruments.