Whether a person violates 18 U.S.C. § 1962(c) by simply knowing an enterprise is collecting a debt that is separately determined to be unlawful

QUESTIONS PRESENTED Under 18 U.S.C. § 1962(c) and (d) anyone “employed by or associated with any enterprise” is prohibited from conspiring to “conduct or participate, directly or indirectly, in the conduct of such enterprise’s affairs through . . . collection of unlawful debt.” The questions presented are: 1. Whether a person violates 18 U.S.C. § 1962(c) by simply knowing an enterprise is collecting a debt that is separately determined to be unlawful, as found by the Third Circuit Court of Appeals, or whether the statute requires a defendant to know that the debt is unlawful and acted willfully to violate that law, as determined by the Second, Fifth, and Eleventh Circuit Courts of Appeals. 2. Whether a litigant who makes a false statement during a civil proceeding commits wire fraud by “defrauding” the counter party out of a right to sue when this Court has limited wire fraud to “traditionally recognized money or property.”