State v. Squires, 2019 UT App 113 (June 20, 2019)

The defendant was convicted of four communications fraud counts and one count of pattern of unlawful activity related to enticing his uncle to post property as collateral on a real estate investment hard money loan with the collateral ultimately lost.  The court held that the State could not establish “closed ended continuity” for purposes of the pattern count “because Squire’s predicate acts of communications fraud extended over a short period of seven to eight months” and Squires’ interactions with this uncle “did not ‘by its nature project[] into the future with a threat of repetition.’”