To this day, Mr. Holder has never publicly taken a position on the FALN pardons with any particularity, except to say that the President had absolute power to give them.
The particularity and high significance of this document lies in an eighteen month long collaboration of two different scientific communities: one on climate change (IPCC) and one on disaster risk reduction (ISDR).
But the argument was good enough to convince the Court to allow Rohlf to amend his counter-petition to specify with more particularity the self-dealing by Mellon BNY, so presumably we will hear more of this case in the coming months.
To make a RICO case stick, however, the plaintiffs must establish a series of acts by management to perpetuate an offense and state those facts with enough particularity to survive a so-called Iqbal challenge, named after a 2009 Supreme Court case that heightened the standards for civil lawsuit claims.