This petition presents three questions on which the circuits disagree:

1. Does a boilerplate release, induced as an integral part of a wire fraud scheme before a plaintiff learns of the fraud, immunize the defendant from RICO liability arising out of that scheme?

2. May the same release operate prospectively, absolving a RICO defendant of violations and injuries that arise after the release was signed?

3. When a party requests first-time leave to amend in opposition to a dispositive motion, and explains why the proposed claim to be added is plausible, may the court deny leave merely because the party had not yet filed a separate, formal motion for leave?

Whether a boilerplate release induced as part of a wire fraud scheme can immunize a defendant from RICO liability and prospectively absolve future violations