Although a claimant's claim against the estate is not yet ripe, as its present lack of value might change, a claim based on the claimant's collection expenses is sufficiently final.
Estate, which as a matter of state law is an inchoate entity, can serve as the nexus for a civil RICO association-in-fact.
http://www.ca2.uscourts.gov/decisions/isysquery/aa7d1353-0417-45d3-8cb2-69fbe6d60e55/1/doc/17-1162_opn.pdf#xml=http://www.ca2.uscourts.gov/decisions/isysquery/aa7d1353-0417-45d3-8cb2-69fbe6d60e55/1/hilite/
Since 2011. An occasional commonplacing of the U.S. Circuit Courts of Appeal.
Neither an authoritative statement of the law nor legal advice. Quick work.