• Report: #1126354

Complaint Review: CHIEF JUDGE STEPHEN MUNSINGER

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  • Submitted: Tue, February 25, 2014
  • Updated: Fri, March 07, 2014

  • Reported By: Leges sine moribus vanae. — Colorado
CHIEF JUDGE STEPHEN MUNSINGER
2 EAST 14TH AVE , Colorado USA

CHIEF JUDGE STEPHEN MUNSINGER Judge Munsinger, Judge Stephen Munsinger, Chief Justice Munsinger, Steve Munsinger, Susan Munsinger, Brook Munsinger, Gary Munsinger, Elva Munsinger, Eddie McGraddy, Leland Coulter Leland M Coulter, Irene Coulter, Irene C. Coulter, Jefferson County Distr DISTINGUISHED JUDGE LOSES MORAL COMPASS AND VIOLATES CONSTITUTIONAL OATH GOLDEN Colorado

*Author of original report: Colorado Probate Attorney John Berman admits to being sexual preditor

*Author of original report: ANONYMOUS JUDGE AND STAFF ATTORNEY JANE BAILEY DENIES MOTION TO RESTORE RECORD

*Author of original report: Colorado Appeals Court. Jane Bailey, as staff attorney, writes anonymous Order

*Author of original report: Additional persons and entities

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"If, indeed, a judge goes against the law so grossly, so palpably, as no imputable degree of folly can account for, and nothing but corruption, malice or wilful wrong can explain, and especially if circumstances prove such motives, he may be punished for the corruption, the malice, the wilful wrong.”

--Thomas Jefferson: Batture at New Orleans, 1812. ME 18:130

 Colorado Legislature House and Senate Judiciary Committees:

200 East Colfax,

Denver Colorado, 80203

 Senator Lois Tochtrop, Chair of the 2011 Performance Audit Committee

Cindy Acree,

Deb Gardner. [continued below]....

.....

Senator Lucia Guzman,

 Jim Kerr,

Senator Steve King,

Joe Miklosi,

Senator Scott Renfroe,

Dianne Ray, State Auditor,

Current House Judiciary Committee Members:

Danial Kagan, Chair,

Peter Lee, vice chair,

John Buchner,

Lois Court,

Bob Gardner,

Polly Lawrence,

Mike McLachian,

Carole Murray,

Brittney Petterson,

Joe Salazar,

Mark Waller,

Current Senate Judiciary Members:

Lucia Guzman, Chair,

Linda Newell, Vice chair,

Michael Johnson,

Steve King,

Kevin Lundberg,

Members of the Colorado Supreme Court,

Governor John Hickenlooper,

Permanent Internet file.

 RE: Request for Audit of Colorado Probate Courts

Dear Sir/Madam:

Attached afterward,  please find two letters addressed to the Colorado Supreme Court, Governor Hickenlooper and members of the legislature, specifically the Judiciary Committees of the House and Senate. I will address one of the last attrocities of Chief Justice Stephen Munsinger (1st judicial district) so that you realize that he is capable of the other accusations noted here concerning numerous, intentional and continued violations of the 2011 Probate Court Performance Audit of the Legislature[1]………

My Father was Leland Coulter, a well-liked and respected attorney who passed away in 1991 and was buried at the family plot at Olinger Crown Hill alongside his brother who had died at childbirth. His wife, my Mother Irene Coulter, passed away on January 6, 2013, after being under the Conservation and Guardian Probate watch of Judge Munsinger since January of 2010. (10PR204; Jefferson County) It was always assumed that our Mother would be buried next to my Father in the Olinger Crown Hill Family plot.  There was no communication after my Mother died from either the Conservator, my younger sister, Paula Coulter or her unscrupulous attorney, John Berman, Esq[2]

On January 15, 9 days after my mother died, he made an emergency motion to Judge Munsinger to remove my father from his grave of 23 years. There was no notice to the parties, there was no hearing, and Judge Munsinger did not have jurisdiction over the parties. Mr. Berman filed the fraudulent motion based on Probate proceedures for wards that had just passed away. My father was not part of the probate and a complete contrary statute applied to his remains and mandate that they not be disturbed.  Judge Munsinger granted the Motion within 12 hours of it being presented to him by Mr. Berman and within 12 hours after that event, my Father’s grave was desecrated by the removal of his remains.  The actions of Stephen Munsinger and John Berman were no different than grave robbers; only instead of pics and shovels, they used a robe and gavel. They are despicable human beings who need to be held accountable for their shameless actions.

Somewhere Stephen Munsinger moral compass steered off course and the robes and titles and awards have been substituted by criminal actions. Now that I have shown what Stephen Munsinger is capable of; I believe it easier to believe what I am about to reveal about him and its relation to the Judicial Committees of the Legislature.

 2011 LEGISLATIVE AUDIT OF THE COLORADO PROBATE COURTS

In 20ll, the Legislature did an Audit of the Probate Court and found very serious shortcomings and accountability by the Courts. Supreme Court Chief Justice Bender was appropriately embarrassed about the report, and promised he would take immediate action to rid the issue. He then signed Legislative policies that he would implement. Most if not all were based on making sure Judges kept a watchful eye over Conservator and Guardians to make sure they weren’t taking advantage of their respective Wards.[3] But what if the Justice handling these cases has lost his/her oath to the Constitution and is complicit with Conservators and their attorneys in decimating the assets of at-risk wards? Those are the exact actions of Stephen Munsinger. Although continually requested and Ordered, Mr. Berman and the Conservator never provided a detailed Conservator Report as required by statute and further highlighted by the Legislative Audit. Mr. Berman never filed one professional invoice even though according to what records I could hobble together, he billed Mrs. Coulter at least $40,000 in attorney’s fees. There was no backup documentation [i.e. check registers, receipts etc] to verify the numbers put on the Conservators report. There were joint accounts between of the Ward and Conservator that Stephen Munsinger refused to put a stop to even though he was Motioned several times on this issue. The beginning and ending balances were off as much as $100,000 in most cases. Again, Stephen Munsinger refused to do anything about it.  And my mother’s largest asset, 400 acres of mining property valued in excess of $500,000 was missing from each and every report. Again  Stephen Munsinger refused to do anything about it and continually refused to have the Conservators reports audited. And the Power of Attorney that named Paula Coulter as Conservator, submitted by John Berman, was written by JoAnne Goddard, Esq.; 3 years after 27 police reports showed Mrs. Coulter believed “neighbors were coming in through her front door keyhole, molesting her car and stealing her food. Said Power of Attorney also came before a second Power of Attorney (dated two months later[4]) that was directed exclusively at Ted Coulter to be sole administrator with completely different language.[5]

A detailed version of Stephen Munsinger’s shameless and criminal acts  and those of John Berman, JoAnna Goddard, Paula Coulter and Ted Coulter can be found in the two attached letters to the Colorado Supreme Court, and the Court files themselves.[6]

The Probate Court in Colorado is in worse shape than when you Audited it in 2011.  Families lives are being torn apart unnecessarily by shameless  judges and attorneys.  I would request you therefore forthwith employ another Audit of the Colorado Probate Courts.

If you have any questions please do not hesitate to call or E-mail.

Thank you for your time and considerations in these matters.

 Sincerely dated this 17th day of February, 2014,

 

/s/Peter Coulter

151 Summer Street #654

Morrison, Colorado 80465

Phone 303 720-1811

Email   Audionly @ Gmail.com

 _______________________________________________________________________

 

 

JUSTICES OF THE COLORADO SUPREME COURT

2 East 14th Ave.

Denver, Colorado 80203

Certified Mail # 9114901159815447323847

Certified Mail # 9114901159818423794662 Governor Hickenlooper

RE:  2011 Legislative Audit of Colorado Probate Courts/ Investigation

 January 1, 2014

 Chief Justice Michael Bender,

Justice Gregory Hobbs Jr.,

Justice Nancy Rice,

Justice Nathan Coats,

Justice Allison Eid,

Justice Monica Marquez,

Justice Brian Boatright,

Legislative Audit Committee,

 Justices and members of the Audit Committee:

 On September 27, 2011, Chief Justice Bender admitted to the Legislative Audit Committee that the Colorado Judicial Branch had a serious problem with their Probate Courts saying, “We understand the problem and we’re going to make it a priority.”

 The issues of the Audit were obviously focused toward Judges and Probate Courts that for some reason or another failed to keep Conservators, Guardians and Receivers accountable. The Supreme Court signed off on remedying these issues and implementing safeguards to end at-risk persons being taken advantage of by unscrupulous persons.

 But what happens if the Probate Judge handling the case is unscrupulous and intentionally refuses to follow the directives signed off by Justice Bender or to follow standard Probate procedures. What if that Judge actually participates in the criminal activity to the point where my entire Mother’s estate was allowed to be decimated by my siblings with the help of John Bergman, Esq. ( A self-admitted sexual predator previously suspended by the Supreme Court and who has been admonished previously for refusing to provide a professional invoice) and JoAnne Goddard, Esq.

 

A review of the cases shows that despite constant efforts by myself, Justice Stephen Munsinger intentionally violated the rules of civil procedure and directives of this Court resulting in incomplete and intentionally erroneous Conservator’s reports, no professional invoices, no audits of missing assets, including my Mother’s largest asset, a mining property valued in excess of $500,000, and the refusal to allow in evidence that 5 years before my Mother allegedly signed her last will and unlawful Power of Attorney used to nominate the Conservator, 27 police reports stated Mrs. Coulter believed “neighbors were coming through the keyhole of her front door, molesting her cat, and stealing her food.” She was not capable of knowing what she was signing yet Justice Munsinger was not  interested in the truth. I believe he had/has some personal bias against me  and/or he was/is protecting JoAnne Goddard and John Berman from their criminal acts.

 At one point during the Conservatorship, the Court ORDERED (I believe it was by mistake now.) the Conservator and her attorney to provide detailed conservator documents (as required by Statute and Directive) where in the end, Mr. Berman produced only mundane hair dresser receipts.  I requested a hearing for contempt. While the hearing was held, Justice Munsinger never addressed the issue and couldn’t get off the bench fast enough. The end result was/is that there has never been a detailed valid accounting of my Mother’s estate even though there were statutory rules, Supreme Court Directives, Statutory requirements and a plethora of Motions and Orders to provide such.

 The end result was Justice Munsinger closing the Conservator case without one accurate detailed report and refusal to have the reports Audited. But it didn’t end here. My Mother passed away on January 6, 2013 and on January 15, 2013, Mr. Berman emailed me and indicated that he was going to have my Father, Leland M. Coulter, Esq. dug up from his grave of 22 years and moved. I objected vehemently but it was of no use. Mr. Berman filed a bogus emergency Motion citing incorrect statutes and within 24 hours the Court granted the Motion. Justice Munsinger granted this despite having no jurisdiction over my Father’s remains, no notice to any of the parties involved and no hearing. To me that is no different than grave robbers digging up his remains; only he used a black robe and gavel.  Judge Munsinger conspired and participated in criminal desecration of a venerated object.

  I appealed the Conservatorship case in timely fashion and submitted a Designation of Record including a transcript of the June 7, 2012 Contempt hearing. I received a call from the Court Reporter saying that recording had disappeared. I didn’t/don’t believe it was a mistake. I believe Justice Munsinger intentionally erased/deleted the tapes to cover his tracks of collusion with Mr. Berman and the Conservator.  I requested an investigation by the appellate Court which was denied by an anonymous person who also refused to restore the record in accordance with Probate statutes. The documents I received from the appellate court were so bizarre, I didn’t know if they were real. There were no signatures and no certificate of service. [I asked three separate attorneys if they had ever seen anything like that and they indicated they had not.] Only the initials JB/sa which the Court refused to tell me who those belonged to; only that it was a staff attorney, not a Judge. I had to file an open records request with the Supreme Court to find out the “JB” stood for Jane Bailey, Esq., a staff attorney, not a Judge. I filed a Motion to reconsider and clarify and to date have not heard back from the Court.

 I hope it is as obvious to you as it is to me that the Chief Justice’s  Court directives, Colorado Rules of Civil Procedure, and Colorado Revised Statutes were intentionally violated by Chief Justice Mussinger. And further, that he has committed the criminal act of desecration of a venerated object, my Father’s remains.

 I have previously presented documents to the Colorado Commission on Judicial Discipline with no response. And I also reported Mr. Berman to the Colorado Attorney Regulation Committee with no response. I would therefore request the above parties to be immediately investigated by the Supreme Court and the Legislative Audit Committee.

 The relevant case no.’s are Jefferson County District Court 2010PR204; 2013PR56; and Colorado Court of Appeals, 13CA1453.

 Thank you for your time and consideration in these matters and would request a response.

 Respectfully requested,

 

/s/ Peter Coulter

151 Summer Street #654

Morrison, Colorado 80465

303 -720-1811

Email Audionly@Gmail.com

 cc;

 Internet permanent file,

 Governor John Hickenlooper,

 JudgeStephenMunsinger.us

The Supreme Council,  33°, Denver Consistory

  ______________________________________________________________________________________

public.access@judicial.state.co.us

Justice Monica Marquez, Supreme Court Chair,

Public Access Committee.

cc: Certified mail 9114901159818423794662 Governor Hickenlooper

 RE: Chief Justice Directive 05-01; access to Court Records.

 January 10, 2014

 Justice Marquez,

Public Access Committee:

 I have a current appeal filed (13CA1453) While it is filled with inconsistencies by the Court and its refusal to make findings or explain why it won’t accept a Rule 60 Motion, of importance here is the issuance of “ORDERS” by anonymous parties and the refusal to provide documentation directly associated with the case in compliance with Chief Justice Directive 05-01. A review of the records shows an ORDER with no Judges name or signature and then the initials “JB/sa.  This was/is followed by an unsigned certificate of service.

My first inclination then and now is that there is a subculture of persons in the Judicial Department that make decisions on their own admonition and then bury the results. This is not just an off the cuff remark as I have documentation of magistrates (Edward Burns) who removed Jury Fees and corresponding requests including ORDERS from the Supreme Court from the official Court registry. In other words, if you look at the official court registry, it looks as if there was no jury requested; but the cash receipt shows there was. Additionally, Magistrate Burns with Head Clerk Tamara Herivel removed all documentation referring to said jury request, including Court Orders from the Colorado Supreme Court.  After I reported them stolen to the Arapahoe County Sheriff, they miraculously reappeared except for the jury demand, associated fee and the Supreme Court Order. There was one issue though; the Court stamp [on the new documents] is above the N/L stamp. That’s impossible as I was/am a prose litigant and had to file everything personally to the Court clerk. The original documents had the court stamp below the L/N stamp. The documents were frauds meant to cover up the criminal actions of Edward Burns and Tammy Herivel [with the help of Charles Pratt and Chris Cross] and eventually cost me in excess of $4M.

And in another instance, I reported attorney William G. Ross to the Attorney Regulation Commission for screwing up a closing, keeping the funds for the title policy and practicing while his license was under suspension. John Gleason was handling the investigation. He eventually told me that Mr. Ross would be suspended for 3 years and that I would have to go after him personally for the title policy fees. It cost me millions. The last thing I asked of Mr. Gleason was a copy of the Order pertaining to Mr. Ross. That was 1994. In 2012, I again asked for a copy of the ORDER and Mr. Gleason denied me saying now I was not entitled to that information. I then find out that Mr. Buchwald, an adverse party in the case, used my title policy to get property taxes refunded to him by the title company. I wrote a letter to the Supreme Court concerning this matter and never heard anything. But, from an anonymous source inside the judicial system, [who uses a park as a unique return address,] I was told that that Alex Martinez and John Gleason were asked to leave because of this event. I have felt the retribution of this event by these parties also.

Bottom line is that there is proof positive that there is a culture of persons within the Judicial branch that issue their own judgments and then make a concerted effort to cover them up.

In the instant case, no one could/would tell me the judge’s name associated with this case, nor would they give me the name of the staff attorney who issued the ORDER unlawfully in violation of substantive and procedural due process of law. The only way I was able to obtain this information was to file a CORA request with the Colorado Supreme Court Administrative Department.

There is absolutely no reason why this information should not be available to the public unless again, it is to cover up some type of hidden agendas. This is no different than having one’s Motions being decided by a person in robes and hood in direct violation of CDJ 03-05 and procedural due process of law.

How can there be an ORDER with no signature and a refusal by the Court to provide this information? I would request an investigation and response into these serious issues.

 Respectfully submitted,

 /s/Peter Coulter

303 720-1811

151 Summer Street #654

Morrison, Colorado, 80465


[2] Mr. Berman has numerous complaints against him with the Supreme Court.  Most pertinent here is a refusal to provide a professional invoice to a client. The most hideous though is Mr. Berman’s perverted act of groping a client’s breasts and trying to kiss her to which he admitted in writing. In any other forum, Mr. Berman would be labelled a sexual predator and imprisoned.  The Supreme Court instead decided to suspend his license and then reinstate it on probation for 24 months. Mr. Berman was/is still under suspension as of today.

In my Mother’s case, it was found that Paula Coulter and Ted Coulter were “gifting” funds from my Mother’s Smith Barney account in amounts of at least $190,000 and most likely upwards of $500,000 before other members found out about the fraudulent Power of Attorney and Will.

[4] Ted and Paula Coulter would stop at nothing to get our Mother’s funds; even to go against each other. Unknown until a couple months ago, Ted Coulter took a mobile Notary to the Alzheimer Ward where my Mother was placed and had a subsequent Power of Attorney Notarized where he was sole agent.  In is obvious by the documents themselves that they were fraudulent shoved in front of her and she signed without a clue of knowing what she was doing. Their actions [Paula Coulter, Ted Coulter, JoAnne Goddard and Stephen Munsinger] are completely incestuous and continue through today.

[5] It

[6] Jefferson County District Court 10PR204 and 13PR56 and Colorado Court of Appeals [where Court Orders are anonymously signed and others removed from the file] 13PR1453.

 


This report was posted on Ripoff Report on 02/25/2014 09:22 AM and is a permanent record located here: http://www.ripoffreport.com/r/CHIEF-JUDGE-STEPHEN-MUNSINGER/Colorado-80203/CHIEF-JUDGE-STEPHEN-MUNSINGER-Judge-Munsinger-Judge-Stephen-Munsinger-Chief-Justice-Mun-1126354. The posting time indicated is Arizona local time. Arizona does not observe daylight savings so the post time may be Mountain or Pacific depending on the time of year.

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#1 Author of original report

Colorado Probate Attorney John Berman admits to being sexual preditor

AUTHOR: Leges sine moribus vanae. - ()

Summaries of Decisions Regarding
Conditional Admission of Misconduct Issued by the PDJThe PDJs approval of a Conditional Admission of Misconduct does not result in a written Opinion but only a brief Order, which does not constitute precedent. Conditional Admissions of Misconduct are public record and are available for review at the Office of the PDJ, 1560 Broadway, Ste. 675, Denver, CO 80202; (303) 866-6658; www.coloradosupremecourt.com/PDJ/pdj.htm. They also are available on LexisNexis.No. 11PDJ078. People v. Berman. 05/11/2012. Attorney Suspended.


People v. Berman
.  11PDJ078.  May 11, 2012.  Attorney Regulation.  The Presiding Disciplinary Judge approved a Conditional Admission of Misconduct submitted by the parties and suspended John A. Berman (Attorney Registration Number 06695) for a period of nine months, all stayed upon the successfulcompletion of a two-year period of probation with conditions, 
effective May 11, 2012. [continued below]....
 
.....  Berman represented a female client in a bankruptcy matter.  Bermans client was dissolving her marriage, and the bankruptcy filing needed to be completed before her divorce could be finalized.  During this representation, Berman touched his client without her consent or permission in a manner she found offensive. [He fondle her breasts and tried to kiss her] This action, coupled with a comment about the clients appearance, caused her emotional discomfort and violated her trust in Berman as her attorney.  His misconduct constitutes grounds for the imposition of discipline pursuant to C.R.C.P. 251.5 and violated Colo. RPC 8.4(h). 
 

JOHN A. BERMAN, John Berman, Marjorie Katz Berman, David Berman, Josua Berman, Laurence Berman, Stephen Berman, Larry Berman, Samss Berman, Daniel Berman, jab@jaberman.com

 

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#2 Author of original report

ANONYMOUS JUDGE AND STAFF ATTORNEY JANE BAILEY DENIES MOTION TO RESTORE RECORD

AUTHOR: Leges sine moribus vanae. - ()

Court of Appeals, State of Appeals

2 East 14th Ave.

Denver, Colorado 80203

303 861-1111

___________________________________________________

Appeal from the District Court, Jefferson County, Colorado

In re: IRENE COULTER

Case no. 2010PR204

Justice Stephen Munsinger, Justice Lilly Oeffler

100 Jefferson County Parkway

Golden, Colorado, 80401

PETER COULTER, Appellant,

 

v.

 

PAULA COULTER;

TED COULTER,

Appellees..

 

 

 

 

 

 

 

 

COURT USE ONLY

PETER COULTER, interested party, heir, pro se

151 Summer Street #654 Morrison Colorado 80465

Phone Number: 303 720-1811

 E-mail:AUDIONLY@GMAIL.COM

Case Number:

 

13-CA-1453

 

 

MOTION FOR CLARIFICATION, RECONSIDERATION,  AND OBJECTION TO ANONYMOUS ORDER SUPPORTED BY AFFIDAVIT

 

COMES NOW the Appellant Peter Coulter, pro se, to ask the Court to clarify the Orders of staff attorney “J.B.”; to reconsider said “ORDERS”; and Objection to staff attorney “J.B” actions reserved for Judges, supported by Affidavit. As good and sufficient cause the Appellant would state as follows:

I. BACKGROUND

1. The Appellant references  his Amended Rule 60 Motion filed with this Court on November 7, 2013, and his Motion for extension of time to file and restore record filed on October 15, 2013  as though fully rewritten herein.

2. The Appellant filed a timely Notice of Appeal and Designation of Record including all transcripts of hearings in the underlying District Court case including the transcript of the June 7, 2012 hearing regarding sanctions against the Conservator for disobeying a direct Court Order to turn over detailed Conservator reports, support documentation and Professional Invoices.

3. On October 1, 2013, the Appellant was contacted by Paula Oden, managing Court Reporter for Jefferson County District Court and told,

 “ 6/07/12 [hearing]    Minute orders indicate a hearing held; however, there’s no audio to transcribe, so I will include this date in my affidavit”

 

4. On November 26th the Jefferson County District Court provided an affidavit to the Appellant and the Court of Appeals that the June 7, 2012 Hearing Transcript is missing and unavailable for the Appellant’s Designation of Record. (Emphasis added) [Addendum 3]

5. Said record was included and is imperative to the Appellant’s case. There is a specific Probate procedure to facilitate the loss of a record as in this case and Appellant filed a proper Motion with the proper Court. [C.R.S. 13-1-105 Procedure where probate record destroyed  Motion Attached as Addendum 1]

6. This Motion was allegedly Denied by someone at the Court of Appeals.

7. On October 23, 2013 the Appellant became aware of a subsequent power of attorney to that of Conservator Paula Coulter. Paula Coulter’s P. of A. has been used extensively over the last 6 years including a sworn Motion to be named as Conservator for Irene Coulter. Said P. of A. took precedence and voided Paula Coulter’s P. of A. The entire Conservator case including the sworn Petition to become Mrs. Coulter’s Conservator was based on authority granted in Paula Coulter’s void and fraudulent Power of Attorney. In addition, it again needs to be noted that prior to any of these Powers of Attorneys being signed by Mrs. Coulter, there were 27 Littleton Police reports indicating Mrs. Coulter believed “the neighbors were coming in through her front door key-hole, molesting her cat and stealing her food] [Addendum 2]

8. Appellant filed Rule 60 Motion on October 30, 2013 and Amended version on November 7, 2013 with the Appellate Court and sent copies to all parties. Under C.R.C.P Rule 121, 1-15(b); Appellees had 21 days until Nov. 20, 2013 to adversely respond and object. No parties elected to respond. Failure of a responding party to file a responsive brief may be considered a confession of the motion. C.R.C.P Rule 121 1-15. On November 14, 2013, the Appellant received a document from the Appellant Court that resembled a Court Order except there was no signature of a Judge. Instead, the salutation stated: BY THE COURT         JB/sa. Upon calling the Clerk of the Court and the Judicial Administrative Department; they both indicated that “J.B” is the initials of a “s.a.”, Staff Attorney. Both said I was not entitled to know who “J.B .” is. I then went and personally reviewed my file at the Appellate Court and it does not contain the names of any Judge who made the rulings in my Appeal.

DISCUSSION  (In Order of presentation in document [ORDER]sic dated 11/15/2013)

9. There is nothing in the document sent to the Appellant on 11/15/2013 that indicates that it is an authentic and official document. There is no Court Seal. There is no Judge referenced. There is no signature of Judge stated and there is no signature (actual or electronic) for the certificate of service. There are printed initials at the end of the ORDER indicating “JB/sa”.  Upon conferring with the Clerk of the Court; they indicated that the “JB” was the initials of a staff attorney, not a Judge, and that I was not entitled to the name referenced in those initials.

 

  1. 10.        According to the Court of Appeals own web site [Addendum 4} the staff attorneys are to make recommendations to an Appellate Judge; not pass judgment themselves. To do so is violation of procedural due process of law and a Constitutional violation of the Appellants civil rights to a fair trial. Colorado Constitution, Section 25. Due Process of law: No person shall be deprived of life, liberty or property without due process of law. The Colorado Supreme Court has ruled that this section requires at least the same guarantees as those protected by the due process provisions of the federal constitution.  Colorado may enlarge, but may not abridge, the federal concept of due process. The Appellant cannot tell if the person who published said “ORDER” is actually a Judge and whether there is a possible conflict of interest. C.R.C.P. Rule 11 signing of pleadings [Addendum 5] requires “JB” [If he is an attorney] to personally sign and state his registration no. The Appellant is entitled again under due process of law to his day in Court with a named Judge.

 

  1. The Appellant would also request clarification and findings on why it denied his Rule 60 Motion. This rule is not a substitute for appeal, but instead is meant to provide relief in the interest of justice in extraordinary circumstances.(emphasis added) De Avila v. Estate of DeHerrera, 75 P.3d 1144 (Colo. App. 2003).  As noted earlier, no parties made timely objections and the new found evidence of the fraudulent Power of Attorney changes the entire landscape of the case. To arbitrarily dismiss it without reason or findings is an abuse of judicial discretion. Further,instead of accommodating the legal knowledge of the Appellant who doesn’t trust lawyers or the Court but is subject to its control. This “document/ORDER” supports that the  judges and court personnel systematically discriminate against litigants who appear pro se by dismissing their Motions out of hand, regardless of their merits.  It is painfully obvious that the Court does not want to Restore the Record as that would allow the Appellant to bring in evidence of the Fraudulent Power of Attorney which currently is not in the Appellate record. That is an abuse of judicial discretion and a further violation of substantive and procedural due process of law.
  2. Attached is an affidavit [Addendum 3]to the Court by the Jefferson County District Court by the Managing Court Reporter, Ms. Oden. She swears that a transcript which was noted in the Appellant’s Designation of Record is unavailable. It is a necessary part of the Appellant’s case and he has provided a specific Statute to the Court to Restore said record. (See Motion to Restore Record, Addendum 1)  To require the Appellant to Order and pay for other transcripts when the Court refuses to restore this pertinent record that was designated and a part of the District Court Record, is a further indication that the Court is not interested in justice but only in “burying” this appeal through continued and flagrant violations of the Appellant’s Constitutional rights and due process of law.
  3.  

WHEREFORE, the Appellant respectfully request the following:

a. Clarification of dismissal and findings as to Appellant’s Rule 60 Motion or alternatively to reconsider it’s Order to Dismiss;

b. Remand of the case to the District Court for proceedings to Restore the Record of the necessary transcript of the June 7, 2012 hearing so that Appellant can comply with Appellant Court rules, i.e. a complete designation of record including all transcripts stated by Appellant;

c. Strike the document [ORDER]of November 14/15 as not complying with Colorado Rules of Civil Procedure or alternatively resubmit with a proper Judicial signature; process of service signature and signature and registration no. of “JB staff attorney”.

 

Respectfully submitted this 29th day of November, 2013,

 

                                  /s/Peter Coulter

 

CERTIFICATE OF SERVICE

I certify that on 11/29/2013 a copy of the above document was served on each of the following:

 

Name of Person to Whom you are Sending this Document

Relationship

Address

Manner of Service*

JOHN BERMAN, ESQ.

ATTORNEY FOR PAULA COULTER,

JAB@JABERMAN.COM

E-MAIL

TED COULTER

HEIR

TED.COULTER@WARDNORTHAMERICAN.COM

E-MAIL

JEFFERSON COUNTY DISTRICT COURT

 

 

MAIL

Legislative Judicial Committee

 

 

E-MAIL

 

 

 

 

 

 

 

 

 

 

 

 

 

*Insert one of the following:  Hand Delivery, First-Class Mail, Certified Mail, E-Served or Faxed.

 

                                                                                                                        /Peter Coulter

 

Judge Munsinger, Judge Stephen Munsinger, Chief Justice Munsinger, Steve Munsinger, Susan Munsinger, Brook Munsinger, Gary Munsinger, Elva Munsinger, Eddie McGraddy, Leland Coulter Leland M Coulter, Irene Coulter, Irene C. Coulter,  Jefferson County District Court 10PR204, 13PR56, Colorado Appellate Court 13CA1453, Paula Coulter, Paula Marie Coulter, Colorado Tennis Hall of Fame, Meadow Creek Tennis and Fitness Club,  Ted Coulter, Kevin Ankenbauer, Greg Skyoldal, Barbara Ammann Coulter, Chantelle Noel Yates, Mellisa Gale Yeates, Stephen Anthony Yates, Yvett Coulter, Christian Coulter, Yvette Yates, Roger Ward Moving San Antonio Inc.,  Colorado First Judicial District, Charles Pratt, Judge Charles Pratt, Christopher Cross, Judge Christopher Cross,  M. Edward Burns, Magistrate M. Edward Burns, Catherine I. Burns, Catherine Irvine Burns, Megan Alexandra Burns, Otasha Tasha Karam, Tammy Herivel, Colorado 18th Judicial District, Colorado Appellate Court, Jane Bailey, Colorado Appellate Court Staff Attorneys,  Jane Bailey, Esq., Bruce Bailey, Ann Bailey, Chief Justice Alan Loeb, Karen Loeb, Roine Loeb, Ralph Loeb, Rachael Loeb,  John Berman, Esq,  Marjorie Berman, Stephen Berman, David Berman, Lawrence Berman, Joshua Berman, Sam Berman, Marlene John, Weiner Zerobnick, Fannie Zerobnick, JoAnna Goddard Esq., Goddard and Goddard, Olinger Crown Hill Mortuary and Cemetery, Olinger Crown Hill, Dignity Memorial, John Logan,  Dzen Filipek, Denver Consistory, Scottish Rite Foundation of Colorado, Vernon B. Ingraham, Lee E. Schlessman, Karl J. Hinkle, Richard G. Frohlick, John W. Groves, Gerald A. Ford, Thomas R. Magnuson, Most Worshipful Grand Lodge of Ancient Free & Accepted Masons of Colorado,  Supreme Council of the Southern Jurisdiction, Supreme Council of the Northern Jurisdiction, Herbert Buchwald, 333 Havana Inc., Tri-Havana, John Gleason, Alex Martinez, Supreme Court Justice Alex Martinez, Brent Evans, Patty Evans, G. Raymond Goodwin, Jesse Aragon, Patti Aragon, Dignity Memorial, William Logan,  Olinger Crown Hill Mortuary and Cemetery, Herb Buchwald, William A. Powers, Esq., Bill Powers, Judge Alex Martinez, Alex Martinez, Christopher T. Ryan.

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#3 Author of original report

Colorado Appeals Court. Jane Bailey, as staff attorney, writes anonymous Order

AUTHOR: Leges sine moribus vanae. - ()

Court of Appeals, State of Appeals

2 East 14th Ave.

Denver, Colorado 80203

303 861-1111

___________________________________________________

Jefferson County

2010PR210            (also concerning 2013PR56)

In the Matter of the Estate of

 

Irene C. Coulter, Deceased,

 

And

 

Appellant:

 

PETER COULTER,

 

v.

 

Appellees:

 

PAULA COULTER;

 

TED COULTER.;

 

JOHN BERMAN, ESQ.

 

 

FILED IN THE COLORADO COURT OF APPEALS NOVEMBER 7, 2013

 

 

 

 

 

 


COURT USE ONLY

PETER COULTER, interested party, heir, pro se

 

151 Summer Street #654 Morrison Colorado 80465

 

Phone Number: 303 720-1811

 

E-mail:AUDIONLY@GMAIL.COM

 

Court of Appeals

Case Number:

 

2013CA1453

 

 

AMENDED MOTION TO VOID PAULA COULTER’S POWER OF ATTORNEY AND ALL ORDERS AND FINDINGS OF THE DISTRICT COURT, FORENSIC AUDIT, RESTITUTION, ATTORNEY FEES, COSTS AND SANCTIONS OR ALTERNATIVELY  FOR LEAVE AND  REMAND TO THE DISTRICT  COURT PURSUANT TO CRCP RULE 60

 

 

 

Court of Appeals, State of Appeals

2 East 14th Ave.

Denver, Colorado 80203

303 861-1111

___________________________________________________

Jefferson County

2010PR210      (also concerning 2013PR56)

In the Matter of the Estate of

 

Irene C. Coulter, Deceased,

 

And

Appellant:

PETER COULTER,

 

v.

 

Appellees:

PAULA COULTER;

TED COULTER;

John Berman, Esquire.

 

 

 

 

 

 

 

 

COURT USE ONLY

PETER COULTER, interested party, heir, pro se

151 Summer Street #654 Morrison Colorado 80465

Phone Number: 303 720-1811

 E-mail:AUDIONLY@GMAIL.COM

Court of Appeals

Case Number:

 

2013CA1453

 

 

CERTIFICATE OF COMPLIANCE

 

 

I hereby certify that this brief complies with all requirements of C.A.R. 28 and C.A.R. 32, including all formatting requirements set forth in these rules.  Specifically, the undersigned certifies that:

 

The brief complies with C.A.R. 28(g).

 

X It does not exceed 30 pages.

 

The brief complies with C.A.R. 28(k).

               x For the party raising the issue:

It contains under a separate heading (1) a concise statement of the applicable standard of appellate review with citation to authority; and (2) a citation to the precise location in the record (R.      , p.          ), not to an entire document, where the issue was raised and ruled on.

              

  XI acknowledge that my brief may be stricken if it fails to comply with any of the requirements    of C.A.R. 28 and C.A.R. 32.

 

 

   /s/ Peter Coulter_________  __                          

Signature of attorney or party                              

 

 COMES NOW the Appellant Peter Coulter, pro se, for his Amended Motion to void Paula Coulter’s April 21, 2006 power of attorney as Fraud upon the Court and all orders and findings thereof; complete joint restitution of Mrs. Coulter’s assets from 2004 to the present by the Appellees; perjury, abuse of a person at risk; attorney fees, costs; sanctions and recommendation of criminal proceedings pursuant to C.R.C.P. Rule 60;Relief from Judgment or Order; C.R.S.§18-8-502, Perjury in the first degree; C.R.S. §18-8-610,Tampering with physical evidence; C.R.S. §26-3.1Financial exploitation of at-risk adults; C.R.S. §18-9-113,Desecration of a venerated object; and C.R.S. §15-12-723, Assets concealed or embezzled; and as good cause would state as follows:

 

  1. I.       CERTIFICATION
  2. PURSUANT TO C.R.C.P. 121 § 1-15(8) No party has made an entry of appearance into this case other than the Appellant. In a September 24, 2013 Email regarding this Appeal, Mr. Berman stated to the Appellant when asked about this requirement: “I oppose these Motions as well as your entire proceeding.
  3.  Because of the relevance and importance of this Motion, Movant will forward courtesy copies to all parties listed in ¶17 below, in addition to all parties of In Re: Irene Coulter (deceased); 2010PR204 and 2013PR56, Jefferson County District Court.
    1. II.      COMPLIANCE WITH C.A.R. 28(k)
    2. This C.R.C.P. Rule 60(Relief from Judgment or Order)(See pg. 11 for recital of Rule.) Motion arises after the October 23rd, 2013 discovery of a subsequent Power of Attorney dated June 19,2006, naming Ted Coulter as sole agent for Irene Coulter; invalidated the April 21, 2006 Power of Attorney for Irene Coulter that Paula Coulter fraudulently produced to various persons, entities and the Court (with the assistance of John Berman, Esq., an officer of the Court) to persuade them that she/they were acting on behalf of their fiduciary, Mrs. Coulter, via said Power of Attorney. C.R.C.P. Rule 60(b)(2) gives the Court explicit authority and jurisdiction to relieve parties such as the Appellant from Judgments, Orders or Proceedings where adverse parties, such as Paula Coulter, her counsel, John Berman and brother Ted Coulter committed continued Fraud and/or Fraud on the Court. Specifically, (but not exclusively) obtaining the Conservatorship and Guardianship of Irene Coulter through a perjured sworn Petition where Paula Coulter affirms that the void and fraudulent Power of Attorney dated April 21, 2006 gave her fiduciary precedence in being Conservator and Guardian for Mrs. Irene Coulter.

 

  1. III.    CASE CITATION
  2. In light of John Berman Esquire’s role in these proceedings; the Appellant requests the Court ORDER that his name be added to the case citation as an Appellee in addition to Paula and Ted Coulter.
    1. IV.      PRO-SE LITIGANT
    2. In Puckett v. Cox, it was held that a pro-se pleading requires less stringent reading than one drafted by a lawyer (456 F2d 233 (1972 Sixth Circuit USCA). Justice Black in Conley v. Gibson, 355 U.S. 41 at 48 (1957) "The Federal Rules rejects the approach that pleading is a game of skill in which one misstep by counsel may be decisive to the outcome and accept the  principle that the purpose of pleading is to facilitate a proper decision on  the merits." According to Rule 8(f) FRCP and the State Court rule which holds that all pleadings shall be construed to do substantial justice." Peter Coulter, the Appellant, is a pro-se litigant in these matters and would request that the Court take this into consideration when making its findings and rendering its decision(s).

 

  1. V.       REFERENCES
  2. The Appellant reference his Motion for Leave to Restore Record with Addendums filed October 10, 2013 as though fully rewritten herein.

 

COLORADO ATTORNEY OATH OF ADMISSION

I DO SOLEMNLY SWEAR by the Everliving God (OR AFFIRM) that:

I will support the Constitution of the United States and the Constitution of the State of Colorado;  I will maintain the respect due to Courts and judicial officers;  I will employ only such means as are consistent with truth and honor;  I will treat all persons whom I encounter through my practice of law with fairness, courtesy, respect and honesty; I will use my knowledge of the law for the betterment of society and the improvement of the legal system; I will never reject, from any consideration personal to myself, the cause of the defenseless or oppressed; I will at all times faithfully and diligently adhere to the Colorado Rules of Professional Conduct.

 
 

  1. VI.      BACKGROUND
  2. On February 18, 2010, Paula Coulter and John Berman, Esq., her attorney,  filed a sworn Petition requesting appointment as Conservator and Guardian for Irene Coulter in 2010PR204, Jefferson County District Court.  See Addendum 1.
  3. ¶8 of said Petition states as follows:

 

  1. ¶10 of said Petition states in pertinent part as follows:

 

 10. Said information is sworn to by Paula Coulter in the following jurat:

 

 11. C.R.S. 18-8-502. Perjury in the first degree, provides as follows:

(1)          A person commits perjury in the first degree if in any official proceeding he knowingly makes a materially false statement, which he does not believe to be true, under an oath required or authorized by law.

(2)           Knowledge of the materiality of the statement is not an element of this crime, and the defendant's mistaken belief that his statement was not material is not a defense, although it may be considered by the court in imposing sentence.

(3)      Perjury in the first degree is a class 4 felony.

 

C.R.S. 18-8-610. Tampering with physical evidence provides as follows:


(1) A person commits tampering with physical evidence if, believing that an official proceeding is pending or about to be instituted and acting without legal right or authority, he:

(a) Destroys, mutilates, conceals, removes, or alters physical evidence with intent to impair its verity or availability in the pending or prospective official proceeding; or

(b) Knowingly makes, presents, or offers any false or altered physical evidence with intent that it be introduced in the pending or prospective official proceeding.

(2) "Physical evidence", as used in this section, includes any article, object, document, record, or other thing of physical substance.

(3) Tampering with physical evidence is a class 6 felony.

 

  1. 12.      The afore mentioned Financial and Medical Power of Attorney of Paula Coulter dated April 21, 2006 are attached. See Addendum 2
  2. Paula Coulter (with assistance at times by John Berman, Esq.) exclusively used this April 21, 2006 Power of Attorney as fiduciary agent for Mrs. Coulter including:
  • To fraudulently act as Mrs. Coulter’s agent for Mrs. Coulter’s accounts at Smith Barney and later Morgan Stanley since 2006 which to the best of Appellants knowledge exceeded $500,000;
  • To fraudulently act to return the joint account of Sheryl Powers and Sheryl Powers, (Irene Coulter’s favorite daughter, best friend and caretaker) into Irene Coulter’s sole account in the approximate amount of $75,000 without knowledge or consulting of any other family members or Mrs. Coulter’s attorney and son in law of 30 years, William A. Powers, Esq. and thereafter removing it in the form of “gifts” to Ted and Paula Coulter at Paula Coulter’s direction.
  • To fraudulently sell/donate Mrs. Coulter’s car;
  • To fraudulently place Mrs. Coulter into Atria Center;
  • To fraudulently and flagrantly “gift” Paula Coulter and Ted Coulter a minimum[1] of $190,000 between the years of 2006 and 2010, contrary to the past history and gifting habits of Irene Coulter and without knowledge or consultation of any other family members or Mrs. Coulter’s attorney, William Powers.
  • To fraudulently act as Mrs. Coulter’s agent in dealing with the Colorado Division of Mines in dealing with Mrs. Coulter’s largest asset, a 3/4 interest in 400 acres owned jointly with Richard Vento through an LLC (South Central Land and Mining).
  • To fraudulently profess to the Court in Mrs. Coulter’s current probate hearing (2013PR56 Jefferson County) that the Will Paula Coulter provided is valid because the April 21, 2006 Power of Attorney was previously found valid by the District Court.[2]
  • To flagrantly and shamelessly desecrate the remains of Leland Coulter who had been laid at peace for 22 years, by John Berman, Esq. filing a fraudulent, misleading and outrageous Forthwith Motion with the District Court in 2013PR56.
  • To fraudulently and continually withhold essential financial information from interested parties despite requests and direct Orders to do so. The Appellant believes this was/is intentionally done to hide further criminal actions by the Appellees. The result today is that there is not an accounting of Mrs. Coulter’s assets or how much Paula Coulter, Ted Coulter and John Berman have decimated them[3]. It should be noted that John Berman was sanctioned before by the Colorado Supreme Court for failing to provide a professional invoice. In the instant case, despite numerous requests, he has again refused to ever (emphasis added) provide a professional invoice despite extravagant requests to the Court for attorney’s fees in managing Mrs. Coulter’s affairs.
  • And most ad rem here, Paula Coulter, her attorney John Berman and Ms. Coulter’s brother Ted Coulter, to act with Fraud, Fraud on the Court and Conspiracy to commit Fraud on the Court in submitting a sworn Petition relying on Paula Coulter’s April 21, 2006 Power of Attorney, filed with the Jefferson County District Court; to be Mrs. Coulter’s Fiduciary Conservator and Guardian and purposely and fraudulently concealing Ted Coulter’s subsequent and exclusive power of attorney that was obtained 3 years after police reports indicated Mrs. Coulter clearly had dementia and not cognizant to sign any documentation.

 VII.    CONCEALED SUBSEQUENT POWER OF ATTORNEY

 14.      Discovered October 25, 2013, the Appellant presents to this Court a subsequent Power of Attorney (emphasis added) to the one allegedly signed on April 21, 2006. Said Power of Attorney is signed by Mrs. Coulter and notarized; giving exclusive Power of Attorney and authority to Theodore Coulter. It is dated June 19, 2006, 59 days after the Power of Attorney that Paula Coulter has since been fraudulently presenting to parties as evidence of her authority to fraudulently steal (along with Ted Coulter and John Berman) assets from their Fiduciary, their own Mother, Irene Coulter. See Addendum 3.

  1. 15.      Said June 19, 2006 notarized power of attorney states in pertinent part:

“This durable power of attorney shall be non-delegable and shall be valid until such time as I die”

 16.      Said Fiduciary power of attorney revokes Paula Coulter’s previous Fiduciary Power of Attorney and any acts Paula Coulter transacted for Irene Coulter after June 19, 2006 are both void and fraudulent including the submission of her Sworn Petition to the Jefferson County District Court to be Mrs. Coulter’s Conservator and Guardian.

    1. 17.      Ted Coulter used his subsequent exclusive Fiduciary Power of Attorney as agent to sell Mrs. Coulter’s[4] home by Warranty Deed and no Title Insurance for $275,000 to a suspect investor who immediately turned around and sold it for $274,000 by Warranty Deed without Title Insurance. See Addendum 4.[5] The Appellant believes that the investor received a kickback from Ted Coulter but has been unable to prove that because Paula Coulter continually refuses to turn over detailed financial documents despite numerous requests and Court Orders[6]. It raises the question of why would anyone buy a property for $275,000 and two months later sell it for $274,000 without a title policy being provided?
    2. 18.      Neither Paula Coulter, her attorney John Berman or Ted Coulter ever disclosed to anyone, including the Court, that there was a subsequent Power of Attorney that made Paula Coulter’s April 21, 2006 Power of Attorney invalid. Paula Coulter was well aware of the subsequent Power of Attorney as personnel at Atria have informed the Appellant that Ted Coulter brought a “mobile Notary” to Mrs. Coulter’s room and had her sign the document. Paula Coulter was incensed and for a time gave explicit instructions to the staff of Atria that in addition to Peter Coulter, Ted Coulter was not to be allowed in Mrs. Coulter’s room alone with her. Paula Coulter was protecting her “gold mine”; not caring and nurturing her.[7]
    3. 19.      The record shows that Paula Coulter and her attorney John Berman brought Paula Coulter’s Power of Attorney up continually to the Court boasting her authority for every action including Paula Coulter’s authority (with Ted Coulter’s express approval and John Berman’s Fraudulent Motion) to shamelessly desecrate our Father, Leland Coulter’s remains.[8]

 

VIII. DISCUSSION

C.R.C.P. Rule 60, Relief from a Judgment or Order provides:

 

(a). Clerical Mistakes. Clerical mistakes in judgments, orders, or other parts of the record and errors therein arising from oversight or omission may be corrected by the court at any time of its own initiative or on the motion of any party and after such notice, if any, as the court orders. During the pendency of an appeal such mistakes may be so corrected before the case is docketed in the appellate court, and thereafter while the appeal is pending may be so corrected with leave of the appellate court.

(b) Mistakes; Inadvertence; Surprise; Excusable Neglect; Fraud; etc. On motion and upon such terms as are just, the court may relieve a party or his legal representative from a final judgment, order, or proceeding for the following reasons: (1) Mistake, inadvertence, surprise, or excusable neglect; (2) fraud (whether heretofore denominated intrinsic or extrinsic), misrepresentation, or other misconduct of an adverse party; (3) the judgment is void; (4) the judgment has been satisfied, released, or discharged, or a prior judgment upon which it is based has been reversed or otherwise vacated, or it is no longer equitable that the judgment should have prospective application; or (5) any other reason justifying relief from the operation of the judgment. The motion shall be made within a reasonable time, and for reasons (1) and (2) not more than six months after the judgment, order, or proceeding was entered or taken. A motion under this section (b) does not affect the finality of a judgment or suspend its operation. This Rule does not limit the power of a court: (1) To entertain an independent action to relieve a party from a judgment, order, or proceeding, or (2) to set aside a judgment for fraud upon the court; or (3) when, for any cause, the summons in an action has not been personally served within or without the state on the defendant, to allow, on such terms as may be just, such defendant, or his legal representatives, at any time within six months after the rendition of any judgment in such action, to answer to the merits of the original action. Writs of coram nobis, audita querela, and bills of review and bills in the nature of a bill of review, are abolished, and the procedure for obtaining any relief from a judgment shall be by motion as prescribed in these rules or by an independent action.

 19.      The final District Court Order in 2010PR204 was issued June 23, 1013 and this C.R.C.P Rule 60 Motion is filed this October 30, 2013; well within the 6 month time frame mandated by C.R.C.P. Rule 60.

  1. 20.      As highlighted above, C.R.C.P. Rule 60(b)(2) specifically addresses Fraud and Fraud on the Court as adequate reasons for relief. Once a valid judgment is entered, the only means by which the trial court may thereafter alter, amend, or vacate the judgment is by appropriate motion under either C.R.C.P. 59 or this rule. Cortvriendt v. Cortvriendt, 146 Colo. 387, 361 P.2d 767 (1961). Authority for relief from a judgment order or proceeding is conferred in an appropriate proceeding by section (b) of this rule. Peercy v. Peercy, 154 Colo. 575, 392 P.2d 609 (1964).
  2. 21.              FRAUD occurs when all of the following elements exist:

1.)     an individual or an organization intentionally makes an untrue representation about an important fact or event:

Paula Coulter with the assistance of her attorney John Berman, made an untrue representation about her invalid Power of Attorney to parties, including the Court who relied on said Fiduciary P.of A. as Paula Coulter’s authority to represent Mrs. Irene Coulter. Further, they purposely concealed the subsequent Power of Attorney in violation of C.R.S. 18-8-502 and 18-8-610; class 4 and class 6 felonies.

2.)     the untrue representation is believed by the victim (the person or organization to whom the representation has been made;

Everyone, including the Court believed Paula Coulter’s assertion that she had Power of Attorney under the April 21, 2006 document.

3.)     the victim relies upon and acts upon the untrue representation;

The following all relied on Paula Coulter’s fraudulent assertion that she had a valid Power of Attorney for the affairs of Irene Coulter:

Smith Barney, Colorado Division of Mines, Wells Fargo Bank, Sheryl Powers Estate, Marty Powers, William Powers, Esq., Jean Powers, Esq. Lora Powers, Olinger Crown Hill Cemetery, the City of Florence, Colorado,(Highlands Cemetery) Colorado Department of Mines, Dr. Cobb, (Mrs. Coulter’s doctor) Atria Center, South Central Land and Mining, Dick Vento (partner of Irene Coulter), Linda Saunders and Bertina (co-owners of land in Fremont County) court witnesses Marie Perigren(sp) and Martha and John Saviers, Esq.; and especially  the Court all relied upon the fraudulent and sworn representations of Paula Coulter and her attorney, John A. Berman, Esq. that Paula Coulter had a valid Power of Attorney, when in fact she knew she didn’t.

4.)     the victim(s)  suffer(s)  loss of money and/or property as a result of relying upon and acting upon the untrue representation.

Through Paula Coulter, Ted Coulter and John Berman’s  fraudulent misrepresentations, hundreds of thousands of dollars has either been misappropriated or is missing from Irene Coulter’s accounts[9]. Additionally, Mrs. Coulter’s largest asset (3/4 interest in 400 acres) is unaccounted for. And the most shameless act was the movement and desecration of our Father, Leland Coulter’s remains.

 

  1. 22.      As an aggravating circumstance, it must be brought to the Court’s attention that 3 years before either of these 2 Powers of Attorney were signed, there were 27 police reports [See Addendum 5] of Mrs. Coulter believing neighbors were coming in through her front door keyhole, molesting her cat and stealing her food. She was clearly demented and Paula and Ted Coulter both shoved Fiduciary Powers of Attorney and a Will in front of her and had her sign them without her knowing what she was signing. They took advantage of a person at risk who happened to be their own Mother. They were/are both so greedy that they were each even willing to sabotage each other to get Irene Coulter’s entire assets.
  2. 23.      "Fraud upon the court" has been defined by the 7th Circuit Court of Appeals to "embrace that species of fraud which does, or attempts to, defile the court itself, or is a fraud perpetrated by officers of the court so that the judicial machinery cannot perform in the usual manner its impartial task of adjudging cases that are presented for adjudication." Kenner v. C.I.R., 387 F.3d 689 (1968); 7 Moore's Federal Practice, 2d ed., p. 512, ¶ 60.23. The 7th Circuit further stated "a decision produced by fraud upon the court is not in essence a decision at all, and never becomes final.
  3. 24.      Paula Coulter’s attorney, John Berman, Esq. (who is currently under suspension/probation with the Colorado Supreme Court[10]) presented the Original sworn Petition and a plethora of other Motions and Document’s using the fraudulent Power of Attorney of April 21, 2006. He is even using it in the current Probate case to justify that since the Court previously found Paula Coulter’s P.of A. OK, that the Will should be OK also and not subject to collateral attack. And most flagrantly, he used the P.of A. to help desecrate the remains of Leland Coulter by filing a Forthwith Motion with the Court and misleading it with incorrect statutes and the April 21, 2006 power of attorney. He has clearly and continually committed Fraud on the Court.
  4. 25.      "Fraud upon the court" makes void the orders and judgments of that court.  It is also clear and well-settled  law that any attempt to commit "fraud upon the court" vitiates the entire proceeding. The People of the State of Illinois v. Fred E. Sterling, 357 Ill. 354; 192 N.E. 229 (1934) ("The maxim that fraud vitiates every transaction into which it enters applies to judgments as well as to contracts and other transactions."); Allen F. Moore v. Stanley F. Sievers, 336 Ill. 316; 168 N.E. 259 (1929) ("The maxim that fraud vitiates every transaction into which it enters ..."); In re Village of Willowbrook, 37 Ill.App.2d 393 (1962) ("It is axiomatic that fraud vitiates everything."); Dunham v. Dunham, 57 Ill.App. 475 (1894), affirmed 162 Ill. 589 (1896); Skelly Oil Co. v. Universal Oil Products Co., 338 Ill.App. 79, 86 N.E.2d 875, 883-4 (1949); Thomas Stasel v. The American Home SecurityCorporation, 362 Ill. 350; 199 N.E. 798 (1935). When any officer of the court has committed "fraud upon the court", the orders and judgment of that court are void, of no legal force or effect. A court may at any time set aside a judgment for after discovered fraud upon the court. Hazel-Atlas Glass v. Hartford, 322 US 238, 64 S. Ct. 997, 88 L. Ed. 1250 - Supreme Court, 1944. Out of deference to the deep rooted policy in favor of the repose of judgments... courts of equity have been cautious in exercising their power [in upsetting judgments]. But when the occasion has demanded, where enforcement of the judgment is 'manifestly unconscionable' . . . they have wielded the power without hesitation." Hayden v. Rumsey Products, 196F.Supp.988 (W.D.N.Y. 1951).
  5. 26.      Where the relevant facts are undisputed, an appellate court may make an independent determination as a matter of law. See People v. Miranda–Olivas, 41 P.3d 658, 661 (Colo. 2001). Here, the undisputed facts establish such fraud as a matter of law. See Aoude v. Mobil Oil Corp., 892 F.2d 1115, 1118 (1st Cir.1989)(“A ‘fraud upon the court’ occurs where it can be demonstrated, clearly and convincingly, that a party has sentiently set in motion some unconscionable scheme calculated to interfere with the judicial system’s ability impartially to adjudicate a matter by improperly influencing the trier or unfairly hampering the presentation of the opposing party's claim or defense.”).  In re C.L.S., 252 P.3d 556, 561 (Colo. App. 2011) cert. denied, 11 SC 261, 2011 WL 2535031 (Colo. June 27, 2011), Therefore, Appellant is entitled to relief under the “fraud upon the court” provision of Rule 60(b).
    1. 1.  MALICE, WILLFULL AND WANTON CONDUCT
    2. 27.      In Colorado, exemplary damages are only available by statute. See Corbetta v. Albertson’s, Inc., 975 P.2d 718, 721 (Colo. 1999). Before a judge may impose exemplary damages, it must determine that the “injury complained of” was “attended by circumstances of fraud, malice, or willful and wanton conduct,” § 13-21-102(1)(a), which must be proved beyond a reasonable doubt, § 13-25-127(2), C.R.S. (2010). Willful and wanton conduct is defined as

conduct purposefully committed which the actor must have realized as dangerous, done heedlessly and recklessly, without regard to consequences, or of the rights and safety of others, particularly the plaintiff.

  1. Subsection 13-21-102(1)(b) of the statute complies with the holding in Philip Morris, 549 U.S. at 357 to the extent it permits the jury to consider the “rights and safety of others” in assessing the willful and wanton nature (i.e. the reprehensibility) of the defendant’s conduct. In Philip Morris, the U.S. Supreme Court explained that a jury may consider harm to nonparties when gauging the “reprehensibility” of the defendant’s actions. Id. at 357 (“[W]e recognize that conduct that risks harm to many is likely more reprehensible than conduct that risks harm to only a few. And a jury consequently may take this fact into account in determining reprehensibility.”). This holding built upon the Court’s prior decision in State Farm which directed trial courts to consider whether the defendant’s conduct evinced “reckless disregard of the health or safety of others” when assessing the reprehensibility of a defendant. 538 U.S. at 419. Here, the statute cabins the jury’s consideration of a defendant’s disregard for “the rights and safety of others” to the narrow task of gauging “willful and wanton conduct.” See §13-21-102(1)(b). By listing harm to nonparties as a factor in assessing reprehensibility, the statute complies with the due process limitations on exemplary damages set forth in both Philip Morris and State Farm. See e.g., Grefer v. Alpha Technical,965 So.2d 511, 517 (La. App. 4th Cir. 2007). Thus, because the statute permits a jury to consider harm to non­parties only for the purpose of assessing whether the defendant’s conduct is willful and wanton, it is not unconstitutional.
  2. The Wilfull and Wanton actions and Fraudulent behavior of Paula Coulter, Ted Coulter and John Berman continued for at least 7 years culminating in a planned scheme to commit Fraud on the Court and violate the due process rights of numerous parties including Irene Coulter, Leland Coulter, Peter Coulter, heirs, partners of Irene Coulter and subsequent owners of Irene Coulter’s property. Mr. Berman’s shameless behavior toward the Appellant was/is incessant. He would fail to send copies of Orders and Motions; fail to notify the Appellant before submitting a proposed Order that was Ordered by the Court; send encrypted Motions for attorney fees that ended up in the spam folder; never providing the Appellant with a Professional Invoice of his services (emphasis added) Never providing detailed Conservator invoices and those he did provide were at times off by $90,000 with no explanation. Never complying with Court Orders to provide the Appellant with detailed Conservator reports; the result being that no one but Paula Coulter,
    Ted Coulter and John Berman know Irene Coulter’s true financial and medical condition. And the most abhorrent act of Mr. Berman was filing a Fraudulent and Misleading Motion in 2013PR56 where he stated that Paula Coulter had the authority as the prescribed Personal Representative (from a Fraudulent Will and Power of Attorney) to dig up[11] and desecrate the remains of Leland Coulter who had been laid to rest 22 years earlier in the Coulter family plot at Olinger Crown Hill Cemetery. There acts shock the conscience.
  3. Ted and Paula Coulter hatched a scheme sometime back in the turn of the century to take advantage of an at-risk person, our Mother, Irene Coulter. Further, they decided to do it at the detriment of Peter Coulter who they later refused to let see his Mother for the sole despicable purpose of protecting their “gold mine”. They kept this act up throughout the Conservator and Guardianship case (2010PR204) and have continued in Mrs. Coulter’s current Probate case (2013PR56). As in the Conservator case; Mr. Berman refuses to provide a list of Assets of Irene Coulter even though the record indicates at least 10 different e-mail requests that went unanswered. The only possible reason for this is to cover more criminal acts by the Appellees.[12]
  4. In 2011, the Colorado Legislate became alarmed with the Probate Court procedures; did an Audit[13] of the Probate Court system and made many proposals to prevent neglect and fraud in the Courts. Chief Justice Michael Bender signed off on those proposals and implemented them into the Colorado Court system. A review of those directives was brought to the attention of the District Court and Mr. Berman on numerous occasions. John Berman, as an officer of the Court, elected to ignore all of them without exception. Most flagrant was his continued act of refusing to provide a comprehensive and detailed Conservator report including Professional Invoices; when requested and/or Ordered constituting further Fraud on the Court.
  5. Ted Coulter, Paula Coulter and John Berman willfully, wantonly and maliciously decimated the assets of an at risk adult, my Mother, Mrs. Irene Coulter and then proceeded to shamelessly desecrate the remains of my Father, Leland Coulter.
    1. X.       C.R.S. 26-3.1 PROTECTIVE SERVICES

 FOR ADULTS AT RISK OF MISTREATMENT

 

  1. (a.5) As required by section 18-6.5-108, C.R.S., certain persons specified in paragraph (b) of this subsection (1) who observe the abuse or exploitation of an at-risk elder, as defined in section 18-6.5-102 (1) and (10), C.R.S., or who have reasonable cause to believe that an at-risk elder has been abused or exploited or is at imminent risk of abuse or exploitation shall report such fact to a law enforcement agency not more than twenty-four hours after making the observation or discovery.

(b) The following persons, whether paid or unpaid, are urged to report as described in paragraph (a) of this subsection (1):

 

(XII) COURT-APPOINTED GUARDIANS AND CONSERVATORS;

 

  1. Under C.R.S. 26 3.1, Paula Coulter, as Court appointed guardian and conservator, was required to report the abuse and exploitation of Irene Coulter by herself, Ted Coulter and John Berman to a law enforcement agency. The record shows she never did. Neither did Paula Coulter or Ted Coulter. But the record shows that Peter Coulter reported Paula Coulter’s abuse to Jefferson County Social Services.
  2.  

 

 

 XIII.   CONCLUSION

        It is self-evident from the evidence presented here by the Appellant that Paula Coulter, Ted Coulter and Paula Coulter’s attorney committed Fraud, Fraud on the Court, Conspiracy to Commit Fraud, Conspiracy to Commit Fraud on the Court, Concealment of evidence; Theft from a person at risk; desecration of a venerated object, Violations of numerous Attorney Code of Professional Conduct, Abuse of Fiduciary Duty, and numerous violations of Supreme Court Directives and Legislative Audits (2011) They kept this Fraud up for at least 6 years without any remorse. And they did it to their own Mother and Father who they swore to protect as their Fiduciaries. Their acts are shameless and shock the conscience. The Court needs to make an example of them so that this does not happen again by implementing punitive damages in addition to full restitution, costs and attorney fees.

 

WHEREFORE, the Appellant Peter Coulter would pray the Court grant relief as a matter of law and find:

ThatJohn Berman Esq. Paula Coulter and Ted Coulter committed Fraud, Fraud on the Court and Conspiracy to Commit Fraud on the Court;

That the April 21, 2006 Power of Attorney and Will are fraudulent and void;

That the June 19, 2006 Power of Attorney is fraudulent and void.

That Ted Coulter, Paula Coulter and John Berman committed Fraud on a person at risk, Mrs. Irene Coulter;

That Ted Coulter, Paula Coulter and John Berman’s fraudulent actions were Willfull, Wanton and Malicious and therefore the Appellant is entitled to Joint Punitive Damages equal to the sum of all funds taken from Mrs. Coulter, costs, and attorney fees.

That as a direct result of Paula Coulter’s and Ted Coulter’s fraudulent actions; they are not entitled to any of Mrs. Coulters assets.

ORDER that John Berman’s name be added to this case cite as an Appellee;

ORDER that Leland Coulter’s remains be Forthwith returned to their original resting place and all costs be paid by the Appellees jointly; and further, that Irene Coulter be disinterred from the Florence, Colorado cemetery and placed next to her husband in the Coulter family plot in Olinger Crown Hill Cemetery where she always believed was her final resting place;

ORDER a complete and thorough 3rd party forensic accounting of all of Paula Coulter’s, Ted Coulter and his wife Barbara Coulter, John Berman’s and Irene Coulter assets, including tax returns, checking and saving accounts, invoices, property and any other financial, personal and real estate documentation from 2000 to the present date to be paid by Appellees jointly;

ORDER that Paula Coulter, Ted Coulter and his wife Barbara Coulter and John Berman fully cooperate with any parties executing said forensic accounting;

ORDER that as a result of these unconscionable frauds; Peter Coulter and numerous other parties and heirs were severely hampered in presenting their case(s) And as a result of these flagrant Frauds on the Court, all the Orders and Judgments of the District Court in 2010PR204 AND 2013PR56 are void and of no legal effect;

ORDER that the Appellees jointly pay restitution for all monies, funds, property, stocks, real estate, costs, rents, attorney fees and any other assets of Mrs. Irene Coulter be paid back in full

ORDER that all attorney fees and costs of Appellant (including time spent filing, writing, responding and researching John Berman’s Motions at the same rate of $250 per hour that John Berman charged for fraudulent attorneys fees.)

ORDER that the Appellees be reported to Social Services and Law Enforcement Agencies for criminal prosecution of their action;

ORDER that Paula Coulter be forthwith removed as Personal Representative of Irene Coulter;

ORDER that Paula Coulter, John Berman and any other party who has any documentation, assets, or any other belongings of Irene Coulter be forthwith placed in the custody  and registry of the Court until such time as a new Personal Representative can be named;

ORDER that Peter Coulter be Forthwith named as Personal Representative of Irene Coulter in 2013PR56.

ORDER that none of the Appellees, Ted Coulter, Paula Coulter or John Berman may dispose, transfer, sell or donate any of their property or assets until such time as the Forensic Audit of Mrs. Coulter can be completed and Restitution thereof fully reimbursed by the Appellees;

And for such further Orders as the Court deems just and necessary to restore the dignity of the Court; the full restitution of an at risk adult, Mrs. Irene Coulter; and the sanctity and respect of Mr. Leland Coulter,

Or ALTERNATIVELY, for an Order to Remand to the Jefferson County District Court for further proceedings consistent with this Court’s findings and Orders.

Respectfully submitted and dated this November 7, 2013,

 

/s/ Peter Coulter

5 Attachments/Addendums

 

Certificate of Service

I certify that on November 7, 2013 a copy of the above Document and was served on each of the following by hand delivery, faxed, first class mail or E-mail:

 

Name of Person to Whom you are Sending this Document

Relationship

Address

Manner of Service*

JOHN BERMAN, ESQ.

ATTORNEY FOR PAULA COULTER,

JAB@JABERMAN.COM

E-MAIL

TED COULTER

SON

TED.COULTER@WARDNORTHAMERICAN.COM

E-MAIL

JEAN POWERS, Esq.

HEIR

 

E-MAIL

LORA POWERS

HEIR

 

E-MAIL

MARTY POWERS

HEIR

 

E-MAIL

WILLIAM POWERS, Esq.

HEIR

 

E-MAIL

Jefferson County District Court    

Olinger Crown Hill Cemetery

Florence Cemetery

Morgan Stanley

Atria

Linda Saunders

Richard Vento

John Williams

Colorado Dept. of Mining

James and Lora Perry

Sheryl Powers Estate

John and Martha Saviers, Esq.

Mrs. Marie Perigren

JoAnne Goddard, Esq.

Freemont County Commissioners

Energy Fuels

Legislative Committee on Judicial Probate Audit

Colorado Supreme Court

 

 

 

2010pr204 and 2013pr56

Hand Del.

 

 

E-MAIL

 

 

 

 

 

 

 

 

 

 

 

 

 

Mail

Mail

         

 

*Insert one of the following:  Hand Delivery, First-Class Mail, Certified Mail, E-Served or Faxed.

 

                                                                                                                       

 

/s/ Peter Coulter



[1] Paula Coulter has had custody of Irene Coulter’s financial records since at least 2005. The record indicates that even though requested and ORDERED to provide complete financials; to date that has never happened. The $190,000 is all Peter Coulter could piece together from information obtained and believes the figure is much higher than that.

[2] See 2013PR56 In re Irene Coulter. Personal Representatives Motion to dismiss Peter Coulter and Marty Powers Objection to Will; ¶8.

[3] While there have been numerous Conservator reports; all, without exception, do not meet accounting and probate rules. They are just numbers on a page with no  backup documentation as required by statute.  Although the record shows that John Berman was paid at least $40,000 in attorney’s fees; he has not provided one professional invoice; an act for which he has been previously sanctioned by the Colorado Supreme Court.  (See Colorado Supreme Court v. Berman 11PDJ078 previous admissions of misconduct.) The record shows that the Appellant found errors in excess of $90,000 in some reports. And despite requirements to provide a list of Mrs. Coulters assets in her current probate case (2013PR56; Jefferson County District Court) the Appellant and other heirs have made no less than 10 separate requests to which Mr. Berman either did not respond or refused to provide a list of assets. Further, despite protest from the Appellant to the Court, Paula Coulter has continued to have a joint account with Mrs. Coulter in violation of Probate Rules making it impossible  to know if funds were being siphoned off by Paula Coulter. A flagrant example of the abuse of this joint account was an entry for $130 to Camping World.  It begs the question, What would a 90 year old woman with stage II Alzheimer locked in a care center want with items from Camping World?

[4] Mrs. Coulter qualifies as an at risk adult under C.R.S. 18-9-113, Financial Exploitation of an at risk adult.  See Addendum 5 where the 27 Littleton police report from 2002-2005  indicate  that she believed neighbors were coming through her front door key hole; molesting her cat and stealing her food.

[5] The Movant believes that the present owners of Mrs. Coulter’s home (Mr. and Mrs. Perry) will want to join in this action of Paula Coulter, Ted Coulter and John Berman, Esquire’s  fraud to protect their warranty deed and cash purchase of Mrs. Coulter’s previous home.

[6] See for example the Appellant’s Motion to Reconstruct the Record filed October 10, 2013 showing Paula Coulter and John Berman’s continued refusal to follow Court Orders and conceal records.

[7] It is important to mention here Paula Coulter’s last words to Leland Coulter before he passed away. Even though he had been stricken with cancer two months before he died; Paula Coulter never came to see him until the day of his death. Her final words to Leland Coulter, “Will you co-sign this note so I can get a car?” and Leland Coulter’s response, “Paula, I’m too sick; I can’t do that.” Leland Coulter passed away within an hour of that conversation. (This shameless conversation was witnessed by more than one family member.}

[8] John Berman filed a fraudulent emergency Motion stating that because Paula Coulter was Conservator and Personal Representative of Irene Coulter; that she had authority under probate rules to desecrate the remains of Leland Coulter by obtaining an ORDER to dig them up. He had been buried for 22 years in the Coulter family plot in Olinger Crown Hill before he was moved, without notice or hearing, to Florence Colorado to be buried in the family plot of Sonny Vento; a brother-in-law that Leland Coulter had refused to talk to for 20 years before he passed away. Further, Mrs. Coulter had not talked to Sonny Vento since 1995 when he tried to fraudulently exclude her from her share of a Trust. Now, for no reason other than the fraudulent acts of Paula Coulter, Ted Coulter and John Berman, Leland Coulter and Irene Coulter are buried in Florence Colorado instead of the Coulter family plot in Olinger Crown Hill Cemetery. Every day is a further desecration of Leland Coulter’s remains.

[9] The Appellant believes the figure to be in excess of $1,000,000 but an accurate figure cannot be acquired until a complete forensic accounting of Mrs. Coulter’s accounts is ORDERED by the Court.

[10] See Colorado Supreme Court v. John Berman, Esq, 11PDJ078.

[11] The Appellant uses “dig-up” intentionally. “Disenter” should only be used when there is a proper hearing. There was no hearing or notice here. As such, this is nothing short of desecration  of Leland Coulter’s remains.

[12] Mr. Berman did finally email a response to the 10th Email request stating that since the Appellant was not a Devisee of the [fraudulent] Will, even as an interested party and listed heir,  the Appellant was not entitled to a list of  Mrs. Coulter’s assets.

[13] The Report stated: "Overall, we found that the courts' processes do not ensure that the rights, welfare and assets of wards are adequately protected," the auditors reported. Colorado Supreme Court Chief Justice Michael Bender, who represented the judicial branch as the report was presented to Colorado's Legislative Audit Committee, told legislators he is "severely, substantially concerned" about the reported problems — and will make sure they are addressed. (Denver Post Sept. 27, 2011.)

Judge Munsinger, Judge Stephen Munsinger, Chief Justice Munsinger, Steve Munsinger, Susan Munsinger, Brook Munsinger, Gary Munsinger, Elva Munsinger, Eddie McGraddy, Leland Coulter Leland M Coulter, Irene Coulter, Irene C. Coulter,  Jefferson County District Court 10PR204, 13PR56, Colorado Appellate Court 13CA1453, Paula Coulter, Paula Marie Coulter, Colorado Tennis Hall of Fame, Meadow Creek Tennis and Fitness Club,  Ted Coulter, Kevin Ankenbauer, Greg Skyoldal, Barbara Ammann Coulter, Chantelle Noel Yates, Mellisa Gale Yeates, Stephen Anthony Yates, Yvett Coulter, Christian Coulter, Yvette Yates, Roger Ward Moving San Antonio Inc.,  Colorado First Judicial District, Charles Pratt, Judge Charles Pratt, Christopher Cross, Judge Christopher Cross,  M. Edward Burns, Magistrate M. Edward Burns, Catherine I. Burns, Catherine Irvine Burns, Megan Alexandra Burns, Otasha Tasha Karam, Tammy Herivel, Colorado 18th Judicial District, Colorado Appellate Court, Jane Bailey, Colorado Appellate Court Staff Attorneys,  Jane Bailey, Esq., Bruce Bailey, Ann Bailey, Chief Justice Alan Loeb, Karen Loeb, Roine Loeb, Ralph Loeb, Rachael Loeb,  John Berman, Esq,  Marjorie Berman, Stephen Berman, David Berman, Lawrence Berman, Joshua Berman, Sam Berman, Marlene John, Weiner Zerobnick, Fannie Zerobnick, JoAnna Goddard Esq., Goddard and Goddard, Olinger Crown Hill Mortuary and Cemetery, Olinger Crown Hill, Dignity Memorial, John Logan,  Dzen Filipek, Denver Consistory, Scottish Rite Foundation of Colorado, Vernon B. Ingraham, Lee E. Schlessman, Karl J. Hinkle, Richard G. Frohlick, John W. Groves, Gerald A. Ford, Thomas R. Magnuson, Most Worshipful Grand Lodge of Ancient Free & Accepted Masons of Colorado,  Supreme Council of the Southern Jurisdiction, Supreme Council of the Northern Jurisdiction, Herbert Buchwald, 333 Havana Inc., Tri-Havana, John Gleason, Alex Martinez, Supreme Court Justice Alex Martinez, Brent Evans, Patty Evans, G. Raymond Goodwin, Jesse Aragon, Patti Aragon, Dignity Memorial, William Logan,  Olinger Crown Hill Mortuary and Cemetery, Herb Buchwald, William A. Powers, Esq., Bill Powers, Judge Alex Martinez, Alex Martinez, Christopher T. Ryan.

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Judge Munsinger, Judge Stephen Munsinger, Chief Justice Munsinger, Steve Munsinger, Susan Munsinger, Brook Munsinger, Gary Munsinger, Elva Munsinger, Eddie McGraddy, Leland Coulter Leland M Coulter, Irene Coulter, Irene C. Coulter,  Jefferson County District Court 10PR204, 13PR56, Colorado Appellate Court 13CA1453, Paula Coulter, Paula Marie Coulter, Colorado Tennis Hall of Fame, Meadow Creek Tennis and Fitness Club,  Ted Coulter, Kevin Ankenbauer, Greg Skyoldal, Barbara Ammann Coulter, Chantelle Noel Yates, Mellisa Gale Yeates, Stephen Anthony Yates, Yvett Coulter, Christian Coulter, Yvette Yates, Roger Ward Moving San Antonio Inc.,  Colorado First Judicial District, Charles Pratt, Judge Charles Pratt, Christopher Cross, Judge Christopher Cross,  M. Edward Burns, Magistrate M. Edward Burns, Catherine I. Burns, Catherine Irvine Burns, Megan Alexandra Burns, Otasha Tasha Karam, Tammy Herivel, Colorado 18th Judicial District, Colorado Appellate Court, Jane Bailey, Colorado Appellate Court Staff Attorneys,  Jane Bailey, Esq., Bruce Bailey, Ann Bailey, Chief Justice Alan Loeb, Karen Loeb, Roine Loeb, Ralph Loeb, Rachael Loeb,  John Berman, Esq,  Marjorie Berman, Stephen Berman, David Berman, Lawrence Berman, Joshua Berman, Sam Berman, Marlene John, Weiner Zerobnick, Fannie Zerobnick, JoAnna Goddard Esq., Goddard and Goddard, Olinger Crown Hill Mortuary and Cemetery, Olinger Crown Hill, Dignity Memorial, John Logan,  Dzen Filipek, Denver Consistory, Scottish Rite Foundation of Colorado, Vernon B. Ingraham, Lee E. Schlessman, Karl J. Hinkle, Richard G. Frohlick, John W. Groves, Gerald A. Ford, Thomas R. Magnuson, Most Worshipful Grand Lodge of Ancient Free & Accepted Masons of Colorado,  Supreme Council of the Southern Jurisdiction, Supreme Council of the Northern Jurisdiction, Herbert Buchwald, 333 Havana Inc., Tri-Havana, John Gleason, Alex Martinez, Supreme Court Justice Alex Martinez, Brent Evans, Patty Evans, G. Raymond Goodwin, Jesse Aragon, Patti Aragon, Dignity Memorial, William Logan,  Olinger Crown Hill Mortuary and Cemetery, Herb Buchwald, William A. Powers, Esq., Bill Powers, Judge Alex Martinez, Alex Martinez, Christopher T. Ryan.

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