M O T I O N T O R E C U S E J U D G E C H A R L E S M . P R A T T
District Court Arapahoe County, Colorado
7325 South Potomac Drive
Centennial, Colorado 80112
UNION STANFORD PROPERTIES,
PETER COULTER, AUDIONLY.COM LLC.
BRENT EVANS, PATTY EVANS, P & B Evans Family LLLP,
JESSE ARAGON, PENNIE ARAGON, AAA EAGLE LIMITED PARTNERSHIP,
PJ ARAGON MANAGEMENT LLC.,
RAYMOND GOODWIN, BADGER CREEK INVESTMENTS LLC,
P.O. Box 3094
Vail Colorado 81657
COMES NOW the Defendant Peter Coulter, pro se to request that Judge Charles Pratt recuse himself from hearing the above case. In compliance with C.R.C.P. 97, the Motion is supported by Affidavit. As good and sufficient cause, Peter Coulter would state as follows:
1. Peter Coulter references his attached affidavit as though fully rewritten herein.
2. The affidavit contains 12 Exhibits that are a part of the affidavit and this Motion.
3. A litigant is entitled to a proceeding before a Judge who does not have a bent of mind. Johnson v. District Court 674 P2d 952 (Colo. 1984) While a judge may be convinced of his own impartiality, he nonetheless may so act as to lead a party to reasonably conclude that he is bias or prejudiced in the pending litigation. It is this appearance of bias or prejudice which undermines not only a litigants confidence in the fairness of the proceeding, but also public confidence in the integrity and impartiality of the justice system. S.S.v.Wakefield 764 P2d. 70,73 (citing Johnson, 674, P2d. at 956.) The appearance of fairness and impartiality is critical to maintaining the integrity of the judicial process. Id.
4. The instant motion must be heard by a judge other than Judge Charles Pratt. The case of Johnson v. District Court, 674 P.2d 952 (Colo. 1984) is apposite. In that case, the Supreme Court said:
Where one of the litigants signs a verified affidavit alleging conduct and statements on the part of a trial judge which, if true, shows bias and prejudice or the appearance of bias or prejudice on the part of the trial judge it is an abuse of discretion if that judge does not withdraw from the case, even though he or she believes the statements are false or that the meaning attributed to them by the party seeking recusal is erroneous. In such a case, the judge should not pass upon the truth or falsity of the facts alleged in the affidavit, but only upon the adequacy of the motion as a matter of law.
5. In another case as reported in the Colorado Lawyer; Wright v.District Court, 16 Colorado Lawyer 541, March 1987 the court ruled that:
The fact that Judge Goldsmith in his own mind does not believe that he is prejudiced against Wright and his firm does not prevent disqualification if the motions and affidavits reflect prejudice and an appearance of impropriety.
6. The Supreme Court went on to say:
Once facts have been set forth that create a reasonable inference of a "bent of mind" that will prevent the judge from dealing fairly with the party seeking recusal, it is incumbent upon the trial judge to recuse himself. See People v. Botham, 629 P.2d 589, 595 (Colo. 1981); C.J.C. Canon 3(C)(1). A trial judge must accept the affidavits filed with the motion as true, even though the judge believes that the statements contained in the affidavits are false or that the meaning attributed to them by the party seeking recusal is erroneous. Johnson v. District Court, 674 P.2d. 952 (Colo. 1984).
7. C.R.C.P. 97 provides:
"A judge shall be disqualified in an action in which he is interested or prejudiced, or has been of counsel for any party, or is or has been a material witness, or is so related or connected with any party of his attorney as to render it improper for him to sit on the trial, appeal, or other proceeding therein. A judge may disqualify himself on his own motion for any of said reasons or any party may move for such disqualification and a motion by a party for disqualification shall be supported by affidavit. Upon the filing by a party of such a motion all other proceedings in the case shall be suspended until a ruling is made thereon. Upon disqualifying himself, a judge shall notify forthwith the chief judge of the district who shall assign another judge in the district to hear the action. If no other judge in the district is available or qualified, the chief judge shall notify forthwith the court administrator who shall obtain from the Chief Justice the assignment of a replacement judge."
8. We said in Johnson v. District Court, 674 P.2d. 952 (Colo. 1984).
"Ordinarily, the question of whether a judge should be disqualified in a civil case is a matter within the discretion of the trial court. In re Marriage of Mann, 655 P.2d 814 (Colo. 1982). However, where an attorney for one of the litigants signs a verified affidavit alleging conduct and statements on the part of a trial judge which, if true, show bias or prejudice or the appearance of bias or prejudice on the part of the trial judge, it is an abuse of discretion if that judge does not withdraw from the case, even though he or she believes the statements are false or that the meaning attributed to them by the party seeking recusal is erroneous. In such a case, the judge should not pass upon the truth or falsity of the facts alleged in the affidavit, but only upon the adequacy of the of the motion as a matter of law. 'The motion and supporting affidavit speak for themselves and the only question involved is whether the facts alleged are sufficient to compel the judge to disqualify himself.' Kovacheff v. Langhart, 147 Colo. 339, 343-44, 363 P.2d 702, 705 (1961). The motion and affidavits are legally adequate if they 'state facts from which it may reasonably be inferred that the judge has bias or prejudice that will prevent him from dealing fairly' with the party seeking recusal. People v. Botham, 629 P.2d 589, 595 (Colo. 1981)."
9. Because the act of appearing Pro-se, installs and grants an individual under the constitution of the United States and the constitution of the State of Colorado, full authority to act as an officer of the court in all matters both civil and criminal, it therefore stands to reason that an affidavit signed by an individual, pro-se and substantiated by others who were witness to the event, should bear up as having the same weight as an affidavit signed by an attorney for a litigant.
10. It therefore stand to reason that:
"A judge must grant a motion for disqualification if the motion and supporting affidavits state facts from which it reasonably may be inferred that the judge has a bias or prejudice that will prevent him from dealing fairly with the party seeking recusal. The judge must accept the affidavits filed with the motion as true even though the judge believes that the statements contained in the affidavits are false." Wright v. District Court, 731 P.2d 661 (Colo. 1987
11. Moreover, established Colorado law provides that a judge should disqualify himself in a proceeding where his impartiality might reasonably be questioned. C.J.C. (3)(C)(1). Courts must meticulously avoid any appearance of partiality. Although the trial judge believes in his own impartiality, it is the courts duty to eliminate every semblance of reasonable doubt or suspicion that a trial by a fair and impartial tribunal may be denied. Pierce v. United Bank, 780 P.2d 6, 7 (Colo. App. 1989) (quoting Zoline v. Telluride Lodge Assn, 732 P.2d 635, 639 (Colo. 1987)). Thus, in assessing the sufficiency of the motion and affidavits, the judge must consider the appearance of bias, for the integrity of the judicial process is impaired when the public perceives partiality on the part of a judge. Wilkerson v. Dist. Court, 925 P.2d 1373, 1376 (Colo. 1996).
THEREFORE, it is submitted that the Justice Pratt must be disqualified from the above numbered and entitled action due to the facts presented in this Motion and Attached affidavit.
Dated this April 25, 2011
Certificate of Service
The above document including attached Affidavit was served upon the following parties by E-mail and/or personally:
G.Raymond Goodwin 7472 S. Shaffer Lane, Littleton, Colorado 80127
AFFIDAVIT OF PETER COULTER
STATE OF COLORADO )
COUNTY OF DENVER )
The undersigned, Peter Coulter does hereby swear, affirm and attest to the following:
This entire case has been a complete travesty of justice and reflective of the corruption and cronyism that has infested our judicial system. The bias shown by Judge Charles Pratt towards myself has been prevalent and ongoing since the first day this case was before him, March 31, 2009. Below are illustrated but a few of the more flagrant violations each of which demonstrates that Judge Pratt should recuse himself:
1. REMOVAL FROM FILE OF COUNTER-CLAIM, CROSS-CLAIM, JURY DEMAND AND JURY FEE
On December 18, 2008, I filed a counter, cross, jury demand and fee for removal to Arapahoe County District Court in the above case. (Ex.1) The counter, cross jury demand and jury fee of $192 was removed from the file without authority (Treason of the Constitution) by Edward Burns and Tammy Herivel. (Ex7) As there was no Public Access Terminal (as required by Supreme Court Directive. See also C.R.S. 13-1-119, Judgment record and register of actions open for inspection.) the only way I was finally able to review the records was to file an Open Records Request with the Administrator of the Colorado Supreme Court. As a result, I was not aware that Burns/Herivel had done these acts until nearly a year later. At the trial held on March 31, 2010, Judge Pratt would not let me present the counter claim and cross-claim against Brent Evans because according to the official court record, as with the jury demand and payment, I never filed it. As such, I was also not allowed to get a subpoena from the Court Clerk for Brent Evans as again he was not an official party according to the official court record. (This seems to be the same path that G. Raymond Goodwin is now following with his objection to discovery that he filed April 18, 2011; that is, there was only an FED action filed with no counter or cross claim.) By not allowing me to put on a defense or show that in fact Union Stanford owed me an offset in excess of what they stated I allegedly owed them; Judge Pratt showed extreme prejudice and bias towards me resulting in the loss of over $2,000,000 in inventory alone.
2. DENIAL/REFUSAL OF JURY TRIAL
The official records of the Court indicate that I did not originally file a counter-claim, cross-claim, jury demand or payment of jury demand, in complete contrast to the court stamped records and cash receipts. (Ex. 1,2) Those entries were illegally removed by Edward Burns and Tammy Herivel in what can only be described as felony theft, fraud, and Treason of the Constitution. (See attached Exhibits) Under Colorado Rules of Civil Procedure Rule 38, (See also Ex 5) I was entitled to the Jury trial I demanded and paid for which was denied by Judge Pratt without reason or explanation other than to attempt to cover up the actions of his associates Tammy Herivel and Edward Burns and the eventual fraudulent and forged contracts put forth by G. Raymond Goodwin, John Brent Evans and associates on March 31, 2009.
3. REMOVAL OF RECORDS FROM FILE INDICATING A JURY TRIAL HAD BEEN REQUESTED
From February 2009, the Court intentionally unplugged the Public Access Terminal at the Arapahoe County District Court making it impossible for any pro-se Defendant as myself from reviewing his/her file and in violation of C.R.S. 13-1-119 and Supreme Court Directive. On March 18, 2009, Peter Coulter filed a Notice of Jury Trial with the District Court. (Ex.5) On March 30, 2009, Peter Coulter filed a Writ of Petition with the Colorado Supreme Court in regards to the demanded jury trial. On April 3, 2009, the Supreme Court issued an ORDER in regards to the Petition. All documents pertaining to the request and demand for jury trial disappeared/stolen from the official court record even though there were official clerk stamps that indicate they had been filed and/or sent from the Supreme Court.
Those documents are as follows:
Counter and Cross claim timely filed on December 18, 2008.
Demand for jury trial in District Court filed and paid for on December 18, 2008.
Arapahoe District Court copy of Petition to Colorado Supreme Court concerning jury trial dated March 30, 2009
Court Order of Supreme Court concerning jury trial dated April 3, 2009.
These documents were intentionally removed by Tammy Herivel and Edward Burns to deny Peter Coulter his right to a Jury trial and were further covered up with the help of Judge Pratt.
4. DENYING AUDIONLYS RIGHTS
Union Stanfords original complaint was for less than $10,000 and they named Audionly.com as a party but never served them. Before the trial on March 31, 2009, Peter Coulter filed a Motion that Audionly.com was a necessary party as they had cosigned the lease for the property with Union Stanford. (This motion was filed before Raymond Goodwin submitted the 2 forged leases.) Judge Pratt decided that even though Audionly was named by Union Stanford Properties and Raymond Goodwin; that they were not entitled to be at the FED trial and proceeded without them. According to the Court Registry, Judge Pratt handed down a final judgment on April 5, 2009 only ordering a Writ of Restitution to Union Stanford Properties and not taking into account the $17,000 dollars that was asked for in the counter and cross-complaint (that were removed from the files) against Union Stanford and John Brent Evans. On June 12, 2009, without notice or appearance by Peter Coulter, Judge Pratt held a hearing with only Raymond Goodwin where the two of them decided to now allow Audionly to be brought in as a party without leave of court, without the presence of Peter Coulter at the hearing and after the Judgment had been rendered. (Transcript of hearing attached Exhibit 4) Trial settings are on Tues. afternoons in Judge Pratts Court. Raymond Goodwin sent me a notice of trial setting on June 5th, 2009 that he was going to call the clerk of the Court at 8:15 on June 12, 2009 and set a one day Jury trial. I called the Court at 8:17am and Judge Pratts clerk, Patricia answered the phone. I told her why I was calling and she said that Raymond Goodwin had no authority to do what he did and that all trial settings were on Tuesday afternoon. I asked her what I should do and she said she would call me back that afternoon. I never received a call and because there was no way for me to review the files (no Public Access Terminal), I had to order a transcript of the hearing to find out what transpired (Ex 5) It is obvious from the transcript that Judge Pratt and G. Raymond Goodwin have been talking to each other as somehow the new jury trial (The previous judgment was not set aside by Judge Pratt; he just decided that were now going to have another trial to help cover up the previous fraud of the Court in conspiracy with Raymond Goodwin, John Brent Evans and Union Stanford Properties) went from one day to three days. Additionally, Raymond Goodwin and Judge Pratt, without the presence or notice of Peter Coulter or Audionly; decided that Audionly can now be brought into the case without leave, after the judgment had been rendered, and with no signature of Audionly on the fraudulent lease submitted by Raymond Goodwin. This hearing without Peter Coulter once again shows the complete bias of Judge Pratt toward Peter Coulter in his further efforts to cover up the actions of Edward Burns, Tammy Herivel and the fraud and forgery of Raymond Goodwin and John Brent Evans and their associates.. S.S. v. Wakefield, 764 P.2d 70 (Colo. 1988)
5. SUPERBOWL SUNDAY ORDERS
In late 2009 at a pretrial hearing, Judge Pratt asked if I was ready to go to trial. I stated then that because John Brent Evans had been removed as a party; (by Edward Burns and Tammy Herivel) Tammy Herivel refused to issue a subpoena for Brent Evans. At the same time, I was properly requesting the Supreme Court Administrative Division to correct the record noted in 3 above without success. Tammy Herivel, Edward Burns and Judge Pratt kept directing me back to Judge Pratts Court to remedy the situation. There was no doubt that they were trying to keep their previous actions hidden and away from public record. Judge Pratt eventually asked me to file a Motion with his Court requesting that Brent Evans be made a Party. Judge Pratt did not restore the record that would have made Brent Evans a party from December 18, 2008 (the day I filed the counter and cross-claim) but a party as of late 2009 when he made the ruling. Judge Pratt did not restore the record of December 18, 2008 where I filed the counter and cross-claim and demand for jury trial against Union Stanford and Brent Evans because that would have meant the trial Judge Pratt held on March 31, 2009 would have yet another reason to be improper and void. G. Raymond Goodwin requested a waiver of service for Brent Evans which was reflected in the Order dated November 3, 2009 which required Mr. Goodwin to be served within 30 days. Raymond Goodwin was served on December 1, 2009 at his office. Thereafter, neither Raymond Goodwin nor Brent Evans responded to the cross-claim nor had they ever properly respond to the original counter-claim. Mr. Goodwin had a habit of not sending Court documents to Peter Coulter and/or intentionally misaddressing them. (It got so bad that I had to contact the Court Clerk every day to see if Raymond Goodwin had filed any documents. On January 22, 2010, Mr. Goodwin filed a nonsensical and improper Motion to remove John Brent Evans from the case without sending notice to Peter Coulter. By this time the Court had Ordered Audionly back into the case without proper leave at a hearing between Judge Pratt and Raymond Goodwin where Peter Coulter was not given notice and prejudicial ex-parte communications took place (Ex.5) and of course Judge Pratt allowed this after he had rendered a Judgment on April 5, 2009. By Statute, Audionly and Peter Coulter had until Monday February 8, 2010 to respond. Peter Coulter filed a response with the Clerk on February 1, 2010 at 1:29pm which is evidenced by the Clerks stamp. That response was intentionally not uploaded by the Clerk to Lexis/Nexis until February 8, the day after the Motion was granted by Judge Christopher Cross at 4:30pm, the half-time of the Super bowl. (See report on Internet concerning manipulation of Court and Lexis/Nexis records concerning this matter in detail) Additionally, Audionly was not given notice of the Motion and was not given the statutory time to respond before the fraudulent ruling of Judge Christopher Cross on Super bowl Sunday; issued before Audionly had a chance to respond and before Peter Coulters response was uploaded to Lexis Nexis by Tammy Herivel. In conclusion, Judge Cross made an Order to a nonsensical Motion that did not follow statutory rules; issued before the statutory time line for Audionly to Answer and with Tammy Herivel intentionally withholding Peter Coulters response filed a week earlier and the coup de grace; a ruling recorded by Lexis/Nexis that was made during the Sunday half-time of the Super Bowl. Judge Pratt has been made aware of this through numerous briefs and continues to ignore it or address it with responses that do not reflect the record. The only conclusion one can then reach is that Judge Pratt is working in collusion with Judge Cross, Edward Burns, Tammy Herival and Raymond Goodwin in a concerted and continuing fraud on Peter Coulter.
6. MCLEAN V. ROBINSON CASE
I didnt know who Edward Burns and Tammy Herivel were or what they were doing in my case until nearly a year after the case had been filed because they were keeping me from seeing my files by unplugging the Public Access Terminal virtually stopping my ability to see what or who was sabotaging my case. And it was sabotaged, or their actions would have been done in open court and there would have been a record of it on the registry. They did not want their actions on the record because they knew what they were doing was seriously wrong and a breach of Edward Burns oath to uphold the Constitution as a lawyer and more importantly as a magistrate. What no one was expecting, including myself, was the corruption of Raymond Goodwin, Brent Evans and their associates in presenting fraudulent and forged documents to the Court and for what purpose? Greed. And what has it gotten them? A lawsuit going on 3 years; a piece of property that has sat empty and the exposure to friends, colleagues, their family and the world who they really are and the frauds they are capable and willing to undertake. But it is Edward Burns crime that is most intriguing. I doubt he would have done it had he known that Raymond Goodwin and Brent Evans were going to produce forged documents to the Court. But the fact is he did do it. There had to be a reason he would take such a risk. First, he had to know that if he was caught doing it; other Judges, i.e. Charles Pratt and Christopher Cross would cover for him as they have done. More importantly is why he did it? It had to be something substantial for him to take such a risk. As I had never had a case in front of Edward Burns, it had to be something else. Then, in the summer of 2010, the picture became clear to me; Mclean v. Robinson. I gave a deposition in that case in 2008. Before that time I did not have any issues with Union Stanford, and its managers/members Raymond Goodwin and Brent Evens. In fact, before Brent Evans showed his true colors, we consider him our friend and went to lunch quite often together and bet on the greyhounds. I did not know that Judge Pratt was the judge on that case and did not find out till the late summer of 2010; about the same time I found out that Edward Burns and Tammy Herivel were responsible for stealing the jury demand and fee in my case where Judge Pratt was assigned. I was and am convinced that the actions of Edward Burns are somehow related to this case where Judge Pratt presided. Having witnessed the actions of Edward Burns, Judge Cross and Judge Pratt as noted above; I felt intimidated in providing my testimony on the witness stand believing that it was going to further influence Judge Pratts actions in my case. I first tried to discourage the doctors attorneys from subpoenaing me and when that didnt work, I had two choices; take the witness stand and refuse to testify and see what Judge Pratt would do to me, or get lost for a couple of weeks so I couldnt be subpoenaed. The boundaries of corruption of Magistrate Edward Burns, Tammy Herivel, Judge Christopher Cross and Judge Charles Pratt have not been described and limited to my case alone. No matter what or how I feel about Ms. McLean; she is entitled to a fair and unbiased trial and judge and like me she did not receive that, no matter the outcome.
7. Trial date settings:
This is the latest bias shown in this case that happened just last week. This action needs background information to fully understand. Brent Evans told me back in July of 2001 when we signed the lease that they had made Raymond Goodwin a 10% manager/member of Union Stanford Properties for helping with a property they had Purchased. Brent Evans also indicated that he wrote the first draft lease he presented to me and Raymond Goodwin wrote the second draft lease and the 3rd final lease for a three year base with 7 one year options which was signed and notarized by Brent Evans, Peter Coulter and Peter Coulter for Audionly.com. Brent Evans requested we go to his bank, Keybank, to have the lease contract notarized and as he only had one copy, he said he would take it home and make a copy and send me the original. To this date, that has never happened even though I had asked for it on numerous occasions over the 8 years and finally refused to pay the lease payment in December 2008 until they provided me a copy of the lease. Instead, Union Stanford, filed an FED. In the next 3 months, I formally asked for the lease on 9 separate occasions with no response. On January 7, 2009, Raymond Goodwin made an appearance into the case to act as Union Stanfords counsel and presented me with two unsigned leases that he intended to use at trial. They were the 2nd draft lease presented by Brent Evans in July of 2002, not the final lease prepared by Raymond Goodwin and signed by all 3 parties in late July 2002. Then, 5 minutes before the trial on March 31, 2009 before Judge Pratt, Raymond Goodwin presents two more leases. The first was a forged lease for the 2160 W. Radcliff property that only had two signatures, not three; the terms of the contract had been changed; (This was not the first time Union Stanford had been caught changing the terms of a contract after it had been signed. See American Comm. v. Union Stanford in Arapahoe County Court.) Linda Greens (Notary) signature did not match the one on file at the Secretary of State and the signing date had been changed to a date that I have evidence that I was not even in the State of Colorado at the time. The second lease was also a blatant forgery. Around 2004, we needed some additional space for cars and leased another small yard from Brent Evans and Union Stanford that was approximately 100 X 100 and was listed as Lot F(Ex 8). The price was normally around $700 but there were a bunch of truck tires and a dirt pile in the yard so Brent Evans discounted the price to $600 and indicated that he would pay us to remove the truck tires. That lease ended around 2005 and we had removed all the tires and also some cars and a meth lab that was on another property of Union Stanford per request of Brent Evans. We were never paid. That was the basis of the cross and counter claim offset that I filed against Union Stanford and Brent Evans that was stolen by Edward Burns and Tammy Herivel. Raymond Goodwin presented a forged lease with my forged signature for Lot V, not lot F. (Ex.9) Lot V was across the roadway from where we rented space and was at least twice as large. The stated rent on the forged document was $1,250. The purpose was to commit a Fraud on the Court by saying the $17,000 I requested in my counter and cross claim had been paid by a reduction in rent. (The difference between the total of the fraudulent and forged lease Mr. Goodwin submitted and the real lease for the entire term was/is approximately $17,000, the same amount asked for in the original counter/cross complaint. This forgery and fraud on Peter Coulter and the Court was brought up numerous times in Motions and Affidavits to Judge Pratt who to date has ignored them. He has no choice. He has to ignore them to protect Edward Burns and Tammy Herivel at the expense of Peter Coulter. This same behavior has been exhibited through the entire tenure of this case; Judge Pratt continually covering up for the acts of Edward Burns, Tammy Herivel, and Raymond Goodwin as partially written in this affidavit. Raymond Goodwin became so comfortable with his actions that he blatantly broke the Rules of Civil Procedure because he knew there would be no consequences; a kind of non spoken conspiracy and collusion between Judge Pratt, Edward Burns, Tammy Herivel, Raymond Goodwin, Brent Evans, Union Stanford and its associates. The only way to keep the despicable acts of the Court under wraps was to promote the fraud being headed and perpetrated by Raymond Goodwin against Peter Coulter. The latest incident began at a Motions hearing held by Judge Pratt in the fall of 2010. I had/have prepared an Amended Complaint against Union Stanford and its associates. Before I filed it, I told Judge Pratt that I would like to get some discovery from Union Stanford. Judge Pratt granted the request which was to be completed around November of 2010. Raymond Goodwin stalled the process and I filed a Motion for Contempt. Judge Pratt changed that to a Motion to Compel. That Motion and the request for discovery is still being considered by Judge Pratt today. In the mean time, despite the objections of Peter Coulter (Ex 10) Raymond Goodwin alone sets a one day trial to the Court without notifying anyone and effectively prohibiting me from filing the Amended Complaint naming him and his associates. Then, on April 4, 2011, 5 months after he secretly set the date with the Court; he sends a notice to Peter Coulter (Ex 11) that there is going to be a one day trial to the Court on May 16, 2011. This was one of the dates mentioned in his original E-mails. Even though Raymond Goodwin knew that a jury trial had been requested, paid for and previously set for 3 days; he secretively without notice and despite objection by Peter Coulter sets a trial date to the Court for one day. The sole purpose of this act again was to prevent Peter Coulter from filing an Amended Complaint joining him and his associates. (once a trial date has been set) When I received the Notice Raymond Goodwin sent on April 4, 2011, (Ex. 11) I immediately called Judge Pratts chambers to find out how Raymond Goodwin was able to accomplish this; especially since the Court knew we still had not finished discovery. Instead of admonishing Raymond Goodwin for his actions and behavior; Judge Pratt covers for him saying it is his fault. (Ex. 12) This comment in the Order of Judge Pratt (Ex. 12) does not match the previous E-mails that Raymond Goodwin sent to Peter Coulter in November of 2010 (Ex. 10)
The above are but a few of the blatant inequities and atrocities that I have endured at the hands of Edward Burns, Tammy Herivel, Judge Christopher Cross, Brent Evans, Raymond Goodwin and associates and Judge Charles Pratt. Judge Pratt has not only shown a continuing bias toward me; he has violated his sworn oath to uphold the Constitution. The affidavit above is not just mindless innuendos but completely backed up by facts/exhibits. As clearly demonstrated here, there is no possibility for me to get a fair trial in Arapahoe County, Colorado.
Sworn to this _________day of April, 2011 by
The forgoing affidavit with 12 attached exhibits were acknowledged before me this __26___day of April, 2011 by Peter Coulter
My commission expires______________________
12 EXHIBITS ATTACHED AS A PART OF THIS AFFIDAVIT.