COLORADO JUDICIARY CHARLES M. PRATT, EDWARD BURNS, TAMMY HERIVEL, RAYMOND GOODWIN, CHRISTOPHER CROSS, JOHN BRENT EVANS, WAITROUS,EHLERS, MIELKE, & GOODWIN, PATTY EVANS, UNION STANFORD PROPERTIES, AIDEN MCGUIRE, PENNIE A Treason of the Constitution, Fraud, Extortion, Conspiracy to Defraud, Theft, Collusion, Corruption in Judical Branch Centennial, Colorado

The Motion to Recuse Judge Charles M. Pratt was filed April 26, 2011.  Union Stanford Properties filed through their associate, manager, member and counsel Raymond Goodwin of WATROUS, EHLERS, MILKE, & GOODWIN LLP filed a response on Tuesday, May 3. I then filed a reply on May 6. I have no way of posting Raymond Goodwin's response without retyping the entire 3 pages of the brief. If Union Stanford Properties / Raymond Goodwin want to post their reply here they are more than welcome to do so. Basically, Raymond Goodwin ignores all the facts presented in my original brief and infers that examples like the ex-parte hearing by Judge Charles Pratt and Raymond Goodwin never happened even though a transcript of the hearing indicates it did. It is just further rhetoric by Raymond Goodwin that has been accepted by the Court. It has to be accepted for Judge Pratt to further cover up the actions of his associates, Tammy Herivel, Edward Burns, and Christopher Cross. Below is my reply:

District Court Arapahoe County, Colorado

7325 South Potomac Drive
Centennial, Colorado 80112

UNION STANFORD PROPERTIES,
Plaintiff,
v.
PETER COULTER, AUDIONLY.COM LLC.                                          
Defendants,
v.
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, AIDEN MCGUIRE,
Cross-claimants.

 Peter Coulter

E-MAIL 2008CV202587@GMAIL.COM

DEFENDANT, PETER COULTERS REPLY TO UNION STANFORDS RESPONSE IN OPPOSITION
TO DEFENDANTS MOTION TO RECUSE  JUDGE CHARLES M.PRATT SUPPORTED BY AFFIDAVIT

COMES NOW Defendant Peter Coulter, pro se and files his Reply to Union Stanfords Response in Opposition to Defendants Motion to Recuse supported by Affidavit.

Union Stanford, through their attorney, member and associate Raymond Goodwin[1] appear to complain that Peter Coulter has shown no basis for recusal and Requests that Recusal be denied. Peter Coulter replies to the allegations madein Union Stanfords Response and shows further sufficient basis for recusal in the following Argument and Citations.

Parties to civil cases have a constitutional right to a fair trial. Latiolais v. Whitley,
93 F.3d 205, 207 (5th Cir.1996); Lemons v. Skidmore, 985
F.2d 354, 357 (7th Cir. 1993); Bailey v. Sys. Innovation, Inc.,
852 F.2d 93, 98 (3d Cir. 1988).
And [t]rial before an unbiased judge is essential to due process. Johnson v. Mississippi, 403 U.S. 212, 216 (1971); accord Concrete Pipe & Prods. v. Constr. Laborers Pension Trust, 508 U.S. 602, 617 (1993) (due process requires a neutral and detached judge in the first instance) (citation omitted).

The United States Supreme Court has stated:

and this stringent rule may sometimes bar trial by judges who have no actual bias and who would do their very best to weigh the scales of justice equally between contending parties.  Offutt v. United States, 348 U.S. 11, 14 (1954), Marshall v. Jerrico, 100 S. Ct. 1610, 446 U.S. 238, 64 L. Ed. 2d 182, (1980).Pg. 243:

We have employed the same principle in a variety of settings, demonstrating the powerful and independent constitutional interest in fair adjudicative procedure. Indeed, "justice must satisfy the appearance of justice,"
and this
 "stringent rule may sometimes bar trial by judges who have no
actual bias and who would do their very best to weigh the scales of justice
equally between contending parties,"

In re Murchison, 349 U.S. 133, 136 (1955). See also Taylor v. Hayes, 418 U.S. 488 (1974).

If the Due Process Clause requires recusal only when a party could prove actual bias arising from personal animus in the judges heart or cold cash in the judges pocket, then the rights of parties to a fair and impartial judge would be imperiled. Probabilities of unfairness, likelihood of bias, and unacceptable perceptions are at the heart of circumstantial evidence, which is sometimes the
only evidence available on the issue of whether a judge is constitutionally required to disqualify Randall T. Shepard, Restraint and Liberty in Judicial Ethics, 9 Geo. J. Legal Ethics 1059, 1087 (1996)

Facts:

A       
On December 19, 2008, Peter Coulter filed a response, counter complaint and cross-complaint against Brent Evans for 17,000.

B       
Additionally, Peter Coulter paid $192 for a jury trial in Arapahoe County District Court.

C.       
Tammy Herivel and Edward Burns, without authority or jurisdiction, removed the counter and
cross-complaint, jury demand and $192 fee.

D       
4 documents referencing the jury trial were removed from official court records by Tammy Herivel and Edward Burns: 1.) Brent Evans as a party, counter and cross claim, jury demand and payment. 2.) Notice of Jury trial filed March 18, 2009, 3.Writ of Petition to Supreme Court (concerning jury trial) filed March 30, 2009. 4. Order of Colorado Supreme Court mailed to the District Court on April 3, 2009.

E       
The Court intentionally violated C.R.S. 13-1-119, Judgment records and register of actions open for
inspection, by not having an operating Public Access Terminal for pro se litigants denying Peter Coulter the ability to review the files and therefore the criminal actions of Edward Burns and Tammy Herivel.

F      
Judge Pratt denied Peter Coulter the jury trial he demanded and paid for.

G      
Judge Pratt denied Peter Coulter to present his offsetting counter claim against Union Stanford at the trial on March 31, 2009

H.      
Judge Pratt held a trial without all named parties being present, i.e. John Brent Evans and Audionly.com even though a Motion was filed previously by Peter Coulter objecting to their
absence.

I     
Union Stanford presented two forged lease contracts to the Court on March 31, 2009 as part of their Complaint. Even though Peter Coulter presented expert testimony to Judge Pratt that his signature was forged on one of the documents; Judge Pratt ignored it without comment.

J       
On April 6, 2009, Judge Pratt issued a final judgment of Restitution to Union Stanford from Peter
Coulter resulting in the immediate loss of over $2,000,000 in inventory alone.

K      
On April 7,  2009, Judge Pratt closed the case.

L      
On Friday June 12, 2009 at 8:15a.m., without notice or appearance by Peter Coulter (ex-parte) or
Audionly, Judge Pratt and Raymond Goodwin have a hearing where Judge Pratt granted Union Stanfords request to bring Audionly into the case without leave of Court, without a signature of Audionly on the forged contract and after the judgment and trial had already been held and the case closed by Judge Pratt.

M       
Judge Pratt denied Peter Coulters Motion for Change of Venue based on Courts violation of C.R.S.
13-1-119. Judgment records and register of actions open for inspection; in not having a Public Access Terminal for Peter Coulter to inspect the records in his case. Peter Coulter had to request an open records demand (Colorado Open Records Act) from the Colorado Supreme Court before he was allowed to inspect his files

N      
The original amount of Union Stanfords complaint was under $9,000 which included attorneys fees.
Peter Coulter, as an officer of Audionly, was therefore qualified to represent Audionly in Court pursuant to C.R.C.P. Rules. Judge Pratt denied Audionly representation by Peter Coulter in yet another violation of due process, conspiracy and collusion with Tammy Herivel, Edward Burns, Union Stanford Properties and its Associates Brent Evans, Raymond Goodwin and others cited as parties in this case.

O      
Judge Pratt allowing, despite objection, a default judgment Motion for over $50,000 by Union Stanford against Audionly when the original complaint amount was only $8,600 in defiance
of Statutes and Court rules that state that a default judgment can be for no more than the initial complaint amount.

P       
Judge Pratt allowing, despite objection, a default judgment Motion for over $50,000 by Union Stanford against Audionly after a final judgment had been rendered by Judge Pratt on April 6, 2009 and the case closed on April 7, 2009.

Q.     
Judge Pratt allowing,despite objection, a default judgment Motion for over $50,000 by Union Stanford against Audionly when the forged lease contract that Raymond Goodwin presented
to the Court on March 31, 2009 at the trial did not contain the signature of Audionly as a party to the contract.

R.      
On January 22nd, 2010, Union Stanford through its attorney and member Raymond Goodwin filed a
fraudulent and non-sensical Motion (that didnt meet CRCP requirements) to remove associate John Brent Evans from the case. As usual Raymond Goodwin did not send notice of the Motion to either Peter Coulter or Audionly (who had been made a party at the ex-party hearing held by Judge Pratt on June 12, 2009. See above.) Peter Coulter found out about it by continually calling the court clerk every day to see what had been filed and filed a response on Monday March 1, 2010 at 1:29pm; well within the timeframe specified for responses to Motions dictated by CRCP Rules. (Under the rules, Peter Coulter and Audionly had until Monday March 8, 2010 by closing time of the court clerk to respond to the Motion. On Wednesday, March 3rd (as evidenced by E-mails to the Supreme Court) Peter Coulter called the Court Clerk and his March 1 Response had not been uploaded to the system. Peter Coulter called again on March 4 and Friday, March 5 at 4:00pm and his Response still had not been scanned and uploaded to the system. Peter Coulter then E-mailed the Supreme Court IT division at 4:30pm Friday to see if they could find out what was going on.[2]The Supreme Court E-mailed me back at 9am Monday March 8th to inform me that she had contacted the Arapahoe County Clerk (Tammy Herivel) and that they had mistakenly uploaded my response with a February 1 date instead of March 1 date when it was filed. I went to the Court immediately and retrieved a
copy of my Response with the original filing date of March 1  and an upload and document number date of March 8, 2010 at 8:30am; not February 1, 2010 as they had E-mailed/told the Colorado Supreme Court.

Additionally, there had been an Order granting RaymondGoodwins Motion by Judge Christopher Cross at 4:30pm on Sunday March 7, 2010which corresponds with the half time of the Super-bowl. (Time was marked and evidenced by Judge Cross uploading transaction time onto Lexis Nexis.) While Peter Coulter believes that both Judge Pratt and Judge Cross had seen Peter Coulters Motion previous to Judge Cross Order of March 7, they did not think Peter Coulter would file a response because Raymond Goodwin never sent notice and they did not want it as part of the record; just like the previous records for the demand of jury trial had been removed. Further, Peter Coulter and Audionly were denied due process by having the Motion ruled on before the deadline for a response, March 8, 2010 at 5pm. This begs the question, Why would Christopher Cross be rendering an Order for Judge Pratt at the half-time of a Super bowl Sunday before the CRCP response deadline had been reached? The only reasonable explanation is that they believed Peter Coulter would not catch them in these deliberate continual acts to deny him his due process of law and fraudulent conspiracy with Edward Burns, Tammy Herivel, Brent Evans, Raymond Goodwin, Union Stanford Properties and their associates and members.

S         
At a hearing in September 2010, I told Judge Pratt that I had an amended complaint prepared to file but wanted to have discovery of Union Stanford first to save time. The court granted the request but Raymond Goodwin stalled the discovery and Peter Coulter filed a contempt Motion. Judge Pratt changed it to a Motion to compel and briefs were filed but never ruled on by Judge Pratt. In the mean time in December,  Raymond Goodwin sets a one day trial to the Court (even though it had previously been a 3 day jury trial) without first notifying Peter Coulter and then despite his objections noted in Emails and thereafter not making the date he set a part of the record. Thence, on April 4, 2011, Raymond Goodwin sends a notice to Peter Coulter that there is
going to be a one day trial to the Court on May 16, 2011. I was furious and called Judge Pratts chambers to see how this was possible. I could tell Judge Pratt was scrambling by the demeanor of his personal clerk Patricia. Instead of admonishing Raymond Goodwin for his fraudulent actions; Judge Pratt covers for him by saying it is the courts fault and ORDERS a new trial date setting which
preempts Peter Coulters prepared Amended Complaint and joinder of additional parties; exactly what Raymond Goodwin was trying to accomplish in the first place.

T                
With all of the above happening in my case; I felt intimidated by Judge Pratt in testifying for Dr. Robinsons attorneys as I believe my testimony would affect the previous bias rulings by Judge Pratt in my own case. The result being whether Ms. Mclean received a fair and unbiased trial from Judge Pratt.

 Clearly, Judge Pratt has reason to disqualify himself. As was stated in Brief Amicus Curiae of 27 Former Chief Justices and Justices In Support of Petitioners in Caperton, et., al., v. At. Massey
Coal Company, Inc., et., al.,. On Petition for a Writ of Certiorari to the Supreme Court of Appeals of West Virginia, No. 0822:

On page 7:
Lord MacMillan, Law and Other Things 217-18(1937). Jerome Frank noted the peculiarly individual factors that can influence decisions: "these uniquely, highly individual, operative influences are far more subtle, far more difficult to get at. Many of them, without possible doubt, are unknown to anyone except the judge. Indeed, often the judge himself is unaware of them." Jerome Frank, Courts on Trial 151 (1950).

On page 8:
But a judge who bases recusal not only on a subjective evaluation of fairness, but also on
a more objective appearance of fairness, preserves much more effectively the litigants
due process right to an impartial judge.

Each of the above bulleted instances in and of itself demonstrate an appearance of bias of Judge Charles M. Pratt required by the Motion; if not an intentional and blatant violation of Peter Coulters right to due process of law and fraudulent conspiracy on Mr. Coulter.

 WHEREFORE, Justice Charles M. Pratt should forthwith recuse himself from the above cited
case.

Sincerely dated this May 5, 2011,

Peter Coulter

CERTIFICATE OF SERVICE

The above document was served on the following parties by first class mail or E-mail this May 6, 2011:

Raymond Goodwin      Goodwin@wemglaw.com


[1]
Raymond Goodwin has continued to deny his association with Union Stanford
properties even though Peter Coulter has produced documents where he has signed
as manager for Union Stanford properties. Further, Mr. Goodwin is a manager of
Badger Creek Investments which is a member of Union Stanford Properties.

[2]
Emails to the Supreme Court are available and have been presented previously to
Judge Pratt in this case.

because the corrupt people who run the corrupt corporations and the corrupt politicians who work for these corrupt people are fueling much of the legal system in this country with MONEY!

Make sure to read this Ripoff Report and spread it all over the web at sites like Twitter & Facebook.

Thank You

*****CORRUPTION ALERT: Don't forget to stay at this site and type in all of the following and read the Ripoff Reports for further proof that the USA is a country whose foundation is solidly built on corruption-

BANK OF AMERICA
PHH MORTGAGE
WELLS FARGO
MERRILL LYNCH
CHASE
GMAC
WACHOVIA
COUNTRYWIDE
US BANK
NBC
INDYMAC
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MORGAN STANLEY
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FEDERAL RESERVE
BUSH
OBAMA
d**k CHENEY
CLINTON
US GOVERNMENT
GM CREDIT CARD SERVICES

CHAPTER 3 MANIPULATION, THEFT AND DESTRUCTION  OF OFFICIAL COURT RECORDS

The State of Colorado uses electronic filing in some of their Courts. It is ripe for manipulation as has been shown in this case by Edward Burns, Tammy Herivel, Judge Charles Pratt and Judge Christopher Cross. This electronic system is used exclusively in the Civil Division of Arapahoe County. It is comprised of two systems. The State portion is called Eclipse and the private contracted portion is called Lexis Nexus File and Serve. Attorneys are required to use Lexis Nexus to file all documentation from their offices. Pro-se litigants are not allowed to use Lexis Nexus and therefore all filings must go through the clerk of the Court where it immediately gets a Court filing
and time stamp and then is supposed to be scanned and uploaded onto Eclipse and Lexis Nexus so that it can be viewed by Attorneys at their office, the Judge from the bench, and pro-se litigants from view only terminals that are required in every court using electronic filing and called Public Access Terminals. (PAT).  The Colorado Supreme Court Administrative Division is very secretive about this system and refuses to answer questions even when subjected to a Colorado Open Records Act request. An example is that the Colorado Supreme Court states that there is no training or operating manuals for the clerks to study, use, and refer to when using the
Eclipse / Lexis Nexus File and Serve system.  As a result, there is no set rule as to when documents submitted to the court clerk are uploaded onto Eclipse and Lexis Nexus.  The court clerk, Tammy Herivel can change the file stamp times on both Eclipse and Lexis Nexis but she cannot change the
document no. and corresponding time that it was uploaded to Lexis Nexis. Three examples from this case exemplify the ability of court personnel, magistrates and judges to manipulate the system with the support and assistance of the Colorado Supreme Court. It needs to be noted here that Arapahoe County Head Clerk Tammy Herivel, is a member of the public access committee of the Supreme Court chaired by Supreme Court Justice Alex Martinez. As such Tammy Herivel is, or should be very familiar with the workings of the Eclipse and Lexis Nexis system and its provisions. Also on the committee with Tammy Herivel are Justice Roger Klein of the 19th District, Judge Leland Anderson of the 1st District, Miles Flesch of the 2nd District, Mike Reid of the 1st District Probation, Chris Yuhas of the 5th District, Bob Roper of the Judicial Business Integrated Technology Division of
the Colorado Supreme Court and Linda Bowers of the JBITS Division of the Colorado Supreme Court. Their Judicial Directive as provided on the Colorado Supreme Court Web page is as follows:

Public Access.Chief Justice Directive 05-01:

The court system's public records are open for inspection by any person at reasonable times except as provided by the Colorado Open Records Act or otherwise provided by federal or state
law, Colorado Supreme Court Rule, court order or local policy. The official custodian of any public records may make local policies regarding the inspection of records that are reasonably necessary for the protection of records and prevention of unnecessary interference with the regular discharge of the duties of the custodian or the custodians office.
The Criminal Justice Records Act ( 24-72-301
et.seq., C.R.S.) addresses court records in criminal proceedings. Two sections of note in the CJRA are:

- 24-72-304 C.R.S - the custodians authority to make rules and regulations for inspection of records. 

- 24-72-305 C.R.S. - the custodians authority to deny inspection if prohibited by law, Colorado Supreme Court rule, existing court order, or if disclosure would be contrary to the public interest. Public Access to Court Records.
Inspection of civil case records is determined by the Colorado Open Records Act unless otherwise provided by law. Included in the Act are the following provisions:

- 24-72-203(1) C.R.S. - the custodians authority to make rules and regulations regarding inspection of records.

- 24-72-204 C.R.S. - the custodians authority to deny inspection if inspection is contrary to law, Supreme Court rule, existing courto rder, or if disclosure would be contrary to the public interest.
The availability of juvenile records is primarily determined by the Childrens Code ( 19-1-301, et. seq., C.R.S.).
Directives issued by the Colorado Supreme Court Chief Justice and the judicial districts Chief Judge impact what public access is allowed with respect to information made, maintained, or kept by the courts. This document is designed specifically as a reference tool only. Refer to the Colorado Revised Statute citations included for more specific details.
Colorado Revised Statutes reiterates this directive in 13-1-119, Judgment record and register of actions open forinspection:

The judgment record and register of actions shall be open at all times during office hours for the inspection of the public without charge, and it is the duty of the clerk to arrange the several
records kept by him in such manner as to facilitate their inspection. In addition to paper records, such information may also be presented onmicrofilm or computer terminal. It would seem simple with these rules in place that is should/would be easy for one to see and review ones file. That was
not the case in dealing with Tammy Herivel, Head Clerk of Arapahoe County, Colorado. My case was removed to Arapahoe County District Court on December 18, 2008 at 8:31am. From that time forward, Arapahoe County District Court did not have an operable Public Access Terminal to view
my file. After numerous attempts by Tammy Herivel and Judge Charles Pratt to keep the matter under wraps and in-house; I finally filed an open records request with the Colorado Supreme Court. They referred me back to Tammy Herivel. She had conveniently forgotten to tell me that there was a PAT terminal in the Aurora division of Arapahoe County Court where I could review the records of the district court. Tammy Herivel, Edward Burns and Judge Charles Pratt were intentionally
keeping me from reviewing my file for over a year while they were manipulating it, not uploading files, destroying others, removing jury demands and taking actions against Peter Coulter while he was under the stay and protection of a Federal Court Order. It was at this time that I discovered the first two manipulations of Eclipse and Lexis/Nexus file and serve. See chapter 4 for 3 examples of manipulation of official court records in this case. 

is available at this website!

*Just type in 502469 and it appears as 'Consumer Comment #4' at Ripoff Report #502469.

Thank You

WELCOME TO THE U.S. LEGAL SYSTEM- WE PROTECT THE CORRUPT PEOPLE WHO WORK ON WALL STREET, THE GOVERNMENT, AND ANYWHERE ELSE IN THIS CORRUPT COUNTRY KNOWN AS THE USA

CORRUPTION POEM

It'll happen again
A financial eruption
'Cause the U.S. economy
Is based on corruption
Our leaders don't care
Their brains must be dead
Bowing down to their masters
The ones at the FED
Keeping Wall Street afloat
Killing Main Street each day
Politicians and big-shots
Still collecting their pay
This poem is over
But corruption is here
An eruption is coming
And that day is quite near.

End.

"CORRUPTION POEM" was originally posted at this site on January 6, 2011. Just type in 648567 and it appears as 'Consumer Comment #3' at Ripoff Report #648567.

Thank You

WELCOME TO THE LEGAL SYSTEM IN AMERICA- ONE BIG LIE

ROR is the wrong venue for your complaint against the judiciary of your state.  Publishing your motions and other "evidence" here is not going to accomplish a darn thing.

I suggest you retain an attorney to represent you in this manner.

Barring that, you should file a written complaint/appeal to your State Judiciary Board to protest the actions of the court.

If you wish to make a complaint on the grounds of "corrupt government,"  the FBI would be an appropriate venue.

You might also consider contacting your Congressional representatives as well as your State Legislature representative.

I wish you good luck, but you're wasting your time and bandwidth posting this stuff here.

turn their heads from the truth and protect the corrupt people who run the many corporations, companies, and even the government, because these corrupt people have what our legal system wants; MONEY!

My guess is that well over 50% of all the lawyers and judges in the USA are corrupt. I believe that well over 90% of the politicians in the USA are corrupt too.

The corrupt people who run the many corporations in the USA ultimately control the government, the military, the mainstream media, and of course- Wall Street. If you want to see who sits at the very top, just 'Google' this- WHO OWNS THE FED?, and go to the site with the 5 charts. The 'bankers' are the ones who really control this country. Much of our legal system protects these 'bankers', and the other so-called 'corporate elite'.

Some people in the mainstream media, the legal system, and in the corporate sector of this country, had information regarding the collapse of the U.S. economy and the stock market crash as early as April of 2005. They chose NOT to alert the American people about it because it would have EXPOSED the ones who ultimately control this CORRUPT country.

***Make sure to stay at this site and type in 271454 and read what was posted in 'Consumer Comment #1' at Ripoff Report #271454 on September 3, 2007. (Pay attention to what was stated in paragraph #3.)

Then type in 269041 at this site and read what was posted in 'Consumer Comment #3' at Ripoff Report #269041 on August 21, 2007. (Pay attention to what was stated in paragraph #4 and the rest of that comment.)

**Both consumer comments were posted a little over a year BEFORE the collapse of the U.S. economy and the stock market crash, which occurred on September 29, 2008. The mainstream media, corporate sector, and the legal system all knew!

WELCOME TO AMERICA- ONE MASSIVE LIE

Exhibit 10 shows the typical behavior and actions of Raymond Goodwin and the Court's (Judge Pratt) typical reaction.
Judge Pratt issued a final judgment and closed the case on April 5, 2009. Then, he opened it back up again and decided I could have a jury trial (had to pay for it again) that was to last 3 days.
We had set a date but it had to be set aside because I had no way of subpoenaing Brent Evans because according to the official court record, I never named him as a party and therefore Tammy Herivel wouldn't issue the summons for me, a pro se litigant. At one point in time I confronted her with the counter and cross-claim I had filed on December 18, 2008 which named Brent Evans and she went and asked Edward Burns what to do and of course he insisted that I needed a Court Order from Judge Pratt. (There is only one way to reform the official court record and that is through the Administrative Division of the Colorado Supreme Court. No judge has the authority or capability to correct court records on his/her own admonition.  It was just another act on the part of Edward Burns, Tammy Herivel and Judge Charles Pratt to hide their actions and violate the constitutional rights of Peter Coulter
In April, 2011, Raymond Goodwin in collusion with the Court (Judge Pratt) decide amongst themselves that they are going to set the trial for a one day trial to the Court instead of a 3 day jury trial that had been asked and paid for. Of course this was done while we hadn't even finished discovery and Peter Coulter had indicated to the Court that he had an amended complaint that he wished to file. The emails show that I objected to what Raymond Goodwin was doing and because he did not send any notice of the trial and put it on the record, I believed we were going to proceed through discovery and my amended complaint before attempting to set it for trial. That was not the case. On April 5, 2011, Raymond Goodwin sent me a Notice (Exhibit 11) that the trial was set for May 16 for a one day trial to the Court. I immediately called Judge Pratt clerk, Patricia, and asked her what was going on? I could tell she was shook up by the revelation and said she would get back to me. Then, the next day Judge Pratt issues an Order (Ex. 12) that indicates that it is his fault and covers for Raymond Goodwin once again. Judge Pratt's comment on his Order (Ex 12) does not match the E-mails of Raymond Goodwin made 4 months earlier.......

Raymond Goodwin of WAITROUS, EHLERS, MELKE & GOODWIN and as a member/manager of the Plaintiff, Union Stanford Properties along with associate John Brent Evans were asked formally 9 times for a copy of the lease to 2060 W. Radcliff and refused to comply. Then, 5 minutes before what was supposed to be a jury trial; Raymond Goodwin submitted two exhibits to the Court and Peter Coulter marked "A" and "B". A was a 12 pg. forged contract missing Audionly's signature and allegedly signed on September 19, 2002; a date that I have evidence that I wasn't even in the State of Colorado. Exhibit B (Exhibit 9 here) was another forged lease put forth by Raymond Goodwin to fraudulently convince the court that the offset of $17,000 I had requested as an offset counter-claim / cross-claim had been paid in the form of reduced rent. Exhibit 9 shows the lease for Lot "V" when in fact we leased lot "F" across the road. Peter Coulter questioned the authenticity of this document in front of Judge Pratt on March 31, 2009; and he ignored it. It was also brought up again in a Motion for Default Judgment against Brent Evans and again it was ignored.

If one looks at the last page of the fraudulent and forged contract where a diagram of the lot is depicted, and compare it to Exhibit 8; one can plainly see that Audionly occupied Lot F and not Lot V.  Raymond Goodwin has committed a Fraud on the Court by submitting known false documents that I believe he prepared. I have proof of this. The notary at Union Stanford's bank, Linda Green, notarized all 3 signatures, Brent Evans, Peter Coulter and Audionly in late July, 2002. The forged contracts presented by Raymond Goodwin and Brent Evans on March 31, 2009 to the Court and Peter Coulter had  Linda Greene's notary only on two signatures with the signature and notary of Audionly missing! The signing date of the Notary had been crossed out from July and written above Sept. with no initials. I asked Linda Greene about this and she indicated that she would usually not do this and if she had, she would have initialed it in accordance with Notary rules. On the other hand, I have found other documents where Raymond Goodwin was the notary and he crossed out the dates in the exact same way with no initials and installed a new date. Also, Linda Greene's signature is on file with the SOS. The "G" in her last name that is on file, looks nothing like the "G" on the forged document. (Expert has issued opinion that Peter Coulter's signature is forged) In fact, the G of Linda Greene's signature looks exactly like the G in Raymond Goodwins signature. All of this has been brought up in detail to Judge Charles Pratt who just ignored it. Again, he has to because he has decided to cover for the actions of his associates Edward Burns and Tammy Herivel in their theft of the counter claim, cross-claim, Brent Evans as a party, demand for Jury trial in the District Court and the $192 fee for the Jury trial in the District Court.

EXHIBIT 8 is the most telling of all the Exhibits. It is a 2004 Google Earth picture of Union Stanfords property. The lower part of the picture shows lot "F" which was leased to Audionly and Peter Coulter for $600 per month. ($100 off because there were truck tires and dirt taking up space.) Lot V at the top of the picture was occupied at the same time by another tenant. The forged and fraudulent lease that Raymond Goodwin and Brent Evans submitted to the Court (Exhibit 9) as Ex. "B" says that Peter Coulter rented Lot V for $1,250. The total difference in the rents that Peter Coulter and Audionly were paying on Lot F and the forged lease that Raymond Goodwin provided the Court on March 31, 2009 is for the total term of the lease was/is $17,000; the exact amount of the counter and cross claim that Peter Coulter originally filed against Union Stanford Properties and John Brent Evans on December 18, 2008. Judge Pratt would not let me present the counter and cross-claim at the trial because according to the "official court record", I never filed them. The exhibits show that I did file them but that they were then removed by Tammy Herivel and Edward Burns and Judge Pratt was covering for their acts.

This is the transcript of a hearing that was held without Peter Coulter present where the Court now decides to allow Raymond Goodwin (who is acting both as attorney and as a manager/member of of Union Stanford Properties) to bring in Audionly after the Judgement was rendered by Judge Pratt, without leave and without notice and presence of Peter Coulter to the hearing.

Attached are the Exhibits for the Motion to Recuse Judge Charles M. Pratt. 

The last page is an opinion of an expert handwriting analyst who indicates that Peter Coulter's signatures and initials on the associated contract  for 2060 West Radcliff that Raymond Goodwin and Brent Evans submitted to Peter Coulter and the Court (Judge Pratt) on March 31, 2009 are forged. This fact was brought to the attention of Judge Pratt in a Forthwith Motion to Reconsider on April 6, 2009. Judge Pratt ignored these facts. He had to in order to cover up the actions of his associates Edward Burns and Tammy Herivel.