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Coulter and her attorney, John A. Berman, Esq. that Paula <br />Coulter had a valid Power of Attorney, when in fact she <br />knew she didn't. <br />the victim suffers loss of money and /or property as a result of relying upon and <br />acting upon the untrue representation. <br />Through Paula Coulter's misrepresentations, hundreds of <br />thousands of dollars has either been misappropriated or <br />is missing from Irene Coulter's accounts. Additionally, <br />Mrs. Coulter's largest asset (3/4 interest in 400 acres) <br />is unaccounted for. And the most shameless act was the <br />movement and desecration of our Father, Leland Coulter's <br />remains. <br />18. As an aggravating circumstance, it must be brought to <br />the Court's attention that 3 years before either of these 2 <br />Powers of Attorney were signed, there were 27 police <br />reports [See Addendum 5] of Mrs. Coulter believing <br />neighbors were coming in through her front door keyhole, <br />molesting her cat and stealing her food. She was clearly <br />demented and Paula and Ted Coulter both shoved Powers of <br />Attorney and a Will in front of her and had her sign them <br />without knowing what she was doing. They took advantage of <br />a person at risk who happened to be their own Mother. They <br />were /are both so greedy that they were each even willing to <br />sabotage each other to get Irene Coulter's entire assets. <br />19. "Fraud upon the court" has been defined by the 7th <br />Circuit Court of Appeals to "embrace that species of fraud <br />which does, or attempts to, defile the court itself, or is <br />a fraud perpetrated by officers of the court so that the <br />11 <br />