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• To fraudulently and flagrantly "gift" Paula Coulter and Ted <br />Coulter a minimum' of $190,000 between the years of 2006 and <br />2010, contrary to the past history and gifting habits of Irene <br />Coulter and without knowledge or consultation of any other <br />family members or Mrs. Coulter's attorney, William Powers. <br />• To fraudulently act as Mrs. Coulter's agent in dealing with <br />the Colorado Division of Mines in dealing with Mrs. Coulter's <br />largest asset, a 3/4 interest in 400 acres owned jointly with <br />Richard Vento through an LLC (South Central Land and Mining). <br />• To fraudulently profess to the Court in Mrs. Coulter's <br />current probate hearing (2013PR56 Jefferson County) that the <br />Will Paula Coulter provided is valid because the April 21, 2006 <br />Power of Attorney was previously found valid by the District <br />Court. <br />• To flagrantly desecrate the remains of Leland Coulter who <br />had been laid at peace for 22 years, by filing a fraudulent and <br />misleading document with the District Court. <br />• And most pertinent here, to act with fraud, Fraud on the <br />Court and Conspiracy to commit Fraud on the Court in a sworn <br />Petition filed with the Jefferson County District Court to be <br />Mrs. Coulter's Conservator and Guardian. <br />1 Paula Coulter has had custody of Irene Coulter's financial records since at least 2005. The record indicates <br />that even though requested and ORDERED to provide complete financials; to date that has never happened. <br />The $190,000 is all Peter Coulter could piece together from information obtained and believes the figure is <br />much higher than that. <br />9 <br />