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best friend and caretaker) into Irene Coulter's sole account <br />in the approximate amount of $75,000 without knowledge or <br />consulting of any other family members or Mrs. Coulter's <br />attorney and son in law of 30 years, William A. Powers, Esq. <br />and thereafter removing it in the form of "gifts" to Ted and <br />Paula Coulter at Paula Coulter's direction. <br />• To fraudulently sell /donate Mrs. Coulter's car; <br />• To fraudulently place Mrs. Coulter into Atria <br />Center; <br />• To fraudulently and flagrantly "gift" Paula Coulter <br />and Ted Coulter a minimum' of $190,000 between the <br />years of 2006 and 2010, contrary to the past <br />history and gifting habits of Irene Coulter and <br />without knowledge or consultation of any other <br />family members or Mrs. Coulter's attorney, William <br />Powers. <br />• To fraudulently act as Mrs. Coulter's agent in <br />dealing with the Colorado Division of Mines in <br />dealing with Mrs. Coulter's largest asset, a 3/4 <br />interest in 400 acres owned jointly with Richard <br />1 Paula Coulter has had custody of Irene Coulter's financial records since at least 2005. The record indicates that <br />even though requested and ORDERED to provide complete financials; to date that has never happened. The <br />$190,000 is all Peter Coulter could piece together from information obtained and believes the figure is much <br />higher than that. <br />