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and any acts Paula Coulter transacted for Irene <br />Coulter after June 19, 2006 are both void and <br />fraudulent including the submission of her Sworn <br />Petition to the Jefferson County District Court <br />to be Mrs. Coulter's Conservator and Guardian. <br />17. Ted Coulter used his subsequent exclusive Fiduciary Power <br />of Attorney as agent to sell Mrs. Coulter' S4 home by Warranty <br />Deed and no Title Insurance for $275,000 to a suspect <br />investor who immediately turned around and sold it for <br />$274,000 by Warranty Deed without Title Insurance. See <br />Addendum 4.5 The Appellant believes that the investor received <br />a kickback from Ted Coulter but has been unable to prove that <br />because Paula Coulter continually refuses to turn over <br />detailed financial documents despite numerous requests and <br />Court Order S6. It raises the question of why would anyone buy <br />a property for $275,000 and two months later sell it for <br />$274,000 without a title policy being provided? <br />18. Neither Paula Coulter, her attorney John Berman <br />or Ted Coulter ever disclosed to anyone, <br />including the Court, that there was a subsequent <br />4 Mrs. Coulter qualifies as an at risk adult under C.R.S. 18 -9 -113, Financial Exploitation of an at risk adult. See <br />Addendum 5 where the 27 Littleton police report from 2002 -2005 indicate that she believed neighbors were <br />coming through her front door key hole; molesting her cat and stealing her food. <br />5 The Movant believes that the present owners of Mrs. Coulter's home (Mr. and Mrs. Perry) will want to join in this <br />action of Paula Coulter, Ted Coulter and John Berman, Esquire's fraud to protect their warranty deed and cash <br />purchase of Mrs. Coulter's previous home. <br />6 See for example the Appellant's Motion to Reconstruct the Record filed October 10, 2013 showing Paula Coulter <br />and John Berman's continued refusal to follow Court Orders and conceal records. <br />