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Everyone, including the Court believed Paula Coulter's <br />assertion that she had Power of Attorney under the April <br />21, 2006 document. <br />3.) the victim relies upon and acts upon the untrue representation; <br />The following all relied on Paula Coulter's fraudulent <br />assertion that she had a valid Power of Attorney for the <br />affairs of Irene Coulter: <br />Smith Barney, Colorado Division of Mines, Wells Fargo Bank, <br />Sheryl Powers Estate, Marty Powers, William Powers, Esq., <br />Jean Powers, Esq. Lora Powers, Olinger Crown Hill Cemetery, <br />the City of Florence, Colorado,(Highlands Cemetery) <br />Colorado Department of Mines, Dr. Cobb, (Mrs. Coulter's <br />doctor) Atria Center, South Central Land and Mining, Dick <br />Vento (partner of Irene Coulter), Linda Saunders and <br />Bertina (co- owners of land in Fremont County) court <br />witnesses Marie Perigren(sp) and Martha and John Saviers, <br />Esq.; and especially the Court all relied upon the <br />fraudulent and sworn representations of Paula Coulter and <br />her attorney, John A. Berman, Esq. that Paula Coulter had a <br />valid Power of Attorney, when in fact she knew she didn't. <br />4.) the victim(s) suffer(s) loss of money and /or property as a result of relying upon and <br />acting upon the untrue representation. <br />Through Paula Coulter, Ted Coulter and John Berman's <br />fraudulent misrepresentations, hundreds of thousands of <br />dollars has either been misappropriated or is missing from <br />Irene Coulter's accounts9. Additionally, Mrs. Coulter's <br />largest asset (3/4 interest in 400 acres) is unaccounted <br />for. And the most shameless act was the movement and <br />desecration of our Father, Leland Coulter's remains. <br />22. As an aggravating circumstance, it must be <br />brought to the Court's attention that 3 years <br />before either of these 2 Powers of Attorney were <br />signed, there were 27 police reports [See <br />Addendum 5] of Mrs. Coulter believing neighbors <br />9 The Appellant believes the figure to be in excess of $1,000,000 but an accurate figure cannot be acquired until a <br />complete forensic accounting of Mrs. Coulter's accounts is ORDERED by the Court. <br />