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Case 1:05-cv-01738-RPM-CBS Document 1-1 Filed 09/07/2005 Page 4 of 7 <br />is <br />The real estate is more specifically described in a deed recorded in the real estate records of Las <br />Animas County, Colorado, at Deed Book 892, pages 716-719, and in Deed Book 1046, pages 411- <br />416. <br />12. On February 3, 2005, in the United States District Court for the Western District of <br />Virginia, MLO recovered a judgment against the Tatums, jointly and severally, in Civil Action No. <br />3:03CV00035, which is styled Morris Law Office, P.C. v. James Eddie Tatum, Ann Tatum, and Tee <br />Engineering Co., Inc. (the "Virginia Judgment"). The principal amount of the Virginia Judgment is <br />$152,525.94. <br />13. MLO a creditor of each of the Tatums within the meaning of that term in CRS § § 38- <br />2-102(5), 38-2-105, and 38-2-106 because MLO has a right to payment of the Virginia Judgment. <br />• 14. On February 23, 2005, MLO registered the Virginia Judgment in this Court in Civil <br />Action No. 05-RJ-7, which is styled Morris Law Office, P.C. v. James Eddie Tatum and Ann Tatum. <br />15. On March 11, 2005, MLO recorded in the real property records of Las Animas <br />County, Colorado a transcript of the Virginia Judgment, as registered in this Court. <br />16. On February 17, 2005, the Tatums jointly and severally conveyed their interest in the <br />subject property to Solitario Purgatory, L.L.C., by deed recorded in the real property records of Las <br />Animas County, Colorado, in Deed Book 1046, pages 411-416. <br />17. Each of the Tatums conveyed the subject property to Solitario Purgatory, L.L.C., with <br />actual intent to hinder, delay, or defraud MLO. <br />18. Upon information. and belief, each of the Tatums is a "person in control" of Sol_itari_o <br />Purgatory, L.L.C., within the meaning of that term in Colorado Revised Statutes ("CRS") § 38-2- <br />-4-