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JEFFERSON DISTRICT COURT, COLORADO

100 Jefferson County Parkway, Golden CO 80401


720.772.2500
______________________________________________________

Lance Cassino,

Plaintiff;

v.

Corporate Officer/Agent: J.P. Morgan Chase Bank; Corporate


Officer/Agent: Mortgage Electronic Registration Systems, Inc.;
Corporate Officer/Agent: Community Mortgage Group, Inc.;
Corporate Officer/Agent: Union Federal Bank of Indianapolis;
Corporate Officer/Agent: Sky Bank as Successor in Interest to
Union Federal Bank of Indianapolis; Corporate Officer/Agent: First
National Bank of Tennessee as Successor in Interest to Sky Bank;
Corporate Officer/Agent: Huntington National Bank, successor by
merger; Federal Deposit Insurance Corporation as receiver;
Corporate Officer/Agent/Receiver: Washington Mutual Bank and/or
its Receiver FDIC-R; Public Trustee Jefferson County, and; all
unknown persons, John and Jane Does who claim any interest in the
subject matter of this action,

Defendants. COURT USE ONLY

BULLOCK LAW L.L.C. Case No: 2017cv231


Attorneys for Plaintiff
By: Tim Bullock Reg. No. 35239 Division:
827 Good Hope Drive
Castle Rock, CO 80108
(p) 888.682.3788, (f) 303.495.2198, Bullocklaw@Gmail.com

VERIFIED SECOND AMENDED COMPLAINT IN PARTITION AND QUIET TITLE

Plaintiff Lance Cassino, through undersigned counsel, through this Second Amended
Complaint claims as follows (proposed amendments to the current, operative Amended
Complaint are italicized. Exhibits 1-9 referred to herein are those same exhibits filed on 8/8/17
with the first Amended Complaint. Exhibits 10, 11 and 12 are introduced for the first time filed
with this Second Amended Complaint).

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I. JURISDICTION & VENUE

1. Jurisdiction in this Court is proper pursuant to C.R.S. 13-1-124(1)(c).

2. All the real property which is the subject of this matter is located in Jefferson County,
Colorado making venue proper under C.R.C.P. Rule 98.

II. BACKGROUND

3. This is an action to partition, reform legal description and quiet title in real property. It is
a proceeding in rem.

III. THE PARTIES

The Legal Owner

4. Cassino, an individual, is the legal owner of two parcels in Jefferson County more
specifically identified as:

Northeast Quarter Northwest Quarter (NE ) of Section 10, Township 7


South Range 71 West of the 6th Principal Meridian, Jefferson County,
Colorado, [containing approximately 40 acres (Parcel 1 recorded
7/19/99 at Reception No.F0910679)], and;

East Half Southeast Quarter Northwest Quarter Northwest Quarter (E


SE NW NW ) of Section 10, Township 7 South, Range 71 West of
the 6th Principal Meridian, Jefferson County, Colorado, [containing
approximately 5 acres (Parcel 2 recorded 12/16/99 at Reception No.
F0992014)].

5. The parcels abut each other and will collectively be referred to herein as Parcels I & II
or as the Parcels.

6. All improvements including Plaintiffs two story residence, a detached garage and a shed
are located on Parcel I with a street address of: 13883 South Wamblee Valley Road, Conifer
Colorado, 80433.

7. A portion of this land was gifted to Cassino by a family member and Cassino has
superior title over all defendants.

The (putative) Mortgagee

8. J.P. Morgan Chase, N.A. (hereafter Chase); as an independent financial institution or;
as successor in interest or; as a servicer, and/or; as a trustee on behalf of a Real Estate Mortgage

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Investment Conduit (REMIC) trust may wrongfully claim to be a holder, qualified
holder,holder in due course or may assert some other claim or interest in Parcels I or II or
both.

8.1 By belief or knowledge, Chase asserts that it is successor in interest to the Casino parcels.

8.2 Any claim alleged by Chase is invalid and/or unenforceable by virtue of C.R.S. 38-39-207
and 13-80-103.5(1)(a).

9. All Defendants claims, if any, in any capacity are without foundation or right.

The Encroaching Parties

10. In 2012, a minor encroachment from a neighboring property onto Parcel II was
discovered.

11. The encroaching property, 29310 South Sunset Trail, is owned by individuals Mark and
Leigh Ann Jordan.

12. Amongst themselves Cassino, the Jordans and the Jordans contractors, Cedar View
Homes - Leigh Ann and Marc Jordan, reached agreement and settlement to reconfigure the lot
lines to accommodate the Jordans existing structure/encroachment at 29310 South Sunset Trail
subject to approval of the county and the mortgagee (Chase wrongly claims to be the mortgagee
of parcels I & II).

13. As between Cassino and the Jordans, the parties have agreed that Cassino will sell 0.40
acres from Parcel II subject to county approval of the Minor Variation Request. Exhibit 1.

14. The county approved the Minor Variation Request on 3/9/17 (pursuant to 1.P of the
Jefferson County Zoning Resolution) allowing for lot sizes of 5.51 acres (Jordans) and 4.71 acres
(Cassino Parcel II) Exhibit 2.

15. To date, the transaction is unable to consummate because of the putative and false
mortgagee interest claimed by Chase and possibly others.

Purchasing Parties

16. John T. and Rebecca S. McSweeney are parties who entered a contract with Cassino for
purchase of a 4.7 acre portion of the described parcels.

17. This transaction has been unable to proceed because of the putative and false mortgagee
interest claimed by Chase and possibly others.

Mortgage Electronic Registration Systems, Inc.

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18. Mortgage Electronic Registration Systems, Inc. (hereafter MERS) is a recording
platform which never owns, nor is assigned, any beneficial interest in any of the properties it
records.

18.1 By belief or knowledge, MERS purports or is purported to have executed that certain
document entitled Corporate Assignment of Deed of Trust dated 9/21/11 on behalf of
Community Mortgage Group, Inc. (CMG). Exhibit 8

18.2 At the time MERS purported to execute the Corporate Assignment of Deed of Trust
dated 9/21/11 on behalf of CMG, CMG had been out of business for approximately five years.

18.3 At the time MERS purported to execute the Corporate Assignment of Deed of Trust, the
signor Mr. Benito Caldwell, (who signed this document in his official capacity as Assistant Vice
President of MERS) was at all times in fact an employee of Chase, in its Delray Beach, Florida
branch.

18.4 At the time MERS purported to execute the Corporate Assignment of Deed of Trust, the
Notary, Michelle Burr, was an Operations Senior Specialist at the Westerville, Ohio branch of
Chase and:

a) had a conflict of interest in notarizing any Chase document;

b) by belief or knowledge, never personally witnessed the signing of the Corporate


Assignment of Deed of Trust as alleged to be executed by Benito E. Caldwell
given the geographical distance between the two Chase branches.

18.5 According to an expert forensic document examiner, The Corporate Assignment of Deed
of Trust, bears evidence of digital manipulation and multiple editing. Exhibit 10

19. By belief or knowledge, MERS never was a custodian of any promissory note or any
other mortgage document of the properties it records including the parcels that are the subject of
this suit.

20. By belief or knowledge, MERS never had any beneficial interest in Parcels I or II and
was never given recipient of legitimate and lawful Power of Attorney on behalf of the true
beneficial owner of these parcels such that MERS never had power to assign a purported interest
in Parcels I or II to any third party.

21. MERS is a wholly owned subsidiary of MERSCORP Holdings.

22. By knowledge or belief, MERS has previously dis-claimed any beneficial interest
(ownership) in Parcels I & II by virtue of allowing entry of that certain document entitled Clerks
Entry of Default filed in Jefferson District Court Case No. 2011CV4858 filed 2/24/12. Exhibit
3.

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23. If MERS claims any interest in Parcels I or II, such claims are without foundation or
right.

Community Mortgage Group, Inc.

24. Community Mortgage Group, Inc. (hereafter CMG) was a financial institution doing
business in Colorado and originated the mortgage on some of the land which is the subject of this
complaint.

25. CMG closed its business in 2005 - 2006.

26. Successors of CMG, the identity of whom is unclear, may claim an interest in Parcels I
& II.

27. CMGs claims and any claims of its successors are without foundation or right.

28. By knowledge or belief, CMG has dis-claimed any beneficial interest (ownership) in
Parcels I & II by virtue of allowing entry of that certain document entitled Clerks Entry of
Default filed in Jefferson District Court Case No. 2011CV4858. Exhibit 3.

29. If CMG claims any interest in Parcels I or II, such claims are without foundation or right.

Washington Mutual Bank, F.A.

30. Washington Mutual Bank, F.A. (hereafter WAMU) was a financial institution doing
business in Colorado and appears to be one of two assignees of the Note on some of the land
which is subject of this suit which is the subject of the original mortgage originated by CMG.

31. WAMU collapsed in 2008 and went into FDIC receivership.

32. Successors of WAMU and the identities of the beneficial interests it held after its collapse
are unclear.

33. WAMU or its successors may claim an interest in Parcels I & II.

34. WAMUs claims and any claims of its successors are without foundation or right.

Federal Deposit Insurance Corporation

35. The Federal Deposit Insurance Corporation (hereafter FDIC) is a United States
government institution providing insurance to depositors in U.S. banks.

36. The FDIC does business in Colorado and may have some claim on a portion of Parcels I
or II by virtue of insuring depositors of WAMU.

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37. Successors of WAMU and the identities of the beneficial interests they hold after its
collapse are unclear.

38. The FDIC may claim an interest in Parcels I & II.

39. If the FDIC claims any interest in Parcels I or II, such claims are without foundation or
right.

Union Federal Bank of Indianapolis

40. Union Federal Bank of Indianapolis (hereafter (UFBI) was a financial institution doing
business in Colorado and appears on the alonge to the Note as the successor-in-interest. Exhibit
7.

41. By knowledge or belief, UFBI is no longer in business as it merged with successor Sky
Bank.

42. UFBI and its successors may claim an interest in Parcels I & II.

43. Claims of UFBI and its successors are without foundation or right.

Sky Bank

44. Sky Bank (hereafter (Sky) was a financial institution doing business in Colorado.

45. By knowledge or belief , Sky was successor in interest to UFBI by merger.

46. By knowledge or belief, Sky is no longer in business as it may have merged with First
National Bank of Tennessee (FNBT).

47. Sky and its successors may claim an interest in Parcels I & II.

48. These claims are without foundation or right.

First National Bank of Tennessee

49. FNBT was a financial institution doing business in Colorado.

50. FNBT and its successors, if any, may claim an interest in Parcels I & II.

51. These claims are without foundation or right.

Huntington Bank

51.1 The Huntington Bank was a financial institution doing business in Indiana.

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51.2. The Huntington Bank and its successors, if any, may claim an interest in Parcels I & II.

51. 3 These claims are without foundation or right.

The Public Trustee of Jefferson County

52. The Jefferson County Public Trustee (hereafter Trustee) operates as trustee for real
property located in Jefferson County Colorado.

53. Both Parcels are located in Jefferson County Colorado.

54. Any interest the Trustee asserts on behalf of any party other than Cassino are without
foundation of right.

55. By its filing dd 11/29/11 in Jefferson District Court Case No. 2011cv4858, the Trustee
has already disclaimed all right, title and interest under any deed of trust which may encumber
the parcels without waiving any right or power of sale otherwise in said property which any
beneficiary or any other person may have. Exhibit 4.

56. If the Trustee claims an interest in Parcels I & II, its claims are without foundation or
right.

IV. GENERAL AVERMENTS

57. In 2012, Chase hired surveyor, Evergreen Surveying, to survey both parcels of land, and
to reform a legal description which would encompass Parcel IIs vacant 5.1 acres together with
the adjoining 5 acres with its home and outbuildings within Parcel Is 40.9 acres.

58. This survey was done in anticipation that upon any refinance, this new legal description
would be used to encumber only 10 acres of ground, including Defendants home, and which
would provide adequate collateral for any new loan obtained.

59. In September 2005, Cassino executed a $200K Note in favor of CMG.

60. As security for the Note, Cassino executed a $200K Deed of Trust in favor of MERS
acting as nominee of CMG encumbering Parcel II recorded 10/6/05 at Reception No.
2005094330. Exhibit 5.

61. By belief or knowledge, the Promissory Note for the above transaction was subsequently
assigned to Washington Mutual Bank F.A. while its alonge reflected a contradictory assignment
by CMG to Washington Mutual Bank, F.A. and UFBI. Exhibits 6 & 7.

62. At all times, up to and during the closing, Cassino believed and intended that the new 10
acre legal description for home and property would be used instead of the 45 acre legal

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descriptions for home and property - to provide the collateral for a future loan and this would be
reflected on the Deed of Trust.

63. In fact, the Deed of Trust securing the Promissory Note only encumbered the vacant 5.1
acre parcel Parcel II.

64. CMG went out of business 2-3 months or so after the closing on 9/26/2005.

65. Six years after CMG went out of business, Chase caused to have recorded in the county
records of Jefferson County that patently false document entitled Corporate Assignment of Deed
of Trust alleging an assignment by MERS, as nominee of CMG, the deed of trust for Parcel II
dated 9/21/11. Exhibit 8. Commented [LRC1]: And almost six years after after closing
date of trust December 23, 2005. And 6 months after they claimed
PETE status with NOEDFS recorded 3-17-2011.
66. Without producing the original note or providing any chain of title evidence, Chase
alleged itself to be ultimate successor in interest and beneficial interest owner of Cassinos
obligation to CMG (Parcel II only).

66.1 By belief or knowledge, Chase and/or MERS do not have a copy of the original Note and
are unable to produce the original copy with alonges.

66.2 By belief or knowledge, Chase and/or MERS were not entitled to enforce the Note and
one or more alonges at the time the note was lost.

66.3 Chase does not establish its right to enforce the note by virtue of its Affidavit of Lost
Instrument executed by Serina Lee in that it claims status merely as a custodian (not the
owner) of the Note. Commented [LRC2]: Affidavit of Lost Note executed by
Ashley Jordan

67. Chase was servicing the account but refused to accept payments from Cassino after
12/15/2010 despite tender by Cassino. Commented [LRC3]: Chase refused to accept payments in
retailiation for Cassino retaining Mitchell J. Stein & Assoicates for
either a loan modification if Chase was holder in due course or if
68. On November 16, 2011 Chase filed a complaint alleging default and to reform the deed not, quiet title.
of trust. Commented [LRC4]: This was 8 months after Chase in
retailiation for retaining an attorney refused Cassinos payments.

69. Chase proceeded to foreclose Parcel II in Jefferson County District Court, Case No.
2011CV4858.

70. Chase was not the owner of the promissory note, could not produce the original and could
not demonstrate through chain of title that it was a Holder, Qualified Holder, Holder in Due
Course (HDC) or beneficial owner of any note whether duly negotiated or endorsed in blank
for Parcels I or II.

70.1 Cassino is not obligated to pay the Note to Chase because Chase does not have the rights
of a holder, an HDC or an assignee and the Note has been either lost or stolen.

71. During the course of these proceedings Chase:

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a) mis-led the Court in Jefferson District Court case 2011CV4858 by falsely
asserting that they were the real party in interest and the sole owner and
beneficiary of the evidence of debt [Chases contention that it is the holder of the
evidence of debt is directly contradicted in sworn testimony on 5/9/12 during
the deposition of Lawrence Nardi, a Chase operations unit manager and officer.
J.P. Morgan Chas Bank, N.A. v. Waisome, Cir.Ct. 5th Cir. Lake County
Florida, Case No 2009CA005717] Exhibit 9.; Commented [LRC5]: Still no mention of FDIC v Chase Exhibit
D paragraph 13 Chase not successor in interest to WaMu loans.

b) recorded a false Corporate Assignment of Deed of Trust (to Chase) from MERS
as a nominee of CMG. This alleged assignment is dated 9/21/11 more than
five years after CMG went out of business. Upon examination of the assignment
by an expert document analyst, there is strong irrefutable evidence of multiple
editing, photocopying and creation of a composite image. This document was
recorded 9/28/11 at Reception No.: 2011087676. Exhibit 8.

c) caused to be recorded a lis-pendens in the real property records of Jefferson


County on or about 8/24/17 asserting a claim to one or more parcels in which it
has no equitable or lawful interest.

d) mis-leads this Court that it has a legal or equitable interest in one or more
parcels by filing an affidavit of lost instrument in which:

i) it contradicts itself in that it claims the original Note is lost yet, in the
same affidavit, claims Chase it is the custodian (not the owner) of the
Note;

ii) it presents Chase as merely the servicer of the loan without representing
that Chase has any beneficial interest or lawful or equitable right to claim
ownership in the Note or these parcels;

e) presents a partial copy of a Whole Bank Purchase Agreement which Chase


would have this Court believe gives it the right to assert a legal or equitable
interest against the property despite:

i) the Agreement contains no accompanying loan-level detail [as called


for in 9.6(c)[Exhibit 12] in the Agreement itself (like a bill of sale,
receivers deed, trustees deed, loan ledger etc.]. See also Section 3.3
which reads:

THE CONVEYANCE OF ALL ASSETS, INCLUDING REAL AND


PERSONAL PROPERTY INTERESTS, PURCHASED BY THE
ASSUMING BANK UNDER THIS AGREEMENT SHALL BE
MADE, AS NECESSARY, BY RECEIVER'S DEED OR RECEIVER'S
BILL OF SALE, . (emphasis in the original). )[Exhibit 12].

ii) Chase has not produced the foregoing detail or documentation.

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iii) the Agreement is more accurately characterized as an unexercised
option to purchase (See 3.2 of the Agreement to wit: [a]ll Assets
and assets of the Failed Bank subject to an option to purchase. It
does not/cannot transfer real property rights without the called for
documents of title.

72. On March 15, 2013 CHASE entered a Settlement Agreement paying Cassino and
dismissing Jefferson District Court 11 CV 4858 case by stipulation without quieting title to the
Parcels.

V. CLAIMS FOR RELIEF

Interference with Contractual Relations


(Chase)

73. Cassino incorporates by reference paragraphs 1 through 72 into the following claims.

74. Chase has caused to have filed in the county records of Jefferson County a patently false
and forged document entitled Corporate Assignment of Deed of Trust which represents to the
world that Chase has a beneficial interest in Cassinos real property as the mortgagee. Exhibit 8.

74.5 Chase has also caused to be filed a lis pendens in the real property records of Jefferson
County in which Chase falsely asserts an interest in one or both parcels preventing Cassino his
right to alienate, sub-divide, re-configure or re-zone either of his parcels.

75. Cassino is attempting to sell a portion his property to Mark and Leigh Ann Jordan to
address the encroachment and for which reconfiguration is not possible as long as Chase claims
an interest as mortgagee and is unwilling to sign off on the plat.

76. Cassino has a contract for the reconfiguration and sale of a portion his property John T.
and Rebecca S. McSweeney which reconfiguration and sale is not possible as long as Chase
claims an interest as mortgagee.

77. Chase is aware of the pending reconfigurations and sales.

78. Chases interference and claims are improper in that Chase has no beneficial or
enforceable interest in the Parcels.

79. Chases interference has caused, and continues to cause, Cassino, the Jordans and the
McSweeneys damage.

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Fraud/Misrepresentation
(Chase and MERS)

79.1 Cassino incorporates by reference paragraphs 1 through 79 into the following claims.

79.2 By belief or knowledge, Chase and MERS created, caused to be created or participated
in the creation of that certain false document entitled Corporate Assignment of Deed of Trust.

79.3 The Corporate Assignment of Deed of Trust is used by Chase in an attempt to establish
its status as a holder-in-due-course (HDC) from WAMU, along with other documents which do
not establish such status.

79.4 Chase presents no proof that WAMU had the Note or the Deed of Trust on its books at
the time WAMU went into receivership.

79.5 The status of Chase a HDC is unproven given that Chase can not/has not produced the
original evidence of debt.

79.6 At the time the Corporate Assignment of Deed of Trust was presented either in public
record or in litigation, Chase and MERS either:

a) knew the Assignment was false, or;

b) were aware that they did not know whether the Assignment was true or false, or;

c) knew or should have known that CMG was no longer in business or otherwise
viable;

d) knew or should have known that MERS never possessed a beneficial interest in
either parcel which it could lawfully or equitably transfer.

79.7 Chase and MERS created the Assignment with the intent that the Plaintiff and others rely
on it to establish the false narrative that Chase had/has a viable claim to the Property, or a
portion of it.

79.8 The Corporate Assignment of Deed of Trust is a scanned composite photocopy that has
been edited multiple times by software and is not genuine. The specifics of this allegation are
particularized in Exhibit 10.

79.9 Introduction of the forged Assignment into the public record and this litigation has
caused, and is causing, Cassino damage and threatening his lawful claim to one or more of his
parcels and the inability to alienate, sub-divide or re-zone one or more parcels.

Spurious Documents
(Chase)

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79.10 Cassino incorporates by reference paragraphs 1 through 79.8 into the following claims.

79.11 The Corporate Assignment of Deed of Trust and Lis Pendens are a spurious documents
pursuant to C.R.S. 38-35-201(3) & (4).

79.12 By belief or knowledge Chase caused the Assignment to be recorded in the real property
records of Jefferson County on 9/28/11 at Reception No.: 2011087676.

79.13 By belief or knowledge Chase caused the Lis Pendens to be recorded in the real property
records of Jefferson County on, or about, 8/24/17.

79.14 Accordingly, the Assignment and Lis Pendens are spurious documents within the
meaning of C.R.S. 38-35-201 et. seq. and C.R.C.P. 105.1, entitling Cassino to anOrder to
Show Cause as to why they should not be declared invalid entitling Cassino to costs and
reasonable attorneys fees.

Fair Debt Collection Practices Act (FDCPA)


(Chase)

79.15 Cassino incorporates by reference paragraphs 1 through 79.14 into the following claims.

79.16 Chase is engaged in the collection of debts from consumers using the mail and is a debt
collector as this term is defined by the FDCPA 15 U.S.C. 1692a(6).

79.17 By correspondence on Chase letterhead dated 9/16/17, Chase mailed a collection letter
to Cassino demanding accelerated payment of $127,477.99. Exhibit 11.

79.18 Exhibit 11 was received by Cassino at his residence in Jefferson County Colorado.

79.19 The alleged debt is, by its nature, incurred for personal, family or household services.

79.20 The Chase statement claims that Cassino has missed payments from 11/01/10 and
declared the entire debt due.

79.21 Chase has threatened to take action to dispossess Cassino of his home without legal
ability to do so.

79.22 Payments were tendered by Cassino, but refused by Chase, at a time when Cassino was
under the mistaken belief that Chase had rightful claim to such payments.

79.23 Payments alleged as owing by Chase are extinguished by the statute of limitations
barring foreclosure under any deed of trust.

79.24 Chase has no present, lawful right to some/all payments alleged as owing under either
the Note or Deed of Trust in violation of 15 U.S.C. 1692f(6) & (1).

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79.25 As a result of the acts alleged above, Cassino has suffered headaches, nausea,
embarrassment, lost weight and has incurred necessary legal expenses to defend his property.

Quiet Title
(All Defendants)

80. Cassino hereby incorporates by reference paragraphs 1 through 79.25 and prays for legal
and equitable relief as follows:

A. complete abjudication of the rights of all parties to this action;

B. a decree determining that no Defendant has an interest, estate, claim of any kind
whatsoever in the Parcels;

C. enjoinment by any Defendant from asserting any claim or title against either
parcel;

D. quieted title in the name of Cassino;

E. a decree that Cassino is the owner in fee simple and so entitled to possession of
the Parcels;

F. a decree reforming parcels as between Cassino and the Jordans pursuant to the
plat labeled as Exhibit 1 and the Administrative Decision Memorandum
approving the Minor Variation dated 3/9/17 labled as Exhibit 2;

G. for costs and attorneys fees and such other relief as the Court deems just and fair;

H. for this Court to issue a Show Cause Order in accord with C.R.C.P. 105.1;

I. For the entry of an Order declaring the Corporate Assignment of Deed of Trust
filed by Chase to be a spurious, digitally manipulated document.

J. for the entry of an Order awarding Cassino damages pursuant to C.R.S. 38-35-
109(3) and its reasonable attorneys fees and costs pursuant to Rule 105.1 and
C.R.S. 38-35- 109(3) and 38-35-204 against Chase and MERS.

K. for the entry of an Order requiring surrender of the proceeds from bond no.
106618578 issued by Travelors Casualty and Surety Company of America to
Cassino.

L. for the entry of an Order declaring the purported Corporate Assignment of Deed
of Trust to be invalid;

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M. a declaratory judgment that Chases conduct violates the FDCPA entitling
Cassino to actual damages, statutory damages, costs and attorneys fees (15
U.S.C. 1692k).

O. for such other and further relief as the Court may deem just and proper.

dd: 10-9-17 BULLOCK LAW L.L.C.

s:/ Tim Bullock


Attorney for Plaintiff
By: Tim Bullock
827 Good Hope Drive
Castle Rock, CO 80108
(p) 888.682.3788, (f) 303.495.2198
Bullocklaw@Gmail.com

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VERIFICATION

I, Lance Cassino verify, certify and affirm as follows:

1. I am over the age of 18.

2. I have read the Second Amended Complaint in Jefferson District Court Case No:
2017cv231 and am familiar with the contents therein and the facts framing the issues in
this case.

3. The contents of the Second Amended Complaint are true and correct to the best of my
knowledge.

dd:

_________________
Lance Cassino

NOTARY
STATE OF _______________________ )
) ss:
COUNTY OF _____________________ )

The foregoing instrument was acknowledged before me this ____ day of ________________,
2017 by _______________________________ .

Witness my hand and official seal.

My commission expires:___________

______________________________
Notary Public

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CERTIFICATE OF SERVICE

I hereby certify and affirm that a copy of the foregoing Second Amended Complaint
was mailed via U.S. Mail, filed electronically via Courtlink on LexisNexis File & Serve or e-
mailed to the following parties:

BRYAN CAVE LLP.,


Attn: Cynthia Lowery Graber, esq., Ron Tomassi, Courtney Warren
1700 Lincoln Street, Suite 4100
Denver, CO 80203-4541

Karsh Fulton Gabler Joseph PC


Attn: Fred Gabler, Alan E. Karsh
1546 Cole Blvd, Bldg. 5, Suite 100
Lakewood, CO 80401

DATED this October 9th, 2017.

s/: Tim Bullock

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