FOR THE DISTRICT OF COLORADO Civil Action No - How Appealing

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13. ISR did not discover the Fabricated Order until on or about March 28, 2007. 14. On April 9, 2007, Fischer admitted his misconduct as set forth herein by the letter to Magistrate Hegarty attached as Exhibit B and incorporated herein by reference. 15. At the time of the fabrication and recording of the Fabricated Order and thereafter until on or about April 9, 2007, Fischer was a partner with Faegre & Benson. Pursuant to, without limitation, Colorado Revised Statutes section 7-60-113, Faegre & Benson is liable to ISR to the same extent as Fischer. 16. Boulder Escrow improperly facilitated the filing of the Fabricated Order and improperly failed to require a certified copy of the Fabricated Order. FIRST CAUSE OF ACTION (Violation Of Colorado Revised Statutes Section 38-35-109) (As Against All Defendants) 17. Plaintiff incorporates by this reference each of the previous paragraphs. Plaintiff repeats and re-alleges each and every allegation contained in the previous paragraphs. 18. By the actions and omissions set forth herein, Defendants have violated Colorado Revised Statutes section 38-35- 109(3). 19. ISR is entitled to the relief set forth in Colorado Revised Statutes section 38-35-109(3), including an award of reasonable attorneys’ fees. 20. As a direct and proximate result of foregoing, ISR has sustained damages, together with interest, costs, and reasonable 4
attorneys’ fees and is entitled to declaratory and/or injunctive relief. 21. Defendants’ actions were, and continue to be, attended by circumstances of malice and/or constituted misconduct purposefully, heedlessly and/or recklessly committed without regard to the consequences or rights of ISR. 22. ISR is entitled to an award of punitive damages. SECOND CAUSE OF ACTION (Fraudulent Transfer) (As Against All Defendants) 23. Plaintiff incorporates by this reference each of the previous paragraphs. Plaintiff repeats and re-alleges each and every allegation contained in the previous paragraphs. 24. All transfers of Defendant Judy Heumann’s real estate from the date of the Fabricated Order were fraudulent transfers pursuant to Colorado Revised Statutes section 38-8-105(a). 25. On February 22, 2007, this Court amended its previous Judgment On Remand to award additional attorneys’ fees and costs to ISR and against Defendant Judy Heumann. 26. On March 8, 2007, Defendant Judy Heumann recorded a quit claim deed attempting to transfer her interest in real property to Defendant Norman Heumann. 27. By the quit claim deed recorded March 8, 2007, Defendant Judy Heumann and Norman Heumann have engaged in a fraudulent transfer pursuant to 38-8-105(a) and (b). 28. ISR is entitled to the relief set forth in Colorado Revised Statutes section 38-8-108. 5
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Page 3: 9. A Judgment On Remand was entered
Page 7 and 8: (Fraud) (As Against All Defendants)
Page 9 and 10: 51. Boulder Escrow failed to ISR to
Page 11 and 12: TENTH CAUSE OF ACTION (Injunctive R

FOR THE DISTRICT OF COLORADO Civil Action No - How Appealing

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