FOR THE DISTRICT OF COLORADO Civil Action No - How Appealing

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29. As a direct and proximate result of foregoing, ISR has sustained damages, together with interest, costs and reasonable attorneys’ fees and is entitled to declaratory and/or injunctive relief. 30. 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. 31. ISR is entitled to an award of punitive damages. THIRD CAUSE OF ACTION (Negligent Supervision) (As Against Faegre & Benson) 32. Plaintiff incorporates by this reference each of the previous paragraphs. Plaintiff repeats and re-alleges each and every allegation contained in the previous paragraphs. Fischer. 33. Faegre & Benson had a duty to ISR to properly supervise 34. Faegre & Benson failed to properly supervise Fischer. 35. Faegre & Benson breached its duties to ISR. 36. As a direct and proximate result of Faegre & Benson’s negligent supervision, ISR has sustained damages, together with interest, costs and reasonable attorneys’ fees and is entitled to declaratory and/or injunctive relief. FOURTH CAUSE OF ACTION 6
(Fraud) (As Against All Defendants) 37. Plaintiff incorporates by this reference each of the previous paragraphs. Plaintiff repeats and re-alleges each and every allegation contained in the previous paragraphs. 38. Defendants made representations of material fact as set forth above which were in fact false. Defendants materially misrepresented that the Court had issued and entered the Fabricated Order. 39. When Defendants made the representations, Defendants knew they were false or Defendants had no reasonable ground for believing the representations were true. 40. Defendants made the representations with the intent to defraud ISR and did defraud ISR. 41. ISR reasonably and properly relied upon its recording of the Judgment On Remand in the Prior Action as a lien against Defendant Judy Heumann’s real property, which would have remained as a lien against Defendant Judy Heumann’s real property but for Defendants’ fraud. 42. As a direct and proximate result of foregoing, ISR has sustained damages, together with interest, costs and reasonable attorneys’ fees and is entitled to declaratory and/or injunctive relief. 43. 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. 44. ISR is entitled to an award of punitive damages. 7
Page 1 and 2: Civil Action No. IN THE UNITED STAT
Page 3 and 4: 9. A Judgment On Remand was entered
Page 5: attorneys’ fees and is entitled t
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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