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IN THE CIRCUIT COURT OF BOONE COUNTY, MISSOURISTATE OF MISSOURI ))Plaintiff, ))v. ) Case No.) OCN:DOCX, LLC, )a Georgia corporation )Registered Agent: )CT Corporation System )1201 Peachtree Street, NE )Atlanta, Georgia 30361 ))Defendant. )
 
INDICTMENT
 
COUNT 1
Forgery – Class C FelonyMo. Charge Code: 1801089.0NCIC Code: 2589The Grand Jurors of the County of Boone, State of Missouri, charge thatDefendant in violation of section 570.090 RSMo, committed the class C felony of forgery, punishable upon conviction under section 560.021, RSMo, in that on or aboutApril 21, 2009, in the County of Boone, State of Missouri, Defendant, acting knowingly inconcert with its employees, with the purpose to defraud, used as genuine or transferredwith the knowledge or belief that it would be used as genuine, a writing, namely Deedof Release number 2009010022, knowing that it had been made or authenticated sothat it purported to have been made by another, or that it had been made so that it
 
2purported to have been made by authority of one who did not give such authority.Defendant is liable under section 562.056(1)(3) RSMo because the conduct constitutingthe offense was engaged in, authorized, solicited, requested, commanded or knowinglytolerated by a high managerial agent acting within the scope of the agent’s employmentand in behalf of the corporation.
COUNT 2
False Declaration – Class B misdemeanorMo. Charge Code: 2910199.0NCIC Code: 5099The Grand Jurors of the County of Boone, State of Missouri, charge thatDefendant in violation of section 575.060 RSMo, committed the class B misdemeanor of making a false declaration, punishable upon conviction under section 560.021, RSMo, inthat on or about April 21, 2009, in the County of Boone, State of Missouri, Defendantacting knowingly in concert with its employees, with the purpose to mislead the BooneCounty Recorder of Deeds, a public servant in the performance of her duty, submittedor invited reliance on a writing, namely Deed of Release number 2009010022, whichDefendant knew to be lacking in authenticity, and which stated a fact material to thepurposes for which the writing was offered.The conduct alleged herein was discovered in 2011, when the purported signer of Deed of Release 2009010022 was found not to have signed Deed of Release2009010022 before the notary public identified in Deed of Release 2009010022.
 
3Defendant is liable under section 562.056(1)(2) RSMo because the conduct constitutingthe offense was engaged in by an agent of the corporation while acting within the scopeof the agent’s employment and in behalf of the corporation.
COUNT 3
Forgery – Class C FelonyMo. Charge Code: 1801089.0NCIC Code: 2589The Grand Jurors of the County of Boone, State of Missouri, charge thatDefendant in violation of section 570.090 RSMo, committed the class C felony of forgery, punishable upon conviction under section 560.021, RSMo, in that on or aboutJuly 7, 2009, in the County of Boone, State of Missouri, Defendant, acting knowingly inconcert with its employees, with the purpose to defraud, used as genuine or transferredwith the knowledge or belief that it would be used as genuine, a writing, namely Deedof Release number 2009018568, knowing that it had been made or authenticated sothat it purported to have been made by another, or that it had been made so that itpurported to have been made by authority of one who did not give such authority.Defendant is liable under section 562.056(1)(3) RSMo because the conduct constituting
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