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Sheldon Chrysler Complaint Against Chris Kane

Sheldon Chrysler Complaint Against Chris Kane

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Categories:Types, Legal forms
Published by: Nick on Jul 11, 2012
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07/11/2012

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1
DISTRICT COURTDENVER COUNTY, COLORADOCOURT ADDRESS:1437 Bannock St # 256Denver, CO 80202
 
Court Use Only
 SHELDON CHRYSLER,Plaintiff,Vs.CHRISTOPHER KANEDefendants.Plaintiff:Sheldon A. Chrysler 743 Glencoe StreetDenver, CO 80220303 355-4872 Case No. 12 CVDivision:COMPLAINT FOR DAMAGESCOMES NOW, the Plaintiff, above-named and submits the within Complaint pro seasserting as follows:1.
 
The amount in controversy exceeds $15,000.00.2.
 
That the Plaintiff, Sheldon Chrysler, currently resides and has resided inthe City and County of Denver at all times relevant in this action.3.
 
Defendant, Christopher Kane, currently resides and has resided inArapahoe County at all time relevant in this action.4.
 
Defendant, Christopher Kane, works and has worked in the City andCounty of Denver at all times relevant in this action.5.
 
That venue is proper in the County of Denver because the loan that wasusurious was entered into contractually in the County of and was recorded
 
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against real property located in the County of Denver at all times relevantto this matter.6.
 
Plaintiff and Defendant had previously been friends for several years.7.
 
Plaintiff had met Defendant through business interactions andsubsequently developed a long-lasting friendship.FIRST CAUSE OF ACTION -USURY 8.
 
Plaintiff would incorporate by reference paragraphs 1 through 7 as setforth above.9.
 
During the course of that friendship, Defendant lent Plaintiff a sum of money at the interest rate of forty-eight percent (48%) interest.10.
 
The Colorado usury laws make it illegal and unlawful for any loan toexceed an interest rate of forty-five percent (45%).11.
 
Defendant secured that loan with an interest rate of forty-eight percent(48%) by filing a lien on a couple of Plaintiff’s parcels of real property between the time of the loan in 2006 and 2012.12.
 
Defendant only released the lien on one of Plaintiff’s properties secured by the promissory note with the forty-right percent (48%) rate of interestwithin the first few months of 2012.13.
 
Plaintiff contends that Defendant knew of or should have known of Colorado’s rather liberal usury statute that set the maximum amount of interest that could be charged on any loan at forty-five percent (45%).14.
 
Prior to the loan at the rate of forty-eight percent (48%), Defendant made aseries of high interest loans to Plaintiff at the interest rate of thirty-two percent (32%).15.
 
Defendant secured those loans by filing those promissory notes secured bydeeds of trust against Plaintiff’s commercial and residential property in theCity and County of Denver and in Arapahoe County, Colorado.16.
 
Throughout the course of several years, Defendant was able to obtain payments of interest on a loan that exceeded the usury laws of the State oColorado.17.
 
As a result of Defendant’s conduct, Plaintiff suffered economic damages.
 
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18.
 
As a proximate result of Defendant's usury loan or loans, Plaintiff wasunable to pay off the loans and subsequently lost the commercial propertythat Plaintiff owned and which was foreclosed on.19.
 
As a result of Defendant’s, Plaintiff has sustained considerable damages ina sum that need to be determined by the trier of fact in this case, to includeeconomic loses, interest expenses, and other damages.20.
 
Plaintiff historically has been a victim of multiple economic crimes.Defendant knew of this and also that Plaintiff was an “at risk” disabledsenior citizen and military veteran. Defendant knew or should have knownthat Plaintiff was dealing with mental health issues, considering Plaintiff’sloss of his twin brother, as well as financial losses.JURY DEMAND21.
 
Plaintiff would hereby request a trial by jury with the maximum number of  jurors allowed pursuant to Colorado law.22.
 
Consequently, Plaintiff is requesting an award of damages, costs, andtreble damages for Defendant violating Colorado’s usury statute and other actions committed by Defendant as part of this legal action.23.
 
WHEREFORE, the Plaintiff demands judgment against the Defendant inthe amount to be determined and for such other and further relief as thisCourt deems just and proper.Respectfully Submitted, _____________________ Sheldon Chrysler Plaintiff (proceeding pro se)

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