DISTRICT COURT, MONTROSE COUNTY, COLORADO Court Address: 1200 N. Grand Ave. Montrose, CO 81401 Plaintiffs: JERRY ESPINOZA, JR., surviving son of Jerry Espinoza, St; BOBBY ESPINOZA, surviving son of Jerry Espinoza, Sr.; STEPHANIE TABOR, surviving daughter of Jerry Espinoza, St.; ANN SAYER, surviving daughter of Patricia Rainey; JANICE MAHAN, surviving sister of Steven Rice; DARLENE MORA, surviving daughter of Jose Adolfo Francisco Mora; SHERREL CARLSON, surviving mother of Joshua Crawford; GLENN CARLSON, surviving father of Joshua Crawford; SARAH MILLER, also known as RUTHIE PETTYJOMN, surviving mother of Brian Jason Allen; IVAN MARKOVIC, surviving son of Gojko Markovic, HEATHER BROWN, surviving daughter of Kristie Brown; ADDAM MCMULLIN, surviving son of Scott McMullin; NATHAN MCMULLIN, surviving son of Scott McMullin; KARI ROZSA, surviving step-daughter of Scott McMullin: VERONICA YATES, surviving step-daughter of Scott McMullin; JUDY BASSET, surviving wife of Theodore W. Bassett; TINA SHANNON, surviving daughter of Lynne Condit; CHARLOTTE CRUZ-SCHENDEL, surviving wife of Michael Schendel; PATRICIA EASTHAM, surviving mother of Livingston Eastham; HENRY MUGLER III, surviving son of Henry Mugler, Jr.; JEEF MURRAY, surviving son of Lois Murray; SCOTT MURRAY, surviving son of Lois Murray; TODD MURRAY, surviving son of Lois Murray, JEAN HEWLETT, surviving mother of Matthew Hewlett; PAUL PIETRZYK, surviving brother of Karen Leslie- Piettzyk; KELLY SMITH, surviving granddaughter of Hope B. Si ; KATHERINE BRADLEY, surviving daughter of Helena Melver Howell; KENNA BURK, surviving daughter of Kenneth Martinez; FREDERICKA HANCOCK, surviving wife of Thomas Hancock; MISCHEL CARVER, surviving daughter of Francis Martin Carver, ALENA HOLLOMAN, surviving daughter of Marlow Holloman; JANET HUTT, surviving daughter of Richard Hutt; REBECCA LEVY, surviving daughter of Thelma Stevens; FRED CARSON, surviving son of Billie Glenn Carson; WENDY COYLE, surviving daughter of Shirley June Green; CONNIE HANSON, surviving mother of Frederick Hanson; HELEN BEECHER, surviving sister of Frederick Hanson; VICKI HOVEY, surviving daughter of Frank David Smart and niece of Eddie Ervin Smart; ROXANNA MCGRATH, surviving daughter of Sally Aime; KELLY MCGRATH, surviving son of Sally Aime; DIANNA MULLER, surviving daughter of Wanda Linsacum; JANICE ing daughter of Hazel D. Miller and wife of Richard L. Rule; DOROTHY GOFF, surviving daughter/sister of Josephine ‘A COURT USE ONLY &Goff and Dolores Daniels; VERONICA HATCH, surviving daughter of Mary Jean Fattore; AARON TAYLOR, surviving grandson of Mary Jean Fattore; SCOTT BERRY, surviving son of Eddie Berry; JACKIE HOLYBEE, surviving daughter of Barbara Seveland; JOHNNIE GARAND, surviving daughter of Barbara Seveland; MICHAEL MORRICK, surviving son of Barbara Seveland; PATRICK MORRICK, surviving son of Barbara Seveland; KELLY MORRICK, surviving son of Barbara Seveland; SHAWN MORRICK; surviving son of Barbara Seveland; TAMMY ALBANO, surviving daughter of Barbara Seveland; KATY. LASALA, surviving daughter of Thomas J. Trehal; AMY BARGER, surviving daughter of Thomas J. Trehal; AMANDA COCA, surviving granddaughter of Elizabeth Rodriguez; SANDRA WILSON, surviving daughter of Lillian Peacock & Harry Peacock; DENISE HENNING, surviving daughter of Lillian Peacock & Harry Peacock; ANGELA SY. JOHN, surviving daughter of Myrna Dolores Cargill, RANDY MCDONALD, surviving grandson of George R. Hirsch and Helga M. Hirsh; NANCY ZILKER, surviving mother of Adam DePeters, MARK DEPETERS, surviving father of Adam DePeters; KONI DUGGAN, surviving spouse of Chris Duggan; TERI VILLANUEVA, surviving daughter of Gary Turner. v Defendants: MEGAN M. HESS, as an individual and as alter-ego and trustee of PEYTON HESS TRUST; SUNSET MESA FUNERAL FOUNDATION, INC., a Colorado nonprofit corporation d/b/a Sunset Mesa Funeral Directors, Donor Services, Colorado Cremation Inc., and Signature Events & Floral; SHIRLEY KOCH, an individual; ALAN KOCH, as an individual and as alter- ego of freight transportation entity of unknown legal name and form; RETRIEVER FREIGHT SERVICES, LLC, a Colorado limited liability company; THOMAS CANFIELD, M.D., as an individual and in his official capacity as the Coroner of Montrose County; MONTROSE COUNTY CORONER'S OFFICE, a government organization; THE BOARD OF COUNTY COMMISSIONERS OF THE COUNTY OF MONTROSE, a government organization; DAVID HAISMAN, an individual and d/b/a FOUR CORNERS CREMATION & BURIAL SOCIETY; HOPEWEST a Colorado nonprofit corporation; NIELSON GJ INVESTMENTS, LLC d/b/a Mesa Funeral Service; M.D. GLOBAL, LLC, a Colorado limited liability company; SOUTHWEST INSTITUTE OF BIO- ADVANCEMENT, an Arizona limited liability company; INNOVED INSTITUTE, LLC, a Delaware limited liability company; AXOGEN CORPORATION, a Delaware corporation; THE AMERICAN PLASTINATION COMPANY, a Michigan 2corporation, ROBARTS RESEARCH INSTITUTE, a Canadian entity of unknown form; DOES 1-20; BODY-USER DOES 21-30. Attorneys for Plaintiffs: Case Number: Michael 8. Burg, Reg. No. 7143 David K. TeSelle, Reg. No. 29648 Holly B. Kammerer, Reg. No. 21752 Burg Simpson Eldredge Hersh & Jardine, P.C. 40 Inverness Drive East Englewood, Colorado 80112 ‘Telephone: (303) 792-5595 Facsimile: (303) 708-0527 E-Mail: mburg@burgsimpson.com E-Mail: dteselle@burgsimpson.com E-Mail: hkammerer@burgsimpson.com COMPLAINT AND JURY DEMAND Plaintiffs, by and through their attorneys Burg Simpson Eldredge Hersh & Jardine, P.C., submit their Complaint and Jury Demand against Defendants and state as follows: IERAL ALLEG. ONS 1, This case concerns a criminal enterprise and civil conspiracy of persons and entities engaged in, facilitating and profiting from a heinous fraud committed upon bereaved families. Grieving mothers, fathers, daughters, spouses and kin are lied to in order to take possession of the bodies of their recently deceased loved-ones, promised dignified cremation services in exchange for payment and then- without consent and often against the families’ explicit wishes—the deceased are dismembered, carved up and sold piecemeal for profit. After the deceased are dissected and sold off in parts, the mourning families are returned urns filled with sand, concrete and cat litter masquerading as their loved-ones’ 2. The bereaved are preyed upon, the deceased are desecrated, and grieving families are left shocked, outraged, betrayed and without peace or knowledge of what has become of their loved-ones.