IN THE CIRCUIT COURT OF BOONE COUNTY, MISSOURI STATE OF MISSOURI Plaintiff, v.

DOCX, LLC, ) a Georgia corporation Registered Agent: CT Corporation System 1201 Peachtree Street, NE Atlanta, Georgia 30361 Defendant. ) ) ) ) ) ) ) ) ) ) ) ) )

Case No. OCN:

INDICTMENT

Defendant 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 about

concert with its employees, with the purpose to defraud, used as genuine or transferred with the knowledge or belief that it would be used as genuine, a writing, namely Deed

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of Release number 2009010022, knowing that it had been made or authenticated so that it purported to have been made by another, or that it had been made so that it 1

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April 21, 2009, in the County of Boone, State of Missouri, Defendant, acting knowingly in

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The Grand Jurors of the County of Boone, State of Missouri, charge that

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Forgery – Class C Felony Mo. Charge Code: 1801089.0 NCIC Code: 2589

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COUNT 1

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purported 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

the offense was engaged in, authorized, solicited, requested, commanded or knowingly tolerated by a high managerial agent acting within the scope of the agent’s employment and in behalf of the corporation. COUNT 2

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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, in that on or about April 21, 2009, in the County of Boone, State of Missouri, Defendant acting knowingly in concert with its employees, with the purpose to mislead the Boone County Recorder of Deeds, a public servant in the performance of her duty, submitted or invited reliance on a writing, namely Deed of Release number 2009010022, which Defendant knew to be lacking in authenticity, and which stated a fact material to the purposes for which the writing was offered.

Deed of Release 2009010022 was found not to have signed Deed of Release

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2009010022 before the notary public identified in Deed of Release 2009010022.

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The conduct alleged herein was discovered in 2011, when the purported signer of

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False Declaration – Class B misdemeanor Mo. Charge Code: 2910199.0 NCIC Code: 5099

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Defendant is liable under section 562.056(1)(2) RSMo because the conduct constituting the offense was engaged in by an agent of the corporation while acting within the scope of the agent’s employment and in behalf of the corporation.

Forgery – Class C Felony Mo. Charge Code: 1801089.0 NCIC Code: 2589

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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 about July 7, 2009, in the County of Boone, State of Missouri, Defendant, acting knowingly in concert with its employees, with the purpose to defraud, used as genuine or transferred with the knowledge or belief that it would be used as genuine, a writing, namely Deed of Release number 2009018568, knowing that it had been made or authenticated so

purported to have been made by authority of one who did not give such authority.

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Defendant is liable under section 562.056(1)(3) RSMo because the conduct constituting

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that it purported to have been made by another, or that it had been made so that it

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COUNT 3

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the offense was engaged in, authorized, solicited, requested, commanded or knowingly tolerated by a high managerial agent acting within the scope of the agent’s employment and in behalf of the corporation. COUNT 4

False Declaration – Class B misdemeanor Mo. Charge Code: 2910199.0 NCIC Code: 5099

The Grand Jurors of the County of Boone, State of Missouri, charge that

making a false declaration, punishable upon conviction under section 560.021, RSMo, in that on or about July 7, 2009, in the County of Boone, State of Missouri, Defendant acting knowingly in concert with its employees, with the purpose to mislead the Boone County Recorder of Deeds, a public servant in the performance of her duty, submitted or invited reliance on a writing, namely Deed of Release number 2009018568, which Defendant knew to be lacking in authenticity, and which stated a fact material to the purposes for which the writing was offered. The conduct alleged herein was discovered in 2011, when the purported signer of Deed of Release 2009018568 was found not to have signed Deed of Release

Defendant is liable under section 562.056(1)(2) RSMo because the conduct constituting

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2009018568 before the notary public identified in Deed of Release 2009018568.

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4

Defendant in violation of section 575.060 RSMo, committed the class B misdemeanor of

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the offense was engaged in by an agent of the corporation while acting within the scope of the agent’s employment and in behalf of the corporation. COUNT 5

Forgery – Class C Felony Mo. Charge Code: 1801089.0 NCIC Code: 2589

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant in violation of section 570.090 RSMo, committed the class C felony of

July 28, 2009, in the County of Boone, State of Missouri, Defendant, acting knowingly in concert with its employees, with the purpose to defraud, used as genuine or transferred with the knowledge or belief that it would be used as genuine, a writing, namely Deed of Release number 2009020598, knowing that it had been made or authenticated so that it purported to have been made by another, or that it had been made so that it purported 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 the offense was engaged in, authorized, solicited, requested, commanded or knowingly tolerated by a high managerial agent acting within the scope of the agent’s employment

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and in behalf of the corporation. COUNT 6 False Declaration – Class B misdemeanor Mo. Charge Code: 2910199.0 5

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forgery, punishable upon conviction under section 560.021, RSMo, in that on or about

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NCIC Code: 5099 The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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, in that on or about July 28, 2009, in the County of Boone, State of Missouri, Defendant acting knowingly in concert with its employees, with the purpose to mislead the Boone County Recorder of Deeds, a public servant in the performance of her duty, submitted

Defendant knew to be lacking in authenticity, and which stated a fact material to the purposes for which the writing was offered.

The conduct alleged herein was discovered in 2011, when the purported signer of Deed of Release 2009020598 was found not to have signed Deed of Release 2009020598 before the notary public identified in Deed of Release 2009020598. Defendant is liable under section 562.056(1)(2) RSMo because the conduct constituting the offense was engaged in by an agent of the corporation while acting within the scope of the agent’s employment and in behalf of the corporation.

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or invited reliance on a writing, namely Deed of Release number 2009020598, which

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COUNT 7 Forgery – Class C Felony Mo. Charge Code: 1801089.0 NCIC Code: 2589

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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 about July 28, 2009, in the County of Boone, State of Missouri, Defendant, acting knowingly in

with the knowledge or belief that it would be used as genuine, a writing, namely Deed of Release number 2009020599, knowing that it had been made or authenticated so that it purported to have been made by another, or that it had been made so that it purported 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 the offense was engaged in, authorized, solicited, requested, commanded or knowingly tolerated by a high managerial agent acting within the scope of the agent’s employment and in behalf of the corporation.

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False Declaration – Class B misdemeanor Mo. Charge Code: 2910199.0 NCIC Code: 5099

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COUNT 8

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concert with its employees, with the purpose to defraud, used as genuine or transferred

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The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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, in that on or about July 28, 2009, in the County of Boone, State of Missouri, Defendant acting knowingly in concert with its employees, with the purpose to mislead the Boone County Recorder of Deeds, a public servant in the performance of her duty, submitted or invited reliance on a writing, namely Deed of Release number 2009020599, which

purposes for which the writing was offered.

The conduct alleged herein was discovered in 2011, when the purported signer of Deed of Release 2009020599 was found not to have signed Deed of Release 2009020599 before the notary public identified in Deed of Release 2009020599. Defendant is liable under section 562.056(1)(2) RSMo because the conduct constituting the offense was engaged in by an agent of the corporation while acting within the scope of the agent’s employment and in behalf of the corporation. COUNT 9

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Defendant in violation of section 570.090 RSMo, committed the class C felony of

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The Grand Jurors of the County of Boone, State of Missouri, charge that

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Forgery – Class C Felony Mo. Charge Code: 1801089.0 NCIC Code: 2589

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Defendant knew to be lacking in authenticity, and which stated a fact material to the

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forgery, punishable upon conviction under section 560.021, RSMo, in that on or about July 28, 2009, in the County of Boone, State of Missouri, Defendant, acting knowingly in

concert with its employees, with the purpose to defraud, used as genuine or transferred with the knowledge or belief that it would be used as genuine, a writing, namely Deed of Release number 2009020600, knowing that it had been made or authenticated so that it purported to have been made by another, or that it had been made so that it purported to have been made by authority of one who did not give such authority.

the offense was engaged in, authorized, solicited, requested, commanded or knowingly tolerated by a high managerial agent acting within the scope of the agent’s employment and in behalf of the corporation.

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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, in

acting knowingly in concert with its employees, with the purpose to mislead the Boone

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County Recorder of Deeds, a public servant in the performance of her duty, submitted

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that on or about July 28, 2009, in the County of Boone, State of Missouri, Defendant

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False Declaration – Class B misdemeanor Mo. Charge Code: 2910199.0 NCIC Code: 5099

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Defendant is liable under section 562.056(1)(3) RSMo because the conduct constituting

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or invited reliance on a writing, namely Deed of Release number 2009020600, which Defendant knew to be lacking in authenticity, and which stated a fact material to the purposes for which the writing was offered.

The conduct alleged herein was discovered in 2011, when the purported signer of Deed of Release 2009020600 was found not to have signed Deed of Release 2009020600 before the notary public identified in Deed of Release 2009020600. Defendant is liable under section 562.056(1)(2) RSMo because the conduct constituting

of the agent’s employment and in behalf of the corporation.

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The Grand Jurors of the County of Boone, State of Missouri, charge that

forgery, punishable upon conviction under section 560.021, RSMo, in that on or about

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July 28, 2009, in the County of Boone, State of Missouri, Defendant, acting knowingly in

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Defendant in violation of section 570.090 RSMo, committed the class C felony of

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Forgery – Class C Felony Mo. Charge Code: 1801089.0 NCIC Code: 2589

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COUNT 11

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the offense was engaged in by an agent of the corporation while acting within the scope

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concert with its employees, with the purpose to defraud, used as genuine or transferred with the knowledge or belief that it would be used as genuine, a writing, namely Deed of Release number 2009020601, knowing that it had been made or authenticated so that it purported to have been made by another, or that it had been made so that it purported 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 the offense was engaged in, authorized, solicited, requested, commanded or knowingly

and in behalf of the corporation.

COUNT 12

False Declaration – Class B misdemeanor Mo. Charge Code: 2910199.0 NCIC Code: 5099 The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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, in that on or about July 28, 2009, in the County of Boone, State of Missouri, Defendant acting knowingly in concert with its employees, with the purpose to mislead the Boone

or invited reliance on a writing, namely Deed of Release number 2009020601, which

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County Recorder of Deeds, a public servant in the performance of her duty, submitted

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tolerated by a high managerial agent acting within the scope of the agent’s employment

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Defendant knew to be lacking in authenticity, and which stated a fact material to the purposes for which the writing was offered.

The conduct alleged herein was discovered in 2011, when the purported signer of Deed of Release 2009020601 was found not to have signed Deed of Release 2009020601 before the notary public identified in Deed of Release 2009020601. Defendant is liable under section 562.056(1)(2) RSMo because the conduct constituting the offense was engaged in by an agent of the corporation while acting within the scope

COUNT 13

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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 about July 28, 2009, in the County of Boone, State of Missouri, Defendant, acting knowingly in concert with its employees, with the purpose to defraud, used as genuine or transferred with the knowledge or belief that it would be used as genuine, a writing, namely Deed

that it purported to have been made by another, or that it had been made so that it

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purported to have been made by authority of one who did not give such authority.

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of Release number 2009020602, knowing that it had been made or authenticated so

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Forgery – Class C Felony Mo. Charge Code: 1801089.0 NCIC Code: 2589

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of the agent’s employment and in behalf of the corporation.

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Defendant is liable under section 562.056(1)(3) RSMo because the conduct constituting the offense was engaged in, authorized, solicited, requested, commanded or knowingly tolerated by a high managerial agent acting within the scope of the agent’s employment and in behalf of the corporation. COUNT 14

False Declaration – Class B misdemeanor Mo. Charge Code: 2910199.0 NCIC Code: 5099

Defendant 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, in that on or about July 28, 2009, in the County of Boone, State of Missouri, Defendant acting knowingly in concert with its employees, with the purpose to mislead the Boone County Recorder of Deeds, a public servant in the performance of her duty, submitted or invited reliance on a writing, namely Deed of Release number 2009020602, which Defendant knew to be lacking in authenticity, and which stated a fact material to the purposes for which the writing was offered. The conduct alleged herein was discovered in 2011, when the purported signer of

2009020602 before the notary public identified in Deed of Release 2009020602.

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Defendant is liable under section 562.056(1)(2) RSMo because the conduct constituting

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Deed of Release 2009020602 was found not to have signed Deed of Release

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The Grand Jurors of the County of Boone, State of Missouri, charge that

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the offense was engaged in by an agent of the corporation while acting within the scope of the agent’s employment and in behalf of the corporation.

COUNT 15

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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 about July 28, 2009, in the County of Boone, State of Missouri, Defendant, acting knowingly in concert with its employees, with the purpose to defraud, used as genuine or transferred with the knowledge or belief that it would be used as genuine, a writing, namely Deed of Release number 2009020603, knowing that it had been made or authenticated so that it purported to have been made by another, or that it had been made so that it

Defendant is liable under section 562.056(1)(3) RSMo because the conduct constituting

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the offense was engaged in, authorized, solicited, requested, commanded or knowingly

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purported to have been made by authority of one who did not give such authority.

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Forgery – Class C Felony Mo. Charge Code: 1801089.0 NCIC Code: 2589

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tolerated by a high managerial agent acting within the scope of the agent’s employment and in behalf of the corporation. COUNT 16

False Declaration – Class B misdemeanor Mo. Charge Code: 2910199.0 NCIC Code: 5099

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant in violation of section 575.060 RSMo, committed the class B misdemeanor of

that on or about July 28, 2009, in the County of Boone, State of Missouri, Defendant acting knowingly in concert with its employees, with the purpose to mislead the Boone County Recorder of Deeds, a public servant in the performance of her duty, submitted or invited reliance on a writing, namely Deed of Release number 2009020603, which Defendant knew to be lacking in authenticity, and which stated a fact material to the purposes for which the writing was offered. The conduct alleged herein was discovered in 2011, when the purported signer of Deed of Release 2009020603 was found not to have signed Deed of Release 2009020603 before the notary public identified in Deed of Release 2009020603.

the offense was engaged in by an agent of the corporation while acting within the scope

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of the agent’s employment and in behalf of the corporation.

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Defendant is liable under section 562.056(1)(2) RSMo because the conduct constituting

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making a false declaration, punishable upon conviction under section 560.021, RSMo, in

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COUNT 17 Forgery – Class C Felony Mo. Charge Code: 1801089.0 NCIC Code: 2589

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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 about July 28, 2009, in the County of Boone, State of Missouri, Defendant, acting knowingly in

with the knowledge or belief that it would be used as genuine, a writing, namely Deed of Release number 2009020604, knowing that it had been made or authenticated so that it purported to have been made by another, or that it had been made so that it purported 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 the offense was engaged in, authorized, solicited, requested, commanded or knowingly tolerated by a high managerial agent acting within the scope of the agent’s employment and in behalf of the corporation.

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False Declaration – Class B misdemeanor Mo. Charge Code: 2910199.0 NCIC Code: 5099

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COUNT 18

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concert with its employees, with the purpose to defraud, used as genuine or transferred

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The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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, in that on or about July 28, 2009, in the County of Boone, State of Missouri, Defendant acting knowingly in concert with its employees, with the purpose to mislead the Boone County Recorder of Deeds, a public servant in the performance of her duty, submitted or invited reliance on a writing, namely Deed of Release number 2009020604, which

purposes for which the writing was offered.

The conduct alleged herein was discovered in 2011, when the purported signer of Deed of Release 2009020604 was found not to have signed Deed of Release 2009020604 before the notary public identified in Deed of Release 2009020604. Defendant is liable under section 562.056(1)(2) RSMo because the conduct constituting the offense was engaged in by an agent of the corporation while acting within the scope of the agent’s employment and in behalf of the corporation.

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COUNT 19

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Defendant knew to be lacking in authenticity, and which stated a fact material to the

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The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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 about July 31, 2009, in the County of Boone, State of Missouri, Defendant, acting knowingly in concert with its employees, with the purpose to defraud, used as genuine or transferred

of Release number 2009020911, knowing that it had been made or authenticated so that it purported to have been made by another, or that it had been made so that it purported 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 the offense was engaged in, authorized, solicited, requested, commanded or knowingly tolerated by a high managerial agent acting within the scope of the agent’s employment and in behalf of the corporation.

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Defendant in violation of section 575.060 RSMo, committed the class B misdemeanor of

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False Declaration – Class B misdemeanor Mo. Charge Code: 2910199.0 NCIC Code: 5099

The Grand Jurors of the County of Boone, State of Missouri, charge that

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with the knowledge or belief that it would be used as genuine, a writing, namely Deed

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Forgery – Class C Felony Mo. Charge Code: 1801089.0 NCIC Code: 2589

making a false declaration, punishable upon conviction under section 560.021, RSMo, in that on or about July 31, 2009, in the County of Boone, State of Missouri, Defendant

acting knowingly in concert with its employees, with the purpose to mislead the Boone County Recorder of Deeds, a public servant in the performance of her duty, submitted or invited reliance on a writing, namely Deed of Release number 2009020911, which Defendant knew to be lacking in authenticity, and which stated a fact material to the purposes for which the writing was offered.

Deed of Release 2009020911 was found not to have signed Deed of Release 2009020911 before the notary public identified in Deed of Release 2009020911. Defendant is liable under section 562.056(1)(2) RSMo because the conduct constituting the offense was engaged in by an agent of the corporation while acting within the scope of the agent’s employment and in behalf of the corporation.

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The Grand Jurors of the County of Boone, State of Missouri, charge that

forgery, punishable upon conviction under section 560.021, RSMo, in that on or about

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June 1, 2009, in the County of Boone, State of Missouri, Defendant, acting knowingly in

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Defendant in violation of section 570.090 RSMo, committed the class C felony of

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Forgery – Class C Felony Mo. Charge Code: 1801089.0 NCIC Code: 2589

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COUNT 21

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The conduct alleged herein was discovered in 2011, when the purported signer of

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concert with its employees, with the purpose to defraud, used as genuine or transferred with the knowledge or belief that it would be used as genuine, a writing, namely Deed of Release number 2009014386, knowing that it had been made or authenticated so that it purported to have been made by another, or that it had been made so that it purported 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 the offense was engaged in, authorized, solicited, requested, commanded or knowingly

and in behalf of the corporation.

COUNT 22

False Declaration – Class B misdemeanor Mo. Charge Code: 2910199.0 NCIC Code: 5099 The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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, in that on or about June 1, 2009, in the County of Boone, State of Missouri, Defendant acting knowingly in concert with its employees, with the purpose to mislead the Boone

or invited reliance on a writing, namely Deed of Release number 2009014386, which

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County Recorder of Deeds, a public servant in the performance of her duty, submitted

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tolerated by a high managerial agent acting within the scope of the agent’s employment

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Defendant knew to be lacking in authenticity, and which stated a fact material to the purposes for which the writing was offered.

The conduct alleged herein was discovered in 2011, when the purported signer of Deed of Release 2009014386 was found not to have signed Deed of Release 2009014386 before the notary public identified in Deed of Release 2009014386. Defendant is liable under section 562.056(1)(2) RSMo because the conduct constituting the offense was engaged in by an agent of the corporation while acting within the scope

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant in violation of section 570.090 RSMo, committed the class C felony of

June 1, 2009, in the County of Boone, State of Missouri, Defendant, acting knowingly in

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concert with its employees, with the purpose to defraud, used as genuine or transferred

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forgery, punishable upon conviction under section 560.021, RSMo, in that on or about

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Forgery – Class C Felony Mo. Charge Code: 1801089.0 NCIC Code: 2589

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COUNT 23

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of the agent’s employment and in behalf of the corporation.

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with the knowledge or belief that it would be used as genuine, a writing, namely Deed of Release number 2009014387, knowing that it had been made or authenticated so that it purported to have been made by another, or that it had been made so that it purported 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 the offense was engaged in, authorized, solicited, requested, commanded or knowingly tolerated by a high managerial agent acting within the scope of the agent’s employment

COUNT 24

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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, in that on or about June 1, 2009, in the County of Boone, State of Missouri, Defendant acting knowingly in concert with its employees, with the purpose to mislead the Boone County Recorder of Deeds, a public servant in the performance of her duty, submitted

Defendant knew to be lacking in authenticity, and which stated a fact material to the

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purposes for which the writing was offered.

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or invited reliance on a writing, namely Deed of Release number 2009014387, which

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False Declaration – Class B misdemeanor Mo. Charge Code: 2910199.0 NCIC Code: 5099

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and in behalf of the corporation.

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The conduct alleged herein was discovered in 2011, when the purported signer of Deed of Release 2009014387 was found not to have signed Deed of Release 2009014387 before the notary public identified in Deed of Release 2009014387. Defendant is liable under section 562.056(1)(2) RSMo because the conduct constituting the offense was engaged in by an agent of the corporation while acting within the scope of the agent’s employment and in behalf of the corporation. COUNT 25

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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 about June 1, 2009, in the County of Boone, State of Missouri, Defendant, acting knowingly in concert with its employees, with the purpose to defraud, used as genuine or transferred with the knowledge or belief that it would be used as genuine, a writing, namely Deed of Release number 2009014388, knowing that it had been made or authenticated so that it purported to have been made by another, or that it had been made so that it

Defendant is liable under section 562.056(1)(3) RSMo because the conduct constituting

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the offense was engaged in, authorized, solicited, requested, commanded or knowingly

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purported to have been made by authority of one who did not give such authority.

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Forgery – Class C Felony Mo. Charge Code: 1801089.0 NCIC Code: 2589

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tolerated by a high managerial agent acting within the scope of the agent’s employment and in behalf of the corporation. COUNT 26

False Declaration – Class B misdemeanor Mo. Charge Code: 2910199.0 NCIC Code: 5099

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant in violation of section 575.060 RSMo, committed the class B misdemeanor of

that on or about June 1, 2009, in the County of Boone, State of Missouri, Defendant acting knowingly in concert with its employees, with the purpose to mislead the Boone County Recorder of Deeds, a public servant in the performance of her duty, submitted or invited reliance on a writing, namely Deed of Release number 2009014388, which Defendant knew to be lacking in authenticity, and which stated a fact material to the purposes for which the writing was offered. The conduct alleged herein was discovered in 2011, when the purported signer of Deed of Release 2009014388 was found not to have signed Deed of Release 2009014388 before the notary public identified in Deed of Release 2009014388.

the offense was engaged in by an agent of the corporation while acting within the scope

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of the agent’s employment and in behalf of the corporation.

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Defendant is liable under section 562.056(1)(2) RSMo because the conduct constituting

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op Fo

re

clo

24

su re

making a false declaration, punishable upon conviction under section 560.021, RSMo, in

Fr au d. co

m

COUNT 27

Forgery – Class C Felony Mo. Charge Code: 1801089.0 NCIC Code: 2589

Defendant 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 about June 1, 2009, in the County of Boone, State of Missouri, Defendant, acting knowingly in concert with its employees, with the purpose to defraud, used as genuine or transferred with the knowledge or belief that it would be used as genuine, a writing, namely Deed of Release number 2009014389, knowing that it had been made or authenticated so that it purported to have been made by another, or that it had been made so that it purported 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

tolerated by a high managerial agent acting within the scope of the agent’s employment

ww

and in behalf of the corporation.

w.

the offense was engaged in, authorized, solicited, requested, commanded or knowingly

St

op Fo

re

clo

25

su re

The Grand Jurors of the County of Boone, State of Missouri, charge that

Fr au d. co

m

COUNT 28 False Declaration – Class B misdemeanor Mo. Charge Code: 2910199.0 NCIC Code: 5099

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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, in that on or about June 1, 2009, in the County of Boone, State of Missouri, Defendant

County Recorder of Deeds, a public servant in the performance of her duty, submitted or invited reliance on a writing, namely Deed of Release number 2009014389, which Defendant knew to be lacking in authenticity, and which stated a fact material to the purposes for which the writing was offered.

The conduct alleged herein was discovered in 2011, when the purported signer of Deed of Release 2009014389 was found not to have signed Deed of Release 2009014389 before the notary public identified in Deed of Release 2009014389. Defendant is liable under section 562.056(1)(2) RSMo because the conduct constituting the offense was engaged in by an agent of the corporation while acting within the scope

w.

of the agent’s employment and in behalf of the corporation. COUNT 29 Forgery – Class C Felony Mo. Charge Code: 1801089.0 26

ww

St

op Fo

re

clo

su re

acting knowingly in concert with its employees, with the purpose to mislead the Boone

Fr au d. co

m

NCIC Code: 2589 The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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 about June 1, 2009, in the County of Boone, State of Missouri, Defendant, acting knowingly in concert with its employees, with the purpose to defraud, used as genuine or transferred with the knowledge or belief that it would be used as genuine, a writing, namely Deed

that it purported to have been made by another, or that it had been made so that it purported 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 the offense was engaged in, authorized, solicited, requested, commanded or knowingly tolerated by a high managerial agent acting within the scope of the agent’s employment and in behalf of the corporation.

op Fo

Defendant in violation of section 575.060 RSMo, committed the class B misdemeanor of

ww

making a false declaration, punishable upon conviction under section 560.021, RSMo, in

w.

The Grand Jurors of the County of Boone, State of Missouri, charge that

St

False Declaration – Class B misdemeanor Mo. Charge Code: 2910199.0 NCIC Code: 5099

re

clo

COUNT 30

27

su re

of Release number 2009014390, knowing that it had been made or authenticated so

Fr au d. co

m

that on or about June 1, 2009, in the County of Boone, State of Missouri, Defendant acting knowingly in concert with its employees, with the purpose to mislead the Boone

County Recorder of Deeds, a public servant in the performance of her duty, submitted or invited reliance on a writing, namely Deed of Release number 2009014390, which Defendant knew to be lacking in authenticity, and which stated a fact material to the purposes for which the writing was offered.

The conduct alleged herein was discovered in 2011, when the purported signer of

2009014390 before the notary public identified in Deed of Release 2009014390. Defendant is liable under section 562.056(1)(2) RSMo because the conduct constituting the offense was engaged in by an agent of the corporation while acting within the scope of the agent’s employment and in behalf of the corporation.

St

op Fo

ww

w.

re

Forgery – Class C Felony Mo. Charge Code: 1801089.0 NCIC Code: 2589

clo

COUNT 31

28

su re

Deed of Release 2009014390 was found not to have signed Deed of Release

Fr au d. co

m

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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 about June 1, 2009, in the County of Boone, State of Missouri, Defendant, acting knowingly in concert with its employees, with the purpose to defraud, used as genuine or transferred with the knowledge or belief that it would be used as genuine, a writing, namely Deed of Release number 2009014394, knowing that it had been made or authenticated so

purported 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 the offense was engaged in, authorized, solicited, requested, commanded or knowingly tolerated by a high managerial agent acting within the scope of the agent’s employment and in behalf of the corporation.

op Fo

False Declaration – Class B misdemeanor Mo. Charge Code: 2910199.0 NCIC Code: 5099

The Grand Jurors of the County of Boone, State of Missouri, charge that

making a false declaration, punishable upon conviction under section 560.021, RSMo, in

ww

that on or about June 1, 2009, in the County of Boone, State of Missouri, Defendant

w.

Defendant in violation of section 575.060 RSMo, committed the class B misdemeanor of

St

re

clo

COUNT 32

29

su re

that it purported to have been made by another, or that it had been made so that it

Fr au d. co

m

acting knowingly in concert with its employees, with the purpose to mislead the Boone County Recorder of Deeds, a public servant in the performance of her duty, submitted or invited reliance on a writing, namely Deed of Release number 2009014394, which Defendant knew to be lacking in authenticity, and which stated a fact material to the purposes for which the writing was offered.

The conduct alleged herein was discovered in 2011, when the purported signer of Deed of Release 2009014394 was found not to have signed Deed of Release

Defendant is liable under section 562.056(1)(2) RSMo because the conduct constituting the offense was engaged in by an agent of the corporation while acting within the scope of the agent’s employment and in behalf of the corporation. COUNT 33

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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 about

concert with its employees, with the purpose to defraud, used as genuine or transferred

ww

with the knowledge or belief that it would be used as genuine, a writing, namely Deed

w.

June 3, 2009, in the County of Boone, State of Missouri, Defendant, acting knowingly in

St

op Fo

re

Forgery – Class C Felony Mo. Charge Code: 1801089.0 NCIC Code: 2589

clo

30

su re

2009014394 before the notary public identified in Deed of Release 2009014394.

Fr au d. co

m

of Release number 2009014719, knowing that it had been made or authenticated so that it purported to have been made by another, or that it had been made so that it

purported 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 the offense was engaged in, authorized, solicited, requested, commanded or knowingly tolerated by a high managerial agent acting within the scope of the agent’s employment and in behalf of the corporation. COUNT 34

False Declaration – Class B misdemeanor Mo. Charge Code: 2910199.0 NCIC Code: 5099 The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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, in that on or about June 3, 2009, in the County of Boone, State of Missouri, Defendant acting knowingly in concert with its employees, with the purpose to mislead the Boone County Recorder of Deeds, a public servant in the performance of her duty, submitted or invited reliance on a writing, namely Deed of Release number 2009014719, which

purposes for which the writing was offered.

ww

w.

Defendant knew to be lacking in authenticity, and which stated a fact material to the

St

op Fo

re

clo

31

su re

Fr au d. co

m

The conduct alleged herein was discovered in 2011, when the purported signer of Deed of Release 2009014719 was found not to have signed Deed of Release 2009014719 before the notary public identified in Deed of Release 2009014719. Defendant is liable under section 562.056(1)(2) RSMo because the conduct constituting the offense was engaged in by an agent of the corporation while acting within the scope of the agent’s employment and in behalf of the corporation.

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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 about June 3, 2009, in the County of Boone, State of Missouri, Defendant, acting knowingly in

with the knowledge or belief that it would be used as genuine, a writing, namely Deed

ww

of Release number 2009014720, knowing that it had been made or authenticated so

w.

concert with its employees, with the purpose to defraud, used as genuine or transferred

St

op Fo

re

Forgery – Class C Felony Mo. Charge Code: 1801089.0 NCIC Code: 2589

clo

COUNT 35

32

su re

Fr au d. co

m

that it purported to have been made by another, or that it had been made so that it purported 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 the offense was engaged in, authorized, solicited, requested, commanded or knowingly tolerated by a high managerial agent acting within the scope of the agent’s employment and in behalf of the corporation. COUNT 36

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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, in that on or about June 3, 2009, in the County of Boone, State of Missouri, Defendant acting knowingly in concert with its employees, with the purpose to mislead the Boone County Recorder of Deeds, a public servant in the performance of her duty, submitted or invited reliance on a writing, namely Deed of Release number 2009014720, which Defendant knew to be lacking in authenticity, and which stated a fact material to the

ww

Deed of Release 2009014720 was found not to have signed Deed of Release

w.

purposes for which the writing was offered. The conduct alleged herein was discovered in 2011, when the purported signer of

St

op Fo

re

clo

33

su re

False Declaration – Class B misdemeanor Mo. Charge Code: 2910199.0 NCIC Code: 5099

Fr au d. co

m

2009014720 before the notary public identified in Deed of Release 2009014720. Defendant is liable under section 562.056(1)(2) RSMo because the conduct constituting

the offense was engaged in by an agent of the corporation while acting within the scope of the agent’s employment and in behalf of the corporation. COUNT 37

Forgery – Class C Felony Mo. Charge Code: 1801089.0 NCIC Code: 2589

Defendant 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 about June 15, 2009, in the County of Boone, State of Missouri, Defendant, acting knowingly in concert with its employees, with the purpose to defraud, used as genuine or transferred with the knowledge or belief that it would be used as genuine, a writing, namely Deed of Release number 2009015916, knowing that it had been made or authenticated so that it purported to have been made by another, or that it had been made so that it purported 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

tolerated by a high managerial agent acting within the scope of the agent’s employment

ww

and in behalf of the corporation.

w.

the offense was engaged in, authorized, solicited, requested, commanded or knowingly

St

op Fo

re

clo

34

su re

The Grand Jurors of the County of Boone, State of Missouri, charge that

Fr au d. co

m

COUNT 38 False Declaration – Class B misdemeanor Mo. Charge Code: 2910199.0 NCIC Code: 5099

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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, in that on or about June 15, 2009, in the County of Boone, State of Missouri, Defendant

County Recorder of Deeds, a public servant in the performance of her duty, submitted or invited reliance on a writing, namely Deed of Release number 2009015916, which Defendant knew to be lacking in authenticity, and which stated a fact material to the purposes for which the writing was offered.

The conduct alleged herein was discovered in 2011, when the purported signer of Deed of Release 2009015916 was found not to have signed Deed of Release 2009015916 before the notary public identified in Deed of Release 2009015916. Defendant is liable under section 562.056(1)(2) RSMo because the conduct constituting the offense was engaged in by an agent of the corporation while acting within the scope

ww

w.

of the agent’s employment and in behalf of the corporation.

St

op Fo

re

clo

35

su re

acting knowingly in concert with its employees, with the purpose to mislead the Boone

Fr au d. co

m

COUNT 39

Forgery – Class C Felony Mo. Charge Code: 1801089.0 NCIC Code: 2589

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant in violation of section 570.090 RSMo, committed the class C felony of

July 7, 2009, in the County of Boone, State of Missouri, Defendant, acting knowingly in concert with its employees, with the purpose to defraud, used as genuine or transferred with the knowledge or belief that it would be used as genuine, a writing, namely Deed of Release number 2009018566, knowing that it had been made or authenticated so that it purported to have been made by another, or that it had been made so that it purported 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 the offense was engaged in, authorized, solicited, requested, commanded or knowingly tolerated by a high managerial agent acting within the scope of the agent’s employment

w.

and in behalf of the corporation. COUNT 40 False Declaration – Class B misdemeanor Mo. Charge Code: 2910199.0 36

ww

St

op Fo

re

clo

su re

forgery, punishable upon conviction under section 560.021, RSMo, in that on or about

Fr au d. co

m

NCIC Code: 5099 The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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, in that on or about July 7, 2009, in the County of Boone, State of Missouri, Defendant acting knowingly in concert with its employees, with the purpose to mislead the Boone County Recorder of Deeds, a public servant in the performance of her duty, submitted

Defendant knew to be lacking in authenticity, and which stated a fact material to the purposes for which the writing was offered.

The conduct alleged herein was discovered in 2011, when the purported signer of Deed of Release 2009018566 was found not to have signed Deed of Release 2009018566 before the notary public identified in Deed of Release 2009018566. Defendant is liable under section 562.056(1)(2) RSMo because the conduct constituting the offense was engaged in by an agent of the corporation while acting within the scope of the agent’s employment and in behalf of the corporation.

St

op Fo

ww

w.

re

Forgery – Class C Felony Mo. Charge Code: 1801089.0 NCIC Code: 2589

clo

COUNT 41

37

su re

or invited reliance on a writing, namely Deed of Release number 2009018566, which

Fr au d. co

m

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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 about July 7, 2009, in the County of Boone, State of Missouri, Defendant, acting knowingly in concert with its employees, with the purpose to defraud, used as genuine or transferred with the knowledge or belief that it would be used as genuine, a writing, namely Deed of Release number 2009018567, knowing that it had been made or authenticated so

purported 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 the offense was engaged in, authorized, solicited, requested, commanded or knowingly tolerated by a high managerial agent acting within the scope of the agent’s employment and in behalf of the corporation.

op Fo

False Declaration – Class B misdemeanor Mo. Charge Code: 2910199.0 NCIC Code: 5099

The Grand Jurors of the County of Boone, State of Missouri, charge that

making a false declaration, punishable upon conviction under section 560.021, RSMo, in

ww

that on or about July 7, 2009, in the County of Boone, State of Missouri, Defendant

w.

Defendant in violation of section 575.060 RSMo, committed the class B misdemeanor of

St

re

clo

COUNT 42

38

su re

that it purported to have been made by another, or that it had been made so that it

Fr au d. co

m

acting knowingly in concert with its employees, with the purpose to mislead the Boone County Recorder of Deeds, a public servant in the performance of her duty, submitted or invited reliance on a writing, namely Deed of Release number 2009018567, which Defendant knew to be lacking in authenticity, and which stated a fact material to the purposes for which the writing was offered.

The conduct alleged herein was discovered in 2011, when the purported signer of Deed of Release 2009018567 was found not to have signed Deed of Release

Defendant is liable under section 562.056(1)(2) RSMo because the conduct constituting the offense was engaged in by an agent of the corporation while acting within the scope of the agent’s employment and in behalf of the corporation.

op Fo

St

ww

Defendant in violation of section 570.090 RSMo, committed the class C felony of

w.

The Grand Jurors of the County of Boone, State of Missouri, charge that

re

Forgery – Class C Felony Mo. Charge Code: 1801089.0 NCIC Code: 2589

clo

COUNT 43

39

su re

2009018567 before the notary public identified in Deed of Release 2009018567.

Fr au d. co

m

forgery, punishable upon conviction under section 560.021, RSMo, in that on or about July 14, 2009, in the County of Boone, State of Missouri, Defendant, acting knowingly in

concert with its employees, with the purpose to defraud, used as genuine or transferred with the knowledge or belief that it would be used as genuine, a writing, namely Deed of Release number 2009019232, knowing that it had been made or authenticated so that it purported to have been made by another, or that it had been made so that it purported to have been made by authority of one who did not give such authority.

the offense was engaged in, authorized, solicited, requested, commanded or knowingly tolerated by a high managerial agent acting within the scope of the agent’s employment and in behalf of the corporation.

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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, in

acting knowingly in concert with its employees, with the purpose to mislead the Boone

ww

County Recorder of Deeds, a public servant in the performance of her duty, submitted

w.

that on or about July 14, 2009, in the County of Boone, State of Missouri, Defendant

St

op Fo

False Declaration – Class B misdemeanor Mo. Charge Code: 2910199.0 NCIC Code: 5099

re

clo

COUNT 44

40

su re

Defendant is liable under section 562.056(1)(3) RSMo because the conduct constituting

Fr au d. co

m

or invited reliance on a writing, namely Deed of Release number 2009019232, which Defendant knew to be lacking in authenticity, and which stated a fact material to the purposes for which the writing was offered.

The conduct alleged herein was discovered in 2011, when the purported signer of Deed of Release 2009019232 was found not to have signed Deed of Release 2009019232 before the notary public identified in Deed of Release 2009019232. Defendant is liable under section 562.056(1)(2) RSMo because the conduct constituting

of the agent’s employment and in behalf of the corporation. COUNT 45

Forgery – Class C Felony Mo. Charge Code: 1801089.0 NCIC Code: 2589 The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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 about July 21, 2009, in the County of Boone, State of Missouri, Defendant, acting knowingly in concert with its employees, with the purpose to defraud, used as genuine or transferred

of Release number 2009019970, knowing that it had been made or authenticated so

ww

that it purported to have been made by another, or that it had been made so that it

w.

with the knowledge or belief that it would be used as genuine, a writing, namely Deed

St

op Fo

re

clo

41

su re

the offense was engaged in by an agent of the corporation while acting within the scope

Fr au d. co

m

purported 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

the offense was engaged in, authorized, solicited, requested, commanded or knowingly tolerated by a high managerial agent acting within the scope of the agent’s employment and in behalf of the corporation. COUNT 46

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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, in that on or about July 21, 2009, in the County of Boone, State of Missouri, Defendant acting knowingly in concert with its employees, with the purpose to mislead the Boone County Recorder of Deeds, a public servant in the performance of her duty, submitted or invited reliance on a writing, namely Deed of Release number 2009019970, which Defendant knew to be lacking in authenticity, and which stated a fact material to the purposes for which the writing was offered.

Deed of Release 2009019970 was found not to have signed Deed of Release

ww

2009019970 before the notary public identified in Deed of Release 2009019970.

w.

The conduct alleged herein was discovered in 2011, when the purported signer of

St

op Fo

re

clo

42

su re

False Declaration – Class B misdemeanor Mo. Charge Code: 2910199.0 NCIC Code: 5099

Fr au d. co

m

Defendant is liable under section 562.056(1)(2) RSMo because the conduct constituting the offense was engaged in by an agent of the corporation while acting within the scope of the agent’s employment and in behalf of the corporation.

Forgery – Class C Felony Mo. Charge Code: 1801089.0 NCIC Code: 2589

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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 about August 25, 2009, in the County of Boone, State of Missouri, Defendant, acting knowingly in concert with its employees, with the purpose to defraud, used as genuine or transferred with the knowledge or belief that it would be used as genuine, a writing, namely Deed of Release number 2009023094, knowing that it had been made or

made so that it purported to have been made by authority of one who did not give such

ww

authority. Defendant is liable under section 562.056(1)(3) RSMo because the conduct

w.

authenticated so that it purported to have been made by another, or that it had been

St

op Fo

re

clo

43

su re

COUNT 47

Fr au d. co

m

constituting the offense was engaged in, authorized, solicited, requested, commanded or knowingly tolerated by a high managerial agent acting within the scope of the agent’s employment and in behalf of the corporation. COUNT 48

False Declaration – Class B misdemeanor Mo. Charge Code: 2910199.0 NCIC Code: 5099

The Grand Jurors of the County of Boone, State of Missouri, charge that

making a false declaration, punishable upon conviction under section 560.021, RSMo, in that on or about August 25, 2009, in the County of Boone, State of Missouri, Defendant acting knowingly in concert with its employees, with the purpose to mislead the Boone County Recorder of Deeds, a public servant in the performance of her duty, submitted or invited reliance on a writing, namely Deed of Release number 2009023094, which Defendant knew to be lacking in authenticity, and which stated a fact material to the purposes for which the writing was offered. The conduct alleged herein was discovered in 2011, when the purported signer of Deed of Release 2009023094 was found not to have signed Deed of Release

Defendant is liable under section 562.056(1)(2) RSMo because the conduct constituting

ww

w.

2009023094 before the notary public identified in Deed of Release 2009023094.

St

op Fo

re

clo

44

su re

Defendant in violation of section 575.060 RSMo, committed the class B misdemeanor of

Fr au d. co

m

the offense was engaged in by an agent of the corporation while acting within the scope of the agent’s employment and in behalf of the corporation. COUNT 49

Forgery – Class C Felony Mo. Charge Code: 1801089.0 NCIC Code: 2589

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant in violation of section 570.090 RSMo, committed the class C felony of

August 25, 2009, in the County of Boone, State of Missouri, Defendant, acting knowingly in concert with its employees, with the purpose to defraud, used as genuine or transferred with the knowledge or belief that it would be used as genuine, a writing, namely Deed of Release number 2009023095, knowing that it had been made or authenticated so that it purported to have been made by another, or that it had been made so that it purported 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 the offense was engaged in, authorized, solicited, requested, commanded or knowingly tolerated by a high managerial agent acting within the scope of the

w.

agent’s employment and in behalf of the corporation. COUNT 50 False Declaration – Class B misdemeanor Mo. Charge Code: 2910199.0 45

ww

St

op Fo

re

clo

su re

forgery, punishable upon conviction under section 560.021, RSMo, in that on or about

Fr au d. co

m

NCIC Code: 5099 The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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, in that on or about August 25, 2009, in the County of Boone, State of Missouri, Defendant acting knowingly in concert with its employees, with the purpose to mislead the Boone County Recorder of Deeds, a public servant in the performance of her duty, submitted

Defendant knew to be lacking in authenticity, and which stated a fact material to the purposes for which the writing was offered.

The conduct alleged herein was discovered in 2011, when the purported signer of Deed of Release 2009023095 was found not to have signed Deed of Release 2009023095 before the notary public identified in Deed of Release 2009023095. Defendant is liable under section 562.056(1)(2) RSMo because the conduct constituting the offense was engaged in by an agent of the corporation while acting within the scope of the agent’s employment and in behalf of the corporation.

ww

w.

St

op Fo

re

clo

46

su re

or invited reliance on a writing, namely Deed of Release number 2009023095, which

Fr au d. co

m

COUNT 51 Forgery – Class C Felony Mo. Charge Code: 1801089.0 NCIC Code: 2589

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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 about August 25, 2009, in the County of Boone, State of Missouri, Defendant, acting knowingly

transferred with the knowledge or belief that it would be used as genuine, a writing, namely Deed of Release number 2009023096, knowing that it had been made or authenticated so that it purported to have been made by another, or that it had been made so that it purported 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 the offense was engaged in, authorized, solicited, requested, commanded or knowingly tolerated by a high managerial agent acting within the scope of the agent’s employment and in behalf of the corporation.

St

op Fo

ww

w.

False Declaration – Class B misdemeanor Mo. Charge Code: 2910199.0 NCIC Code: 5099

re

clo

COUNT 52

47

su re

in concert with its employees, with the purpose to defraud, used as genuine or

Fr au d. co

m

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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, in that on or about August 25, 2009, in the County of Boone, State of Missouri, Defendant acting knowingly in concert with its employees, with the purpose to mislead the Boone County Recorder of Deeds, a public servant in the performance of her duty, submitted or invited reliance on a writing, namely Deed of Release number 2009023096, which

purposes for which the writing was offered.

The conduct alleged herein was discovered in 2011, when the purported signer of Deed of Release 2009023096 was found not to have signed Deed of Release 2009023096 before the notary public identified in Deed of Release 2009023096. Defendant is liable under section 562.056(1)(2) RSMo because the conduct constituting the offense was engaged in by an agent of the corporation while acting within the scope of the agent’s employment and in behalf of the corporation. COUNT 53

St

ww

Defendant in violation of section 570.090 RSMo, committed the class C felony of

w.

The Grand Jurors of the County of Boone, State of Missouri, charge that

op Fo

re

Forgery – Class C Felony Mo. Charge Code: 1801089.0 NCIC Code: 2589

clo

48

su re

Defendant knew to be lacking in authenticity, and which stated a fact material to the

Fr au d. co

m

forgery, punishable upon conviction under section 560.021, RSMo, in that on or about April 28, 2009, in the County of Boone, State of Missouri, Defendant, acting knowingly in

concert with its employees, with the purpose to defraud, used as genuine or transferred with the knowledge or belief that it would be used as genuine, a writing, namely Deed of Release number 2009010725, knowing that it had been made or authenticated so that it purported to have been made by another, or that it had been made so that it purported to have been made by authority of one who did not give such authority.

the offense was engaged in, authorized, solicited, requested, commanded or knowingly tolerated by a high managerial agent acting within the scope of the agent’s employment and in behalf of the corporation.

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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, in

acting knowingly in concert with its employees, with the purpose to mislead the Boone

ww

County Recorder of Deeds, a public servant in the performance of her duty, submitted

w.

that on or about April 28, 2009, in the County of Boone, State of Missouri, Defendant

St

op Fo

False Declaration – Class B misdemeanor Mo. Charge Code: 2910199.0 NCIC Code: 5099

re

clo

COUNT 54

49

su re

Defendant is liable under section 562.056(1)(3) RSMo because the conduct constituting

Fr au d. co

m

or invited reliance on a writing, namely Deed of Release number 2009010725, which Defendant knew to be lacking in authenticity, and which stated a fact material to the purposes for which the writing was offered.

The conduct alleged herein was discovered in 2011, when the purported signer of Deed of Release 2009010725 was found not to have signed Deed of Release 2009010725 before the notary public identified in Deed of Release 2009010725. Defendant is liable under section 562.056(1)(2) RSMo because the conduct constituting

of the agent’s employment and in behalf of the corporation.

op Fo

The Grand Jurors of the County of Boone, State of Missouri, charge that

forgery, punishable upon conviction under section 560.021, RSMo, in that on or about

ww

April 28, 2009, in the County of Boone, State of Missouri, Defendant, acting knowingly in

w.

Defendant in violation of section 570.090 RSMo, committed the class C felony of

St

re

Forgery – Class C Felony Mo. Charge Code: 1801089.0 NCIC Code: 2589

clo

COUNT 55

50

su re

the offense was engaged in by an agent of the corporation while acting within the scope

Fr au d. co

m

concert with its employees, with the purpose to defraud, used as genuine or transferred with the knowledge or belief that it would be used as genuine, a writing, namely Deed of Release number 2009010726, knowing that it had been made or authenticated so that it purported to have been made by another, or that it had been made so that it purported 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 the offense was engaged in, authorized, solicited, requested, commanded or knowingly

and in behalf of the corporation.

COUNT 56

False Declaration – Class B misdemeanor Mo. Charge Code: 2910199.0 NCIC Code: 5099 The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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, in that on or about April 28, 2009, in the County of Boone, State of Missouri, Defendant acting knowingly in concert with its employees, with the purpose to mislead the Boone

or invited reliance on a writing, namely Deed of Release number 2009010726, which

ww

w.

County Recorder of Deeds, a public servant in the performance of her duty, submitted

St

op Fo

re

clo

51

su re

tolerated by a high managerial agent acting within the scope of the agent’s employment

Fr au d. co

m

Defendant knew to be lacking in authenticity, and which stated a fact material to the purposes for which the writing was offered.

The conduct alleged herein was discovered in 2011, when the purported signer of Deed of Release 2009010726 was found not to have signed Deed of Release 2009010726 before the notary public identified in Deed of Release 2009010726. Defendant is liable under section 562.056(1)(2) RSMo because the conduct constituting the offense was engaged in by an agent of the corporation while acting within the scope

COUNT 57

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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 about April 28, 2009, in the County of Boone, State of Missouri, Defendant, acting knowingly in concert with its employees, with the purpose to defraud, used as genuine or transferred with the knowledge or belief that it would be used as genuine, a writing, namely Deed

that it purported to have been made by another, or that it had been made so that it

ww

purported to have been made by authority of one who did not give such authority.

w.

of Release number 2009010727, knowing that it had been made or authenticated so

St

op Fo

re

clo

Forgery – Class C Felony Mo. Charge Code: 1801089.0 NCIC Code: 2589

52

su re

of the agent’s employment and in behalf of the corporation.

Fr au d. co

m

Defendant is liable under section 562.056(1)(3) RSMo because the conduct constituting the offense was engaged in, authorized, solicited, requested, commanded or knowingly tolerated by a high managerial agent acting within the scope of the agent’s employment and in behalf of the corporation. COUNT 58

False Declaration – Class B misdemeanor Mo. Charge Code: 2910199.0 NCIC Code: 5099

Defendant 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, in that on or about April 28, 2009, in the County of Boone, State of Missouri, Defendant acting knowingly in concert with its employees, with the purpose to mislead the Boone County Recorder of Deeds, a public servant in the performance of her duty, submitted or invited reliance on a writing, namely Deed of Release number 2009010727, which Defendant knew to be lacking in authenticity, and which stated a fact material to the purposes for which the writing was offered. The conduct alleged herein was discovered in 2011, when the purported signer of

2009010727 before the notary public identified in Deed of Release 2009010727.

ww

Defendant is liable under section 562.056(1)(2) RSMo because the conduct constituting

w.

Deed of Release 2009010727 was found not to have signed Deed of Release

St

op Fo

re

clo

53

su re

The Grand Jurors of the County of Boone, State of Missouri, charge that

Fr au d. co

m

the offense was engaged in by an agent of the corporation while acting within the scope of the agent’s employment and in behalf of the corporation.

COUNT 59

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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 about April 28, 2009, in the County of Boone, State of Missouri, Defendant, acting knowingly in concert with its employees, with the purpose to defraud, used as genuine or transferred with the knowledge or belief that it would be used as genuine, a writing, namely Deed of Release number 2009010728, knowing that it had been made or authenticated so that it purported to have been made by another, or that it had been made so that it

Defendant is liable under section 562.056(1)(3) RSMo because the conduct constituting

ww

the offense was engaged in, authorized, solicited, requested, commanded or knowingly

w.

purported to have been made by authority of one who did not give such authority.

St

op Fo

re

clo

54

su re

Forgery – Class C Felony Mo. Charge Code: 1801089.0 NCIC Code: 2589

Fr au d. co

m

tolerated by a high managerial agent acting within the scope of the agent’s employment and in behalf of the corporation. COUNT 60

False Declaration – Class B misdemeanor Mo. Charge Code: 2910199.0 NCIC Code: 5099

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant in violation of section 575.060 RSMo, committed the class B misdemeanor of

that on or about April 28, 2009, in the County of Boone, State of Missouri, Defendant acting knowingly in concert with its employees, with the purpose to mislead the Boone County Recorder of Deeds, a public servant in the performance of her duty, submitted or invited reliance on a writing, namely Deed of Release number 2009010728, which Defendant knew to be lacking in authenticity, and which stated a fact material to the purposes for which the writing was offered. The conduct alleged herein was discovered in 2011, when the purported signer of Deed of Release 2009010728 was found not to have signed Deed of Release 2009010728 before the notary public identified in Deed of Release 2009010728.

the offense was engaged in by an agent of the corporation while acting within the scope

ww

of the agent’s employment and in behalf of the corporation.

w.

Defendant is liable under section 562.056(1)(2) RSMo because the conduct constituting

St

op Fo

re

clo

55

su re

making a false declaration, punishable upon conviction under section 560.021, RSMo, in

Fr au d. co

m

COUNT 61 Forgery – Class C Felony Mo. Charge Code: 1801089.0 NCIC Code: 2589

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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 about May 11, 2009, in the County of Boone, State of Missouri, Defendant, acting knowingly in

with the knowledge or belief that it would be used as genuine, a writing, namely Deed of Release number 2009012041, knowing that it had been made or authenticated so that it purported to have been made by another, or that it had been made so that it purported 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 the offense was engaged in, authorized, solicited, requested, commanded or knowingly tolerated by a high managerial agent acting within the scope of the agent’s employment and in behalf of the corporation.

St

op Fo

ww

w.

False Declaration – Class B misdemeanor Mo. Charge Code: 2910199.0 NCIC Code: 5099

re

clo

COUNT 62

56

su re

concert with its employees, with the purpose to defraud, used as genuine or transferred

Fr au d. co

m

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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, in that on or about May 11, 2009, in the County of Boone, State of Missouri, Defendant acting knowingly in concert with its employees, with the purpose to mislead the Boone County Recorder of Deeds, a public servant in the performance of her duty, submitted or invited reliance on a writing, namely Deed of Release number 2009012041, which

purposes for which the writing was offered.

The conduct alleged herein was discovered in 2011, when the purported signer of Deed of Release 2009012041 was found not to have signed Deed of Release 2009012041 before the notary public identified in Deed of Release 2009012041. Defendant is liable under section 562.056(1)(2) RSMo because the conduct constituting the offense was engaged in by an agent of the corporation while acting within the scope of the agent’s employment and in behalf of the corporation.

ww

w.

St

op Fo

re

clo

COUNT 63

57

su re

Defendant knew to be lacking in authenticity, and which stated a fact material to the

Fr au d. co

m

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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 about May 19, 2009, in the County of Boone, State of Missouri, Defendant, acting knowingly in concert with its employees, with the purpose to defraud, used as genuine or transferred

of Release number 2009013007, knowing that it had been made or authenticated so that it purported to have been made by another, or that it had been made so that it purported 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 the offense was engaged in, authorized, solicited, requested, commanded or knowingly tolerated by a high managerial agent acting within the scope of the agent’s employment and in behalf of the corporation.

op Fo

St

ww

Defendant in violation of section 575.060 RSMo, committed the class B misdemeanor of

w.

False Declaration – Class B misdemeanor Mo. Charge Code: 2910199.0 NCIC Code: 5099

The Grand Jurors of the County of Boone, State of Missouri, charge that

re

clo

COUNT 64

58

su re

with the knowledge or belief that it would be used as genuine, a writing, namely Deed

Fr au d. co

m

Forgery – Class C Felony Mo. Charge Code: 1801089.0 NCIC Code: 2589

making a false declaration, punishable upon conviction under section 560.021, RSMo, in that on or about May 19, 2009, in the County of Boone, State of Missouri, Defendant

acting knowingly in concert with its employees, with the purpose to mislead the Boone County Recorder of Deeds, a public servant in the performance of her duty, submitted or invited reliance on a writing, namely Deed of Release number 2009013007, which Defendant knew to be lacking in authenticity, and which stated a fact material to the purposes for which the writing was offered.

Deed of Release 2009013007 was found not to have signed Deed of Release 2009013007 before the notary public identified in Deed of Release 2009013007. Defendant is liable under section 562.056(1)(2) RSMo because the conduct constituting the offense was engaged in by an agent of the corporation while acting within the scope of the agent’s employment and in behalf of the corporation.

op Fo

The Grand Jurors of the County of Boone, State of Missouri, charge that

forgery, punishable upon conviction under section 560.021, RSMo, in that on or about

ww

June 23, 2009, in the County of Boone, State of Missouri, Defendant, acting knowingly in

w.

Defendant in violation of section 570.090 RSMo, committed the class C felony of

St

re

Forgery – Class C Felony Mo. Charge Code: 1801089.0 NCIC Code: 2589

clo

COUNT 65

59

su re

The conduct alleged herein was discovered in 2011, when the purported signer of

Fr au d. co

m

concert with its employees, with the purpose to defraud, used as genuine or transferred with the knowledge or belief that it would be used as genuine, a writing, namely Deed of Release number 2009017022, knowing that it had been made or authenticated so that it purported to have been made by another, or that it had been made so that it purported 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 the offense was engaged in, authorized, solicited, requested, commanded or knowingly

and in behalf of the corporation.

COUNT 66

False Declaration – Class B misdemeanor Mo. Charge Code: 2910199.0 NCIC Code: 5099 The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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, in that on or about June 23, 2009, in the County of Boone, State of Missouri, Defendant acting knowingly in concert with its employees, with the purpose to mislead the Boone

or invited reliance on a writing, namely Deed of Release number 2009017022, which

ww

w.

County Recorder of Deeds, a public servant in the performance of her duty, submitted

St

op Fo

re

clo

60

su re

tolerated by a high managerial agent acting within the scope of the agent’s employment

Fr au d. co

m

Defendant knew to be lacking in authenticity, and which stated a fact material to the purposes for which the writing was offered.

The conduct alleged herein was discovered in 2011, when the purported signer of Deed of Release 2009017022 was found not to have signed Deed of Release 2009017022 before the notary public identified in Deed of Release 2009017022. Defendant is liable under section 562.056(1)(2) RSMo because the conduct constituting the offense was engaged in by an agent of the corporation while acting within the scope

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant in violation of section 570.090 RSMo, committed the class C felony of

June 23, 2009, in the County of Boone, State of Missouri, Defendant, acting knowingly in

ww

concert with its employees, with the purpose to defraud, used as genuine or transferred

w.

forgery, punishable upon conviction under section 560.021, RSMo, in that on or about

St

op Fo

re

Forgery – Class C Felony Mo. Charge Code: 1801089.0 NCIC Code: 2589

clo

COUNT 67

61

su re

of the agent’s employment and in behalf of the corporation.

Fr au d. co

m

with the knowledge or belief that it would be used as genuine, a writing, namely Deed of Release number 2009017028, knowing that it had been made or authenticated so that it purported to have been made by another, or that it had been made so that it purported 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 the offense was engaged in, authorized, solicited, requested, commanded or knowingly tolerated by a high managerial agent acting within the scope of the agent’s employment

COUNT 68

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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, in that on or about June 23, 2009, in the County of Boone, State of Missouri, Defendant acting knowingly in concert with its employees, with the purpose to mislead the Boone County Recorder of Deeds, a public servant in the performance of her duty, submitted

Defendant knew to be lacking in authenticity, and which stated a fact material to the

ww

purposes for which the writing was offered.

w.

or invited reliance on a writing, namely Deed of Release number 2009017028, which

St

op Fo

re

clo

False Declaration – Class B misdemeanor Mo. Charge Code: 2910199.0 NCIC Code: 5099

62

su re

and in behalf of the corporation.

Fr au d. co

m

The conduct alleged herein was discovered in 2011, when the purported signer of Deed of Release 2009017028 was found not to have signed Deed of Release 2009017028 before the notary public identified in Deed of Release 2009017028. Defendant is liable under section 562.056(1)(2) RSMo because the conduct constituting the offense was engaged in by an agent of the corporation while acting within the scope of the agent’s employment and in behalf of the corporation. COUNT 69

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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 about June 23, 2009, in the County of Boone, State of Missouri, Defendant, acting knowingly in concert with its employees, with the purpose to defraud, used as genuine or transferred with the knowledge or belief that it would be used as genuine, a writing, namely Deed of Release number 2009017029, knowing that it had been made or authenticated so that it purported to have been made by another, or that it had been made so that it

Defendant is liable under section 562.056(1)(3) RSMo because the conduct constituting

ww

the offense was engaged in, authorized, solicited, requested, commanded or knowingly

w.

purported to have been made by authority of one who did not give such authority.

St

op Fo

re

clo

63

su re

Forgery – Class C Felony Mo. Charge Code: 1801089.0 NCIC Code: 2589

Fr au d. co

m

tolerated by a high managerial agent acting within the scope of the agent’s employment and in behalf of the corporation. COUNT 70

False Declaration – Class B misdemeanor Mo. Charge Code: 2910199.0 NCIC Code: 5099

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant in violation of section 575.060 RSMo, committed the class B misdemeanor of

that on or about June 23, 2009, in the County of Boone, State of Missouri, Defendant acting knowingly in concert with its employees, with the purpose to mislead the Boone County Recorder of Deeds, a public servant in the performance of her duty, submitted or invited reliance on a writing, namely Deed of Release number 2009017029, which Defendant knew to be lacking in authenticity, and which stated a fact material to the purposes for which the writing was offered. The conduct alleged herein was discovered in 2011, when the purported signer of Deed of Release 2009017029 was found not to have signed Deed of Release 2009017029 before the notary public identified in Deed of Release 2009017029.

the offense was engaged in by an agent of the corporation while acting within the scope

ww

of the agent’s employment and in behalf of the corporation.

w.

Defendant is liable under section 562.056(1)(2) RSMo because the conduct constituting

St

op Fo

re

clo

64

su re

making a false declaration, punishable upon conviction under section 560.021, RSMo, in

Fr au d. co

m

COUNT 71

Forgery – Class C Felony Mo. Charge Code: 1801089.0 NCIC Code: 2589

Defendant 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 about June 26, 2009, in the County of Boone, State of Missouri, Defendant, acting knowingly in concert with its employees, with the purpose to defraud, used as genuine or transferred with the knowledge or belief that it would be used as genuine, a writing, namely Deed of Release number 2009017438, knowing that it had been made or authenticated so that it purported to have been made by another, or that it had been made so that it purported 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

tolerated by a high managerial agent acting within the scope of the agent’s employment

ww

and in behalf of the corporation.

w.

the offense was engaged in, authorized, solicited, requested, commanded or knowingly

St

op Fo

re

clo

65

su re

The Grand Jurors of the County of Boone, State of Missouri, charge that

Fr au d. co

m

COUNT 72 False Declaration – Class B misdemeanor Mo. Charge Code: 2910199.0 NCIC Code: 5099

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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, in that on or about June 26, 2009, in the County of Boone, State of Missouri, Defendant

County Recorder of Deeds, a public servant in the performance of her duty, submitted or invited reliance on a writing, namely Deed of Release number 2009017438, which Defendant knew to be lacking in authenticity, and which stated a fact material to the purposes for which the writing was offered.

The conduct alleged herein was discovered in 2011, when the purported signer of Deed of Release 2009017438 was found not to have signed Deed of Release 2009017438 before the notary public identified in Deed of Release 2009017438. Defendant is liable under section 562.056(1)(2) RSMo because the conduct constituting the offense was engaged in by an agent of the corporation while acting within the scope

w.

of the agent’s employment and in behalf of the corporation. COUNT 73 Forgery – Class C Felony Mo. Charge Code: 1801089.0 66

ww

St

op Fo

re

clo

su re

acting knowingly in concert with its employees, with the purpose to mislead the Boone

Fr au d. co

m

NCIC Code: 2589 The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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 about June 26, 2009, in the County of Boone, State of Missouri, Defendant, acting knowingly in concert with its employees, with the purpose to defraud, used as genuine or transferred with the knowledge or belief that it would be used as genuine, a writing, namely Deed

that it purported to have been made by another, or that it had been made so that it purported 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 the offense was engaged in, authorized, solicited, requested, commanded or knowingly tolerated by a high managerial agent acting within the scope of the agent’s employment and in behalf of the corporation.

op Fo

Defendant in violation of section 575.060 RSMo, committed the class B misdemeanor of

ww

making a false declaration, punishable upon conviction under section 560.021, RSMo, in

w.

The Grand Jurors of the County of Boone, State of Missouri, charge that

St

False Declaration – Class B misdemeanor Mo. Charge Code: 2910199.0 NCIC Code: 5099

re

clo

COUNT 74

67

su re

of Release number 2009017439, knowing that it had been made or authenticated so

Fr au d. co

m

that on or about June 26, 2009, in the County of Boone, State of Missouri, Defendant acting knowingly in concert with its employees, with the purpose to mislead the Boone

County Recorder of Deeds, a public servant in the performance of her duty, submitted or invited reliance on a writing, namely Deed of Release number 2009017439, which Defendant knew to be lacking in authenticity, and which stated a fact material to the purposes for which the writing was offered.

The conduct alleged herein was discovered in 2011, when the purported signer of

2009017439 before the notary public identified in Deed of Release 2009017439. Defendant is liable under section 562.056(1)(2) RSMo because the conduct constituting the offense was engaged in by an agent of the corporation while acting within the scope of the agent’s employment and in behalf of the corporation.

St

op Fo

ww

w.

re

Forgery – Class C Felony Mo. Charge Code: 1801089.0 NCIC Code: 2589

clo

COUNT 75

68

su re

Deed of Release 2009017439 was found not to have signed Deed of Release

Fr au d. co

m

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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 about June 26, 2009, in the County of Boone, State of Missouri, Defendant, acting knowingly in concert with its employees, with the purpose to defraud, used as genuine or transferred with the knowledge or belief that it would be used as genuine, a writing, namely Deed of Release number 2009017440, knowing that it had been made or authenticated so

purported 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 the offense was engaged in, authorized, solicited, requested, commanded or knowingly tolerated by a high managerial agent acting within the scope of the agent’s employment and in behalf of the corporation.

op Fo

False Declaration – Class B misdemeanor Mo. Charge Code: 2910199.0 NCIC Code: 5099

The Grand Jurors of the County of Boone, State of Missouri, charge that

making a false declaration, punishable upon conviction under section 560.021, RSMo, in

ww

that on or about June 26, 2009, in the County of Boone, State of Missouri, Defendant

w.

Defendant in violation of section 575.060 RSMo, committed the class B misdemeanor of

St

re

clo

COUNT 76

69

su re

that it purported to have been made by another, or that it had been made so that it

Fr au d. co

m

acting knowingly in concert with its employees, with the purpose to mislead the Boone County Recorder of Deeds, a public servant in the performance of her duty, submitted or invited reliance on a writing, namely Deed of Release number 2009017440, which Defendant knew to be lacking in authenticity, and which stated a fact material to the purposes for which the writing was offered.

The conduct alleged herein was discovered in 2011, when the purported signer of Deed of Release 2009017440 was found not to have signed Deed of Release

Defendant is liable under section 562.056(1)(2) RSMo because the conduct constituting the offense was engaged in by an agent of the corporation while acting within the scope of the agent’s employment and in behalf of the corporation. COUNT 77

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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 about

concert with its employees, with the purpose to defraud, used as genuine or transferred

ww

with the knowledge or belief that it would be used as genuine, a writing, namely Deed

w.

June 30, 2009, in the County of Boone, State of Missouri, Defendant, acting knowingly in

St

op Fo

re

Forgery – Class C Felony Mo. Charge Code: 1801089.0 NCIC Code: 2589

clo

70

su re

2009017440 before the notary public identified in Deed of Release 2009017440.

Fr au d. co

m

of Release number 2009017814, knowing that it had been made or authenticated so that it purported to have been made by another, or that it had been made so that it

purported 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 the offense was engaged in, authorized, solicited, requested, commanded or knowingly tolerated by a high managerial agent acting within the scope of the agent’s employment and in behalf of the corporation. COUNT 78

False Declaration – Class B misdemeanor Mo. Charge Code: 2910199.0 NCIC Code: 5099 The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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, in that on or about June 30, 2009, in the County of Boone, State of Missouri, Defendant acting knowingly in concert with its employees, with the purpose to mislead the Boone County Recorder of Deeds, a public servant in the performance of her duty, submitted or invited reliance on a writing, namely Deed of Release number 2009017814, which

purposes for which the writing was offered.

ww

w.

Defendant knew to be lacking in authenticity, and which stated a fact material to the

St

op Fo

re

clo

71

su re

Fr au d. co

m

The conduct alleged herein was discovered in 2011, when the purported signer of Deed of Release 2009017814 was found not to have signed Deed of Release 2009017814 before the notary public identified in Deed of Release 2009017814. Defendant is liable under section 562.056(1)(2) RSMo because the conduct constituting the offense was engaged in by an agent of the corporation while acting within the scope of the agent’s employment and in behalf of the corporation.

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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 about July 20, 2009, in the County of Boone, State of Missouri, Defendant, acting knowingly in

with the knowledge or belief that it would be used as genuine, a writing, namely Deed

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of Release number 2009019809, knowing that it had been made or authenticated so

w.

concert with its employees, with the purpose to defraud, used as genuine or transferred

St

op Fo

re

Forgery – Class C Felony Mo. Charge Code: 1801089.0 NCIC Code: 2589

clo

COUNT 79

72

su re

Fr au d. co

m

that it purported to have been made by another, or that it had been made so that it purported 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 the offense was engaged in, authorized, solicited, requested, commanded or knowingly tolerated by a high managerial agent acting within the scope of the agent’s employment and in behalf of the corporation. COUNT 80

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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, in that on or about July 20, 2009, in the County of Boone, State of Missouri, Defendant acting knowingly in concert with its employees, with the purpose to mislead the Boone County Recorder of Deeds, a public servant in the performance of her duty, submitted or invited reliance on a writing, namely Deed of Release number 2009019809, which Defendant knew to be lacking in authenticity, and which stated a fact material to the

ww

Deed of Release 2009019809 was found not to have signed Deed of Release

w.

purposes for which the writing was offered. The conduct alleged herein was discovered in 2011, when the purported signer of

St

op Fo

re

clo

73

su re

False Declaration – Class B misdemeanor Mo. Charge Code: 2910199.0 NCIC Code: 5099

Fr au d. co

m

2009019809 before the notary public identified in Deed of Release 2009019809. Defendant is liable under section 562.056(1)(2) RSMo because the conduct constituting

the offense was engaged in by an agent of the corporation while acting within the scope of the agent’s employment and in behalf of the corporation. COUNT 81

Forgery – Class C Felony Mo. Charge Code: 1801089.0 NCIC Code: 2589

Defendant 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 about July 20, 2009, in the County of Boone, State of Missouri, Defendant, acting knowingly in concert with its employees, with the purpose to defraud, used as genuine or transferred with the knowledge or belief that it would be used as genuine, a writing, namely Deed of Release number 2009019810, knowing that it had been made or authenticated so that it purported to have been made by another, or that it had been made so that it purported 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

tolerated by a high managerial agent acting within the scope of the agent’s employment

ww

and in behalf of the corporation.

w.

the offense was engaged in, authorized, solicited, requested, commanded or knowingly

St

op Fo

re

clo

74

su re

The Grand Jurors of the County of Boone, State of Missouri, charge that

Fr au d. co

m

COUNT 82 False Declaration – Class B misdemeanor Mo. Charge Code: 2910199.0 NCIC Code: 5099

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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, in that on or about July 20, 2009, in the County of Boone, State of Missouri, Defendant

County Recorder of Deeds, a public servant in the performance of her duty, submitted or invited reliance on a writing, namely Deed of Release number 2009019810, which Defendant knew to be lacking in authenticity, and which stated a fact material to the purposes for which the writing was offered.

The conduct alleged herein was discovered in 2011, when the purported signer of Deed of Release 2009019810 was found not to have signed Deed of Release 2009019810 before the notary public identified in Deed of Release 2009019810. Defendant is liable under section 562.056(1)(2) RSMo because the conduct constituting the offense was engaged in by an agent of the corporation while acting within the scope

ww

w.

of the agent’s employment and in behalf of the corporation.

St

op Fo

re

clo

75

su re

acting knowingly in concert with its employees, with the purpose to mislead the Boone

Fr au d. co

m

COUNT 83

Forgery – Class C Felony Mo. Charge Code: 1801089.0 NCIC Code: 2589

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant in violation of section 570.090 RSMo, committed the class C felony of

July 20, 2009, in the County of Boone, State of Missouri, Defendant, acting knowingly in concert with its employees, with the purpose to defraud, used as genuine or transferred with the knowledge or belief that it would be used as genuine, a writing, namely Deed of Release number 2009019811, knowing that it had been made or authenticated so that it purported to have been made by another, or that it had been made so that it purported 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 the offense was engaged in, authorized, solicited, requested, commanded or knowingly tolerated by a high managerial agent acting within the scope of the agent’s employment

w.

and in behalf of the corporation. COUNT 84 False Declaration – Class B misdemeanor Mo. Charge Code: 2910199.0 76

ww

St

op Fo

re

clo

su re

forgery, punishable upon conviction under section 560.021, RSMo, in that on or about

Fr au d. co

m

NCIC Code: 5099 The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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, in that on or about July 20, 2009, in the County of Boone, State of Missouri, Defendant acting knowingly in concert with its employees, with the purpose to mislead the Boone County Recorder of Deeds, a public servant in the performance of her duty, submitted

Defendant knew to be lacking in authenticity, and which stated a fact material to the purposes for which the writing was offered.

The conduct alleged herein was discovered in 2011, when the purported signer of Deed of Release 2009019811 was found not to have signed Deed of Release 2009019811 before the notary public identified in Deed of Release 2009019811. Defendant is liable under section 562.056(1)(2) RSMo because the conduct constituting the offense was engaged in by an agent of the corporation while acting within the scope of the agent’s employment and in behalf of the corporation.

St

op Fo

ww

w.

re

Forgery – Class C Felony Mo. Charge Code: 1801089.0 NCIC Code: 2589

clo

COUNT 85

77

su re

or invited reliance on a writing, namely Deed of Release number 2009019811, which

Fr au d. co

m

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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 about July 20, 2009, in the County of Boone, State of Missouri, Defendant, acting knowingly in concert with its employees, with the purpose to defraud, used as genuine or transferred with the knowledge or belief that it would be used as genuine, a writing, namely Deed of Release number 2009019812, knowing that it had been made or authenticated so

purported 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 the offense was engaged in, authorized, solicited, requested, commanded or knowingly tolerated by a high managerial agent acting within the scope of the agent’s employment and in behalf of the corporation.

op Fo

False Declaration – Class B misdemeanor Mo. Charge Code: 2910199.0 NCIC Code: 5099

The Grand Jurors of the County of Boone, State of Missouri, charge that

making a false declaration, punishable upon conviction under section 560.021, RSMo, in

ww

that on or about July 20, 2009, in the County of Boone, State of Missouri, Defendant

w.

Defendant in violation of section 575.060 RSMo, committed the class B misdemeanor of

St

re

clo

COUNT 86

78

su re

that it purported to have been made by another, or that it had been made so that it

Fr au d. co

m

acting knowingly in concert with its employees, with the purpose to mislead the Boone County Recorder of Deeds, a public servant in the performance of her duty, submitted or invited reliance on a writing, namely Deed of Release number 2009019812, which Defendant knew to be lacking in authenticity, and which stated a fact material to the purposes for which the writing was offered.

The conduct alleged herein was discovered in 2011, when the purported signer of Deed of Release 2009019812 was found not to have signed Deed of Release

Defendant is liable under section 562.056(1)(2) RSMo because the conduct constituting the offense was engaged in by an agent of the corporation while acting within the scope of the agent’s employment and in behalf of the corporation.

op Fo

St

ww

Defendant in violation of section 570.090 RSMo, committed the class C felony of

w.

The Grand Jurors of the County of Boone, State of Missouri, charge that

re

Forgery – Class C Felony Mo. Charge Code: 1801089.0 NCIC Code: 2589

clo

COUNT 87

79

su re

2009019812 before the notary public identified in Deed of Release 2009019812.

Fr au d. co

m

forgery, punishable upon conviction under section 560.021, RSMo, in that on or about July 20, 2009, in the County of Boone, State of Missouri, Defendant, acting knowingly in

concert with its employees, with the purpose to defraud, used as genuine or transferred with the knowledge or belief that it would be used as genuine, a writing, namely Deed of Release number 2009019813, knowing that it had been made or authenticated so that it purported to have been made by another, or that it had been made so that it purported to have been made by authority of one who did not give such authority.

the offense was engaged in, authorized, solicited, requested, commanded or knowingly tolerated by a high managerial agent acting within the scope of the agent’s employment and in behalf of the corporation.

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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, in

acting knowingly in concert with its employees, with the purpose to mislead the Boone

ww

County Recorder of Deeds, a public servant in the performance of her duty, submitted

w.

that on or about July 20, 2009, in the County of Boone, State of Missouri, Defendant

St

op Fo

False Declaration – Class B misdemeanor Mo. Charge Code: 2910199.0 NCIC Code: 5099

re

clo

COUNT 88

80

su re

Defendant is liable under section 562.056(1)(3) RSMo because the conduct constituting

Fr au d. co

m

or invited reliance on a writing, namely Deed of Release number 2009019813, which Defendant knew to be lacking in authenticity, and which stated a fact material to the purposes for which the writing was offered.

The conduct alleged herein was discovered in 2011, when the purported signer of Deed of Release 2009019813 was found not to have signed Deed of Release 2009019813 before the notary public identified in Deed of Release 2009019813. Defendant is liable under section 562.056(1)(2) RSMo because the conduct constituting

of the agent’s employment and in behalf of the corporation. COUNT 89

Forgery – Class C Felony Mo. Charge Code: 1801089.0 NCIC Code: 2589 The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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 about July 20, 2009, in the County of Boone, State of Missouri, Defendant, acting knowingly in concert with its employees, with the purpose to defraud, used as genuine or transferred

of Release number 2009019814, knowing that it had been made or authenticated so

ww

that it purported to have been made by another, or that it had been made so that it

w.

with the knowledge or belief that it would be used as genuine, a writing, namely Deed

St

op Fo

re

clo

81

su re

the offense was engaged in by an agent of the corporation while acting within the scope

Fr au d. co

m

purported 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

the offense was engaged in, authorized, solicited, requested, commanded or knowingly tolerated by a high managerial agent acting within the scope of the agent’s employment and in behalf of the corporation. COUNT 90

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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, in that on or about July 20, 2009, in the County of Boone, State of Missouri, Defendant acting knowingly in concert with its employees, with the purpose to mislead the Boone County Recorder of Deeds, a public servant in the performance of her duty, submitted or invited reliance on a writing, namely Deed of Release number 2009019814, which Defendant knew to be lacking in authenticity, and which stated a fact material to the purposes for which the writing was offered.

Deed of Release 2009019814 was found not to have signed Deed of Release

ww

2009019814 before the notary public identified in Deed of Release 2009019814.

w.

The conduct alleged herein was discovered in 2011, when the purported signer of

St

op Fo

re

clo

82

su re

False Declaration – Class B misdemeanor Mo. Charge Code: 2910199.0 NCIC Code: 5099

Fr au d. co

m

Defendant is liable under section 562.056(1)(2) RSMo because the conduct constituting the offense was engaged in by an agent of the corporation while acting within the scope of the agent’s employment and in behalf of the corporation.

Forgery – Class C Felony Mo. Charge Code: 1801089.0 NCIC Code: 2589

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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 about July 21, 2009, in the County of Boone, State of Missouri, Defendant, acting knowingly in concert with its employees, with the purpose to defraud, used as genuine or transferred with the knowledge or belief that it would be used as genuine, a writing, namely Deed of Release number 2009019968, knowing that it had been made or authenticated so

purported to have been made by authority of one who did not give such authority.

ww

Defendant is liable under section 562.056(1)(3) RSMo because the conduct constituting

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that it purported to have been made by another, or that it had been made so that it

St

op Fo

re

clo

83

su re

COUNT 91

Fr au d. co

m

the offense was engaged in, authorized, solicited, requested, commanded or knowingly tolerated by a high managerial agent acting within the scope of the agent’s employment and in behalf of the corporation. COUNT 92

False Declaration – Class B misdemeanor Mo. Charge Code: 2910199.0 NCIC Code: 5099

The Grand Jurors of the County of Boone, State of Missouri, charge that

making a false declaration, punishable upon conviction under section 560.021, RSMo, in that on or about July 21, 2009, in the County of Boone, State of Missouri, Defendant acting knowingly in concert with its employees, with the purpose to mislead the Boone County Recorder of Deeds, a public servant in the performance of her duty, submitted or invited reliance on a writing, namely Deed of Release number 2009019968, which Defendant knew to be lacking in authenticity, and which stated a fact material to the purposes for which the writing was offered. The conduct alleged herein was discovered in 2011, when the purported signer of Deed of Release 2009019968 was found not to have signed Deed of Release

Defendant is liable under section 562.056(1)(2) RSMo because the conduct constituting

ww

w.

2009019968 before the notary public identified in Deed of Release 2009019968.

St

op Fo

re

clo

84

su re

Defendant in violation of section 575.060 RSMo, committed the class B misdemeanor of

Fr au d. co

m

the offense was engaged in by an agent of the corporation while acting within the scope of the agent’s employment and in behalf of the corporation. COUNT 93

Forgery – Class C Felony Mo. Charge Code: 1801089.0 NCIC Code: 2589

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant in violation of section 570.090 RSMo, committed the class C felony of

July 21, 2009, in the County of Boone, State of Missouri, Defendant, acting knowingly in concert with its employees, with the purpose to defraud, used as genuine or transferred with the knowledge or belief that it would be used as genuine, a writing, namely Deed of Release number 2009019969, knowing that it had been made or authenticated so that it purported to have been made by another, or that it had been made so that it purported 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 the offense was engaged in, authorized, solicited, requested, commanded or knowingly tolerated by a high managerial agent acting within the scope of the agent’s employment

w.

and in behalf of the corporation. COUNT 94 False Declaration – Class B misdemeanor Mo. Charge Code: 2910199.0 85

ww

St

op Fo

re

clo

su re

forgery, punishable upon conviction under section 560.021, RSMo, in that on or about

Fr au d. co

m

NCIC Code: 5099 The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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, in that on or about July 21, 2009, in the County of Boone, State of Missouri, Defendant acting knowingly in concert with its employees, with the purpose to mislead the Boone County Recorder of Deeds, a public servant in the performance of her duty, submitted

Defendant knew to be lacking in authenticity, and which stated a fact material to the purposes for which the writing was offered.

The conduct alleged herein was discovered in 2011, when the purported signer of Deed of Release 2009019969 was found not to have signed Deed of Release 2009019969 before the notary public identified in Deed of Release 2009019969. Defendant is liable under section 562.056(1)(2) RSMo because the conduct constituting the offense was engaged in by an agent of the corporation while acting within the scope of the agent’s employment and in behalf of the corporation.

ww

w.

St

op Fo

re

clo

86

su re

or invited reliance on a writing, namely Deed of Release number 2009019969, which

Fr au d. co

m

COUNT 95 Forgery – Class C Felony Mo. Charge Code: 1801089.0 NCIC Code: 2589

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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 about August 3, 2009, in the County of Boone, State of Missouri, Defendant, acting knowingly

transferred with the knowledge or belief that it would be used as genuine, a writing, namely Deed of Release number 2009021215, knowing that it had been made or authenticated so that it purported to have been made by another, or that it had been made so that it purported 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 the offense was engaged in, authorized, solicited, requested, commanded or knowingly tolerated by a high managerial agent acting within the scope of the agent’s employment and in behalf of the corporation.

St

op Fo

ww

w.

False Declaration – Class B misdemeanor Mo. Charge Code: 2910199.0 NCIC Code: 5099

re

clo

COUNT 96

87

su re

in concert with its employees, with the purpose to defraud, used as genuine or

Fr au d. co

m

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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, in that on or about August 3, 2009, in the County of Boone, State of Missouri, Defendant acting knowingly in concert with its employees, with the purpose to mislead the Boone County Recorder of Deeds, a public servant in the performance of her duty, submitted or invited reliance on a writing, namely Deed of Release number 2009021215, which

purposes for which the writing was offered.

The conduct alleged herein was discovered in 2011, when the purported signer of Deed of Release 2009021215 was found not to have signed Deed of Release 2009021215 before the notary public identified in Deed of Release 2009021215. Defendant is liable under section 562.056(1)(2) RSMo because the conduct constituting the offense was engaged in by an agent of the corporation while acting within the scope of the agent’s employment and in behalf of the corporation. COUNT 97

St

ww

Defendant in violation of section 570.090 RSMo, committed the class C felony of

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The Grand Jurors of the County of Boone, State of Missouri, charge that

op Fo

re

Forgery – Class C Felony Mo. Charge Code: 1801089.0 NCIC Code: 2589

clo

88

su re

Defendant knew to be lacking in authenticity, and which stated a fact material to the

Fr au d. co

m

forgery, punishable upon conviction under section 560.021, RSMo, in that on or about August 3, 2009, in the County of Boone, State of Missouri, Defendant, acting knowingly

in concert with its employees, with the purpose to defraud, used as genuine or transferred with the knowledge or belief that it would be used as genuine, a writing, namely Deed of Release number 2009021216, knowing that it had been made or authenticated so that it purported to have been made by another, or that it had been made so that it purported to have been made by authority of one who did not give such

constituting the offense was engaged in, authorized, solicited, requested, commanded or knowingly tolerated by a high managerial agent acting within the scope of the agent’s employment and in behalf of the corporation. COUNT 98

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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, in

acting knowingly in concert with its employees, with the purpose to mislead the Boone

ww

County Recorder of Deeds, a public servant in the performance of her duty, submitted

w.

that on or about August 3, 2009, in the County of Boone, State of Missouri, Defendant

St

op Fo

False Declaration – Class B misdemeanor Mo. Charge Code: 2910199.0 NCIC Code: 5099

re

clo

89

su re

authority. Defendant is liable under section 562.056(1)(3) RSMo because the conduct

Fr au d. co

m

or invited reliance on a writing, namely Deed of Release number 2009021216, which Defendant knew to be lacking in authenticity, and which stated a fact material to the purposes for which the writing was offered.

The conduct alleged herein was discovered in 2011, when the purported signer of Deed of Release 2009021216 was found not to have signed Deed of Release 2009021216 before the notary public identified in Deed of Release 2009021216. Defendant is liable under section 562.056(1)(2) RSMo because the conduct constituting

of the agent’s employment and in behalf of the corporation.

op Fo

The Grand Jurors of the County of Boone, State of Missouri, charge that

forgery, punishable upon conviction under section 560.021, RSMo, in that on or about

ww

August 3, 2009, in the County of Boone, State of Missouri, Defendant, acting knowingly

w.

Defendant in violation of section 570.090 RSMo, committed the class C felony of

St

re

Forgery – Class C Felony Mo. Charge Code: 1801089.0 NCIC Code: 2589

clo

COUNT 99

90

su re

the offense was engaged in by an agent of the corporation while acting within the scope

Fr au d. co

m

in concert with its employees, with the purpose to defraud, used as genuine or transferred with the knowledge or belief that it would be used as genuine, a writing,

namely Deed of Release number 2009021217, knowing that it had been made or authenticated so that it purported to have been made by another, or that it had been made so that it purported 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 the offense was engaged in, authorized, solicited, requested, commanded

agent’s employment and in behalf of the corporation. COUNT 100

False Declaration – Class B misdemeanor Mo. Charge Code: 2910199.0 NCIC Code: 5099 The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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, in that on or about August 3, 2009, in the County of Boone, State of Missouri, Defendant acting knowingly in concert with its employees, with the purpose to mislead the Boone

or invited reliance on a writing, namely Deed of Release number 2009021217, which

ww

w.

County Recorder of Deeds, a public servant in the performance of her duty, submitted

St

op Fo

re

clo

91

su re

or knowingly tolerated by a high managerial agent acting within the scope of the

Fr au d. co

m

Defendant knew to be lacking in authenticity, and which stated a fact material to the purposes for which the writing was offered.

The conduct alleged herein was discovered in 2011, when the purported signer of Deed of Release 2009021217 was found not to have signed Deed of Release 2009021217 before the notary public identified in Deed of Release 2009021217. Defendant is liable under section 562.056(1)(2) RSMo because the conduct constituting the offense was engaged in by an agent of the corporation while acting within the scope

COUNT 101

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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 about August 11, 2009, in the County of Boone, State of Missouri, Defendant, acting knowingly in concert with its employees, with the purpose to defraud, used as genuine or transferred with the knowledge or belief that it would be used as genuine, a writing,

authenticated so that it purported to have been made by another, or that it had been

ww

made so that it purported to have been made by authority of one who did not give such

w.

namely Deed of Release number 2009021863, knowing that it had been made or

St

op Fo

re

clo

Forgery – Class C Felony Mo. Charge Code: 1801089.0 NCIC Code: 2589

92

su re

of the agent’s employment and in behalf of the corporation.

Fr au d. co

m

authority. Defendant is liable under section 562.056(1)(3) RSMo because the conduct constituting the offense was engaged in, authorized, solicited, requested, commanded or knowingly tolerated by a high managerial agent acting within the scope of the agent’s employment and in behalf of the corporation. COUNT 102

False Declaration – Class B misdemeanor Mo. Charge Code: 2910199.0 NCIC Code: 5099

Defendant 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, in that on or about August 11, 2009, in the County of Boone, State of Missouri, Defendant acting knowingly in concert with its employees, with the purpose to mislead the Boone County Recorder of Deeds, a public servant in the performance of her duty, submitted or invited reliance on a writing, namely Deed of Release number 2009021863, which Defendant knew to be lacking in authenticity, and which stated a fact material to the purposes for which the writing was offered. The conduct alleged herein was discovered in 2011, when the purported signer of

2009021863 before the notary public identified in Deed of Release 2009021863.

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Defendant is liable under section 562.056(1)(2) RSMo because the conduct constituting

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Deed of Release 2009021863 was found not to have signed Deed of Release

St

op Fo

re

clo

93

su re

The Grand Jurors of the County of Boone, State of Missouri, charge that

Fr au d. co

m

the offense was engaged in by an agent of the corporation while acting within the scope of the agent’s employment and in behalf of the corporation.

COUNT 103

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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 about August 11, 2009, in the County of Boone, State of Missouri, Defendant, acting knowingly in concert with its employees, with the purpose to defraud, used as genuine or transferred with the knowledge or belief that it would be used as genuine, a writing, namely Deed of Release number 2009021864, knowing that it had been made or authenticated so that it purported to have been made by another, or that it had been

authority. Defendant is liable under section 562.056(1)(3) RSMo because the conduct

ww

constituting the offense was engaged in, authorized, solicited, requested, commanded

w.

made so that it purported to have been made by authority of one who did not give such

St

op Fo

re

clo

94

su re

Forgery – Class C Felony Mo. Charge Code: 1801089.0 NCIC Code: 2589

Fr au d. co

m

or knowingly tolerated by a high managerial agent acting within the scope of the agent’s employment and in behalf of the corporation. COUNT 104

False Declaration – Class B misdemeanor Mo. Charge Code: 2910199.0 NCIC Code: 5099

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant in violation of section 575.060 RSMo, committed the class B misdemeanor of

that on or about August 11, 2009, in the County of Boone, State of Missouri, Defendant acting knowingly in concert with its employees, with the purpose to mislead the Boone County Recorder of Deeds, a public servant in the performance of her duty, submitted or invited reliance on a writing, namely Deed of Release number 2009021864, which Defendant knew to be lacking in authenticity, and which stated a fact material to the purposes for which the writing was offered. The conduct alleged herein was discovered in 2011, when the purported signer of Deed of Release 2009021864 was found not to have signed Deed of Release 2009021864 before the notary public identified in Deed of Release 2009021864.

the offense was engaged in by an agent of the corporation while acting within the scope

ww

of the agent’s employment and in behalf of the corporation.

w.

Defendant is liable under section 562.056(1)(2) RSMo because the conduct constituting

St

op Fo

re

clo

95

su re

making a false declaration, punishable upon conviction under section 560.021, RSMo, in

Fr au d. co

m

COUNT 105 Forgery – Class C Felony Mo. Charge Code: 1801089.0 NCIC Code: 2589

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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 about August 11, 2009, in the County of Boone, State of Missouri, Defendant, acting knowingly

transferred with the knowledge or belief that it would be used as genuine, a writing, namely Deed of Release number 2009021868, knowing that it had been made or authenticated so that it purported to have been made by another, or that it had been made so that it purported 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 the offense was engaged in, authorized, solicited, requested, commanded or knowingly tolerated by a high managerial agent acting within the scope of the agent’s employment and in behalf of the corporation.

St

op Fo

ww

w.

False Declaration – Class B misdemeanor Mo. Charge Code: 2910199.0 NCIC Code: 5099

re

clo

COUNT 106

96

su re

in concert with its employees, with the purpose to defraud, used as genuine or

Fr au d. co

m

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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, in that on or about August 11, 2009, in the County of Boone, State of Missouri, Defendant acting knowingly in concert with its employees, with the purpose to mislead the Boone County Recorder of Deeds, a public servant in the performance of her duty, submitted or invited reliance on a writing, namely Deed of Release number 2009021868, which

purposes for which the writing was offered.

The conduct alleged herein was discovered in 2011, when the purported signer of Deed of Release 2009021868 was found not to have signed Deed of Release 2009021868 before the notary public identified in Deed of Release 2009021868. Defendant is liable under section 562.056(1)(2) RSMo because the conduct constituting the offense was engaged in by an agent of the corporation while acting within the scope of the agent’s employment and in behalf of the corporation.

ww

w.

St

op Fo

re

clo

COUNT 107

97

su re

Defendant knew to be lacking in authenticity, and which stated a fact material to the

Fr au d. co

m

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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 about August 11, 2009, in the County of Boone, State of Missouri, Defendant, acting knowingly in concert with its employees, with the purpose to defraud, used as genuine or

namely Deed of Release number 2009021869, knowing that it had been made or authenticated so that it purported to have been made by another, or that it had been made so that it purported 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 the offense was engaged in, authorized, solicited, requested, commanded or knowingly tolerated by a high managerial agent acting within the scope of the agent’s employment and in behalf of the corporation. COUNT 108

St

ww

Defendant in violation of section 575.060 RSMo, committed the class B misdemeanor of

w.

The Grand Jurors of the County of Boone, State of Missouri, charge that

op Fo

False Declaration – Class B misdemeanor Mo. Charge Code: 2910199.0 NCIC Code: 5099

re

clo

98

su re

transferred with the knowledge or belief that it would be used as genuine, a writing,

Fr au d. co

m

Forgery – Class C Felony Mo. Charge Code: 1801089.0 NCIC Code: 2589

making a false declaration, punishable upon conviction under section 560.021, RSMo, in that on or about August 11, 2009, in the County of Boone, State of Missouri, Defendant

acting knowingly in concert with its employees, with the purpose to mislead the Boone County Recorder of Deeds, a public servant in the performance of her duty, submitted or invited reliance on a writing, namely Deed of Release number 2009021869, which Defendant knew to be lacking in authenticity, and which stated a fact material to the purposes for which the writing was offered.

Deed of Release 2009021869 was found not to have signed Deed of Release 2009021869 before the notary public identified in Deed of Release 2009021869. Defendant is liable under section 562.056(1)(2) RSMo because the conduct constituting the offense was engaged in by an agent of the corporation while acting within the scope of the agent’s employment and in behalf of the corporation.

op Fo

The Grand Jurors of the County of Boone, State of Missouri, charge that

forgery, punishable upon conviction under section 560.021, RSMo, in that on or about

ww

August 11, 2009, in the County of Boone, State of Missouri, Defendant, acting knowingly

w.

Defendant in violation of section 570.090 RSMo, committed the class C felony of

St

re

Forgery – Class C Felony Mo. Charge Code: 1801089.0 NCIC Code: 2589

clo

COUNT 109

99

su re

The conduct alleged herein was discovered in 2011, when the purported signer of

Fr au d. co

m

in concert with its employees, with the purpose to defraud, used as genuine or transferred with the knowledge or belief that it would be used as genuine, a writing,

namely Deed of Release number 2009021870, knowing that it had been made or authenticated so that it purported to have been made by another, or that it had been made so that it purported 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 the offense was engaged in, authorized, solicited, requested, commanded

agent’s employment and in behalf of the corporation. COUNT 110

False Declaration – Class B misdemeanor Mo. Charge Code: 2910199.0 NCIC Code: 5099 The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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, in that on or about August 11, 2009, in the County of Boone, State of Missouri, Defendant acting knowingly in concert with its employees, with the purpose to mislead the Boone

or invited reliance on a writing, namely Deed of Release number 2009021870, which

ww

w.

County Recorder of Deeds, a public servant in the performance of her duty, submitted

St

op Fo

re

clo

100

su re

or knowingly tolerated by a high managerial agent acting within the scope of the

Fr au d. co

m

Defendant knew to be lacking in authenticity, and which stated a fact material to the purposes for which the writing was offered.

The conduct alleged herein was discovered in 2011, when the purported signer of Deed of Release 2009021870 was found not to have signed Deed of Release 2009021870 before the notary public identified in Deed of Release 2009021870. Defendant is liable under section 562.056(1)(2) RSMo because the conduct constituting the offense was engaged in by an agent of the corporation while acting within the scope

Defendant 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 about

ww

August 11, 2009, in the County of Boone, State of Missouri, Defendant, acting knowingly in concert with its employees, with the purpose to defraud, used as genuine or 101

w.

St

The Grand Jurors of the County of Boone, State of Missouri, charge that

op Fo

re

Forgery – Class C Felony Mo. Charge Code: 1801089.0 NCIC Code: 2589

clo

COUNT 111

su re

of the agent’s employment and in behalf of the corporation.

Fr au d. co

m

transferred with the knowledge or belief that it would be used as genuine, a writing, namely Deed of Release number 2009021871, knowing that it had been made or authenticated so that it purported to have been made by another, or that it had been made so that it purported 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 the offense was engaged in, authorized, solicited, requested, commanded or knowingly tolerated by a high managerial agent acting within the scope of the

COUNT 112

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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, in that on or about August 11, 2009, in the County of Boone, State of Missouri, Defendant acting knowingly in concert with its employees, with the purpose to mislead the Boone County Recorder of Deeds, a public servant in the performance of her duty, submitted

Defendant knew to be lacking in authenticity, and which stated a fact material to the

ww

purposes for which the writing was offered.

w.

or invited reliance on a writing, namely Deed of Release number 2009021871, which

St

op Fo

re

clo

False Declaration – Class B misdemeanor Mo. Charge Code: 2910199.0 NCIC Code: 5099

102

su re

agent’s employment and in behalf of the corporation.

Fr au d. co

m

The conduct alleged herein was discovered in 2011, when the purported signer of Deed of Release 2009021871 was found not to have signed Deed of Release 2009021871 before the notary public identified in Deed of Release 2009021871. Defendant is liable under section 562.056(1)(2) RSMo because the conduct constituting the offense was engaged in by an agent of the corporation while acting within the scope of the agent’s employment and in behalf of the corporation. COUNT 113

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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 about August 25, 2009, in the County of Boone, State of Missouri, Defendant, acting knowingly in concert with its employees, with the purpose to defraud, used as genuine or transferred with the knowledge or belief that it would be used as genuine, a writing, namely Deed of Release number 2009023097, knowing that it had been made or authenticated so that it purported to have been made by another, or that it had been

authority. Defendant is liable under section 562.056(1)(3) RSMo because the conduct

ww

constituting the offense was engaged in, authorized, solicited, requested, commanded

w.

made so that it purported to have been made by authority of one who did not give such

St

op Fo

re

clo

103

su re

Forgery – Class C Felony Mo. Charge Code: 1801089.0 NCIC Code: 2589

Fr au d. co

m

or knowingly tolerated by a high managerial agent acting within the scope of the agent’s employment and in behalf of the corporation. COUNT 114

False Declaration – Class B misdemeanor Mo. Charge Code: 2910199.0 NCIC Code: 5099

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant in violation of section 575.060 RSMo, committed the class B misdemeanor of

that on or about August 25, 2009, in the County of Boone, State of Missouri, Defendant acting knowingly in concert with its employees, with the purpose to mislead the Boone County Recorder of Deeds, a public servant in the performance of her duty, submitted or invited reliance on a writing, namely Deed of Release number 2009023097, which Defendant knew to be lacking in authenticity, and which stated a fact material to the purposes for which the writing was offered. The conduct alleged herein was discovered in 2011, when the purported signer of Deed of Release 2009023097 was found not to have signed Deed of Release 2009023097 before the notary public identified in Deed of Release 2009023097.

the offense was engaged in by an agent of the corporation while acting within the scope

ww

of the agent’s employment and in behalf of the corporation.

w.

Defendant is liable under section 562.056(1)(2) RSMo because the conduct constituting

St

op Fo

re

clo

104

su re

making a false declaration, punishable upon conviction under section 560.021, RSMo, in

Fr au d. co

m

COUNT 115

Forgery – Class C Felony Mo. Charge Code: 1801089.0 NCIC Code: 2589

Defendant 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 about August 25, 2009, in the County of Boone, State of Missouri, Defendant, acting knowingly in concert with its employees, with the purpose to defraud, used as genuine or transferred with the knowledge or belief that it would be used as genuine, a writing, namely Deed of Release number 2009023098, knowing that it had been made or authenticated so that it purported to have been made by another, or that it had been made so that it purported 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

or knowingly tolerated by a high managerial agent acting within the scope of the

ww

agent’s employment and in behalf of the corporation.

w.

constituting the offense was engaged in, authorized, solicited, requested, commanded

St

op Fo

re

clo

105

su re

The Grand Jurors of the County of Boone, State of Missouri, charge that

Fr au d. co

m

COUNT 116 False Declaration – Class B misdemeanor Mo. Charge Code: 2910199.0 NCIC Code: 5099

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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, in that on or about August 25, 2009, in the County of Boone, State of Missouri, Defendant

County Recorder of Deeds, a public servant in the performance of her duty, submitted or invited reliance on a writing, namely Deed of Release number 2009023098, which Defendant knew to be lacking in authenticity, and which stated a fact material to the purposes for which the writing was offered.

The conduct alleged herein was discovered in 2011, when the purported signer of Deed of Release 2009023098 was found not to have signed Deed of Release 2009023098 before the notary public identified in Deed of Release 2009023098. Defendant is liable under section 562.056(1)(2) RSMo because the conduct constituting the offense was engaged in by an agent of the corporation while acting within the scope

w.

of the agent’s employment and in behalf of the corporation. COUNT 117 Forgery – Class C Felony Mo. Charge Code: 1801089.0 106

ww

St

op Fo

re

clo

su re

acting knowingly in concert with its employees, with the purpose to mislead the Boone

Fr au d. co

m

NCIC Code: 2589 The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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 about September 1, 2009, in the County of Boone, State of Missouri, Defendant, acting knowingly in concert with its employees, with the purpose to defraud, used as genuine or transferred with the knowledge or belief that it would be used as genuine, a writing,

authenticated so that it purported to have been made by another, or that it had been made so that it purported 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 the offense was engaged in, authorized, solicited, requested, commanded or knowingly tolerated by a high managerial agent acting within the scope of the agent’s employment and in behalf of the corporation. COUNT 118

Defendant in violation of section 575.060 RSMo, committed the class B misdemeanor of

ww

making a false declaration, punishable upon conviction under section 560.021, RSMo, in

w.

The Grand Jurors of the County of Boone, State of Missouri, charge that

St

op Fo

False Declaration – Class B misdemeanor Mo. Charge Code: 2910199.0 NCIC Code: 5099

re

clo

107

su re

namely Deed of Release number 2009023632, knowing that it had been made or

Fr au d. co

m

that on or about September 1, 2009, in the County of Boone, State of Missouri, Defendant acting knowingly in concert with its employees, with the purpose to mislead the Boone County Recorder of Deeds, a public servant in the performance of her duty, submitted or invited reliance on a writing, namely Deed of Release number 2009023632, which Defendant knew to be lacking in authenticity, and which stated a fact material to the purposes for which the writing was offered.

The conduct alleged herein was discovered in 2011, when the purported signer of

2009023632 before the notary public identified in Deed of Release 2009023632. Defendant is liable under section 562.056(1)(2) RSMo because the conduct constituting the offense was engaged in by an agent of the corporation while acting within the scope of the agent’s employment and in behalf of the corporation.

St

op Fo

ww

w.

re

Forgery – Class C Felony Mo. Charge Code: 1801089.0 NCIC Code: 2589

clo

COUNT 119

108

su re

Deed of Release 2009023632 was found not to have signed Deed of Release

Fr au d. co

m

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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 about September 21, 2009, in the County of Boone, State of Missouri, Defendant, acting knowingly in concert with its employees, with the purpose to defraud, used as genuine or transferred with the knowledge or belief that it would be used as genuine, a writing, namely Deed of Release number 2009024997, knowing that it had been made or

made so that it purported 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 the offense was engaged in, authorized, solicited, requested, commanded or knowingly tolerated by a high managerial agent acting within the scope of the agent’s employment and in behalf of the corporation.

op Fo

False Declaration – Class B misdemeanor Mo. Charge Code: 2910199.0 NCIC Code: 5099

The Grand Jurors of the County of Boone, State of Missouri, charge that

making a false declaration, punishable upon conviction under section 560.021, RSMo, in

ww

that on or about September 21, 2009, in the County of Boone, State of Missouri,

w.

Defendant in violation of section 575.060 RSMo, committed the class B misdemeanor of

St

re

clo

COUNT 120

109

su re

authenticated so that it purported to have been made by another, or that it had been

Fr au d. co

m

Defendant acting knowingly in concert with its employees, with the purpose to mislead the Boone County Recorder of Deeds, a public servant in the performance of her duty,

submitted or invited reliance on a writing, namely Deed of Release number 2009024997, which Defendant knew to be lacking in authenticity, and which stated a fact material to the purposes for which the writing was offered.

The conduct alleged herein was discovered in 2011, when the purported signer of Deed of Release 2009024997 was found not to have signed Deed of Release

Defendant is liable under section 562.056(1)(2) RSMo because the conduct constituting the offense was engaged in by an agent of the corporation while acting within the scope of the agent’s employment and in behalf of the corporation. COUNT 121

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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 about

knowingly in concert with its employees, with the purpose to defraud, used as genuine

ww

or transferred with the knowledge or belief that it would be used as genuine, a writing,

w.

September 21, 2009, in the County of Boone, State of Missouri, Defendant, acting

St

op Fo

re

Forgery – Class C Felony Mo. Charge Code: 1801089.0 NCIC Code: 2589

clo

110

su re

2009024997 before the notary public identified in Deed of Release 2009024997.

Fr au d. co

m

namely Deed of Release number 2009024998, knowing that it had been made or authenticated so that it purported to have been made by another, or that it had been

made so that it purported 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 the offense was engaged in, authorized, solicited, requested, commanded or knowingly tolerated by a high managerial agent acting within the scope of the agent’s employment and in behalf of the corporation. COUNT 122

False Declaration – Class B misdemeanor Mo. Charge Code: 2910199.0 NCIC Code: 5099 The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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, in that on or about September 21, 2009, in the County of Boone, State of Missouri, Defendant acting knowingly in concert with its employees, with the purpose to mislead the Boone County Recorder of Deeds, a public servant in the performance of her duty, submitted or invited reliance on a writing, namely Deed of Release number 2009024998,

the purposes for which the writing was offered.

ww

w.

which Defendant knew to be lacking in authenticity, and which stated a fact material to

St

op Fo

re

clo

111

su re

Fr au d. co

m

The conduct alleged herein was discovered in 2011, when the purported signer of Deed of Release 2009024998 was found not to have signed Deed of Release 2009024998 before the notary public identified in Deed of Release 2009024998. Defendant is liable under section 562.056(1)(2) RSMo because the conduct constituting the offense was engaged in by an agent of the corporation while acting within the scope of the agent’s employment and in behalf of the corporation.

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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 about September 21, 2009, in the County of Boone, State of Missouri, Defendant, acting

or transferred with the knowledge or belief that it would be used as genuine, a writing,

ww

namely Deed of Release number 2009024999, knowing that it had been made or

w.

knowingly in concert with its employees, with the purpose to defraud, used as genuine

St

op Fo

re

Forgery – Class C Felony Mo. Charge Code: 1801089.0 NCIC Code: 2589

clo

COUNT 123

112

su re

Fr au d. co

m

authenticated so that it purported to have been made by another, or that it had been made so that it purported 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 the offense was engaged in, authorized, solicited, requested, commanded or knowingly tolerated by a high managerial agent acting within the scope of the agent’s employment and in behalf of the corporation. COUNT 124

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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, in that on or about September 21, 2009, in the County of Boone, State of Missouri, Defendant acting knowingly in concert with its employees, with the purpose to mislead the Boone County Recorder of Deeds, a public servant in the performance of her duty, submitted or invited reliance on a writing, namely Deed of Release number 2009024999, which Defendant knew to be lacking in authenticity, and which stated a fact material to

ww

Deed of Release 2009024999 was found not to have signed Deed of Release

w.

the purposes for which the writing was offered. The conduct alleged herein was discovered in 2011, when the purported signer of

St

op Fo

re

clo

113

su re

False Declaration – Class B misdemeanor Mo. Charge Code: 2910199.0 NCIC Code: 5099

Fr au d. co

m

2009024999 before the notary public identified in Deed of Release 2009024999. Defendant is liable under section 562.056(1)(2) RSMo because the conduct constituting

the offense was engaged in by an agent of the corporation while acting within the scope of the agent’s employment and in behalf of the corporation. COUNT 125

Forgery – Class C Felony Mo. Charge Code: 1801089.0 NCIC Code: 2589

Defendant 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 about October 5, 2009, in the County of Boone, State of Missouri, Defendant, acting knowingly in concert with its employees, with the purpose to defraud, used as genuine or transferred with the knowledge or belief that it would be used as genuine, a writing, namely Deed of Release number 2009026052, knowing that it had been made or authenticated so that it purported to have been made by another, or that it had been made so that it purported 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

or knowingly tolerated by a high managerial agent acting within the scope of the

ww

agent’s employment and in behalf of the corporation.

w.

constituting the offense was engaged in, authorized, solicited, requested, commanded

St

op Fo

re

clo

114

su re

The Grand Jurors of the County of Boone, State of Missouri, charge that

Fr au d. co

m

COUNT 126 False Declaration – Class B misdemeanor Mo. Charge Code: 2910199.0 NCIC Code: 5099

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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, in that on or about October 5, 2009, in the County of Boone, State of Missouri, Defendant

County Recorder of Deeds, a public servant in the performance of her duty, submitted or invited reliance on a writing, namely Deed of Release number 2009026052, which Defendant knew to be lacking in authenticity, and which stated a fact material to the purposes for which the writing was offered.

The conduct alleged herein was discovered in 2011, when the purported signer of Deed of Release 2009026052 was found not to have signed Deed of Release 2009026052 before the notary public identified in Deed of Release 2009026052. Defendant is liable under section 562.056(1)(2) RSMo because the conduct constituting the offense was engaged in by an agent of the corporation while acting within the scope

ww

w.

of the agent’s employment and in behalf of the corporation.

St

op Fo

re

clo

115

su re

acting knowingly in concert with its employees, with the purpose to mislead the Boone

Fr au d. co

m

COUNT 127

Forgery – Class C Felony Mo. Charge Code: 1801089.0 NCIC Code: 2589

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant in violation of section 570.090 RSMo, committed the class C felony of

October 5, 2009, in the County of Boone, State of Missouri, Defendant, acting knowingly in concert with its employees, with the purpose to defraud, used as genuine or transferred with the knowledge or belief that it would be used as genuine, a writing, namely Deed of Release number 2009026053, knowing that it had been made or authenticated so that it purported to have been made by another, or that it had been made so that it purported 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 the offense was engaged in, authorized, solicited, requested, commanded or knowingly tolerated by a high managerial agent acting within the scope of the

w.

agent’s employment and in behalf of the corporation. COUNT 128 False Declaration – Class B misdemeanor Mo. Charge Code: 2910199.0 116

ww

St

op Fo

re

clo

su re

forgery, punishable upon conviction under section 560.021, RSMo, in that on or about

Fr au d. co

m

NCIC Code: 5099 The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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, in that on or about October 5, 2009, in the County of Boone, State of Missouri, Defendant acting knowingly in concert with its employees, with the purpose to mislead the Boone County Recorder of Deeds, a public servant in the performance of her duty, submitted

Defendant knew to be lacking in authenticity, and which stated a fact material to the purposes for which the writing was offered.

The conduct alleged herein was discovered in 2011, when the purported signer of Deed of Release 2009026053 was found not to have signed Deed of Release 2009026053 before the notary public identified in Deed of Release 2009026053. Defendant is liable under section 562.056(1)(2) RSMo because the conduct constituting the offense was engaged in by an agent of the corporation while acting within the scope of the agent’s employment and in behalf of the corporation.

St

op Fo

ww

w.

re

Forgery – Class C Felony Mo. Charge Code: 1801089.0 NCIC Code: 2589

clo

COUNT 129

117

su re

or invited reliance on a writing, namely Deed of Release number 2009026053, which

Fr au d. co

m

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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 about October 5, 2009, in the County of Boone, State of Missouri, Defendant, acting knowingly in concert with its employees, with the purpose to defraud, used as genuine or transferred with the knowledge or belief that it would be used as genuine, a writing, namely Deed of Release number 2009026054, knowing that it had been made or

made so that it purported 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 the offense was engaged in, authorized, solicited, requested, commanded or knowingly tolerated by a high managerial agent acting within the scope of the agent’s employment and in behalf of the corporation.

op Fo

False Declaration – Class B misdemeanor Mo. Charge Code: 2910199.0 NCIC Code: 5099

The Grand Jurors of the County of Boone, State of Missouri, charge that

making a false declaration, punishable upon conviction under section 560.021, RSMo, in

ww

that on or about October 5, 2009, in the County of Boone, State of Missouri, Defendant

w.

Defendant in violation of section 575.060 RSMo, committed the class B misdemeanor of

St

re

clo

COUNT 130

118

su re

authenticated so that it purported to have been made by another, or that it had been

Fr au d. co

m

acting knowingly in concert with its employees, with the purpose to mislead the Boone County Recorder of Deeds, a public servant in the performance of her duty, submitted or invited reliance on a writing, namely Deed of Release number 2009026054, which Defendant knew to be lacking in authenticity, and which stated a fact material to the purposes for which the writing was offered.

The conduct alleged herein was discovered in 2011, when the purported signer of Deed of Release 2009026054 was found not to have signed Deed of Release

Defendant is liable under section 562.056(1)(2) RSMo because the conduct constituting the offense was engaged in by an agent of the corporation while acting within the scope of the agent’s employment and in behalf of the corporation.

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Defendant in violation of section 570.090 RSMo, committed the class C felony of

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The Grand Jurors of the County of Boone, State of Missouri, charge that

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Forgery – Class C Felony Mo. Charge Code: 1801089.0 NCIC Code: 2589

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COUNT 131

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2009026054 before the notary public identified in Deed of Release 2009026054.

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forgery, punishable upon conviction under section 560.021, RSMo, in that on or about October 5, 2009, in the County of Boone, State of Missouri, Defendant, acting knowingly

in concert with its employees, with the purpose to defraud, used as genuine or transferred with the knowledge or belief that it would be used as genuine, a writing, namely Deed of Release number 2009026055, knowing that it had been made or authenticated so that it purported to have been made by another, or that it had been made so that it purported to have been made by authority of one who did not give such

constituting the offense was engaged in, authorized, solicited, requested, commanded or knowingly tolerated by a high managerial agent acting within the scope of the agent’s employment and in behalf of the corporation. COUNT 132

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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, in

acting knowingly in concert with its employees, with the purpose to mislead the Boone

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County Recorder of Deeds, a public servant in the performance of her duty, submitted

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that on or about October 5, 2009, in the County of Boone, State of Missouri, Defendant

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False Declaration – Class B misdemeanor Mo. Charge Code: 2910199.0 NCIC Code: 5099

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authority. Defendant is liable under section 562.056(1)(3) RSMo because the conduct

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or invited reliance on a writing, namely Deed of Release number 2009026055, which Defendant knew to be lacking in authenticity, and which stated a fact material to the purposes for which the writing was offered.

The conduct alleged herein was discovered in 2011, when the purported signer of Deed of Release 2009026055 was found not to have signed Deed of Release 2009026055 before the notary public identified in Deed of Release 2009026055. Defendant is liable under section 562.056(1)(2) RSMo because the conduct constituting

of the agent’s employment and in behalf of the corporation. COUNT 133

Forgery – Class C Felony Mo. Charge Code: 1801089.0 NCIC Code: 2589 The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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 about October 19, 2009, in the County of Boone, State of Missouri, Defendant, acting knowingly in concert with its employees, with the purpose to defraud, used as genuine

namely Deed of Release number 2009026958, knowing that it had been made or

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authenticated so that it purported to have been made by another, or that it had been

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or transferred with the knowledge or belief that it would be used as genuine, a writing,

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the offense was engaged in by an agent of the corporation while acting within the scope

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made so that it purported 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 the offense was engaged in, authorized, solicited, requested, commanded or knowingly tolerated by a high managerial agent acting within the scope of the agent’s employment and in behalf of the corporation. COUNT 134

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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, in that on or about October 19, 2009, in the County of Boone, State of Missouri, Defendant acting knowingly in concert with its employees, with the purpose to mislead the Boone County Recorder of Deeds, a public servant in the performance of her duty, submitted or invited reliance on a writing, namely Deed of Release number 2009026958, which Defendant knew to be lacking in authenticity, and which stated a fact material to the purposes for which the writing was offered.

Deed of Release 2009026958 was found not to have signed Deed of Release

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2009026958 before the notary public identified in Deed of Release 2009026958.

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The conduct alleged herein was discovered in 2011, when the purported signer of

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False Declaration – Class B misdemeanor Mo. Charge Code: 2910199.0 NCIC Code: 5099

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Defendant is liable under section 562.056(1)(2) RSMo because the conduct constituting the offense was engaged in by an agent of the corporation while acting within the scope of the agent’s employment and in behalf of the corporation.

Forgery – Class C Felony Mo. Charge Code: 1801089.0 NCIC Code: 2589

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant 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 about June 3, 2009, in the County of Boone, State of Missouri, Defendant, acting knowingly in concert with its employees, with the purpose to defraud, used as genuine or transferred with the knowledge or belief that it would be used as genuine, a writing, namely Deed of Release number 2009014721, knowing that it had been made or authenticated so

purported to have been made by authority of one who did not give such authority.

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Defendant is liable under section 562.056(1)(3) RSMo because the conduct constituting

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that it purported to have been made by another, or that it had been made so that it

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COUNT 135

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the offense was engaged in, authorized, solicited, requested, commanded or knowingly tolerated by a high managerial agent acting within the scope of the agent’s employment and in behalf of the corporation. COUNT 136

False Declaration – Class B misdemeanor Mo. Charge Code: 2910199.0 NCIC Code: 5099

The Grand Jurors of the County of Boone, State of Missouri, charge that

making a false declaration, punishable upon conviction under section 560.021, RSMo, in that on or about June 3, 2009, in the County of Boone, State of Missouri, Defendant acting knowingly in concert with its employees, with the purpose to mislead the Boone County Recorder of Deeds, a public servant in the performance of her duty, submitted or invited reliance on a writing, namely Deed of Release number 2009014721, which Defendant knew to be lacking in authenticity, and which stated a fact material to the purposes for which the writing was offered. The conduct alleged herein was discovered in 2011, when the purported signer of Deed of Release 2009014721 was found not to have signed Deed of Release

Defendant is liable under section 562.056(1)(2) RSMo because the conduct constituting

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2009014721 before the notary public identified in Deed of Release 2009014721.

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Defendant in violation of section 575.060 RSMo, committed the class B misdemeanor of

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the offense was engaged in by an agent of the corporation while acting within the scope of the agent’s employment and in behalf of the corporation.

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NO TRUE BILL

A TRUE BILL

Foreperson

Foreperson

Respectfully submitted, CHRIS KOSTER Attorney General

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Received and filed on the ____ day of February 2012 and bail set at $____________________.

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Matthew L. Dameron Missouri Bar No. 52093 Special Assistant Attorney General Stueve Siegel Hanson LLP 460 Nichols Road, Suite 200 Kansas City, Missouri 64112 (816) 714-7100 Fax: (816) 714-7101

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Sean A. Smith Missouri Bar No. 63257 Assistant Attorney General Post Office Box 899 Jefferson City, Missouri 65102 (573) 751-3321 Fax: (573) 751-2041 Special Prosecuting Attorneys

___________________________________ Circuit Judge

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Range of Punishment:

Odd-Numbered Counts 1-135 – Class C Felony of Forgery: A fine not to exceed $10,000.00 or double the gain. Even-Number Counts 2-136 – Class B Misdemeanor of False Declaration: A fine not to exceed $2,000.00 or double the gain.

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