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DISTRICT COURT DENVER COUNTY, COLORADO COURT ADDRESS: 1437 Bannock St # 256 Denver, CO 80202

SHELDON CHRYSLER, Plaintiff, Vs. CHRISTOPHER KANE Defendants. Plaintiff: Sheldon A. Chrysler 743 Glencoe Street Denver, CO 80220 303 355-4872 Case No. 12 CV Division: Court Use Only

COMPLAINT FOR DAMAGES COMES NOW, the Plaintiff, above-named and submits the within Complaint pro se asserting as follows: 1. 2. 3. 4. 5. The amount in controversy exceeds $15,000.00. That the Plaintiff, Sheldon Chrysler, currently resides and has resided in the City and County of Denver at all times relevant in this action. Defendant, Christopher Kane, currently resides and has resided in Arapahoe County at all time relevant in this action. Defendant, Christopher Kane, works and has worked in the City and County of Denver at all times relevant in this action. That venue is proper in the County of Denver because the loan that was usurious was entered into contractually in the County of and was recorded

against real property located in the County of Denver at all times relevant to this matter. 6. 7. Plaintiff and Defendant had previously been friends for several years. Plaintiff had met Defendant through business interactions and subsequently developed a long-lasting friendship. FIRST CAUSE OF ACTION -USURY 8. 9. 10. 11. Plaintiff would incorporate by reference paragraphs 1 through 7 as set forth above. During the course of that friendship, Defendant lent Plaintiff a sum of money at the interest rate of forty-eight percent (48%) interest. The Colorado usury laws make it illegal and unlawful for any loan to exceed an interest rate of forty-five percent (45%). Defendant secured that loan with an interest rate of forty-eight percent (48%) by filing a lien on a couple of Plaintiffs parcels of real property between the time of the loan in 2006 and 2012. Defendant only released the lien on one of Plaintiffs properties secured by the promissory note with the forty-right percent (48%) rate of interest within the first few months of 2012. Plaintiff contends that Defendant knew of or should have known of Colorados rather liberal usury statute that set the maximum amount of interest that could be charged on any loan at forty-five percent (45%). Prior to the loan at the rate of forty-eight percent (48%), Defendant made a series of high interest loans to Plaintiff at the interest rate of thirty-two percent (32%). Defendant secured those loans by filing those promissory notes secured by deeds of trust against Plaintiffs commercial and residential property in the City and County of Denver and in Arapahoe County, Colorado. Throughout the course of several years, Defendant was able to obtain payments of interest on a loan that exceeded the usury laws of the State o Colorado. As a result of Defendants conduct, Plaintiff suffered economic damages.

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As a proximate result of Defendant's usury loan or loans, Plaintiff was unable to pay off the loans and subsequently lost the commercial property that Plaintiff owned and which was foreclosed on. As a result of Defendants, Plaintiff has sustained considerable damages in a sum that need to be determined by the trier of fact in this case, to include economic loses, interest expenses, and other damages. Plaintiff historically has been a victim of multiple economic crimes. Defendant knew of this and also that Plaintiff was an at risk disabled senior citizen and military veteran. Defendant knew or should have known that Plaintiff was dealing with mental health issues, considering Plaintiffs loss of his twin brother, as well as financial losses. JURY DEMAND

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Plaintiff would hereby request a trial by jury with the maximum number of jurors allowed pursuant to Colorado law. Consequently, Plaintiff is requesting an award of damages, costs, and treble damages for Defendant violating Colorados usury statute and other actions committed by Defendant as part of this legal action. WHEREFORE, the Plaintiff demands judgment against the Defendant in the amount to be determined and for such other and further relief as this Court deems just and proper. Respectfully Submitted,

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_____________________ Sheldon Chrysler Plaintiff (proceeding pro se)

District Court, Denver County, Colorado Court Address: 1437 Bannock Street Denver, CO 80202

SHELDON CHRYSLER, PlaintifF, v. CHRISTOPHER KANE Defendant

COURT USE ONLY


Case Number: 12 CV Division: Courtroom:

DISTRICT COURT CIVIL SUMMONS


TO THE ABOVE NAMED DEFENDANT: CHRISTOPHER KANE YOU ARE HEREBY SUMMONED and required to file with the Clerk of this Court an answer or other response to the attached Complaint. If service of the Summons and Complaint was made upon you within the State of Colorado, you are required to file your answer or other response within 21 days after such service upon you. If service of the Summons and Complaint was made upon you outside of the State of Colorado, you are required to file your answer or other response within 35 days after such service upon you. Your answer or counterclaim must be accompanied with the applicable filing fee. If you fail to file your answer or other response to the Complaint in writing within the applicable time period, the Court may enter judgment by default against you for the relief demanded in the Complaint without further notice. Dated: _____________________ ___________________________________________ Clerk of Court/Clerk ___________________________________________ Signature of Plaintiff ___________________________________________ Address of Plaintiff ___________________________________________ ___________________________________________ Plaintiffs Phone Number

This Summons is issued pursuant to Rule 4, C.R.C.P., as amended. A copy of the Complaint must be served with this Summons. This form should not be used where service by publication.

COUNTY COURT DENVER COUNTY, COLORADO COURT ADDRESS: 1437 Bannock Street Denver, CO 80202 SHELDON CHRYSLER, Plaintiff, Vs. CHRISTOPHER KANE, Defendant. Court Use Only Case No. 12 CV Division:

Plaintiff: Sheldon A. Chrysler 743 Glencoe Street Denver, CO 80220 303 355-4872

RETURN OF SERVICE
State of COLORADO County of _____________ I declare under oath that I served the following documents: Complaint for Damages; Summons; on the Defendant in Check one: by handing it to the person identified to me as the person indicated above. by leaving it with the defendant who refused service. by leaving it with designated to receive service for the defendant. _ I am over the age of 18 years and am not interested in nor a party to this case. I attempted to serve the person indicated above on _____occasions but have not been able to locate the person indicated above. ____________________________ Private Process Server Date County on at at the following location:

Signed under oath before me on _________ Notary Notary Public/Address My Commission expires: ____________