Free Proposed Jury Instructions - District Court of Colorado - Colorado

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 03-cv-281-WDM-MJW OLOYEA D. WALLIN, Plaintiff, v. MR. ALFARO, MR. BURK, MR. R. SATTERLY, MS. GANSEMER, MS. MILLER, Defendants. ______________________________________________________________________________ DEFENDANTS' PROPOSED JURY INSTRUCTIONS AND VERDICT FORMS

Defendants Alfaro, Burk, R. Satterly, Gansemer, and Miller, by and through their counsel, Hall & Evans, L.L.C., hereby submit Defendants' proposed Jury Instructions as follows: Dated this _____ day of July, 2006.

Respectfully submitted, s/ Jennifer L. Veiga___________________ Jennifer L. Veiga Hall & Evans, L.L.C. 1125 Seventeenth Street, Suite 600 Denver, Colorado 80202-5817 (303) 628-3300 D.C. Box No. 05 ATTORNEYS FOR DEFENDANTS

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INSTRUCTION NO. 1 Members of the jury, we are about to begin the trial of this case. Before the trial begins, however, there are certain instructions you should have to better understand what will be presented to you and how you should conduct yourselves during the trial. The party who brings a lawsuit is called plaintiff. In this action the plaintiff is Oloyea D. Wallin. The party against whom the suit is brought is called defendant. In this action the defendants are Charles Alfaro, Jerod Burk, Robbie Satterly, Kay Gansemer, and Pam Miller. The plaintiff seeks damages for what he alleges was the wrongful confiscation of certain commissary items alleged to have been taken during a facility wide cell search at the Kit Carson Correctional Facility. The defendants deny any wrongdoing and claim that no unauthorized items were taken from Plaintiff during the cell search and all items removed from the cell were removed for legitimate security reasons.

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INSTRUCTION NO. 2 In order for plaintiff(s) to establish his claim of conversion, he has the burden of proving the following essential elements by a preponderance of the evidence: 1. 2. Defendants took possession of Plaintiff's property without legal justification; and Defendants asserted control over Plaintiff's property treating it as if it were their own.

If you find that plaintiff has failed to prove any of those two elements by a preponderance of the evidence, then your verdict must be for Defendants, as to the claim of conversion. If, on the other hand, you find that plaintiff has proved the two elements by a preponderance of the evidence, then your verdict must be for plaintiff on this claim.

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INSTRUCTION NO. 3 The parties to this lawsuit have agreed to certain fact which you must treat as having been proved. Those facts are: 1. At the time of the incident, Plaintiff was lawfully incarcerated at the Kit Carson

Correctional Center. 2. Defendants Alfaro, Burk, Satterly, Gansemer and Miller, were employed at the Kit

Carson Correctional Center at the time of the incident. 3. Various sundry and commissary items were taken from Plaintiff's cell by Defendants

during a facility wide cell search of the correctional facility.

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INSTRUCTION NO. 4 Now, I will give you some preliminary instructions to guide you in your participation in the trial. Duty of Jury It will be your duty to find from the evidence what the facts are. You, and you alone, are the judges of the facts. You will then have to apply to those facts the law as I, the court, will give it to you. You must follow that law whether you agree with it or not. Nothing I may say or do during the course of the trial is intended to indicate, or should be taken by you as indicating, what your verdict should be. Evidence The evidence from which you will find the facts will consist of the testimony of witnesses, documents and other things received into the record as exhibits, and any facts the lawyers agree or stipulate to, or that I may instruct you to find. Certain things are not evidence and must not be considered by you. I will list them for you now: 1. Statements, arguments, and questions by lawyers are not evidence. 2. Objections to questions are not evidence. Lawyers have an obligation to their clients to make an objection when they believe evidence being offered is improper under the rules of evidence. You should not be influenced by the objection or by my ruling on it. If the objection is sustained, ignore the question. If it is overruled, treat the answer like any other. If you are instructed that some item of evidence is received for a limited purpose only, you must follow that instruction. 3. Testimony that I have excluded or told you to disregard is not evidence and

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must not be considered. 4. Anything you may have seen or heard outside the courtroom is not evidence and must be disregarded. You are to decide the case solely on the evidence presented here in the courtroom. There are two kinds of evidence: direct and circumstantial. Direct evidence is direct proof of a fact, such as testimony of an eyewitness. Circumstantial evidence is proof of facts from which you may infer or conclude that other facts exist. I will give you further instructions on these as well as other matters at the end of the case, but have in mind that you may consider both kinds of evidence. It will be up to you to decide which witnesses to believe, which witnesses not to believe, and how much of any witness's testimony to accept or reject. I will give you some guidelines for determining the credibility of witnesses at the end of the case. Burden of Proof This is a civil case. The plaintiff has the burden of proving his case by what is called the preponderance of the evidence. That means the plaintiff has to produce evidence which, considered in the light of all the facts, leads you to believe that what plaintiff claims is more likely true than not. To put it differently, if you were to put plaintiff's and defendants' evidence on opposite sides of the scales, plaintiff's would have to make the scales tip somewhat on his side. If plaintiff fails to meet this burden, the verdict must be for defendants. Those of you who have sat on criminal cases will have heard of proof beyond a reasonable doubt. That requirement does not apply to a civil case, and you should therefore put it out of your mind.

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Conduct by the Jury Now, a few words about your conduct as jurors. First, I instruct you that during the trial you are not to discuss the case with anyone, including yourselves and your families, or permit anyone to discuss it with you. Until you retire to the jury room at the end of the case to deliberate on your verdict, you simply are not to talk about this case. Second, do not read or listen to anything touching on this case in any way. If anyone should try to talk to you about it, bring it to my attention promptly. Third, do not try to do any research or make any investigation about the case on your own. Finally, do not form any opinion until all the evidence is in. Keep an open mind until you start your deliberation at the end of the case. If you wish, you may take notes to help your recollection. If you do, leave them in the jury room when you leave at night. And remember that they are for your own personal use--they are not to be given or read to anyone else. Course of the Trial The trial will now begin. First, each side may make an opening statement. An opening statement is neither evidence nor argument; it is an outline of what that party intends to prove, offered to help you follow the evidence. Next, plaintiff will present his witnesses, and defendants may cross-examine them. Then defendants will present their witnesses, and plaintiff may crossexamine them. Plaintiff then may have a final opportunity to present rebuttal evidence, again subject to the defendants' cross examination. After that, the attorneys will make their closing

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arguments to summarize and interpret the evidence for you. Those will be followed by further instructions on the law. You will then retire to deliberate on your verdict.

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INSTRUCTION NO. 5

MULTIPLE DEFENDANTS Although there is more than one defendant in this action, it does not follow from that fact alone that if one defendant is liable to the plaintiff, all defendants are liable. Each defendant is entitled to a fair consideration of the evidence. One defendant is not to be prejudiced should you find against any other defendant. Unless otherwise stated, all instructions I give you govern the case as to each defendant.

Authority: O'Malley, Grenig & Lee, Federal Jury Practice and Instruction, vol. 3, § 103.14 (5th ed. 2000) ["Multiple Defendants"].

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INSTRUCTION NO. 6

EVIDENCE ­ DIRECT AND CIRCUMSTANTIAL There are two kinds of evidence: direct and circumstantial. Direct evidence is testimony by a witness about what that witness personally saw or heard or did. Circumstantial evidence is indirect evidence; that is, it is proof of one or more facts from which one can find that another fact exists or is true. You should consider both kinds of evidence in deciding this case. It is for you to decide how much weight to give to any evidence, direct or circumstantial. There are rules of evidence which control what can be received into evidence. When one lawyer asks a question or offers an exhibit into evidence and another lawyer on the other side thinks that it is not permitted by the rules of evidence, the other lawyer may object. If I overrule the objection, the question may be answered or the exhibit received. If I sustain the objection, the question cannot be answered and the exhibit cannot be received. Whenever I sustain an objection to a question, you must ignore the question and must not guess what the answer might have been. Sometimes I may order that evidence be stricken from the record and that you disregard or ignore such evidence. That means that when you are deciding the case, you must not consider the evidence which I told you to disregard.

Authority: Stock jury instruction for a civil case received from the chambers of the Honorable John L. Kane.

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INSTRUCTION NO. 7 JUROR CONDUCT I will now say a few words about your conduct as jurors. First, do not talk with one another about this case or about anyone who has anything to do with it until the end of the case when you go to the jury room to decide on your verdict. Second, do not talk with anyone else about this case or about anyone who has anything to do with it until the trial has ended and you have been discharged as jurors. "Anyone else" includes members of your family and your friends. You may tell them that you are a juror in a case and that I have ordered you not to tell them anything else about the case until I have discharged you. Third, do not let anyone talk to you about the case or about anyone who has anything to do with it. If someone tries to talk to you, please report it to me immediately. Fourth, do not read any news stories or articles or listen to any radio or television reports about the case or about anyone who has anything to do with the case. Fifth, do not do any research, such as consulting dictionaries or other reference materials, and do not make any investigation about the case on your own. Sixth, do not make up your mind about what the verdict should be until after you have gone to the jury room to decide the case and you and your fellow jurors have discussed the evidence. Keep an open mind until then.

Authority: Stock jury instruction for a civil case received from the chambers of the Honorable John L. Kane.

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INSTRUCTION NO. 8

IMPEACHMENT ­ FELONY CONVICTION A witness may be discredited or impeached by evidence that the witness has been convicted of a felony, that is, an offense punishable by imprisonment for in excess of one year. If you believe that any witness has been impeached and thus discredited, it is your exclusive responsibility to give the testimony of that witness such credibility, if any, as you think it deserves.

Authority: O'Malley, Grenig & Lee, Federal Jury Practice and Instructions (5th ed. 2000), at vol. 3, § 105.05 ["Impeachment-Conviction of Felony"].

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STIPULATED INSTRUCTION NO. 9 ELEMENTS OF CLAIM ­ CONVERSION Your verdict must be for plaintiff and against defendants Charles Alfaro, Jerod Burk, Robbie Satterly, Kay Gansemer, and Pam Miller if all of the following elements have been proved by the preponderance of the evidence: First, Mr. Alfaro, Mr. Burk, Mr. Satterly, Ms. Gansemer, and Ms. Miller took possession of Plaintiff's property without legal justification; and Second, Defendants asserted control over Plaintiff's property treating it as if it were their own; and Third, as a direct result, plaintiff was damaged.

Authority:

E.L. Davis v The American National Bank of Denver, 367 P.2d 325 (Colo.

1961); Martinelli v. Merchants Oil Inc., 470 P.2d 55 (Colo. 1970).

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STIPULATED INSTRUCTION NO. 10 DECISIONS ENTITLED TO DEFERENCE Courts recognize the professional expertise of correctional officials and, in the absence of substantial evidence on the record that those officials have exaggerated their response, courts will defer to their judgment and discretion.

Authority: Pell v. Procunier, 417 U.S. 817, 827 (1974); Hewitt v. Helms, 459 U.S. 460, 474 (1983).

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STIPULATED INSTRUCTION NO. 11

DAMAGES If you find in favor of Plaintiff, then you must award Plaintiff such sum as you find from the preponderance of the evidence will fairly and justly compensate Plaintiff for the value of the property taken. Remember, throughout your deliberations, you must not engage in any speculation, guess, or conjecture and must not award damages by way of punishment or through sympathy.

Authority: Gates Factory Store v. Carl Horace Coleman, 350 P.2d 559 (Colo. 1960).

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STIPULATED INSTRUCTION NO. 12 Upon retiring to the jury room, you will select one of your members to act as your foreperson. The foreperson will preside over your deliberations, and will be your spokesman here in Court. Forms of verdict have been prepared for your convenience. [Forms of verdict read.] You will take these forms to the jury room and, when you have reached unanimous agreement as to your verdict, you will have your foreperson fill in, date and sign the form which sets forth the verdict upon which you unanimously agree; and then return with your verdict to the courtroom.

Authority: O'Malley, Grenig & Lee, Federal Jury Practice and Instructions (5th ed. 2000), at vol. 3, § 106.04 ["Election of Foreperson-General Verdict"].

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INSTRUCTION NO. 13 MEMBERS OF THE JURY: Now that you have heard the evidence (and the argument), it becomes my duty to further instruct you concerning the law governing this case in addition to the introductory instructions. It is your duty as jurors to follow the law as I state it to you. You will then apply that law to the facts as you find them from the evidence in the case. You are not to single out one instruction alone as stating the law, but must consider the instructions as a whole. You are not to be concerned with the wisdom of any rule of law stated by me. It would be a violation of the oath which you have sworn as jurors to base your verdict on anything other than the law as presented in these instructions and the facts as you find them. Counsel may properly refer to some of the governing rules of law in their arguments. If, however, there is any difference between the law as stated by counsel and that stated by me in these instructions, you are governed by my instructions. As members of the jury, you are the sole and exclusive judges of the facts. You pass upon the evidence. You determine what witnesses and what evidence to believe. You resolve conflicts in the testimony. Nothing I say in these instructions is to be taken as an indication that I have any opinion about the facts of the case, or what that opinion is. It is not my function to determine the facts; it is yours. You must perform your duties as jurors without bias or prejudice as to any party. The law does not permit you to be governed by sympathy, prejudice, or public opinion. The court and the parties expect that you will carefully and impartially consider all of evidence, follow the law as it is now being given to you, and reach a just verdict, regardless of the consequences.

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INSTRUCTION NO. 14 I do not invite communications from you, but if it becomes necessary during your

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deliberations to communicate with the court, you may send a note by the court security officer, signed by your foreperson or by one or more members of the jury. No member of the jury should ever attempt to communicate with the court by any means other than a signed writing, and the court will never communicate with any member of the jury on any subject touching the merits of the case other than in writing, or orally here in open court. Upon receipt of a note from you, I will need to convene a meeting with counsel to discuss your question or request. It may well take considerable time and effort to respond. You will note from the oath about to be taken by the court security officer that he or she, as well as all other persons, are forbidden to communicate in any way or manner with any member of the jury on any subject touching the merits of the case. Let me know immediately if anyone attempts any such communication. Bear in mind also that you are never to reveal to any person--not even to the court--how the jury stands, numerically or otherwise, on the questions before you, until after you have reached a unanimous verdict.

INSTRUCTION NO. 15 You are the sole judges of the credibility of the witnesses and the weight to be given their testimony. You should take into consideration their means of knowledge, strength of memory, and opportunities for observation; the reasonableness or unreasonableness of their testimony; the

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consistency or lack of consistency in their testimony; their motives; their intelligence; their ability to observe the matters about which they have testified; whether their testimony has been contradicted or supported by other evidence; their bias, prejudice, or interests, if any; their manner or demeanor upon the witness stand; and all other facts and circumstances shown by the evidence which affect the credibility of the witnesses. Based on these considerations, you may believe all, part, or none of the testimony of a witness and you may give the testimony such weight, if any, as you think it deserves.

INSTRUCTION NO. 16 You should not resolve factual issues in the case solely by adding up the number of witnesses who testify on each side of a certain issue. If you believe the testimony of a single witness who testifies about a disputed event, such testimony is enough for you to resolve the factual dispute in accordance with this single witness's version of the event, even though a

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number of witnesses may have testified to the contrary. The test is not which side brings the greater number of witnesses, or presents the greater quantity of evidence; the test, rather, is which witness or witnesses, and which evidence, appeals to your minds as being most accurate, believable, and otherwise trustworthy.

INSTRUCTION NO. 17 A witness may be discredited or impeached by contradictory evidence, or by evidence that at some other time the witness has said or done something, or has failed to say or do something, which is inconsistent with the witness's present testimony. If you believe any witness has been impeached and thus discredited, it is your exclusive province to give the testimony of that witness such credibility, if any, as you may think it deserves.

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If a witness is shown knowingly to have testified falsely concerning any material matter, you have a right to distrust such witness's testimony in other particulars and you may reject part or all of the testimony of that witness or give it such weight as you may think it deserves.

INSTRUCTION NO. 18 I will now instruct you on the proper measure of damages, if any, to be recovered by Plaintiff should you find in his favor on his claim. The fact that I will instruct you on the proper measure of damages should not be considered as an indication of any view of mine as to which party is entitled to your verdict in this case. These instructions are given only for your guidance, in the event that you should find in favor of plaintiff on the question of liability in accordance with the other instructions. If you should find for defendants, you should disregard these instructions on damages.

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INSTRUCTION NO. 19 In determining the amount of any damages that you decide to award, you should be guided by dispassionate common sense. You must use sound discretion in fixing an award of damages, drawing reasonable inferences from the facts in evidence. You may not award damages based on sympathy, speculation, or guess work. On the other hand, the law does not require that the plaintiff prove the amount of his losses with mathematical precision, but only with as much definiteness and accuracy as circumstances permit.

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INSTRUCTION NO. 20 The verdict must be unanimous and represent the considered judgment of each juror. To return a verdict, it is necessary that each juror agrees. It is your duty, as jurors, to consult with one another, and to deliberate with a view to reaching an agreement, if you can do so without violence to individual judgment. You must each decide the case for yourself, but only after an impartial consideration of the evidence in the case with your fellow jurors. In the course of your deliberations, do not hesitate to reexamine your own views, and change your opinion, if convinced it is erroneous. But do not surrender your honest conviction as to the weight or effect of evidence, solely because of the opinion of your fellow jurors, or for the mere purpose of

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returning a verdict. Remember at all times that you are not partisans. You are judges -- judges of the facts. Your sole interest is to seek the truth from the evidence in the case.

INSTRUCTION NO. 21 Upon retiring to the jury room, you shall select one of your number to act as your foreperson. The foreperson will preside over your deliberations and be your spokesperson here in court. Verdict forms have been prepared for your convenience to take to the jury room. You will note that the forms include a number of interrogatories or questions which call for a "yes" or "no" answer. The answer to each question must be the unanimous answer of the jury. Your foreperson will write the unanimous answer of the jury in the space provided for each response. As you will note from the wording of the questions, it may not be necessary to consider or answer every question. When you have completed the verdict form, the foreperson will sign and date the form, which should be brought to the courtroom when you return.

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 03-cv-281-WDM-MJW OLOYEA D. WALLIN, Plaintiff, v. MR. ALFARO, MR. BURK, MR. R. SATTERLY, MS. GANSEMER, MR. MILLER, Defendants. ______________________________________________________________________________ VERDICT FORM ­ CHARLES ALFARO

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THE JURY MUST UNANIMOUSLY AGREE ON THE ANSWERS TO ALL OF THE QUESTIONS SET OUT BELOW. We, the Jury, being duly impaneled and sworn to try the above-entitled case, unanimously find the following answers to the questions submitted by the Court, based upon the preponderance of the evidence: SECTION A 1. Did Oloyea Wallin prove by a preponderance of the evidence that Defendant

Charles Alfaro converted his personal property in violation of law as defined in Instruction No. ______? YES _______________ NO _______________

IF YOUR ANSWER IS "NO," THEN STOP HERE. IF YOUR ANSWER IS "YES," PLEASE ANSWER QUESTION 2. 2. Did Oloyea Wallin prove by a preponderance of the evidence that he is entitled to

any actual damages due to Defendant Charles Alfaro's actions that you found to be unlawful? YES _______________ NO _______________

IF YOUR ANSWER IS "NO," THEN STOP HERE. IF YOUR ANSWER IS "YES," PLEASE ANSWER QUESTION 3. 3. Please write down the amount of damages as defined in Instruction No. ____, if

any, Plaintiff proved by a preponderance of the evidence that he sustained as a result of Charles Alfaro's conduct you found to be unlawful. $ ____________________________

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_________________________________ Jury Foreperson

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 03-cv-281-WDM-MJW OLOYEA D. WALLIN, Plaintiff, v. MR. ALFARO, MR. BURK, MR. R. SATTERLY, MS. GANSEMER, MR. MILLER, Defendants. ______________________________________________________________________________ VERDICT FORM ­ JEROD BURK

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THE JURY MUST UNANIMOUSLY AGREE ON THE ANSWERS TO ALL OF THE QUESTIONS SET OUT BELOW. We, the Jury, being duly impaneled and sworn to try the above-entitled case, unanimously find the following answers to the questions submitted by the Court, based upon the preponderance of the evidence: SECTION A 1. Did Oloyea Wallin prove by a preponderance of the evidence that Defendant

Jerod Burk converted his personal property in violation of law as defined in Instruction No. ____ ______? YES _______________ NO _______________

IF YOUR ANSWER IS "NO," THEN STOP HERE. IF YOUR ANSWER IS "YES," PLEASE ANSWER QUESTION 2. 2. Did Oloyea Wallin prove by a preponderance of the evidence that he is entitled to

any actual damages due to Defendant Jerod Burk's actions that you found to be unlawful? YES _______________ NO _______________

IF YOUR ANSWER IS "NO," THEN STOP HERE. IF YOUR ANSWER IS "YES," PLEASE ANSWER QUESTION 3. 3. Please write down the amount of damages as defined in Instruction No. ____, if

any, Plaintiff proved by a preponderance of the evidence that he sustained as a result of Jerod Burk's conduct you found to be unlawful. $ ____________________________

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_________________________________ Jury Foreperson

THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 03-cv-281-WDM-MJW OLOYEA D. WALLIN, Plaintiff, v. MR. ALFARO, MR. BURK, MR. R. SATTERLY, MS. GANSEMER, MR. MILLER, Defendants. ______________________________________________________________________________ VERDICT FORM ­ KAY GANSEMER

THE JURY MUST UNANIMOUSLY AGREE ON THE ANSWERS TO ALL OF THE QUESTIONS SET OUT BELOW.

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We, the Jury, being duly impaneled and sworn to try the above-entitled case, unanimously find the following answers to the questions submitted by the Court, based upon the preponderance of the evidence: SECTION A 1. Did Oloyea Wallin prove by a preponderance of the evidence that Defendant Kay

Gansemer converted his personal property in violation of law as defined in Instruction No. ____ ______? YES _______________ NO _______________

IF YOUR ANSWER IS "NO," THEN STOP HERE. IF YOUR ANSWER IS "YES," PLEASE ANSWER QUESTION 2. 2. Did Oloyea Wallin prove by a preponderance of the evidence that he is entitled to

any actual damages due to Defendant Kay Gansemer's actions that you found to be unlawful? YES _______________ NO _______________

IF YOUR ANSWER IS "NO," THEN STOP HERE. IF YOUR ANSWER IS "YES," PLEASE ANSWER QUESTION 3. 3. Please write down the amount of damages as defined in Instruction No. ____, if

any, Plaintiff proved by a preponderance of the evidence that he sustained as a result of Kay Gansemer's conduct you found to be unlawful. $ ____________________________

_________________________________ Jury Foreperson

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 03-cv-281-WDM-MJW OLOYEA D. WALLIN, Plaintiff, v. MR. ALFARO, MR. BURK, MR. R. SATTERLY, MS. GANSEMER, MR. MILLER, Defendants. ______________________________________________________________________________ VERDICT FORM ­ PAM MILLER

THE JURY MUST UNANIMOUSLY AGREE ON THE ANSWERS TO ALL OF THE QUESTIONS SET OUT BELOW.

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We, the Jury, being duly impaneled and sworn to try the above-entitled case, unanimously find the following answers to the questions submitted by the Court, based upon the preponderance of the evidence: SECTION A 1. Did Oloyea Wallin prove by a preponderance of the evidence that Defendant Pam

Miller converted his personal property in violation of law as defined in Instruction No. ______? YES _______________ NO _______________

IF YOUR ANSWER IS "NO," THEN STOP HERE. IF YOUR ANSWER IS "YES," PLEASE ANSWER QUESTION 2. 2. Did Oloyea Wallin prove by a preponderance of the evidence that he is entitled to

any actual damages due to Defendant Pam Miller's actions that you found to be unlawful? YES _______________ NO _______________

IF YOUR ANSWER IS "NO," THEN STOP HERE. IF YOUR ANSWER IS "YES," PLEASE ANSWER QUESTION 3. 3. Please write down the amount of damages as defined in Instruction No. ____, if

any, Plaintiff proved by a preponderance of the evidence that he sustained as a result of Pam Miller's conduct you found to be unlawful. $ ____________________________

_________________________________ Jury Foreperson

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CERTIFICATE OF MAILING I HEREBY certify that on this 5th day of July, 2006, I placed a true and correct copy of the foregoing DEFENDANTS' PROPOSED JURY INSTRUCTIONS AND VERDICT FORMS in the United States Mail, first-class postage prepaid, and addressed to the following: John Andrew McNamara, III John A. McNamara, P.C. 1733 High Street Denver, Colorado 80218

s/ Valerie Hahl_______________________

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