Colorado Secretary of State

Date and Time: 05/17/2016 09:31 PM

Document must be filed electronically. ID Number: 19931112707
Paper documents are not accepted.
Fees & forms are subject to change. Document number: 20161340706
For more information or to print copies Amount Paid: $25.00
of filed documents, visit www.sos.state.co.us.
ABOVE SPACE FOR OFFICE USE ONLY

Statement of Dissolution
Limited Liability Company
Filed pursuant to 7-80-802 of the Colorado Revised Statutes (C.R.S)

ID number: 19931112707
_____________________

1. Entity name: O'POER L.L.C.

______________________________________________________

2. Principal office address:

Street address 2676 W ALAMO AVE

______________________________________________________
(Street number and name)
______________________________________________________
LITTLETON
__________________________ CO ____________________
____ 80120
(City) (State) (ZIP/Postal Code)
United States
_______________________ ______________
(Province if applicable) (Country)

Mailing address PO Box 102048

______________________________________________________
(leave blank if same as above) (Street number and name or Post Office Box information)
______________________________________________________
Denver
__________________________ CO ____________________
____ 80250
(City) (State) (ZIP/Postal Code)
Colorado
_______________________ United States
______________.
(Province if applicable) (Country)

3. (Optional) Delayed effective date: ______________________

(mm/dd/yyyy)

4. This document contains additional information as provided by law.

Notice:

Causing this document to be delivered to the secretary of state for filing shall constitute the affirmation or
acknowledgment of each individual causing such delivery, under penalties of perjury, that the document is the
individual's act and deed, or that the individual in good faith believes the document is the act and deed of the
person on whose behalf the individual is causing the document to be delivered for filing, taken in conformity
with the requirements of part 3 of article 90 of title 7, C.R.S., the constituent documents, and the organic
statutes, and that the individual in good faith believes the facts stated in the document are true and the
document complies with the requirements of that Part, the constituent documents, and the organic statutes.

This perjury notice applies to each individual who causes this document to be delivered to the secretary of
state, whether or not such individual is named in the document as one who has caused it to be delivered.

DISS_LLC Page 1 of 2 Rev. 4/02/2012

5. Name(s) and address(es) of the
individual(s) causing the document
to be delivered for filing: Powers
____________________ William
______________ Martin
______________ _____
(Last) (First) (Middle) (Suffix)
PO Box 102048
______________________________________________________
(Street name and number or Post Office Box information)
______________________________________________________
Denver
__________________________ CO ____________________
____ 80250
(City) (State) (Postal/Zip Code)
United States
_______________________ ______________
(Province if applicable) (Country if not US)

This document contains the true name and mailing address of one or more additional individuals
causing the document to be delivered for filing.

Disclaimer:
This form, and any related instructions, are not intended to provide legal, business or tax advice, and are
offered as a public service without representation or warranty. While this form is believed to satisfy minimum
legal requirements as of its revision date, compliance with applicable law, as the same may be amended from
time to time, remains the responsibility of the user of this form. Questions should be addressed to the users
attorney.

DISS_LLC Page 2 of 2 Rev. 4/02/2012

Tuesday, May 17, 2016

COLORADO SECRETARY OF STATE

RE: STATEMENT OF INTENT TO DISSOLVE

Please take this notice to serve as intent to immediately dissolve the following LLCs as of May 17, 2016:
SECOND
DISSOLUTION LAST
FIRST
DATE DISSOLUTION
DISSOLUTION
William A. DATE
FORMATION DATE
ID Powers William A.
DATE Sheryl J
Alter Ego Powers
Powers Death
Adjudication Incompetence
(04/09/2006)
& (12/03/2015)
Confirmation
Barristers LTD 19871375978 6/21/1979 6/9/2006 2010 2/2/2016
O'Poer 19931112707 10/7/1993 6/9/2006 2010 2/2/2016
Guinness Harp LLC 19961165862 12/20/1996 2/2/2016
JP Juris 19961165864 12/20/1996 2/2/2016
Powers & Associates 20001066419 3/31/2000 6/9/2006 2010 2/2/2016
Shennayr 19981223728 12/16/1998 6/9/2006 2010 2/2/2016
Silver Fox 19941113486 10/11/1994 2010 2/2/2016
JSB&B 19921108429 11/10/1992 6/9/2006 2010 2/2/2016
AFA12 19951127813 10/17/1995 2010 2/2/2016

REASONS FOR DISSOLUTION

A Sheryl J. Powers was a Manager and interest holder in many of the identified Powers' family LLCs. Where Sheryl J. Powers was a member in any LLC,
with her death on April 09, 2006, these LLCs would have been dissolved on June 9, 2006 (First Dissolution Date) in accordance with relevant Colorado
LLC Statutes. Remaining Manager never gave notice, held meetings or received written consent by remaining members of their "intent" to continue
participation in any of the LLCs. After the death of Sheryl J. Powers, William A. Powers continued to operate the LLCs incorrectly and without
acceptable form as required by Colorado LLC Statute.
B William A. Powers and the LLCs were challenged in a lawsuit by Joseph Seller in 2010 on a collection issue regarding work at one of the LLC properties.
The Arapahoe County Court adjudicated (Trial) and confirmed (Appeal) that William A Powers and the LLCs were alter egos of each other and were
out of conformance with Colorado LLC Statutes in 2010 (Second Dissolution Date). William A. Powers continued to operate the LLCs incorrectly and
without acceptable form as required by Colorado LLC Statute.
C William A Powers suffered a disabling stroke at the end of November 2015. The stroke left William A. Powers without any cognitive abilities and his
body was left in a complete state of paralysis. On December 3, 2015 Arapahoe County District Court Judge Fasing found William A. Powers to be
incompetent (2015PR31083) and a Special Conservator was named to manage William A Powers' LLC management responsibilities and estate.

D Upon the Dissociation of a Member, unless the business of the Company is continued by the consent of the Majority of Interest (this is determined
by LLC documents to include tax filings) within 60 days after the dissociation the LLC ceases to exist and is determined to be dissolved. Dissociation
was defined at the time of the formation of the relevant LLCs to occur when a member is adjudicated to be incompetent. Sixty-one days after William
A Powers was adjudicated incompetent (December 3, 2015) by Arapahoe County Court was February 2, 2016 (Last Dissolution Date).

E Remaining members of the LLCs of William A Powers are known to include, but may not be limited to, Lora J Powers, Jean M Powers, William M
Powers, and possibly 5 minor children who are his grandchildren. Documents confirming LLC membership and interest have been requested from
Lora J. Powers and are yet to be provided. Tax documents confirm the names identified above are known to be members of the LLCs. Upon review of
the LLCs signed operating agreement, minute orders and official records kept in accordance of the Laws and Rules of the State of Colorado other
members may be discovered. In any event, the remaining members of William A Powers' LLCs have declined to continue any of the LLCs as
permitted by law and have failed to file any written notice of "intent" to continue as required by law. The Arapahoe County Conservatorship Court
(2015PR31083) and the Arapahoe County Probate Court (2016PR30159) have sole authority and jurisdiction over the estate of William A Powers and
his assets placed in the LLC's which have now DISSOLVED as of 02/02/2016, at the latest.

F Most, if not all, of the LLCs managed by William A. Powers or with his participation as a member were dissolved on multiple occasions since 2006
(First, Second & Last Dissolution). Poor record keeping, lack of notice and the failure to operate in accordance to Colorado LLC Statutes caused the
Arapahoe County Court to recognize William A. Powers' LLCs as his alter egos (2010). William A. Powers was attempting to shelter his personal assets
from his law practice with the protection of a LLC. With each dissolution opportunity, no notice, meeting or written intent was secured by Manager
to continue the LLCs in compliance with relevant Colorado LLC Statute.

5/17/2016 1
G As a matter of law, once the Petition for Adjudication for Intestacy and Formal Appointment of Personal Representative (Arapahoe County,
Colorado (2016PR30159) Division 21) was filed (02/19/2016), all assets of William A Powers (to include his membership authority and interest in any
LLC) are under the control and jurisdiction of the Probate Court. The personal representative named by the will or appointed by the court will have
all authority to act on behalf of the Member's estate.
H The remaining members of the respective LLCs elected NOT to continue the LLCs. The member's interest and authority in the Company upon written
notice or meeting "of their intent whether to continue the business of the Company" was never initiated by the Manager or meeting of remaining
members. The time for notice expired February 1, 2016 without any known notice of meeting, written intent or unanimous vote of remaining
members to continue the business of Company.
- Any LLC with Sheryl J Powers as a member dissolved June 9, 2006
- Any LLC with William A. Powers as a member dissolved February 2, 2016.
I All assets under management of the LLCs and direct interest of William A Powers have been assigned to the Probate Court of Arapahoe County
(2016PR30159). William A Powers died without a will and the issues of William A Powers' interest in these LLCs and his general estate are pending
the appointment of a Personal Representative by the Probate Court. Arapahoe Probate Court will make rulings of any division of the LLCs and general
estate after formal motions and court appearances of William A Powers identified heirs Lora Jane Powers, Jean Marie Powers and William Martin
Powers.
J Under the Operating Agreements, once the LLCs become in a state of dissolution, they will cease to operate. No LLC assets can be sold, gifted,
bartered, transferred or conveyed in any way without the acceptance and ruling of the Arapahoe County Probate Court.
K As the LLC's sole manager, William A Powers was deemed incompetent by a court of competent jurisdiction (Arapahoe County District Court on
December 3, 2015) and subsequently died. The LLCs are in dissolution, remaining members did not elect to continue LLCs, the LLCs have no manager
authorized to proceed on any decision of the particular LLC without direction from the Arapahoe County Probate Court (2016PR30159).

L Barry S Korman is not authorized to act as a Registered Agent for any of the LLCs.

M Lora J. Powers is not a Manager for any of the LLCs and has no authority to make decisions as a Manager/agent for William A. Powers or any LLCs
identified.
N The following documents have been submitted to the Colorado Secretary of State by various representatives. These documents have been submitted
without authorization, submitted as a document that may be considered perjury by the Colorado Secretary of State or other authorities or otherwise
not authorized as a result of the LLCs being dissolved as of 02/02/2016:

CONTESTED DATE SUBMITTED

LLC SOS ID DOCUMENT SUBMITTED DOCUMENT BY NOTES
Barristers 19871375978 20161110067 2/16/2016 Registered Barry Korman As of the filing, the LLC was dissolved, Korman had no
LTD Agent authorization to act on behalf of William A. Powers, the
LLC or members of the LLC.

O'Poer 19931112707 20151831700 12/29/2015 Periodic William A This document is believed to be submitted as a perjury
Report Powers document under the Colorado Secretary of State submittal
criteria. William A Powers was incapacitated and deemed
incompetent December 3, 2015. He could not have filed
the document at the filing date.

O'Poer 19931112707 20161109994 2/16/2016 Registered Barry Korman As of the filing, the LLC was dissolved, Korman had no
Agent authorization to act on behalf of William A. Powers, the
LLC or members of the LLC.

O'Poer 19931112707 20161260742 4/13/2016 Amended Barry Korman As of the filing, the LLC was dissolved, Korman had no
Articles Of authorization to act on behalf of William A. Powers, the
Organization LLC or members of the LLC. Lora J. Powers is not a
Manager of the LLC and has no authority to act as a
Manager. William A. Powers' LLC assets and estate are
under the jurisdiction of the Arapahoe County Probate
Court (2016PR30159).

Guinness 19961165862 20161099528 2/9/2016 Periodic William A This document is believed to be submitted as a perjury
Harp LLC Report Powers document under the Colorado Secretary of State submittal
criteria. William A Powers was incapacitated and deemed
incompetent December 3, 2015. He could not have filed
the document at the filing date.

Guinness 19961165862 20161109941 2/16/2016 Registered Barry Korman As of the filing, the LLC was dissolved, Korman had no
Harp LLC Agent authorization to act on behalf of William A. Powers, the
LLC or members of the LLC.

5/17/2016 2
 CONTESTED DATE SUBMITTED
LLC SOS ID DOCUMENT SUBMITTED DOCUMENT BY NOTES
Guinness 19961165862 20161260759 4/13/2016 Amended Barry Korman As of the filing, the LLC was dissolved, Korman had no
Harp LLC Articles Of authorization to act on behalf of William A. Powers, the
Organization LLC or members of the LLC. Members of the LLC have not
agreed to continue this LLC or add members. William A.
Powers' LLC assets and estate are under the jurisdiction of
the Arapahoe County Probate Court (2016PR30159).

JP Juris 19961165864 20161099513 2/9/2016 Periodic William A This document is believed to be submitted as a perjury
Report Powers document under the Colorado Secretary of State submittal
criteria. William A Powers was incapacitated and deemed
incompetent December 3, 2015. He could not have filed
the document at the filing date. As of the filing, the LLC
was dissolved and its Members did not authorize the
document to be filed with the Colorado Secretary of State.

Powers & 20001066419 Periodic As of the filing, the LLC was dissolved, Korman had no
Associates Report Due authorization to act on behalf of William A. Powers, the
LLC or members of the LLC. The decedent's law practice is
CLOSED.

Shennayr 19981223728 20151428704 6/30/2015 Articles Of The LLC was dissolved as of 06/09/2006 with the death of
Reinstatement Sheryl J. Powers (04/09/2006). The LLC was out of
WAP compliance with the relevant State of Colorado Statutes
and no reports were filed from 1998 to 2015. The LLC
would have been dissolved for a second time on
02/02/2016 with the adjudication of William A. Powers'
incompetence (12/03/2015).

Shennayr 19981223728 20161109853 2/16/2016 Registered Barry Korman As of the filing, the LLC was dissolved, Korman had no
Agent authorization to act on behalf of William A. Powers, the
LLC or members of the LLC.
Shennayr 19981223728 20161260771 4/13/2016 Amended Barry Korman As of the filing, the LLC was dissolved, Korman had no
Articles Of authorization to act on behalf of William A. Powers, the
Organization LLC or members of the LLC. Lora J. Powers is not a
Manager of the LLC and has no authority to act as a
Manager. William A. Powers' LLC assets and estate are in
Arapahoe County Probate Court (2016PR30159).

Silver Fox 19941113486 20151785646 12/8/2015 Periodic William A This document is believed to be submitted as a perjury
Report Powers document under the Colorado Secretary of State submittal
criteria. William A Powers was incapacitated and deemed
incompetent December 3, 2015. He could not have filed
the document at the filing date.

Silver Fox 19941113486 20161109965 2/16/2016 Registered Barry Korman As of the filing, the LLC was dissolved, Korman had no
Agent authorization to act on behalf of William A. Powers, the
LLC or members of the LLC.

Silver Fox 19941113486 20161260765 4/13/2016 Amended Barry Korman As of the filing, the LLC was dissolved, Korman had no
Articles Of authorization to act on behalf of William A. Powers, the
Organization LLC or members of the LLC. Lora J. Powers is not a
Manager of the LLC and has no authority to act as a
Manager. William A. Powers' LLC assets and estate are in
Arapahoe County Probate Court (2016PR30159).

5/17/2016 3
 CONTESTED DATE SUBMITTED
LLC SOS ID DOCUMENT SUBMITTED DOCUMENT BY NOTES
Silver Fox 19941113486 20161260765 4/13/2016 Amended Barry Korman Original Members of Silver Fox LLC were Beverly C Niles
Articles Of (Death Certificate Notice 07/14/1998) and William A Niles
Organization (Death Certificate notice 02/18/07). The LLC was dissolved
(1998) in accordance with the LLC Operating Agreement
and/or in accordance with Colorado LLC statutes. William
A Powers and Powers Professional Corporation were the
Registered Agent of the LLC during operation. Lora J
Powers was not a member of the Silver Fox LLC. Any
assets of William A Powers under the control of Silver Fox
LLC are now in the control of the Arapahoe County Probate
Court (2016PR30159).

Silver Fox 19941113486 20161260765 4/13/2016 Amended Barry Korman Tripp Avenue property in Oak Lawn, IL initially purchased in
Articles Of 2004 was under the possession of Marie Pell (Death
Organization Certificate Notice 09/19/2014) and Erwin F Lareau (Death
Certificate Notice 12/18/2015). It is believed William A.
Powers assumed control of the Tripp property as his
personal property at the time of purchase in 2004. William
A Powers' LLC assets and estate are in the control of
Arapahoe County Probate Court (2016PR30159). The Tripp
Avenue property may be considered part of the estate of
Sheryl J. Powers as marital assets at her death in 2006.

Silver Fox 19941113486 3/26/2016 Sale Of Tripp Lora Powers Per representations by Bobby Bennett of Chicago (May, 4,
Property Barry Korman 2016), Real Estate Agents and Lora J Powers knew that
Remax 10 Tripp property could not be sold if William A Powers had
passed. William A Powers passed on February 14, 2016

JSB&B 19921108429 20161025535 1/12/2016 Periodic William A This document is believed to be submitted as a perjury
Report Powers document under the Colorado Secretary of State submittal
criteria. William A Powers was incapacitated and deemed
incompetent December 3, 2015. He could not have filed
the document at the filing date.
JSB&B 19921108429 20161109924 2/16/2016 Registered Barry Korman As of the filing, the LLC was dissolved, Korman had no
Agent authorization to act on behalf of William A. Powers.
JSB&B 19921108429 20161262632 4/14/2016 Amended Barry Korman As of the filing, the LLC was dissolved, Korman had no
Articles Of authorization to act on behalf of William A. Powers. Per
Organization May 4, 2016 meeting and documentation with Bobby
Bennett, William A Powers had no capital or economic
interest in the LLCs and Lora J Powers has no capital or
economic interest in the LLC. Bobby Bennett does not
understand the role of the Manager in the LLC and was
notified by Lora J Powers that Lora J Powers appointed
herself the Manager of his LLC. Mr. Bennett made the
representation that Lora J Powers advised him of the legal
changes to the LLC. Mr Bennett made the comment there
was no meeting or election of members, "Lora just did it"'
After the meeting with Bobby Bennett, it is obvious Mr.
Bennett has no idea of the authority of a Manager in his
own LLC. Lora J. Powers is not an attorney and it appears
that she is advising Bobby Bennett regarding the legal
aspects of LLCs. Lora J. Powers appears to be practicing
law from William A Powers' office (Powers Professional
Corporation) and advising on LLCs prepared and
constructed by attorney William A Powers.

AFA12 19951127813 In process of dissolution. All of William A Powers interest

in AFA12LLC is part of the Probate procedures in Arapahoe
County District Court (2016PR30159).

5/17/2016 4
O Sheryl J Powers died April 9, 2006. As a member and / or Manager of many of these LLCs, with her death, these companies were in dissolution
starting April 9, 2006 thru June 8, 2006. No notice of intent to continue was issued by Manager / members, meeting notices were never issued,
members never convened to introduce new members or continue the business of the LLCs. Therefore the LLCs were dissolved June 9, 2006. No new
members or Managers were elected by members, therefore with the passing of William A Powers, there are no authorized individuals that have
authority to act in the interest of these LLCs. William A Powers died without a will and his estate and interests in LLCs are before the Arapahoe
County Probate Court (2016PR30159).

P Lora J. Powers, legal counsel Barry Korman, legal counsel Theresa Moore and/ or Anna Plute have been filing erroneous documents with the Colorado
Secretary of State since December 2015 regarding the status of the LLCs and making representations as to Manager status (Amended Articles) with
the LLCs. Attorney Barry Korman and Theresa Moore have no authority as a Registered Agent or counsel for the LLCs by the existing members. Lora J
Powers has no authority as a Manager with the LLCs. Lora J Powers, Jean Marie Powers and William Martin Powers are members of the LLCs and do
not have Manager status as recognized by the Colorado LLC statutes. Anna Plute is not authorized to conduct work on behalf of any of the LLCs by
the remaining members. Only the Arapahoe County Probate Court has authorization to act on the estate and assets of the LLCs and William A
Powers. All of the LLC have been dissolved, there can be no Company business transacted without authorization by Arapahoe County Probate Court.

Q As William A Powers' estate and assets in the LLCs are in the control of the Arapahoe County Probate Court, no assets of the LLCs or William A
Powers' personal estate may be leased, sold, bartered, gifted, tendered or transferred in any way without the proper notice and consideration of
Arapahoe County Probate Court (2016PR30159) and the respective parties.

5/17/2016 5
May 17, 2016

Barry Korman Esq.

2676 West Alamo Avenue
Littleton, Colorado, 80120

Mr. Korman-

The acts described within this document allege counsel for Lora J. Powers are aiding and
abetting Lora J. Powers unlawful conduct, filing of false information with government
regulatory agencies, escalating conflict and legal cost to family members, damage / loss
of estate assets and contempt of Probate Court authority, orders and applicable
statutes.

On February 16, 2016 (two days after William A. Powers death), without authority or
permission from Arapahoe District Probate Court (15PR31083 & 16PR30159), you
registered as an agent for the LLCs owned and managed by William A. Powers. You are
not a member or manager of the LLC, do not have the majority memberships
permission to act on behalf of the LLC, and as a third party, do not have a legal right to
cause a filing with the Colorado Secretary of State. The LLCs which you affected were
dissolved and terminated on multiple occasions, most recently on February 2, 2016.
Your filings were an attempt to revive the Companies and cause a false public
impression. Lora J. Powers, an heir of William A. Powers and for a short time
Conservator with legal fiduciary duties, with legal counsels assistance has been able to
plunder the estate of William A. Powers (violating the Probate Courts jurisdiction) as a
direct result of the fraud caused by filings with the Secretary of State. The Arapahoe
County Probate Court (2015PR31083 & 2016PR30159) has authority and jurisdiction
over the assets of William A. Powers including any assets from LLCs upon their windup.
William A. Powers membership interest in the LLCs are subject to Probate since he was
adjudicated incompetent on December 3, 2015 and died on February 14, 2016.

A copy of this document will be filed with the Secretary of State (with William A. Powers
LLCs that you have filed as a registered agent), the Colorado Supreme Court Attorney
Regulatory Counsel, Colorado Attorney General Office, and prosecutors with jurisdiction
requesting a full investigation of counselors actions and your client Lora J. Powers
breach of fiduciary duties.
1
Page
 Conflict of Interest
Current Clients & Personal Interest Conflict

As of William A. Powers date of incompetence (December 3, 2015), the LLCs of William

A. Powers had previously been dissolved, terminated and neglected to be wound up.
The majority of remaining members of the LLCs do not authorized Barry Korman,
Theresa Moore or Lora J. Powers to act on behalf of the LLC.

According to counselors filings with the Colorado Secretary of State, on February 16,
2016 you named yourself registered agent and are thereby representing yourself as
legal counsel for the LLCs owned by William A. Powers.

In April of 2016, you introduced yourself as legal counsel for Lora J. Powers. Lora J.
Powers is an heir at law to the estate of William A. Powers and an individual William A.
Powers has issued LLC K-1s in the past. Lora J. Powers siblings (Jean M. Powers and
myself) have also received K-1 member filings from William A. Powers LLCs and are in
contest with Lora J. Powers for inheritance of property from the wind up of the
membership interest of William A. Powers LLCs and his estate assets.

I believe your legal representation of the above clients violates the Model Rules of
Professional Conduct 1.7, 1.8, and 8.4. Your clients (LLCs of William A. Powers and Lora
J. Powers) are involved in matters that are substantially related and are parties in
conflict in Arapahoe County Probate Court matters (2015PR31083 and 2016PR30159).

At the time of the LLCs dissolution, Lora J. Powers was not a Manager nor was she the
only member. LLC documents as well as submitted IRS tax filings prepared by William A.
Powers and certified professionals identify members of the LLC through K-1s to include
Lora J. Powers, Jean M. Powers, William M. Powers, Jacqueline M. Pepper, Jane M.
Pepper, Adam J. Powers, Peyton Hengen and Ryan Hengen. These individuals are also
heirs at law of William A. Powers estate.

Loyalty to the LLCs of William A. Powers prohibits you, Barry Korman Esq, from
undertaking Lora J. Powers legal representation. Engaging in legal representation with
clients who have conflicts of interest will cause you to be subject to discipline, and cause
personal liability for malpractice and breach of fiduciary duty.

Barry Kormans Personal Interest Conflicts

Your attorney registration indicates you operate your law firm out of the Barrister
Building located at 2676 W Alamo Avenue, Littleton, Colorado 80120. William A. Powers
and his LLCs own this building. Your landlord is William A. Powers and his LLCs. Your
landlord tenant relationship triggers a conflict created by your own interest.
2
Page
In addition, a lawyer may not allow related business interest to affect representation.
Since William A. Powers incapacity, Powers Professional Corporation (William A.
Powers Law Practice) has been referring new clients to your law firm. See Rule 1.8 and
1.10 for specific Rules pertaining to a number of personal interest conflicts, including
business transactions with clients.

As a licensed Colorado attorney, you should have avoided the conflict as well as the
appearance of impropriety you have caused. You have a duty as an attorney to have
exercised independent professional judgment and measured the potential for damage
to both existing client relationships as well as perceptions of the legal system itself.
Rather than play ostrich and ignore the risks of representing clients with conflicts of
interest, you should have employed a conflict checking system appropriate to the size
and type of law you practice. It appears you neither have competence in corporate
entitles, probate, or litigation. You have engaged in barratry, the generation of profit for
legal services by an attorney who stirs up a dispute and encourages lawsuits in order to
accrue legal expenses and to support your client Lora J. Powers interest that conflicts
with your other clients interests.

Lora J. Powers

The conflict between Lora J. Powers and myself arises from my father William A.
Powers death and matters of inheritance. Lora J. Powers is my sister and we are both
the children of William A. Powers and Sheryl J. Powers. There are three children from
this marriage, Lora J. Powers, Jean M. Powers and myself William Marty Powers.
Pursuant to the probate laws, it is my understanding since my father died without a will,
the Arapahoe County Probate Court will divide his assets equally between his children.
The court with jurisdiction over the estate of William A. Powers is Arapahoe County
District Court Judge T. Slade (15PR31083) and (16PR30159).

It is undisputed William A. Powers purchased property and assets during the course of
his life and took title in his own name. That he organized and enrolled himself and
family into LLCs and quit claimed titled of his personal property for nominal amounts (ie:
$10 for Tripp St Property to Silver Fox LLC in 2005). My parents (William A. Powers and
Sheryl J. Powers) were the original managers of the LLCs. The LLCs were established to
last for a specific duration with an ability to continue the LLC only upon agreement of
their children at the time of their deaths or 30 years. When the LLC were valid, the
managers of the family LLCs issued K-1 to the members to be filed with taxes annually.
Upon my mothers death in 2006, my father struggled with grief and health issues.
Unable to comply with the formalities of the LLCs, they immediately fell into neglect and
were terminated June 9, 2006 after going through a period of dissolution (per the
Operating Agreements and LLC statutes April 9, 2006 - June 8, 2006) where no notice to
members, intent to continue or meetings were convened to continue the business of
3

the Companies.
Page
After approximately four years of improper operation of the LLCs by Manager William A.
Powers and associated accounting professionals, the Courts determined in 2010 that the
LLCs and my father were one in the same and the alter egos of each other. After the
Court finding and the dissolution and termination of the LLCs in 2010, William A. Powers
inappropriately attempted to move assets from one LLC to another without regard to
business formalities required in the Operating Agreements. He failed to observe
recordkeeping requirements of the LLCs Operating Agreements, failed to provide asset
valuations when he accumulated and comingled properties, inducted new members into
the LLC without authorization or consent of members, underfunded the LLCs and paid
his personal expenses from accounts titled in LLCs name and vice versa. There are
numerous occasions and official court rulings (and affirmations upon appeal) that
demonstrate the LLCs were the alter ego of William A. Powers.

It is shocking and disgusting that Lora J. Powers is now arming herself with legal services
from Theresa Moore and Barry Korman and wielding fraudulent authority so that she
may attempt to solely possess and control all my fathers assets and attempt to avoid
probate by inappropriately reviving the LLCs without notice, consent or meeting of
members under your guidance. Pursuant to law and statute, my father was dissociated
from his LLCs and died without a will. Through the death of member Sheryl J. Powers
(April 9, 2006) and the adjudication of incompetence of William A. Powers on December
3, 2015, any LLC membership interest that had not been formally wound up upon
termination of the LLCs and in compliance with Operating Agreements and LLC statutes,
would be subject to Probate Courts jurisdiction to be divided intestate. Each heir is
entitled to one third of William A. Powers estate assets which include his LLCs
membership interest when wound up by the Personal Representative appointed by the
Arapahoe County Probate Court. Frivolous and negligent attorney representation by
Lora J. Powers counsel is needlessly escalating costs against William A. Powers estate
and running up unconscionable legal expenses.

Breach of Fiduciary Duty and Abuse of Authority

Withholding Documentation

Since William A. Powers incapacity, Lora J. Powers has abused the authority from a co-
agent power of attorney (POA) and special conservatorship. She attempted to use the
POA and Conservatorship authority to revive dissolved LLCs and appoint herself as the
Managing Member. Lora J. Powers violated a do not resuscitate (DNR) / do not intubate
(DNI) on multiple occasions after William A. Powers massive stroke (November 2015) in
an attempt to facilitate the sale of William A. Powers real estate assets as a co-agent
POA. Lora J. Powers sold estate assets under the control of the Arapahoe County
Probate Court in March of 2016 (after William A. Powers 02/14/2016 death and
termination of conservatorship and co-agent POA) and made false representations
across state lines to real estate professionals in the sale of the Tripp Property (Chicago,
4

IL). Heirs to William A. Powers have confirmation that Lora J. Powers legal counsel, real
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estate professionals (buyer and seller) and Lora J. Powers knew that the co-agent POA
would not be valid if William A. Powers died prior to the sale. Lora J. Powers also
violated the Special Conservatorship of Jean M. Powers in December 2015 when she
listed the Tripp property for sale with Remax 10 . To date, the Arapahoe County
Probate Court has not appointed a Personal Representative for William A. Powers as the
heirs are embroiled in conflict. Through counsel, Lora J. Powers has refused to provide
documentation to justify her actions and is hiding documents and monies received from
the sale of the Tripp property. It is Lora J. Powers habit and strategy to exaggerate her
authority. This has been illustrated when Lora J. Powers represented herself to be the
only Power of Attorney for my father but refused to provide a copy of the POA until
confronted in Court. When the POA was finally produced, it was realized there were in
fact two POAs and they named co-agents (myself, sister and Lorraine Smuda). This is
Lora J. Powers strategy, to give bits and pieces of information to cause false
impressions, bully and manipulate others to achieve her goals. Her actions are
compounding the problems associated with the Tripp Avenue property sale in Chicago.
Remax 10 is refusing to provide documentation of the sale and legal costs are escalating
in an attempt to understand the details and authorizations of the property sale.

Lora J. Powers legal counsel is experienced and has the obligation to exercise due
diligence to validate and understand the details she reports to counsel and understand
records submitted and relied upon by the public on associated transactions. Counsel
has a legal responsibility to provide documents to your opponents when the case is filed
by a judicial officer. As the youngest child in our family, I have been subject to Lora J.
Powers abuse, deceit and lies my entire life. I know her to be a malicious, deceptive
and an unaccountable person. I dont believe anything she says and always require
proof of her statements and authority. At this point, I believe her to have mental
capacity issues that impede her already questionable judgement. Lora J. Powers
counsel is facilitating her lies, engaging in frivolous legal conduct, inappropriately
alienating me from my legal rights as an heir to William A. Powers and causing a
significant financial impact to the estate of William A. Powers. I suggest you protect
yourself and demand documents and proof of Lora J. Powers authority as I do or you
may find yourself on the wrong side of her deceit and dishonesty. I plan to seek
damages for William A. Powers estate concerning any inappropriate conduct of Lora J.
Powers and her counsel. I believe it is only a matter of time before Lora J. Powers will
turn on her legal counsel when it has been determined that she is complicated with
telling the truth.

Conflicts Relating to the Estate of William A. Powers

William A. Powers was a retired attorney who managed his professional liability and
personal assets with LLCs. William A. Powers suffered strokes beginning in 2010
escalating to a massive stroke on November 27, 2015 and fatal stroke on February 13,
2016. On December 1, 2015 a petition for conservatorship was filed in the District Court
5

in Arapahoe County Colorado. On December 3, 2015 District Court Judge Timothy Fasing
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adjudicated William A. Powers incompetent after an evidentiary hearing. The court

opened a conservatorship, (2015PR31083), and appointed Jean M. Powers to be the
Special Conservator. On January 20, 2016 Lora J. Powers was substituted as the
Conservator. On February 14, 2016 William A. Powers died. On February 19, 2016, Lora
J. Powers petitioned the probate court to appoint a personal representative and
probate the intestate estate of William A. Powers.

Unauthorized Filing with Colorado Secretary of State and

Unauthorized Practice of Law

On November 27, 2015 when William A. Powers had his massive hemorrhagic stroke,
he was an inactive, retired attorney whose law practice was named Powers Professional
Corporation. At the time of his massive strove, he had failed to wrap up his law firm and
LLCs. Powers Professional Corporation (William A. Powers Law firm) continues to be
open for business at the time of this notice, answering the phone and emails as a law
firm. William A. Powers COLTAF account remains open with a balance and he has failed
to notify clients of his retirement or arranged for the return of their files. William A.
Powers secretary, Anna Plute, continues to come into the office on a regular basis
despite the office being closed and William A. Powers inactive attorney status. To make
things more complicated, it is realized that William A. Powers and Anna Plute have been
engaged in an intimate relationship since 1998. It appears that the law firm has
remained active as an adulterous ploy to keep the office open and continue their
relationship. Anna Plute is married, and was participating in the affair with William A.
Powers for eight years while Sheryl J. Powers (my mother) was battling cancer. Anna
Plute advised William Powers family of their intimate relationship and the existence
caused friction between my father and myself. My father tormented my mother with
his relationships with Anna Plute, and other women. William A. Powers attempted to
punish me financially through the family LLCs and emotionally when I rejected his
adulterous lifestyle. Sadly, in the final years of my mothers life, my father initiated a
second and concurrent affair with Carmel Connelly. At the time of his death, it appears
that William A. Powers was in a relationship with both women. There are probably
more women that I was not aware of that never came forward.

Upon notice of his massive stroke (November 2015) and the apparent authority of the
co-agent Power Of Attorney (POA), Lora J. Powers attempted, under the guidance of
legal counsel, to use the now invalid co-agent POA (invalid upon death of William A.
Powers) to revive the terminated LLCs and take over legal activities associated with the
William A. Powers Law firm and real estate assets. She locked myself and Jean M.
Powers (who is an attorney and operated her law firm out of the 2676 West Alamo
Avenue Building (Barrister Building)) out of William A. Powers Law office within hours of
my fathers November 27, 2015 stroke. Since my fathers massive stroke and
subsequent death, Lora J. Powers and Anna Plute have engaged in the practice of law by
an unlicensed attorney.
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 - They have caused emails to be sent from William A. Powers Esq email account
to his clients about legal services. The emails indicate the sender to be William A.
Powers Esq. and the content of the email is protected by the legal disclaimer
that appeared on all of my fathers professional communications.
- Lora J. Powers and Anna Plute have acted as inventory counsel without authority
or permission from the Colorado Supreme Court.
- Lora J. Powers and Anna Plute have caused William A. Powers legal client files to
be handed over to third parties in violation of the attorney client privilege.
- Lora J. Powers has sent legal correspondence to William A. Powers clients on
law firm letter head after his death.
- Lora J. Powers and Anna Plute have intercepted and detained mail from the
Colorado Supreme Court addressed to attorney Jean M. Powers at her registered
law address (2676 West Alamo Avenue) causing a formal investigation of non-
response to the Colorado Supreme Court inquiry.
- On two separate occasions, Lora J. Powers and Anna Plute have intercepted,
detained and cancelled checks authorized by Jean M. Powers, the Special
Conservator of William A. Powers from December 03, 2015 to January 20, 2016.
One check was returned directly by Lora J. Powers legal counsel Theresa Moore
after it was cancelled. The second check was cancelled (without notice to
parties) on January 20, 2016 that was intended for a legal trust account for
William A. Powers conservatory issues in conflict with Lora J. Powers fiduciary
responsibilities. Through her legal counsel and with the assistance of John
Barringer (court identified financial advisor), Lora J. Powers has coordinated and
manipulated the accounts of William A. Powers against her siblings in an attempt
to diminish their inheritance rights, violate probate statutes and deceive real
estate professionals in the sale of William A. Powers assets.

These acts constitute unauthorized practice of law and have been reported to the
Colorado Supreme Court, Colorado Secretary of State and the Colorado Attorney
General.

Power of Attorney CRS 15-14-701et seq

Colorado Revised Statutes adopts the Uniform Power of Attorney Act (UPOAA)
effective January 1, 2010, requires all Powers of Attorney signed after January 1, 2010,
must specifically state the agent has certain powers, casually referred to as hot
powers. Since the power of attorney drafted by William A. Powers does not include
these hot powers then the agent(s) lacks the authority to exercise any of these
powers.

The POAs in William A. Powers matter were poorly drafted and executed. Neither POA
revokes the prior or provides direction for subsequent POAs. The POAs may be read to
7

be either co-agent or successor-agent. Both POAs were signed after January 1, 2010
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and fail to specifically authorize an agent to exercise hot powers. The names of
persons who are co / successor agents includes; Lora J. Powers, William M. Powers, Jean
M. Powers and Lorraine Smuda. 1

Colorado Revised Statutes which requires all Powers of Attorney signed after January 1,
2010, must specifically state the agent has certain powers, casually referred to as hot
powers. Since the power of attorney drafted by William A. Powers does not include
these hot powers then the agent(s) lacks the authority to exercise any of these
powers.
These hot powers include the power of the agent to:
1. Make a gift;
2. Create or change rights of survivorship;
3. Create or change a beneficiary designation;
4. Create, amend, revoke, or terminate a trust;
5. Delegate authority granted under a power of attorney;
6. Waive the principals right to be a beneficiary of a joint and survivor annuity, including
a survivor benefit under a retirement plan;
7. Exercise various powers held by the principal in a fiduciary capacity;
8. Disclaim or release properties or a power of appointment;
9. Exercise powers, rights, or authority as a partner, member, or manager of a
partnership.

Issues with Power of Attorneys:

Having more than one Agent as a decision maker in this case caused discord.

Medical: Lora J. Powers told University of Hospital physicians by phone that she was the
only child of William A. Powers. Physicians advised us of this fact and were skeptical
when we introduced ourselves 24 hours after my fathers stroke. As Lora J. Powers was
not able to be present after William A. Powers suffered the massive stroke in Chicago,
under the terms of the POAs, Jean M. Powers, William M. Powers and Lorraine Smuda
were the actual co-agent/co-successor agents of the POA at the time of the massive
stroke.
Without consultation with co-agents of the POAs, Lora J. Powers placed William A.

8
Powers on DNR / DNI (do not resuscitate / intubate). Lora J. Powers vacillated back and
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forth on enforcing the DNR/DNI on multiple occasions as my father suffered multiple

1Conditional (Durable) Power of Attorney dated April 26, 2012 names Lora Hengen-
Powers, then Marty Powers, then Jean M Powers as his attorneys-in-fact who each shall
have full power and authority to exercise all my powers regarding my property, my
business and all other personal affairs to the same extent as I myself might do. The
second Conditional (Durable) Power of Attorney dated June 18, 2013 does not revoke
the prior POA and names Lora Hengen-Powers, then Lorraine Smuda, then Jean M
Powers as attorneys-in-fact who each shall have full power and authority to exercise all
my powers regarding my property, my business and all other personal affairs to the
same extent as I myself might do.
strokes during his hospitalization between November 2015 and his death on February
14, 2016. Lora J. Powers instructed medical professionals to not provide information to
co-agents/concurrent agents who are the natural children of William A. Powers.

Death: On February 12, 2016, my fathers condition significantly deteriorated to a point

where the doctors advised Lora J. Powers that he was in the last stages of life. Lora J.
Powers gave notice to me by text on February 13, 2016 that dad had suffered a setback
and that she would provide more information when she went to Chicago.
Lora J. Powers was put on notice of William A. Powers final hours of life on
February 12, 2016 by University of Illinois medical staff
Lora J. Powers put my father on life support February 12, 2016, without
notice to family members and made arrangements to fly out to Chicago for
last goodbyes with our father.
Lora J. Powers waited till she was boarding the plane to Chicago on the
morning of February 13, 2016 when she provided an innocuous text
message that dad had suffered a setback.
I called the hospital after receiving Lora J. Powers vague text and Barry
Blackmans wife (Barry Blackman is a long-time friend of William A. Powers)
notified me that my father was diagnosed as terminal and that he would be
passing within hours.
I notified Mrs. Blackman that Jean and I were on our way immediately and
that we would catch the next available flight out to see our father and say
goodbye.
Upon arrival in Chicago around noon Central time, Lora J. Powers
individually and without consultation with Jean M. Powers or myself was
advised by the medical staff that my father would pass very quickly if taken
off life support. Lora J. Powers made the decision to immediately take
William A. Powers off life support when she knew we were out of state in
an effort to maliciously deny us from having the opportunity to say final
good byes. Lora J. Powers was aware that my sister and I were on the next
available flight out to Chicago and intentionally took our father off life
support, attempting to punish my sister and I emotionally and denying us
the opportunity of a final moment with our father. Lora J. Powers depth of
deceit and vial behavior has no bounds and is in direct conflict with Probate
Court Judges advisement on January 20, 2016 to set conservatorship issues
aside and spend the necessary time with our father, as we may not have
much time left. Lora J. Powers conduct is offensive and yet another
example of why she should not be considered for the Personal
Representative of William A. Powers probate.

Burial: Jean M. Powers and I believed William A. Powers should be cremated. Lora J.
Powers overrode our objections to an expensive burial and determined on her own he
9
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would be buried in a closed casket ceremony. Lora J. Powers caused the significant
expenses of two funeral services and transportation of body across the country without
agreement. My father spent my entire youth and adult life professing that he did not
want an expensive burial. Put me in a pine box, it is a waste of money was his mantra
that I heard over and over throughout my life. He had expressed to me and friends later
in life that he wanted cremation. Lora J. Powers obviously had other ideas.

Release of Property: Without any notice to the Special Conservator, Lora J. Powers
caused William A. Powers Tripp Avenue property (Oak Lawn, IL) to be listed on the
market for sale on December 15, 2015 (Jean M. Powers was the identified Special
Conservator at this time). Lora J. Powers executed a warranty deed selling Tripp Street
Property on March 26, 2016 (6 weeks after my father died and all of her authority under
the POA and conservatorship had ended). It has been confirmed that Lora J. Powers,
her counsel and real estate professionals were aware that the POA would terminate the
selling authority of the POA and would make things more difficult.

Exercise member/manager authority and powers:

Lora J. Powers, with Barry Kormans legal representation and counsel, caused fraudulent
filings with Colorado Secretary of State to change registered agent for LLCs that have
been dissolved, adjudicated by the Courts to be William A. Powers alter ego,
terminated or closed on multiple occasions. Lora J. Powers, with Barry Kormans
representation and counsel, caused fraudulent filings with Colorado Secretary of State
to improperly revive the LLCs with Amended Articles of Organizations and naming
herself as the Manager. Lora J. Powers has no authority over the LLCs and her counsel is
causing William A. Powers estate to experience significant legal costs. I will contest any
and all legal expenses by counselors firm and will seek damages if counselors conduct
is determined to negatively affect William A. Powers estate.

Under legal counsels advisement, Lora J. Powers has abused her authority as the co-
agent POA and Conservator of my fathers estate. Lora J. Powers is trying to alienate me
from my intestate share of my fathers estate and participation in family LLCs. Lora J.
Powers is using (without authorization) the financial resources of William A. Powers to
exercise the powers, rights and authority of the LLCs. Lora J. Powers is using my fathers
financial resources and attempting to alienate the members and heirs at law of William
A. Powers the use and enjoyment of property that are intestate. Lora J. Powers has
plundered and wasted William A. Powers assets for her own personal use and is trying
to take a larger share of inheritance. Lora J. Powers has ignored or disrespected Probate
Court authority and sold, transferred or wasted estate assets fraudulently asserting she
is the sole POA, sole member of LLCs, and sole Manager. Lora J. Powers has comingled
the assets between William A. Powers as an individual and the LLCs in her own
Conservatorship.
10

Lora J. Powers gifted estate assets of William A. Powers to her friends without Probate
Court authority or any other legal justification. She has specifically provided on-going
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financial resources to Anna Plute (William A. Powers mistress since 1998) and Carmel
Connelly (concurrent mistress approximately 2005) a woman whom he dated while
married and involved with Anna Plute.

POA after date of Death (February 14, 2016):

In April of 2016, the siblings of Lora J. Powers, who are heirs at law and have intestate
interests of my fathers assets once held in LLCs, by filing a joint verified motion for
preliminary injunction and temporary restraining order pursuant to Rule 65, have
attempted to enjoin Lora J. Powers from acting in any fashion for the estate of William
A. Powers or for any LLCs previously owned or operated by the decedent including any
financial accounts associated there with.

Conservatorship Authority and Actions

Arapahoe District Court, Colorado 15PR31083

On or about December 1, 2015 a Petition to appoint Conservator for William A. Powers

was filed. On or about December 3, 2015 District Court Judge Timothy Fasing heard
sworn testimony and issued findings and orders that William A. Powers to be legally
incapacitated and authorized Jean M. Powers to act as Special Conservator. On January
20, 2016 Lora J. Powers was substituted by District Court Judge Theresa Slade to be the
Conservator. All conservatorship authority ended upon William A. Powers death on
February 14, 2016.

Lora J. Powers filed her conservator inventory on April 29, 2016. The document is
incomplete and full of errors and formal objections are being prepared and will be filed
by William A. Powers heirs at law and members of LLCs.

William A. Powers LLC

Business Practices and Record Keeping

William A. Powers LLCs were dissolved and terminated on the 61st day (June 9, 2006)
following Sheryl J. Powers death (April 9, 2006). William A. Powers inappropriately
continued utilizing LLC accounts without authority and routinely comingled LLC accounts
with his personal assets. In 2010, Arapahoe County Courts identified William A. Powers
LLCs as his alter egos by adjudication and appeal confirmation.

There are many LLCs that were created when his wife Sheryl J. Powers was alive and she
is named the original co-owner, manager and member of each of the LLCs. At the time
of organization, articles were filed with the Colorado Secretary of State identifying
Sheryl J. and William A. Powers as co-managers, members, owners, and registered
11

agents. While state law requires a written and executed operating agreement
containing memberships percentage of ownership, rights and responsibilities,
Page

members voting powers, allocation of profit and losses, management details, fiduciary
and duties of members and managers, they are not required to be filed with the
Colorado Secretary of State. There are no written and executed operating agreements
for any of William A. Powers LLCs. Heirs of William A. Powers and members of the LLCs
have repeatedly requested Lora J. Powers to provide access and proof of LLC operating
agreements and statutory required business records. Under advisement of legal
counsel, Lora J. Powers has refused to produce any documents for review by heirs
counsel. Lora J. Powers attorneys have failed to respond to legal document requests
submitted to the Arapahoe County Probate Court. It is realized by their refusal to
cooperate that either the documents do not exist or they fail to support Lora J. Powers
conduct and false authority.

In general William A. Powers operated the LLCs as his alter egos and courts have ruled
and affirmed the LLC entities and William A. Powers are one and the same. The LLC
records indicate William A. Powers as Manager failed to observe formalities regarding
division of authority within the entities, failed to notice and require meetings or
formally waive them and neglectfully engaged in insufficient recordkeeping. Financial
affairs were not maintained separately. Salary, lease and loan agreements were not
authorized by the correct powers, meeting were not held or formally waived. The
Operating agreements were not executed by all of the members. While bank accounts
and credit cards were established in the entities name when assets were transferred to
a business in exchange for an ownership interest, managements care was not taken to
ensure that legal title was effectively transferred. Transfer of real estate and motor
vehicles requires that a formal document of title that takes a certain form be executed
and recorded. Even when assets were initially separate this was not maintained and
there is a pattern of co-mingling assets between the LLCs and managers personal
assets. Lastly, when considering any capital contribution provided by members after the
initial capitalization, the operating agreements and LLC statues require the previous
assets to be revalued by independent agencies to insure capital account records are
maintained accurately, proportionally and accepted by the members of the LLC. There
is nothing demonstrated in the LLCs documents or managements conduct over the last
30 years that would indicate that these business practices were appropriately followed.

Dissolution and Termination of LLCs

Colorado Revised statute states when a LLC member dies, the remaining members must
affirm in writing within 60 days of their intent to continue the LLC or the LLC will
automatically be dissolved. Sheryl J. Powers died on April 9, 2006. The remaining
members of the LLCs failed to express intent to continue the LLC in writing and all the
LLCs were dissolved by operation of law on June 9, 2006. Following this same analysis
William A. Powers was adjudicated incompetent on December 3, 2015. Remaining
members failed to file intent to continue the LLCs by February 1, 2016 (60 days) so the
12

LLC automatically dissolved on February 2, 2016.

Page
Statutes and case law indicates other events can trigger dissolution of the LLC such as
judicial determination the LLC are the alter ego of the owner. In 2010, Joseph Seller filed
a suit against William A. Powers and the LLCs for collection in Arapahoe County Court. A
trial found William A. Powers failure to follow mandatory rules imposed on business
entities by the state as the main reason for invoking the alter ego finding and permitting
the creditor to pierce the LLCs veil. The testimony established William A. Powers failed
to separate his financial affairs from the entitys financial affairs, and/or observe
statutory formalities regarding division of authority within the entity, and/or conduct
the required meetings and establish appropriate recording keeping practices. The
judgment was appealed and Arapahoe District Judge Christopher Cross affirmed the trial
courts judgment. Colorado law requires LLCs to be maintained independently. Written
operating agreements were not filed and to the knowledge of members who have
received K-1s over the years have never been executed. The LLCs are believed to have
fallen into neglect due to William A. Powers deteriorating health and failure to establish
business processes that separated the proper record keeping of independent business
transactions of the LLCs from personal ownership of property and assets.

Dissolution in relation to Initial Capitalization:

In actions to pierce the LLCs veil, courts examine the capitalization of the business at
the time the LLC was formed and the continuation of capital contributions to the LLC by
the members.

Lora J. Powers has manipulated William A. Powers in his declining years and mental
frailties to move assets around in the LLCs so as to create her own personal windfall
without any required notice to members or capital contribution. With the unauthorized
movement of assets between the LLCs, extensive documentation, analysis, notice and
approvals are required of which none where provided or accounted for. By submitting
the perjured documents recorded with the Colorado Secretary of State, Lora J. Powers is
making false representations to the public that she is the Manager of the LLCs. As all of
these LLCs have been dissolved on multiple occasions with respect to the Operating
Agreements and LLC statutes, Lora J. Powers, through her legal counsel, is attempting to
revive LLCs that have been specifically terminated by the acts or specific lack of intent
by the members to continue the Companies. Lora J. Powers is attempting to claim
ownership of the dissolved LLCs and the personal property of William A. Powers that
were inappropriately placed in the LLCs. By creating the false impression with the
Colorado Secretary of State (perjured documents), real estate professionals have relied
on these documents to transfer property that is under the control of the Arapahoe
County Probate Court (2016PR30159).

A look at the initial capitalization of the LLC will show Lora J. Powers did not contribute
13

capital greater than her siblings and does not have a greater membership interest than
her siblings/members.
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 During Lora J. Powers dissolution (divorce) from Brian Hengen, Lora J. Powers
did not report on her financial disclosures the membership interest of William A.
Powers LLCs. Douglas County divorce records will confirm had she included the
assets she now asserts ownership over the child support and maintenance
calculation would have been substantially reduced and she might have owed
money to her spouse.

Since the incapacity and death of William A. Powers, the LLCs have been underfunded
and required Lora J. Powers to pay LLC debts with the personal finances of William A.
Powers. William A. Powers also employed this practice of comingling funds. No records
exist to certify when an equity interest was received in return for a contribution of
property to the entity.

Mixed Use Assets placed in LLC

The law is clear that personal residences should never be transferred to a business
entity. Doing so would be improper and an intent to defraud creditors, taxes and in this
case heirs. The assets named in the LLCs are mixed use assets. Each property listed as
an asset of William A. Powers LLCs is a residence to himself and his family. While the
Alamo address is the place where William A. Powers operated his business, he has also
listed the location as his personal residence and is the address of residence for Jean M.
Powers (heir at law, member) on her drivers license and voter registration. The Datura
property has never been a business and is only a personal asset and long time family
residence of William A. and Sheryl J. Powers and now Jean M. Powers and her children.
The Vail property has been the residence of William A. Powers, Lora J. Powers, Jean M.
Powers and myself and never been a place of business (although it has been rarely
rented for nominal amounts). The Florida properties have only been personal residences
of William A. Powers. The Chicago properties have only been residences. The Texas
Properties are undeveloped residential land.

Management and Operation of LLC

The lack of observation of business practices and separation of ownership from LLC was
not monitored or enforced during William A. Powers life because the family recognized
all the property was in fact owned personally by William A. Powers and upon his death
the LLCs would be dissolved pursuant to statute and law. Lora J. Powers seeks a
different course because she has nothing to loose with her argument. If the Court
accepts the division as Jean and I suggest each of us will get one third of the assets and
we will each be responsible for our own legal fees. If the Court accepts the division Lora
J. Powers proposes, she will get control of 100% of the property and the majority of the
financial accounts. Lora J. Powers will dissociate me and Jean M. Powers from the LLCs
14

and avoid distributing my fathers estate equally between my siblings and me in

accordance to probate law. Despite being the legal son of William A. Powers and having
Page

not been disinherited by any will (my father was an attorney fully able to execute a will
and disinherit me had that been his intention), Lora J. Powers legal counsel Theresa
Moore has proposed Lora J. Powers will share William A. Powers assets with Jean M.
Powers so long as there is agreement to exclude me. This offer is conditioned upon Lora
J. Powers being recognized as the sole manager and member of the LLCs giving her
managers control to deny access or use of any of my fathers properties to Jean and her
children. I understand Jean has refused this indecent proposal.

During his lifetime and under his management of the LLCs, William A. Powers co-
mingled personal and business assets. As an owner he has used business resources for
personal purposes and violated the rules regarding separation and documentation of
assets. Here the lack of records and authorization means the expenses incurred are not
legitimate business expenses but instead personal expenses of the owner. Due to
neglect and dissolution the LLCs, financial accounts have insufficient cash available to
pay the bills and fatal asset co-mingling has occurred. The LLCs will not be able to
endure the scrutiny from the professional Personal Representative appointed by the
Arapahoe County Probate Court and will conclude with the same findings as the Courts
did in 2010, that the LLCs are the alter egos of the owner William A. Powers.

Fraudulent Sale Probate Assets

The Probate Court serves to ensure that the property of the deceased person is
safeguarded and that it is distributed only to those who have a right to it: either because
they are named in a will or because they are an heir under law and entitled to it. The
probate process is standardized with forms, process and procedures to insure the
property is protected during the probate that Lora J. Powers and her attorneys are
usurping.

Lora J. Powers Lack of Authority, Breach of Fiduciary Duty

and illegal conveyances

Lora J. Powers is not a manager or sole member of William A. Powers LLCs as they were
dissolved in 2006, 2010 and 2016.

The POA does not provide Lora J. Powers hot powers to Disclaim or release
properties or a power of appointment or to exercise powers, rights, or authority as a
partner, member, or manager of a partnership.

The Conservator authority for Lora J. Powers is limited to dates between January 20,
2016 and February 14, 2016.

William A. Powers estate is a contested probate with actual significant challenges

15

identifying heirs, property and title disputes. The Probate Court has indicated it will
require a Personal Representative before any LLC can be accessed, transferred, or sold.
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Lora J. Powers has misappropriated funds, sold assets, and lied (by omission) to the
Probate Court (I believe that is called perjury).

Lora J. Powers will be reported to the Attorney General and prosecutors for mail theft,
fraud, conspiracy, concealment, disposition of estate property, and engaging in
monetary transactions in property derived from specified unlawful activity. It will be
conveyed to the authorities that Lora J. Powers was under the counsel of multiple
attorneys that have facilitated her in her efforts to defraud heirs and the public.

Lora J. Powers actions constitute a blatant transgression against the lawful rights and
interests of William A. Powers heirs at law. Failure to respect the Arapahoe District
Probate Courts authority has caused estate dispute claims of breach of fiduciary duty,
wrongful interference with inheritance, fraudulent conveyances, conversions and
misappropriations, self-dealing, negligence and claims for accounting.

10153 Tripp Ave

Cook County IL Property tax Portal: Info for Tax Year: 2015 William A.
Powers, 2676 W Alamo Ave, Littleton, Co 80120
PIN: 24-10-411-049-0000
Address: 10153 TRIPP AVE
City: OAK LAWN
Zip Code: 60453
Township: WORTH
Info for Tax Year: 2015
Estimated Property Value: $207,240

William A. Powers purchased the asset identified as 10153 Tripp Ave for $265,000 on
September 8, 2004 with funding through Morgan Stanley. 2004 through 2015 tax
documents and the Cook County Assessor office list William A. Powers as the owner and
person responsible for taxes. Through fraud and with the intent to deprive the heirs of
William A. Powers for their inheritance, Lora J. Powers executed a warranty deed on
March 26, 2016 (after the death of William A. Powers), for the Tripp Property and fails
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to account for the sale proceeds in the conservator report filed April 29, 2016. Lora J.
Powers commits fraud and theft when she executes the warranty deed for property
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purchased by William A. Powers and according to Illinois tax records owned by William
A. Powers.

Colorado Secretary of State records indicate Silver Fox LLC was organized by William A.
Powers Esq for Beverly and William Niles. Beverly Niles died in 1998 and William Niles
died in 2007. Powers Professional Corporations (William A. Powers Law firm) is the
registered agent for this LLC. There are no transfers of ownership or amended articles
filed with the Secretary of State to indicate William A. Powers is a member or interest
holder in Silver Fox LLC. William Powers tax records do however indicate he reports on
a K-1 an interest in Silver Fox LLC. There are no LLC documents or business records to
indicate Silver Fox LLC was a valid entity in 2005 when William A. Powers quit claimed
the property to the LLC. The LLC is automatically dissolved and terminated upon the
death of its members in 1998, 2007.

Lora J. Powers reports in a Conservator report filed on April 29th 2016 to have used the
personal assets of William A. Powers to pay the debts and cost of Silver Fox LLC related
to the Tripp Avenue property. Lora J. Powers conservator report also indicates she
received monies from Erwin Larue (the former tenant of the Tripp property) $19,066.79
on March 6, 2016. Erwin Larue died on December 18, 2015. Erwin Larue made the
payment to the Silver Fox LLC 89 days after his death.

Conclusion

I anticipate when Lora J. Powers is held accountable for her actions, she will affirm she
was relying on the advice of her legal counsel. She will continue her course of action
and attempt to disinherit me and take possession/control of all my fathers assets. In
Lora J. Powers view, she was my fathers favorite, the oldest, and deserves all of the
assets held in my fathers name and in his LLC because she has self-appointed herself
manager of the dissolved LLCs. Lora J. Powers is the greedy daughter who manipulated
our father when his health was failing and when he was struggling with his mortality.
Lora J. Powers has submitted perjured and misleading documents to the Colorado
Secretary of State under the advisement of legal counsel in an attempt to deceive the
public and to sell William A. Powers personal assets currently under the jurisdiction and
control of the Arapahoe County Probate Court.

Lora J. Powers has breached her fiduciary duties as conservator and my counsel has
petitioned the Probate court to address her actions.

Lora J. Powers fails to realize that when William A. Powers was the manager of the LLCs
(when they were valid), he had fiduciary duties to all his members and could not favor
one member over another member.
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Lora J. Powers further fails to acknowledge William A. Powers property and the LLCs
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property are one in the same and under the control of the Arapahoe County Probate
Court. That my fathers mismanagement of the LLCs, comingling of assets and negligent
recordkeeping caused judicial adjudications and the affirmation (appeal) that the LLCs
were his alter egos.

Lora J. Powers will deny knowledge or accountability when her attorneys failed to
respond to request for LLC documents and proof of her authority.

Lora J. Powers will act confused and ignorant if questioned why she did not respect the
Probate Courts jurisdiction. She will claim that her counsel advised her that she could
sell the assets of William A. Powers without the probate courts permission.

As I have stated previously, Lora J. Powers has always had trouble accepting
responsibility for her actions throughout her life. With her, it has always been the case
of being someone elses fault. I believe she will file malpractice claims against her
attorneys so as to avoid responsibly for her greed and deception. I believe that she feels
entitled and will not bear any financial sanctions for her conduct alone as she intends to
use our fathers financial assets to bully, manipulate and deceive her siblings into
submission with the appointment of her legal counsel and financial advisors. After her
legal counsel(s) and advisors have run up exorbitant expenses, Lora J. Powers will throw
her them under the bus and complain to the Court she is a grieving daughter who has
no experience in judicial maters and was following the advice of counsel / advisors who
neglected her and committed malpractice. Lora J. Powers grew up in a family of
attorneys and business owners. Lora J. Powers is well aware of what she is doing when
she deceives the Court and her counsel. In the end, I project that it will be the
professional liability insurance of Lora J. Powers counsel employed to deceive the
Probate Court that will pay for the damage and malpractice caused against William A.
Powers estate and heirs Lora J. Powers, Jean M. Powers and myself.

Regards,

William M. Powers
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