CEO INDICTED -LORRAINE BROWN OF DOCX LPS -FORGERY, FALSE DECLARATIONS

8/3/2019 CEO INDICTED -LORRAINE BROWN OF DOCX LPS -FORGERY, FALSE DECLARATIONS

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FILEDBOONE COUNTYIN THE CIRCillT COURT OF BOONE COUNTY, MISSOURifEB 0 3 2012

STATE OF MISSOURIPlaintiff,

v.LORRAINE 0. BROWN

Defendant.

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Case No. JJJ5f) ~ Y l 00 i3oOCN:

INDICTMENTCOUNT 1

Forgery- Class C FelonyMo. Charge Code: 1801089.0NCIC Code: 2589

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant inviolation of section 570.090 RSMo, committed the class C felony of forgery, punishable uponconviction under sections 558.011 and 560.011, RSMo, in that on or about Apri l21, 2009, in theCounty of Boone, State of Missouri, Defendant, acting knowingly in concert with DOCX LLCand its employees, with the purpose to defraud, used as genuine or transferred with theknowledge or belief that it would be used as genuine, a writing, namely Deed of Release number2009010022, knowing that it had been made or authenticated so that it purported to have beenmade by another, or that it had been made so that it purported to have been made by authority ofone who did not give such authority.

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COUNT2False Declaration- Class B misdemeanorMo. Charge Code: 2910199.0NCIC Code: 5099

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant inviolation of section 575.060 RSMo, committed the class B misdemeanor of making a falsedeclaration, punishable upon conviction under sections 558.011 and 560.016, RSMo, in that onor about Apri l21, 2009, in the County of Boone, State of Missouri, Defendant acting knowinglyin concert with DOCX LLC and its employees, with the purpose to mislead the Boone CountyRecorder of Deeds, a public servant in the performance of her duty, submitted or invited relianceon a writing, namely Deed ofRelease number 2009010022, which Defendant knew to be lackingin authenticity, and which stated a fact material to the purposes for which the writing wasoffered.

The conduct alleged herein was discovered in 2011, when the purported signer of Deedof Release 2009010022 was found not to have signed Deed of Release 2009010022 before thenotary public identified in Deed of Release 2009010022.

COUNT3Forgery- Class C Felony

Mo. Charge Code: 1801089.0NCIC Code: 2589The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant in

violation of section 570.090 RSMo, committed the class C felony of forgery, punishable uponconviction under sections 558.011 and 560.011, RSMo, in that on or about July 7, 2009, in theCounty of Boone, State of Missouri, Defendant, acting knowingly in concert with DOCX LLCand its employees, with the purpose to defraud, used as genuine or transferred with the

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knowledge or belief that it would be used as genuine, a writing, namely Deed of Release number2009018568, knowing that it had been made or authenticated so that it purported to have beenmade by another, or that it had been made so that it purported to have been made by authority ofone who did not give such authority.

COUNT4

False Declaration- Class B misdemeanorMo. Charge Code: 2910199.0NCIC Code: 5099The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant in

violation of section 575.060 RSMo, committed the class B misdemeanor of making a falsedeclaration, punishable upon conviction under sections 558.011 and 560.016, RSMo, in that onor about July 7, 2009, in the County of Boone, State ofMissouri, Defendant acting knowingly inconcert with DOCX LLC and its employees, with the purpose to mislead the Boone CountyRecorder of Deeds, a public servant in the performance ofher duty, submitted or invited relianceon a writing, namely Deed ofRelease number 2009018568, which Defendant knew to be lackingin authenticity, and which stated a fact material to the purposes for which the writing wasoffered.

The conduct alleged herein was discovered in 2011, when the purported signer of Deedof Release 2009018568 was found not to have signed Deed of Release 2009018568 before thenotary public identified in Deed ofRelease 2009018568.

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COUNTSForgery- Class C Felony

Mo. Charge Code: 1801089.0NCIC Code: 2589

The Grand Jurors of the County of Boone, State.-uf Missouri, charge that Defendant inviolation of section 570.090 RSMo, committed the class C felony of forgery, punishable uponconviction under sections 558.011 and 560.011, RSMo, in that on or about July 28, 2009, in theCounty of Boone, State of Missouri, Defendant, acting knowingly in concert with DOCX LLCand its employees, with the purpose to defraud, used as genuine or transferred with theknowledge or belief that it would be used as genuine, a writing, namely Deed of Release number2009020598, knowing that it had been made or authenticated so that it purported to have beenmade by another, or that it had been made so that it purported to have been made by authority ofone who did not give such authority.

COUNT6False Declaration- Class B misdemeanorMo. Charge Code: 2910199.0

NCIC Code: 5099The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant in

violation of section 575.060 RSMo, committed the class B misdemeanor of making a falsedeclaration, punishable upon conviction under sections 558.011 and 560.016, RSMo, in that onor about July 28, 2009, in the County of Boone, State of Missouri, Defendant acting knowinglyin concert with DOCX LLC and its employees, with the purpose to mislead the Boone CountyRecorder of Deeds, a public servant in the performance of her duty, submitted or invited relianceon a writing, namely Deed of Release number 2009020598, which Defendant knew to be lacking

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in authenticity, and which stated a fact material to the purposes for which the writing wasoffered.

The conduct alleged herein was discovered in 2011, when the purported signer of Deedof Release 2009020598 was found not to have signed, Deed of Release 2009020598 before thenotary public identified in Deed ofRelease 2009020598.

COUNT7


The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant inviolation of section 570.090 RSMo, committed the class C felony of forgery, punishable uponconviction under sections 558.011 and 560.011, RSMo, in that on or about July 28, 2009, in theCounty of Boone, State of Missouri, Defendant, acting knowingly in concert with DOCX LLCand its employees, with the purpose to defraud, used as genuine or transferred with theknowledge or belief that it would be used as genuine, a writing, namely Deed of Release number2009020599, knowing that it had been made or authenticated so that it purported to have beenmade by another, or that it had been made so that it purported to have been made by authority ofone who did not give such authority.

COUNTSFalse Declaration- Class B misdemeanor

Mo. Charge Code: 2910199.0NCIC Code: 5099The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant in

violation of section 575.060 RSMo, committed the class B misdemeanor of making a falsedeclaration, punishable upon conviction under sections 558.011 and 560.016, RSMo, in that on

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or about July 28, 2009, in the County of Boone, State of Missouri, Defendant acting knowinglyin concert with DOCX LLC and its employees, with the purpose to mislead the Boone CountyRecorder of Deeds, a public servant in the performance of her duty, submitted or invited relianceon a writing, namely Deed of Release number 200-9020599, which Defendant knew to be lackingin authenticity, and which stated a fact material to the purposes for which the writing wasoffered.


COUNT9Forgery- Class C FelonyMo. Charge Code: 1801089.0NCIC Code: 2589


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COUNT 10

False Declaration- Class B misdemeanorMo. Charge Code: 2910199.0NCIC Code: 5099The Grand Jurors of the County of B


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COUNT 12


violation of section 575.060 RSMo, committed the class B misdemeanor of making a falsedeclaration, punishable upon conviction under sections 558.011 and 560.016, RSMo, in that onor about July 28, 2009, in the County of Boone, State of Missouri, Defendant acting knowinglyin concert with DOCX LLC and its employees, with the purpose to mislead the Boone CountyRecorder of Deeds, a public servant in the performance of her duty, submitted or invited relianceon a writing, namely Deed of Release number 2009020601, which Defendant knew to be lackingin authenticity, and which stated a fact material to the purposes for which the writing wasoffered.


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COUNT 13

Forgery- Class C FelonyMo. Charge Code: 1801089.0NCIC Code: 2589The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant in

violation of section 570.090 RSMo, committed the class C felony of forgery, punishable uponconviction under sections 558.011 and 560.011, RSMo, in that on or about July 28, 2009, in theCounty of Boone, State of Missouri, Defendant, acting knowingly in concert with DOCX LLCand its employees, with the purpose to defraud, used as genuine or transferred with theknowledge or bel ief that it would be used as genuine, a writing, namely Deed of Release number2009020602, knowing that it had been made or authenticated so that it purported to have beenmade by another, or that it had been made so that it purported to have been made by authority ofone who did not give such authority.

COUNT 14



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The conduct alleged herein was discovered in 2011, when the purported signer of Deedof Release 2009020602 was f o u n d ~ not to have signed Deed of Release 2009020602 before thenotary public identified in Deed of Release 2009020602.

COUNT 15Forgery- Class C FelonyMo. Charge Code: 1801089.0NCIC Code: 2589


COUNT16



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or about July 28, 2009, in the County of Boone, State of Missouri, Defendant acting knowinglyin concert with DOCX LLC and its employees, with the purpose to mislead the Boone CountyRecorder of Deeds, a public servant in the performance of her duty, submitted or invited relianceon a writing, namely Deed ofRelease number 2009020603, which Defendant knew to be lackingin authenticity, and which stated a fact material to the purposes for which the writing wasoffered.

The conduct alleged herein was discovered in 20 11, when the purported signer of Deedof Release 2009020603 was found not to have signed Deed of Release 2009020603 before thenotary public identified in Deed of Release 2009020603.

COUNT 17


violation of section 570.090 RSMo, committed the class C felony of forgery, punishable uponconviction under sections 558.011 and 560.011, RSMo, in that on or about July 28, 2009, in theCounty of Boone, State of Missouri, Defendant, acting knowingly in concert with DOCX LLCand its employees, with the purpose to defraud, used as genuine or transferred with theknowledge or belief that it would be used as genuine, a writing, namely Deed of Release number2009020604, knowing that it had been made or authenticated so that it purported to have beenmade by another, or that it had been made so that it purported to have been made by authority ofone who did not give such authority.

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COUNT 18

False Declaration- Class B misdemeanorMo. Charge Code: 2910199.0NCIC Code: 5099The Grand Juror,s ef:the County of Boone, State of Missouri, charge that Defendant in

violation of section 575.060 RSMo, committed the class B misdemeanor of making a falsedeclaration, punishable upon conviction under sections 558.011 and 560.016, RSMo, in that onor about July 28, 2009, in the County of Boone, State of Missouri, Defendant acting knowinglyin concert with DOCX LLC and its employees, with the purpose to mislead the Boone CountyRecorder of Deeds, a public servant in the performance of her duty, submitted or invited relianceon a writing, namely Deed of Release number 2009020604, which Defendant knew to be lackingin authenticity, and which stated a fact material to the purposes for which the writing wasoffered.


COUNT 19


violation of section 570.090 RSMo, committed the class C felony of forgery, punishable uponconviction under sections 558.011 and 560.011, RSMo, in that on or about July 31, 2009, in theCounty of Boone, State of Missouri, Defendant, acting knowingly in concert with DOCX LLCand its employees, with the purpose to defraud, used as genuine or transferred with the

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The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant inviolation of section 575.060 RSMo, committed the class B misdemeanor of making a falsedeclaration, punishable upon conviction under sections 558.011 and 560.016, RSMo, in that onor about July 31, 2009, in the County of Boone, State of Missouri, Defendant acting knowinglyin concert with DOCX LLC and its employees, with the purpose to mislead the Boone CountyRecorder of Deeds, a public servant in the performance of her duty, submitted or invited relianceon a writing, namely Deed of Release number 2009020911, which Defendant knew to be lackingin authenticity, and which stated a fact material to the purposes for which the writing wasoffered.


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The Grand;"'Jurors of the County of Boone, State of Missouri, charge that Defendant inviolation of section 570.090 RSMo, committed the class C felony of forgery, punishable uponconviction under sections 558.011 and 560.011, RSMo, in that on or about June 1, 2009, in theCounty of Boone, State of Missouri, Defendant, acting knowingly in concert with DOCX LLCand its employees, with the purpose to defraud, used as genuine or transferred with theknowledge or belief that it would be used as genuine, a writing, namely Deed of Release number2009014386, knowing that it had been made or authenticated so that it purported to have beenmade by another, or that it had been made so that it purported to have been made by authority ofone who did not give such authority.



violation of section 575.060 RSMo, committed the class B misdemeanor of making a falsedeclaration, punishable upon conviction under sections 558.011 and 560.016, RSMo, in that onor about June 1, 2009, in the County of Boone, State of Missouri, Defendant acting knowingly inconcert with DOCX LLC and its employees, with the purpose to mislead the Boone CountyRecorder of Deeds, a public servant in the performance of her duty, submitted or invited relianceon a writing, namely Deed of Release number 2009014386, which Defendant knew to be lacking

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The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant inviolation of section 570.090 RSMo, committed the class C felony of forgery, punishable uponconviction under sections 558.011 and 560.011, RSMo, in that on or about June 1, 2009, in theCounty of Boone, State of Missouri, Defendant, acting knowingly in concert with DOCX LLCand its employees, with the purpose to defraud, used as genuine or transferred with theknowledge or belief that it would be used as genuine, a writing, namely Deed of Release number2009014387, knowing that it had been made or authenticated so that it purported to have beenmade by another, or that it had been made so that it purported to have been made by authority ofone who did not give such authority.


The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant inviolation of section 575.060 RSMo, committed the class B misdemeanor of making a falsedeclaration, punishable upon conviction under sections 558.011 and 560.016, RSMo, in that on

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or about June 1, 2009, in the County of Boone, State of Missouri, Defendant acting knowingly inconcert with DOCX LLC and its employees, with the purpose to mislead the Boone CountyRecorder of Deeds, a public servant in the performance ofher duty, submitted or invited relianceon a writing, namely Deed of Release number 2009014387, which Defendant knew to be lackingin authenticity, and which stated a fact material to the purposes for which the writing wasoffered.


COUNT25


violation of section 570.090 RSMo, committed the class C felony of forgery, punishable uponconviction under sections 558.011 and 560.011, RSMo, in that on or about June 1, 2009, in theCounty of Boone, State of Missouri, Defendant, acting knowingly in concert with DOCX LLCand its employees, with the purpose to defraud, used as genuine or transferred with theknowledge or belief that it would be used as genuine, a writing, namely Deed of Release number2009014388, knowing that it had been made or authenticated so that it purported to have beenmade by another, or that it had been made so that it purported to have been made by authority ofone who did not give such authority.

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The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant inviolation of section 575.060 RSMo, committed the class B misdemeanor of making a falsedeclaration, punishable upon conviction under sections 558.011 and 560.016, RSMo, in that onor about June 1, 2009, in the County of Boone, State of Missouri, Defendant acting knowingly inconcert with DOCX LLC and its employees, with the purpose to mislead the Boone CountyRecorder of Deeds, a public servant in the performance of her duty, submitted or invited relianceon a writing, namely Deed of Release number 2009014388, which Defendant knew to be lackingin authenticity, and which stated a fact material to the purposes for which the writing wasoffered.



The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant inviolation of section 570.090 RSMo, committed the class C felony of forgery, punishable uponconviction under sections 558.011 and 560.011, RSMo, in that on or about June 1, 2009, in theCounty of Boone, State of Missouri, Defendant, acting knowingly in concert with DOCX LLCand its employees, with the purpose to defraud, used as genuine or transferred with the

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The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant inviolation of section 575.060 RSMo, committed the class B misdemeanor of making a falsedeclaration, punishable upon conviction under sections 558.011 and 560.016, RSMo, in that onor about June 1, 2009, in the County of Boone, State of Missouri, Defendant acting knowingly inconcert with DOCX LLC and its employees, with the purpose to mislead the Boone CountyRecorder of Deeds, a public servant in the performance ofher duty, submitted or invited relianceon a writing, namely Deed of Release number 2009014389, which Defendant knew to be lackingin authenticity, and which stated a fact material to the purposes for which the writing wasoffered.


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'" The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant inviolation of section 570.090 RSMo, committed the class C felony of forgery, punishable uponconviction under sections 558.011 and 560.011, RSMo, in that on or about June 1, 2009, in theCounty of Boone, State of Missouri, Defendant, acting knowingly in concert with DOCX LLCand its employees, with the purpose to defraud, used as genuine or transferred with theknowledge or belief that it would be used as genuine, a writing, namely Deed of Release number2009014390, knowing that it had been made or authenticated so that it purported to have beenmade by another, or that it had been made so that it purported to have been made by authority ofone who did not give such authority.

COUNT30False Declarat ion- Class B misdemeanorMo. Charge Code: 2910199.0


violation of section 575.060 RSMo, committed the class B misdemeanor of making a falsedeclaration, punishable upon conviction under sections 558.011 and 560.016, RSMo, in that onor about June 1, 2009, in the County of Boone, State of Missouri, Defendant acting knowingly inconcert with DOCX LLC and its employees, with the purpose to mislead the Boone CountyRecorder of Deeds, a public servant in the performance of her duty, submitted or invited relianceon a writing, namely Deed of Release number 2009014390, which Defendant knew to be lacking

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The conduct alleged herein was discovered in 2011, when the purported signer of Deed- ~ : ' ' " ' - , of Release 2009014390 was found not to have signed Deed of Release 2009014390 before the

notary public identified in Deed of Release 2009014390.COUNT31


violation of section 570.090 RSMo, committed the class C felony of forgery, punishable uponconviction under sections 558.011 and 560.011, RSMo, in that on or about June 1, 2009, in theCounty of Boone, State of Missouri, Defendant, acting knowingly in concert with DOCX LLCand its employees, with the purpose to defraud, used as genuine or transferred with theknowledge or belief that it would be used as genuine, a writing, namely Deed of Release number2009014394, knowing that it had been made or authenticated so that it purported to have beenmade by another, or that it had been made so that it purported to have been made by authority ofone who did not give such authority.



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COUNT34False Declarat ion- Class B misdemeanorMo. Charge Code: 2910199.0NCIC Code: 5099

The Grand Jurors of the County of Boone, State of Missouri, charge. that Defendant inviolation of section 575.060 RSMo, committed the class B misdemeanor of making a falsedeclaration, punishable upon conviction under sections 558.011 and 560.016, RSMo, in that onor about June 3, 2009, in the County of Boone, State of Missouri, Defendant acting knowingly inconcert with DOCX LLC and its employees, with the purpose to mislead the Boone CountyRecorder of Deeds, a public servant in the performance of her duty, submitted or invited relianceon a writing, namely Deed of Release number 2009014719, which Defendant knew to be lackingin authenticity, and which stated a fact material to the purposes for which the writing wasoffered.

The conduct alleged herein was discovered in 2011, when the purported signer of Deedof Release 2009014 719 was found not to have signed Deed of Release 2009014 719 before thenotary public identified in Deed of Release 2009014719.



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The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant inviolation of section 575.060 RSMo, committed the class B misdemeanor of making a falsedeclaration, punishable upon conviction under sections 558.011 and 560.016, RSMo, in that onor about June 3, 2009, in the County of Boone, State of Missouri, Defendant acting knowingly inconcert with DOCX LLC and its employees, with the purpose to mislead the Boone CountyRecorder of Deeds, a public servant in the performance of her duty, submitted or invited relianceon a writing, namely Deed of Release number 2009014720, which Defendant knew to be lackingin authenticity, and which stated a fact material to the purposes for which the writing wasoffered.


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COUNT38False Declarat ion- Class B misdemeanorMo. Charge Code: 2910199.0


violation of section 575.060 RSMo, committed the class B misdemeanor of making a falsedeclaration, punishable upon conviction under sections 558.011 and 560.016, RSMo, in that onor about June 15, 2009, in the County of Boone, State of Missouri, Defendant acting knowinglyin concert with DOCX LLC and its employees, with the purpose to mislead the Boone CountyRecorder of Deeds, a public servant in the performance of her duty, submitted or invited relianceon a writing, namely Deed of Release number 2009015916, which Defendant knew to be lacking

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or about July 7, 2009, in the County of Boone, State of Missouri, Defendant acting knowingly inconcert with DOCX LLC and its employees, with the purpose to mislead the Boone CountyRecorder of Deeds, a public servant in the performance ofher duty, submitted or invited relianceon a writing, namely Deed ofRelease number 2009018566, which Defendant knew to be lackingin authenticity, and which stated a fact material to the purposes for which the writing wasoffered.




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The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant inviolation of section 575.060 RSMo, committed the class B misdemeanor of making a falsedeclaration, punishable upon conviction under sections 558.011 and 560.016, RSMo, in that onor about July 7, 2009, in the County of Boone, State of Missouri, Defendant acting knowingly inconcert with DOCX LLC and its employees, with the purpose to mislead the Boone CountyRecorder of Deeds, a public servant in the performance ofher duty, submitted or invited relianceon a writing, namely Deed of Release number 2009018567, which Defendant knew to be lackingin authenticity, and which stated a fact material to the purposes for which the writing wasoffered.



The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant inviolation of section 570.090 RSMo, committed the class C felony of forgery, punishable uponconviction under sections 558.011 and 560.011, RSMo, in that on or about July 14, 2009, in theCounty of Boone, State of Missouri, Defendant, acting knowingly in concert with DOCX LLCand its employees, with the purpose to defraud, used as genuine or transferred with the

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The Grand Jurors of the County of Boone, State of Missouri, charge that Defendanhhviolation of section 570.090 RSMo, committed the class C felony of forgery, punishable uponconviction under sections 558.011 and 560.011, RSMo, in that on or about July 21, 2009, in theCounty of Boone, State of Missouri, Defendant, acting knowingly in concert with DOCX LLCand its employees, with the purpose to defraud, used as genuine or transferred with theknowledge or belief that it would be used as genuine, a writing, namely Deed of Release number2009019970, knowing that it had been made or authenticated so that it purported to have beenmade by another, or that it had been made so that it purported to have been made by authority ofone who did not give such authority.




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The conduct alleged herein was discovered in 2011, when the purported signer of Deed,,,of Release 2009019970 was found not to have signed Deed of Release 2009019970 before the

notary public identified in Deed of Release 2009019970.COUNT47


violation of section 570.090 RSMo, committed the class C felony of forgery, punishable uponconviction under sections 558.011 and 560.011, RSMo, in that on or about August 25, 2009, inthe County of Boone, State of Missouri, Defendant, acting knowingly in concert with DOCXLLC and its employees, with the purpose to defraud, used as genuine or transferred with theknowledge or belief that it would be used as genuine, a writing, namely Deed of Release number2009023094, knowing that it had been made or authenticated so that it purported to have beenmade by another, or that it had been made so that it purported to have been made by authority ofone who did not give such authority.



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or about August 25, 2009, in the County of Boone, State of Missouri, Defendant actingknowingly in concert with DOCX LLC and its employees, with the purpose to mislead theBoone County Recorder of Deeds, a public servant in the performance of her duty, submitted or

. ~ , invited reliance on a writing, namely Deed of Release number 2009023094, which Defendantknew to be lacking in authenticity, and which stated a fact material to the purposes for which thewriting was offered.



The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant inviolation of section 570.090 RSMo, committed the class C felony of forgery, punishable uponconviction under sections 558.011 and 560.011, RSMo, in that on or about August 25, 2009, inthe County of Boone, State of Missouri, Defendant, acting knowingly in concert with DOCXLLC and its employees, with the purpose to defraud, used as genuine or transferred with theknowledge or belief that it would be used as genuine, a writing, namely Deed of Release number2009023095, knowing that it had been made or authenticated so that it purported to have beenmade by another, or that it had been made so that it purported to have been made by authority ofone who did not give such authority.

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COUNT 50

False Declaration - Class B misdemeanorMo. Charge Code: 2910199.0NCIC Code: 5099The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant in

violation of section 575.060 RSMo, committed the class B misdemeanor of making a falsedeclaration, punishable upon conviction under sections 558.011 and 560.016, RSMo, in that onor about August 25, 2009, in the County of Boone, State of Missouri, Defendant actingknowingly in concert with DOCX LLC and its employees, with the purpose to mislead theBoone County Recorder of Deeds, a public servant in the performance of her duty, submitted orinvited reliance on a writing, namely Deed of Release number 2009023095, which Defendantknew to be lacking in authenticity, and which stated a fact material to the purposes for which thewriting was offered.


COUNT 51


violation of section 570.090 RSMo, committed the class C felony of forgery, punishable uponconviction under sections 558.011 and 560.011, RSMo, in that on or about August 25, 2009, inthe County of Boone, State of Missouri, Defendant, acting knowingly in concert with DOCXLLC and its employees, with the purpose to defraud, used as genuine or transferred with the

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COUNT 52

False Declarat ion- Class B misdemeanorMo. Charge Code: 2910199.0NCIC Code: 5099The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant in

violation of section 575.060 RSMo, committed the class B misdemeanor of making a falsedeclaration, punishable upon conviction under sections 558.011 and 560.016, RSMo, in that onor about August 25, 2009, in the County of Boone, State of Missouri, Defendant actingknowingly in concert with DOCX LLC and its employees, with the purpose to mislead theBoone County Recorder of Deeds, a public servant in the performance of her duty, submitted orinvited reliance on a writing, namely Deed of Release number 2009023096, which Defendantknew to be lacking in authenticity, and which stated a fact material to the purposes for which thewriting was offered.


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COUNT 53


The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant inviolation of section 570.090 RSMo, committed the class C felony of forgery, punishable uponconviction under sections 558.011 and 560.011, RSMo, in that on or about April28, 2009, in theCounty of Boone, State of Missouri, Defendant, acting knowingly in concert with DOCX LLCand its employees, with the purpose to defraud, used as genuine or transferred with theknowledge or belief that it would be used as genuine, a writing, namely Deed of Release number2009010725, knowing that it had been made or authenticated so that it purported to have beenmade by another, or that it had been made so that it purported to have been made by authority ofone who did not give such authority.

COUNT 54

False Declaration- Class B misdemeanorMo. Charge Code: 2910199.0NCIC Code: 5099

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant inviolation of section 575.060 RSMo, committed the class B misdemeanor of making a falsedeclaration, punishable upon conviction under sections 558.011 and 560.016, RSMo, in that onor about April28, 2009, in the County of Boone, State of Missouri, Defendant acting knowinglyin concert with DOCX LLC and its employees, with the purpose to mislead the Boone CountyRecorder of Deeds, a public servant in the performance of her duty, submitted or invited relianceon a writing, namely Deed of Release number 2009010725, which Defendant knew to be lacking

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COUNT 55Forgery- Class C FelonyMo. Charge Code: 1801089.0NCIC Code: 2589

The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant inviolation of section 570.090 RSMo, committed the class C felony of forgery, punishable uponconviction under sections 558.011 and 560.011, RSMo, in that on or about April28, 2009, in theCounty of Boone, State of Missouri, Defendant, acting knowingly in concert with DOCX LLCand its employees, with the purpose to defraud, used as genuine or transferred with theknowledge or belief that it would be used as genuine, a writing, namely Deed of Release number2009010726, knowing that it had been made or authenticated so that it purported to have beenmade by another, or that it had been made so that it purported to have been made by authority ofone who did not give such authority.

COUNT 56



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or about April 28, 2009, in the County of Boone, State ofMissouri, Defendant acting knowinglyin concert with DOCX LLC and its employees, with the purpose to mislead the Boone CountyRecorder of Deeds, a public servant in the performance ofher duty, submitted or invited relianceon a writing, namely Deed of Release number 2009010726, which Defendant knew to be lackingin authenticity, and which stated a fact material to the purposes for which the writing wasoffered.

The conduct alleged herein was discovered in 2011, when the purported signer of Deedof Release 2009010726 was found not to have signed Deed of Release 200901 0726 before thenotary public identified in Deed of Release 2009010726.

COUNT 57


violation of section 570.090 RSMo, committed the class C felony of forgery, punishable uponconviction under sections 558.011 and 560.011, RSMo, in that on or about April28, 2009, in theCounty of Boone, State of Missouri, Defendant, acting knowingly in concert with DOCX LLCand its employees, with the purpose to defraud, used as genuine or transferred with theknowledge or belief that it would be used as genuine, a writing, namely Deed of Release number2009010727, knowing that it had been made or authenticated so that it purported to have beenmade by another, or that it had been made so that it purported to have been made by authority ofone who did not give such authority.

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COUNT 58


violation of section 575.060 RSMo, committed the class B misdemeanor of making a falsedeclaration, punishable upon conviction under sections 558.011 and 560.016, RSMo, in that onor about April 28, 2009, in the County of Boone, State of Missouri, Defendant acting knowinglyin concert with DOCX LLC and its employees, with the purpose to mislead the Boone CountyRecorder of Deeds, a public servant in the performance ofher duty, submitted or invited relianceon a writing, namely Deed of Release number 2009010727, which Defendant knew to be lackingin authenticity, and which stated a fact material to the purposes for which the writing wasoffered.


COUNT 59


violation of section 570.090 RSMo, committed the class C felony of forgery, punishable uponconviction under sections 558.011 and 560.011, RSMo, in that on or about April28, 2009, in theCounty of Boone, State of Missouri, Defendant, acting knowingly in concert with DOCX LLCand its employees, with the purpose to defraud, used as genuine or transferred with the

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COUNT60


violation of section 575.060 RSMo, committed the class B misdemeanor of making a falsedeclaration, punishable upon conviction under sections 558.011 and 560.016, RSMo, in that onor about April28, 2009, in the County of Boone, State of Missouri, Defendant acting knowinglyin concert with DOCX LLC and its employees, with the purpose to mislead the Boone CountyRecorder of Deeds, a public servant in the performance of her duty, submitted or invited relianceon a writing, namely Deed of Release number 2009010728, which Defendant knew to be lackingin authenticity, and which stated a fact material to the purposes for which the writing wasoffered.


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The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant inviolation of section 570.090 RSMo, committed the class C felony of forgery, punishable uponconviction under sections 558.011 and 560.011, RSMo, in that on or about May 11, 2009, in theCounty of Boone, State of Missouri, Defendant, acting knowingly in concert with DOCX LLCand its employees, with the purpose to defraud, used as genuine or transferred with theknowledge or belief that it would be used as genuine, a writing, namely Deed of Release number2009012041, knowing that it had been made or authenticated so that it purported to have beenmade by another, or that it had been made so that it purported to have been made by authority ofone who did not give such authority.



violation of section 575.060 RSMo, committed the class B misdemeanor of making a falsedeclaration, punishable upon conviction under sections 558.011 and 560.016, RSMo, in that onor about May 11, 2009, in the County of Boone, State of Missouri, Defendant acting knowinglyin concert with DOCX LLC and its employees, with the purpose to mislead the Boone CountyRecorder of Deeds, a public servant in the performance of her duty, submitted or invited relianceon a writing, namely Deed of Release number 2009012041, which Defendant knew to be lacking

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The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant inviolation of section 570.090 RSMo, committed the class C felony of forgery, punishable uponconviction under sections 558.011 and 560.011, RSMo, in that on or about May 19, 2009, in theCounty of Boone, State of Missouri, Defendant, acting knowingly in concert with DOCX LLCand its employees, with the purpose to defraud, used as genuine or transferred with theknowledge or belief that it would be used as genuine, a writing, namely Deed of Release number2009013007, knowing that it had been made or authenticated so that it purported to have beenmade by another, or that it had been made so that it purported to have been made by authority ofone who did not give such authority.



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or about May 19, 2009, in the County of Boone, State of Missouri, Defendant acting knowinglyin concert with DOCX LLC and its employees, with the purpose to mislead the Boone CountyRecorder of Deeds, a public servant in the performance of her duty, submitted or invited relianceon a writing, namely Deed of Release number 2009013007, which Defendant knew to be lackingin authenticity, and which stated a fact material to the purposes for which the writing wasoffered.




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The Grand-Jurors of the County of Boone, State of Missouri, charge that Defendant inviolation of section 575.060 RSMo, committed the class B misdemeanor of making a falsedeclaration, punishable upon conviction under sections 558.011 and 560.016, RSMo, in that onor about June 23, 2009, in the County of Boone, State of Missouri, Defendant acting knowinglyin concert with DOCX LLC and its employees, with the purpose to mislead the Boone CountyRecorder of Deeds, a public servant in the performance of her duty, submitted or invited relianceon a writing, namely Deed of Release number 2009017022, which Defendant knew to be lackingin authenticity, and which stated a fact material to the purposes for which the writing wasoffered.




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knowledge or belief that it would be used as genuine, a writing, namely Deed of Release number2009017028, knowing that it had been made or authenticated so that it purported to have beenmade by another, or that it had been made so that it purported to have been made by authority ofone who did not .give such authority.


The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant inviolation of section 575.060 RSMo, committed the class B misdemeanor of making a falsedeclaration, punishable upon conviction under sections 558.011 and 560.016, RSMo, in that onor about June 23, 2009, in the County of Boone, State of Missouri, Defendant acting knowinglyin concert with DOCX LLC and its employees, with the purpose to mislead the Boone CountyRecorder of Deeds, a public servant in the performance of her duty, submitted or invited relianceon a writing, namely Deed of Release number 2009017028, which Defendant knew to be lackingin authenticity, and which stated a fact material to the purposes for which the writing wasoffered.


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or about June 26, 2009, in the County of Boone, State of Missouri, Defendant acting knowinglyin concert with DOCX LLC and its employees, with the purpose to mislead the Boone CountyRecorder of Deeds, a public servant in the performance of her duty, submitted or invited relianceon a writing, namely Deed of Release number 200901743 8, which Defendant knew to be lacking""in authenticity, and which stated a fact material to the purposes for which the writing wasoffered.




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The Grand Jurors of the County of Boone, State of Missouri, charge that Defendanhnviolation of section 575.060 RSMo, committed the class B misdemeanor of making a falsedeclaration, punishable upon conviction under sections 558.011 and 560.016, RSMo, in that onor about June 26, 2009, in the County of Boone, State of Missouri, Defendant acting knowinglyin concert with DOCX LLC and its employees, with the purpose to mislead the Boone CountyRecorder of Deeds, a public servant in the performance of her duty, submitted or invited relianceon a writing, namely Deed of Release number 2009017439, which Defendant knew to be lackingin authenticity, and which stated a fact material to the purposes for which the writing wasoffered.




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The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant inviolation of section 575.060 RSMo, committed the class B misdemeanor of making a falsedeclaration, punishable upon conviction under sections 558.011 and 560.016, RSMo, in that onor about June 26, 2009, in the County of Boone, State of Missouri, Defendant acting knowinglyin concert with DOCX LLC and its employees, with the purpose to mislead the Boone CountyRecorder of Deeds, a public servant in the performance ofher duty, submitted or invited relianceon a writing, namely Deed of Release number 2009017440, which Defendant knew to be lackingin authenticity, and which stated a fact material to the purposes for which the writing wasoffered.

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

of Release 2009017440 was found not to have signed Deed of Release 2009017440 before thenotary public identified in Deed of Release 2009017440.

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The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant inviolation of section 570.090 RSMo, committed the class C felony of forgery, punishable uponconviction under sections 558.011 and 560.011, RSMo, in that on or about June 30, 2009, in theCounty of Boone, State of Missouri, Defendant, acting knowingly in concert with DOCX LLCand its employees, with the purpose to defraud, used as genuine or transferred with theknowledge or belief that it would be used as genuine, a writing, namely Deed of Release number200901 7814, knowing that it had been made or authenticated so that it purported to have beenmade by another, or that it had been made so that it purported to have been made by authority ofone who did not give such authority.




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COUNT SOFalse Declaration- Class B misdemeanorMo. Charge Code: 2910199.0NCIC Code: 5099


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or about July 20, 2009, in the County of Boone, State of Missouri, Defendant acting knowinglyin concert with DOCX LLC and its employees, with the purpose to mislead the Boone CountyRecorder of Deeds, a public servant in the performance of her duty, submitted or invited relianceon a writing, namely Deed of Release number 2009019809, which Defendant knew to be lackingin authenticity, and which stated a fact material to the purposes for which the writing wasoffered.

The conduct alleged herein was discovered in 2011, when the purported signer of Deedof Release 2009019809 was found not to have signed Deed of Release 2009019809 before thenotary public identified in Deed of Release 20090 19809.


The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant inviolation of section 570.090 RSMo, committed the class C felony of forgery, punishable uponconviction under sections 558.011 and 560.011, RSMo, in that on or about July 20, 2009, in theCounty of Boone, State of Missouri, Defendant, acting knowingly in concert with DOCX LLCand its employees, with the purpose to defraud, used as genuine or transferred with theknowledge or beliefth'!-t it would be used as genuine, a writing, namely Deed of Release number2009019810, knowing that it had been made or authenticated so that it purported to have beenmade by another, or that it had been made so that it purported to have been made by authority ofone who did not give such authority.

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The Grand Jurors of the County of Boone, State of Missouri, charge that Defendant inviolation of section 570.090 RSMo, committed the class C felony of forgery, punishable uponconviction under sections 558.011 and 560.011, RSMo, in that on or about July 20, 2009, in theCounty of Boone, State of Missouri, Defendant, acting knowingly in concert with DOCX LLCand its employees, with the purpose to defraud, used as genuine or transferred with the

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The conduct alleged herein was discovered in 2011, when the purported signer of Deedof Release 2009019812 was found-not to have signed Deed of Release 2009019812 before thenotary public identified in Deed ofRelease 2009019812.





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or about July 20, 2009, in the County of Boone, State of Missouri, Defendant acting knowinglyin concert with DOCX LLC and its employees, with the purpose to mislead the Boone CountyRecorder of Deeds, a public servant in the performance of her duty, submitted or invited relianceon a writing, namely Deed ofRelease number 2009019813, which Defendant knew to be lackingin authenticity, and which stated a fact material to the purposes for which the writing wasoffered.




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The Grand Jurors ~ G f the County of Boone, State of Missouri, charge that Defendant inviolation of section 575.060 RSMo, committed the class B misdemeanor of making a falsedeclaration, punishable upon conviction under sections 558.011 and 560.016, RSMo, in that onor about July 20, 2009, in the County of Boone, State ofMissouri, Defendant acting knowinglyin concert with DOCX LLC and its employees, with the purpose to mislead the Boone CountyRecorder of Deeds, a public servant in the performance ofher duty, submitted or invited relianceon a writing, namely Deed of Release number 2009019814, which Defendant knew to be lackingin authenticity, and which stated a fact material to the purposes

Documents

CEO INDICTED -LORRAINE BROWN OF DOCX LPS -FORGERY, FALSE DECLARATIONS