DISTRICT COURT, JEFFERSON COUNTY, 

STATE OF COLORADO 

100 Jefferson County Parkway 

Golden, Colorado 80401 

Phone: (303) 271-6145 

Fax: (303) 582-3112 

Ÿ COURT USE ONLY Ÿ

Plaintiff: BANK OF CHOICE, a Colorado corporation, 

v.

Defendants: CROSSROADS COMMERCIAL 

CENTER, LTD., LLLP, a Colorado limited liability 

limited partnership, and RANDOLPH G. CURRIER, 

an individual. 

Attorneys for Defendants: 

ANTON LAW GROUP, LLC 

Damon M. Semmens (Reg. No. 37023) 

225 East Sixteenth Avenue, Suite 690 

Denver, Colorado 80203 

Phone: (720) 536-4600 

Fax: (720) 536-4601 

Email: dms@antonlaw.com 

Case No.: 2010 CV 5138 

Div.: 3 Ctrm: 4F 

MOTION FOR CONSOLIDATION 

 Defendants, Crossroads Commercial Center, Ltd., LLLP, and Mr. Randolph G. Currier, 

by and through their attorney, Damon M. Semmens, Esq., of the Anton Law Group, LLC, 

pursuant to C.R.C.P. 42, respectfully moves for an Order consolidating Civil Action No. 2010 

CV 4988 into the action captioned above. As grounds therefore, Defendants state as following: 

Rule 121 § 15 Certification: The undersigned spoke with Mr. Kraft’s counsel, John 

Lobus, Esq. (counsel in action 2010 CV 4988). Mr. Kraft opposes this consolidation. Conferral 

with Plaintiff’s counsel was unnecessary as Plaintiff has already opposed Defendants’ request to 

amend their counterclaims. 

1. On or about October 20, 2010, Defendant Crossroads Commercial Center, Ltd., 

LLLP (acting as plaintiff) commenced Civil Action No. 2010 CV 4988 against Defendant Garold 

B. Kraft (d.b.a. Exotic Motors).

2. On or about October 27, 2010, Plaintiff commenced this action against 

Defendants Crossroads Commercial Center, Ltd., LLLP, and Randolph G. Currier. 

DENIED 

WITH 

COMMENTS 

The moving party is hereby ORDERED 

to provide a copy of this Order to any pro 

se parties who have entered an 

appearance in this action within 10 days 

from the date of this order. 

___________________________ 

Jane Tidball 

Jefferson District Court Judge 

EFILED Document DATE OF ORDER INDICATED ON ATTACHMENT

CO Jefferson County District Court 1st JD 

Filing Date: Apr 14 2011 12:01PM MDT 

Filing ID: 37041591 

Review Clerk: Beth B

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64699 - 2 - 2010 CV 5138 

3. Through discovery, Defendants have come to understand the cases are related.

Specifically, in their Amended Counterclaims, Defendants allege the leases at issue in case 2010 

CV 4988 were a part of a larger scheme orchestrated by Plaintiff to induce Defendants into 

certain loan agreements at issue in this case.

4. Both civil actions therefore involve common issues of fact and law, and there are 

common parties to both actions. Consolidation of these actions would be more efficient and 

economical for both the Court and the parties.

5. Pursuant to C.R.C.P. § 121 1-8, a motion shall be determined by the court in the 

case first filed, unless otherwise ordered by the court.

6. Defendants request a special order merging case 2010 CV 4988 into the case at 

hand. The instant case is by far the most dominant case of the two and has already been 

established in a manner that accounts for the claims in both cases. It would therefore be more 

efficient for case 2010 CV 4988 to be merged into these proceedings than for these proceedings 

to be merged into case 2010 CV 4988, which is a simplified procedure action.

7. Both cases are in the early stages of discovery and the parties to each case are 

intimately familiar to the parties and relevant facts involved in the other case. Therefore, no 

party will be prejudiced by a consolidation of the two matters.

 WHEREFORE, Defendants pray this court issue an order consolidating case 2010 CV 

4988, into this action, 2010 CV 5138, and for such additional relief as the Court deems just and 

proper.

 Respectfully submitted this 24th day of February, 2011. 

Original signature on file in the law 

offices of Anton Law Group, LLC, per 

C.R.C.P. Rule 121 § 1-26(9) 

/s/ Damon M. Semmens, Esq.

Damon M. Semmens (Reg. No. 37023) 

Attorney for Defendants 

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64699 - 3 - 2010 CV 5138 

CERTIFICATE OF SERVICE

 The undersigned hereby certifies that on this 24th day of February, 2011, a true and 

correct copy of the foregoing MOTION FOR CONSOLIDATION as served electronically via 

LexisNexis File & Serve to the following: 

Shannon Lyons, Esq. 

Michael C. Payne, Esq. 

Brent Coan, Esq. 

Otis, Coan & Peters, LLC 

1812 56th Avenue, 2nd Floor 

Greeley, Colorado 80634 

Attorneys for Plaintiff Bank of Choice 

John A. Lobus, Esq. 

The Law Firm of John A. Lobus, P.C. 

710 Kipling Street, #402 

Lakewood, Colorado 80215 

Attorney for Garold Kraft 

Original signature on file at the law offices 

of Anton Law Group, LLC 

Case 1:11-cv-02286-REB-CBS Document 21 Filed 08/31/11 USDC Colorado Page 3 of 4
Denied as MOOT. 

/s/ Judge Jane A Tidball 

Court: CO Jefferson County District Court 1st JD 

Judge: Jane A Tidball 

Alternate Judge: Unassigned 

File & Serve 

Transaction ID: 36138185 

Current Date: Apr 14, 2011 

Case Number: 2010CV5138 

Case Name: BANK OF CHOICE vs. CROSSROADS COMMERCIAL CENTER LTD LLLP et al 

Court Authorizer: Jane A Tidball 

Court Authorizer 

Comments: 

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