public servant in the performance of her duty, submitted or invited reliance on a writing, namely Deed of Release number 2009023094, which Defendant knew to be lacking in authenticity, and which stated a fact material to the purposes for which the writing was offered. The conduct alleged herein was discovered in 2011, when the purported signer of Deed of Release 2009023094 was found not to have signed Deed of Release 2009023094 before the notary public identified in Deed of Release 2009023094. Defendant is liable under section 562.056(1)(2) RSMo because the conduct constituting the offense was engaged in by an agent of the corporation while acting within the scope of the agent’s employment and in behalf of the corporation. 49 Forgery – Class C Felony Mo. Charge Code: 1801089.0 NCIC Code: 2589 The 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 upon conviction under section 560.021, RSMo, in that on or about August 25, 2009, in the County of Boone, State of Missouri, Defendant, acting knowingly in concert with its employees, with the purpose to defraud, used as genuine or transferred with the knowledge or belief that it would be used as genuine, a writing, namely Deed of Release number 2009023095, knowing that it had been made or authenticated so that it purported to have been made by another, or that it had been made so that it purported to have been made by authority of one who did not give such authority. Defendant is liable under section 562.056(1)(3) RSMo because the conduct constituting the offense was engaged in, authorized, solicited, requested, commanded or knowingly tolerated by a
servant in the performance of her duty, submitted or invited reliance on a writing, namely Deed of Release number 2009017440, which Defendant knew to be lacking in authenticity, and which stated a fact material to the purposes for which the writing was offered. 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 the notary public identified in Deed of Release 2009017440. Defendant is liable under section 562.056(1)(2) RSMo because the conduct constituting the offense was engaged in by an agent of the corporation while acting within the scope of the agent’s employment and in behalf of the corporation. COUNT 77 Forgery – Class C Felony Mo. Charge Code: 1801089.0 NCIC Code: 2589 The 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 upon conviction under section 560.021, RSMo, in that on or about June 30, 2009, in the County of Boone, State of Missouri, Defendant, acting knowingly in concert with its employees, with the purpose to defraud, used as genuine or transferred with the knowledge or belief that it would be used as genuine, a writing, namely Deed of Release number 2009017814, knowing that it had been made or authenticated so that it purported to have been made by another, or that it had been made so that it purported to have been made by authority of one who did not give such authority. Defendant is liable under section 562.056(1)(3) RSMo because the conduct constituting the offense was engaged in, authorized, solicited, requested, commanded or knowingly tolerated by a