DISTRICT COURT, COUNTY OF JEFFERSON

STATE OF COLORADO
Court Address: 100 Jefferson County Parkway
Golden, CO 80401
Court Telephone: 303-271-6145

Plaintiff: LANCE CASSINO

v.

Defendants: JPMORGAN CHASE BANK, NATIONAL

ASSOCIATION,
CYNTHIA RILEY-GRABER,
JOHN DOES 1-3. COURT USE ONLY

Attorney for Defendant: Case No.: 17CV231

Lance Cassino Pro Se
until attorney retained
POB 1050
Conifer, CO 80433
303-838-0221
lancecassino@msn.com

MOTION TO COMPEL PRODUCTION OF A LIMITED LIEN RELEASE

Comes now Plaintiff with his Motion to Compel Production of a Limited Lien Release

from JPMORGAN CHASE BANK, NATIONAL ASSOCIATION.

The undersigned has attempted to confer with Defendants 4 attorneys: Cynthia Lowery-

Graber, Robert Tuchman, Andrea Hicks and Ronald Tomassi Jr. via phone and email on several

occasions and from initial response this motion is or will be opposed by Defendants.

BACKGROUND

Page 1 of 8
 Regardless of whether Chase or Cassino prevails in this case 17CV231, both Plaintiff

and Defendant Chase had and still have a common problem a 3rd party Cassinos neighbors,

Marcus and Leigh Ann Jordan, whose home encroaches on Cassinos vacant 5.1 acre parcel fully

documented at www.CassinovJordans.weebly.com that Cassino has had listed for sale at

$145,000 with Keller Williams since 2012 see Exhibit 1 Vacant 5.1 acre parcel on the Deed

of Trust.

Cassino took the initiative of solving this problem for Chase and Cassino on March 9,

2016 by filing case number 2016CV030409 - a Complaint to remove Jordans home from

Cassinos vacant 5.1 acre parcel - as it was preventing selling the property listed for sale at

$145,000 with Keller Williams broker Craig Marks - as a marketable property from a title

insurance company view that the encroachment is not resolved.

The encroachment lawsuit 2016CV030409 was settled in September 2016 by Cassino

agreeing to selling .4 acres of the vacant 5.1 acre parcel to the Jordans for $11,600 after a

Minor Adjustment to properly record with Jefferson County Planning & Zoning and the

Jefferson County Clerk & Recorder land records the proper legal descriptions of the .4 acres and

remaining 4.7 acres again which also has a contract on it for $145,000 to close by 7/31/2017 or

refund $5,000 deposit with Keller Williams.

The sale of the .4 acres was also conditioned by the release of Chases alleged

fraudulent lien based on lying to the court in another previous case number 2011CV4858 about

this - Cassinos WaMu loan they never had - and the falsified fraudulent Corporate Assignment

of Deed of Trust that Chase or their law firm attorneys recorded in the land records a felony

and then Chase also served fraud upon the court and trustee.

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 It has taken Cassino tens of thousands of dollars in both attorney fees and other costs plus

16 months to hopefully be able to close on Monday July 10 with a limited lien release based

upon the legal description for the .4 acres see Exhibit 2 Legal Description of .4 acres

Encroachment - to solve Chase and Cassino common problem - the Jordans and the .4 acres to

solve their encroachment problem. That is what this motion is about for Chase to in good faith

- recording in the land records a release of lien or equivalent on just the .4 acre legal

description per Exhibit 2, so the closing can be completed Monday July 10 and then 3rd party

Jordans are one less problem for Chase, Cassino, Judge and jury for case 17CV231. If this

limited lien release is not done, then the Jordans will be added as Plaintiffs to this case, as well

as John and Rebecca McSweeney on their purchase of the remaining 4.7 acres for $145,000 due

to close by 7/31/2017,

That is the essence of this motion can we eliminate with this motion an innocent 3rd

party the Jordans caught between Chase and Cassino in this instant case who otherwise will

have to become an additional Plaintiffs to this case to solve their encroachment problem lawsuit.

Dated this 5th day of July, 2017

By ____________________________________________
Lance Cassino
POB 1050
Conifer, CO 80433

Page 3 of 8
Exhibit 1 Vacant 5.1 acre parcel on the Deed of Trust

Page 4 of 8
Exhibit 2 Legal Description of .4 acres Encroachment

Page 5 of 8
 CERTIFICATE OF SERVICE

I certify that on July 5, 2017 a true and correct copy of the above Motion was served on

each of the following via by both their email and USPS address:

Cynthia Lowery-Graber, 1700 Lincoln St #41000, Bryan Cave LLP, Denver, CO 80203, 303-

866-0331 cynthia.lowery-graber@bryancave.com

Robert Tuchman, 1700 Lincoln St #41000, Bryan Cave LLP, Denver, CO 80203

Andrea M. Hicks 1700 Lincoln St #41000, Bryan Cave LLP, Denver, CO 80203 303-866-0285

fax 415-675-3445 andrea.hicks@bryancave.com

Ronald J. Tomassi Jr. 1700 Lincoln St #41000, Bryan Cave LLP, Denver, CO 80203, 303-866-

0219 fax 786-322-7390 ron.tomassi@bryancave.com

Lance Cassino
POB 1050
Conifer, CO 80433
303-838-0221
lancecassino@msn.com

Page 6 of 8
DISTRICT COURT, COUNTY OF JEFFERSON
STATE OF COLORADO
Court Address: 100 Jefferson County Parkway
Golden, CO 80401
Court Telephone: 303-271-6145

Plaintiff: LANCE CASSINO

v.

Defendants: JPMORGAN CHASE BANK, NATIONAL

ASSOCIATION,
CYNTHIA RILEY-GRABER,
JOHN DOES 1-3. COURT USE ONLY

Attorney for Defendant: Case No.: 17CV231

Lance Cassino Pro Se
until attorney retained
POB 1050
Conifer, CO 80433
303-838-0221
lancecassino@msn.com

MOTION TO COMPEL PRODUCTION OF LIMITED LIEN RELEASE

THIS CAUSE having come before the Court on the Motion of the Plaintiff to Compel

Production by Chase of a Limited Lien Release on .4 acres, and the Court having reviewed the

subject Motion and being otherwise fully advised in the premises, hereby GRANTS the subject

Motion and deems that the proposed Limited Lien Release is to be filed by Chase forthwith or in

the alternative this order can be recorded in the land records by Plaintiff.

DONE AND ORDERED in Jefferson County, Colorado on this _____ day of July, 2017.

__________________________
DISTRICT COURT JUDGE

Page 7 of 8
Copies to:

Cynthia Lowery-Graber, 1700 Lincoln St #41000, Bryan Cave LLP, Denver, CO 80203, 303-

866-0331 cynthia.lowery-graber@bryancave.com

Robert Tuchman, 1700 Lincoln St #41000, Bryan Cave LLP, Denver, CO 80203, 303-866-

0645, robert.tuchman@bryancave.com

Andrea M. Hicks, 1700 Lincoln St #41000, Bryan Cave LLP, Denver, CO 80203 303-866-0285

fax 415-675-3445 andrea.hicks@bryancave.com

Ronald J. Tomassi Jr., 1700 Lincoln St #41000, Bryan Cave LLP, Denver, CO 80203, 303-

866-0219 fax 786-322-7390 ron.tomassi@bryancave.com

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