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An Eagle Point woman filed a lawsuit amounting to more than $500,000 against a Lake Oswego man who she claims committed elder financial abuse against a Bly man.

Sandra Chambers is the personal representative for Curtis Allen’s estate. Allen died on July 28, 2017, from chronic medical conditions at age 77.

Chambers, represented by Klamath Falls attorney Barbara DiIaconi, alleges that Nicholas Randolph Radke — a licensed financial advisor and securities broker — and transaction management company Escrow Leaders made a series of deceitful financial agreements with Allen.

In the civil complaint filed in Klamath County Circuit Court, Chambers alleges that Radke represented himself as a financial advisor with Idaho-based limited liability company American Independent Securities Group.

Financial abuse claim

Civil court documents say Radke had access to Allen’s bank account. On July 25, July 28 and July 31, 2017, financial deposits in respective amounts of $109,000.01, $175,000.01 and $100,000.02 were made into Allen’s account, documents say.

In 2017, court documents claim four checks payable to Radke were drawn from Allen’s same bank account in amounts of $10,000, $12,500, $250,000 and $5,000.09.

The $250,000 check was dated July 19, but not negotiated until two days after Allen’s death, court documents say. The other checks had been deposited before Allen’s death.

On July 17, court documents say that Radke entered into a promissory note and security agreement (a signed document promising to pay a specific amount of money back to a person at a certain time) for $250,000. The amount was payable to Allen.

Chambers alleges that Radke entered into this security agreement wrongfully as Allen was “a vulnerable person…old, in ill health and unable to take in and make meaningful decisions concerning his finance.”

Fraud claim, relief claims

Chambers alleges that Radke and Escrow Leaders committed fraud against Allen by agreeing to pay Allen back with the security agreement and promissory note.

Radke nor Escrow Leaders has paid any money back to Allen since his death, court documents say.

“Defendants Radke and Escrow Leaders knew the representations were false and/or made such representation without knowledge of their truth or falsity,” documents say.

On top of the $250,000 covered by the promissory note, Chambers alleges that Radke received checks throughout 2017 amounting to $277,500.09 “in exchange for promises made and not kept.”

Chambers also alleges that Radke entered into a contract to borrow $12,500 from Allen on April 14, 2017, which he never repaid.

Chambers argues that Allen’s estate is entitled to the recovery of that money and any profits Radke made from it.

“Formal Demand for payment has been made by the Plaintiff and Defendant Radke refused and continues to refuse to make the requested payment,” court documents say.