Paul Andrew Mitchell, Sui Juris
Citizen of Arizona state
c/o general delivery at:
2509 North Campbell Avenue
Tucson [zip code exempt]
ARIZONA STATE
In Propria Persona
All Rights Reserved
without prejudice
DISTRICT COURT OF THE UNITED STATES
JUDICIAL DISTRICT OF ARIZONA
State of Arizona, ) Docket No. ___________________
) TCC docket number #97284647
Plaintiff, ) FOURTH VERIFIED CRIMINAL
v. ) CROSS-COMPLAINT:
)
Paul Andrew Mitchell, ) First Amendment,
) Petition Clause;
Defendant. ) Fifth Amendment,
________________________________) Due Process Clause;
) Sixth Amendment,
Paul Andrew Mitchell, ) Assistance of Counsel;
) Arizona Revised Statutes infra;
Cross-Plaintiff, ) Universal Declaration of
) Human Rights;
v. ) International Covenant on
) Civil and Political Rights,
State of Arizona, ) enacted with explicit
County of Pima, ) Reservations by the
City of Tucson, ) United States Congress;
Larry Bahill, ) Rule 201(d),
Laura Brynwood, ) Federal Rules of Evidence;
Timothy J. Cranshaw, ) 28 U.S.C. 1746(1);
Carl R. Davison III, ) Privileges and Immunities
Beverly A. Ginn, ) Clause; Supremacy Clause;
Gerard M. Guerin, ) Guarantee Clause; Thirteenth
James B. Martin, ) Amendment (1819)
Officer Newman [sic], )
Michael Pollard, ) JURY TRIAL DEMANDED
F. Ann Rodriguez, )
Linda Scharbach, )
Douglas F. Smith, )
George Stoner, )
Fife Symington III, )
Grant Woods, )
Eugene Hays (formerly Doe #1), )
John Doe #2, )
John Doe #3, ) [Please continue next page.]
Fourth Verified Criminal Cross-Complaint:
Page 1 of 26
Christopher H. Bayley (Doe #4), )
Margaret Elizabeth Broderick )
(Doe #5), )
Eugene A. Burns (Doe #6), )
Linda H. Burns (Doe #7), )
Evangelina Cardenas (Doe #8), )
Lawrence E. Condit (Doe #9), )
Herbert Crawford (Doe #10), )
Louise Crawford (Doe #11), )
Keven Entzel (Doe #12), )
Tim Hay (Doe #13), )
Adolf Karl Hoch (Doe #14), )
James Hoey (Doe #15), )
Laura M. Hoey (Doe #16), )
Procter Hug (Doe #17), )
Pamela L. Johnson (Doe #18), )
Todd V. Jones (Doe #19), )
Jim Kolbe (Doe #20), )
William D. Keller (Doe #21), )
Jon Kyl (Doe #22), )
Floyd Raymond Looker (Doe #23), )
Nora Manella (Doe #24), )
John McCain (Doe #25), )
Janet Napolitano (Doe #26), )
Neil T. Nordbrock (Doe #27), )
Rupert Randall Parsons )
(Doe #28), )
Irvin Heil Paugh (Doe #29), )
John M. Roll (Doe #30), )
Richard Rineer (Doe #31), )
LeRoy Michael Schweitzer )
(Doe #32), )
Susan Shew (Doe #33), )
Rudy Stanko (Doe #34), )
Dickran M. Tevrizian (Doe #35), )
William H. Tinney (Doe #36), )
Cyndi Valdez (Doe #37), )
Bernardo P. Velasco (Doe #38), )
David Wallen (Doe #39), )
Sheila T. Wallen (Doe #40), )
Richard H. Weare (Doe #41), )
Walter U. Weber (Doe #42), )
and Does 43 thru 100, )
)
Cross-Defendants. )
________________________________)
[Please continue next page et seq.]
Fourth Verified Criminal Cross-Complaint:
Page 2 of 26
COMES NOW Paul Andrew Mitchell, Sui Juris, Citizen of Arizona
state, expressly not a citizen of the United States ("federal
citizen"), Counselor at Law, Federal Witness, Private Attorney
General, Candidate for the U.S. House of Representatives,
Defendant and Cross-Plaintiff in the instant case (hereinafter
"Defendant"), to provide formal Notice to all interested
party(s), and to demand mandatory judicial notice by this
honorable Court, pursuant to Rule 201(d) of the Federal Rules of
Evidence, of this, Defendant's FOURTH VERIFIED CRIMINAL CROSS-
COMPLAINT, charging the following named individuals, both jointly
and severally, with the corresponding criminal violations
enumerated infra.
Defendant hereby formally charges:
Mr. Christopher H. Bayley with:
(1) making a false or fraudulent representation concerning a
proceeding under title 11, after the filing of the petition,
and after having devised, or intended to devise, a scheme
and/or artifice to defraud, and for the purpose of executing
or concealing such a scheme and/or artifice, in violation of
18 U.S.C. 157 (one (1) count);
(2) knowingly and fraudulently concealing and making false
entries in recorded information, including books, documents,
records, and papers, relating to the property or financial
affairs of the Debtor, in violation of 18 U.S.C. 152 (one
(1) count).
Mrs. Margaret Elizabeth Broderick with:
(1) deprivation of Defendant's fundamental Rights as guaranteed
by the Constitutions for the United States of America as
lawfully amended, and for Arizona state, in violation of 18
U.S.C. 242 (one count);
(2) conspiracy to deprive Defendant's fundamental Rights as
guaranteed by the Constitutions for the United States of
America as lawfully amended, and for Arizona state, in
violation of 18 U.S.C. 241 (one count);
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Fourth Verified Criminal Cross-Complaint:
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(3) racketeering to convert real property across state lines, in
violation of the Racketeering Influenced and Corrupt
Organizations Act ("RICO"), 18 U.S.C. 1962 (one (1) count);
(4) aiding and abetting grand theft of Defendant's professional
services, in violation of the pertinent California and
Arizona state criminal statutes (one (1) count).
Mr. Eugene A. Burns with:
(1) making a false or fraudulent representation concerning a
proceeding under title 11, after the filing of the petition,
and after having devised, or intended to devise, a scheme
and/or artifice to defraud, and for the purpose of executing
or concealing such a scheme and/or artifice, in violation of
18 U.S.C. 157 (one (1) count);
(2) knowingly and fraudulently concealing and making false
entries in recorded information, including books, documents,
records, and papers, relating to the property or financial
affairs of the Debtor, in violation of 18 U.S.C. 152 (one
(1) count);
(3) mail fraud, by creating and/or maintaining a fictitious
trustee name for use by the New Life Health Center Company
and by using same on bank checks and on PS Forms 3811
transmitted via United States mail, in violation of 18
U.S.C. 1341 (one (1) or more counts);
(4) bank fraud, by creating and/or maintaining a fictitious
trustee name and by using same on bank checks transmitted
via United States mail, in violation of 18 U.S.C. 1005 and
1344 (one (1) count each);
(5) perjury before the United States District Court, District of
Arizona, in violation of 18 U.S.C. 1623 (two (2) counts);
(6) contempt of the United States District Court, District of
Arizona, in violation of 18 U.S.C. 402 (one (1) count);
(7) tampering with a federal witness, victim, or an informant,
in violation of 18 U.S.C. 1512 (one (1) or more counts);
(8) retaliating against federal witness, victim, or an
informant, in violation of 18 U.S.C. 1513 (one (1) or more
counts);
(9) deprivation of Defendant's fundamental Rights as guaranteed
by the Constitutions for the United States of America as
lawfully amended, and for Arizona state, in violation of 18
U.S.C. 242 (one (1) count);
(10) conspiracy to deprive Defendant's fundamental Rights as
guaranteed by the Constitutions for the United States of
America as lawfully amended, and for Arizona state, in
violation of 18 U.S.C. 241 (one (1) count); [continued ...]
Fourth Verified Criminal Cross-Complaint:
Page 4 of 26
(11) defamation against Defendant with intent to injure, fraud
upon Defendant for false non-disclosure agreement, and fraud
upon Defendant for false appointment to the office of Vice
President for Legal Affairs of the New Life Health Center
Company, in violation of the pertinent Arizona Revised
Statutes (one (1) count each).
Mrs. Linda H. Burns with:
(1) making a false or fraudulent representation concerning a
proceeding under title 11, after the filing of the petition,
and after having devised, or intended to devise, a scheme
and/or artifice to defraud, and for the purpose of executing
or concealing such a scheme and/or artifice, in violation of
18 U.S.C. 157 (one (1) count);
(2) knowingly and fraudulently concealing and making false
entries in recorded information, including books, documents,
records, and papers, relating to the property or financial
affairs of the Debtor, in violation of 18 U.S.C. 152 (one
(1) count);
(3) deprivation of Defendant's fundamental Rights as guaranteed
by the Constitutions for the United States of America as
lawfully amended, and for Arizona state, in violation of 18
U.S.C. 242 (one (1) count);
(4) conspiracy to deprive Defendant's fundamental Rights as
guaranteed by the Constitutions for the United States of
America as lawfully amended, and for Arizona state, in
violation of 18 U.S.C. 241 (one (1) count);
(5) perjury before the United States District Court, District of
Arizona, on a false Proof of Service form, in violation of
18 U.S.C. 1623 (one (1) count);
(6) being an accessory after the fact to contempt of the United
States District Court, District of Arizona, in violation of
18 U.S.C. 3 and 402 (one (1) count each);
(7) being an accessory after the fact to mail fraud, by creating
and/or maintaining a fictitious trustee name for use by the
New Life Health Center Company and by using same on bank
checks transmitted via United States mail, in violation of
18 U.S.C. 3 and 1341 (one (1) count each);
(8) being an accessory after the fact to bank fraud, by creating
and/or maintaining a fictitious trustee name and by using
same on bank checks transmitted via United States mail, in
violation of 18 U.S.C. 3, 1005 and 1344 (one (1) count
each);
(9) retaliating against federal witness, victim, or an
informant, in violation of 18 U.S.C. 1513 (one (1) count);
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Fourth Verified Criminal Cross-Complaint:
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(10) aiding and abetting fraud upon Defendant for creating and/or
maintaining a fictitious trustee name, aiding and abetting
fraud for creating and/or maintaining a false non-disclosure
agreement, aiding and abetting fraud for creating and/or
maintaining a false appointment to the office of Vice
President for Legal Affairs of the New Life Health Center
Company, and aiding and abetting defamation against
Defendant with intent to injure, all in violation of the
pertinent Arizona Revised Statutes (one (1) count each).
Ms. Evangelina Cardenas with:
(1) aiding and abetting the obstruction of correspondence
transmitted via first class, certified, and registered
United States mail, under color of law, in violation of 18
U.S.C. 2 and 1702 (twenty-five (25) counts);
(2) aiding and abetting the act of tampering with a federal
grand jury, in violation of 18 U.S.C. 2 and 1512 (twenty-
five (25) counts);
(3) aiding and abetting obstruction of criminal investigations,
in violation of 18 U.S.C. 2 and 1510 (twenty-five (25)
counts);
(4) deprivation of fundamental Rights under color of law,
specifically the Right to Petition a lawfully convened
federal grand jury for a formal investigation, in violation
of 18 U.S.C. 242 (twenty-five (25) counts);
(5) conspiracy to commit all of the above, in violation of 18
U.S.C. 241 and 371 (twenty-five (25) counts);
(6) impersonating an officer of the United States, in violation
of 5 U.S.C. 3331 and 18 U.S.C. 912 (one (1) count each).
Mr. Lawrence E. Condit with:
(1) making a false entry in a book, report, or statement of the
Bank of America, Downtown Branch, Tucson, Arizona state,
with intent to injure and/or defraud Defendant, in violation
of 18 U.S.C. 1005 and 1344 (one (1) count each);
(2) placing in a Post Office a fraudulent bank check to be
delivered to Defendant by the United States Postal Service,
for the sole purpose of executing a scheme and/or artifice
to defraud Defendant, in violation of 18 U.S.C. 1341 (one
(1) count);
(3) being an accessory after the fact to tampering with a
federal witness, victim, or an informant, in violation of 18
U.S.C. 3 and 1512 (one (1) count each);
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Fourth Verified Criminal Cross-Complaint:
Page 6 of 26
(4) being an accessory after the fact to retaliating against
federal witness, victim, or an informant, in violation of 18
U.S.C. 3 and 1513 (one (1) count each);
(5) deprivation of Defendant's fundamental Right to due process
of law as guaranteed by the Constitutions for the United
States of America as lawfully amended, and for Arizona
state, in violation of 18 U.S.C. 242 (one (1) count);
(6) conspiracy to deprive Defendant's fundamental Rights as
guaranteed by the Constitutions for the United States of
America as lawfully amended, and for Arizona state, in
violation of 18 U.S.C. 241 (one (1) count);
(7) actual fraud upon the Defendant and upon the Pima County
Consolidated Justice Court, pursuant to a scheme and/or
artifice to defraud, knowingly to obtain a monetary benefit
by means of false and fraudulent pretenses, representations,
promises, and/or material omissions, in violation of Arizona
Revised Statute ("ARS") 13-2310 (two (2) counts);
(8) aiding and abetting embezzlement of funds, aiding and
abetting conversion of private property, aiding and abetting
defamation against Defendant with intent to injure, all in
violation of the pertinent Arizona Revised Statutes (one (1)
count each).
Mr. Herbert Crawford with:
(1) tampering with a federal witness, victim, or an informant,
in violation of 18 U.S.C. 1512 (one (1) count);
(2) retaliating against federal witness, victim, or an
informant, in violation of 18 U.S.C. 1513 (one (1) count);
(3) deprivation of Defendant's fundamental Right to due process
of law as guaranteed by the Constitutions for the United
States of America as lawfully amended, and for Arizona
state, in violation of 18 U.S.C. 242 (one (1) or more
counts);
(4) conspiracy to deprive Defendant's fundamental Rights as
guaranteed by the Constitutions for the United States of
America as lawfully amended, and for Arizona state, in
violation of 18 U.S.C. 241 (one (1) or more counts);
(5) obstruction of criminal investigations, in violation of 18
U.S.C. 2 and 1510 (one (1) count each);
(6) racketeering to convert real property across state lines, in
violation of the Racketeering Influenced and Corrupt
Organizations Act ("RICO"), 18 U.S.C. 1962 (one (1) count);
(7) grand theft of Defendant's private property, in violation of
the pertinent Arizona Revised Statutes.
Fourth Verified Criminal Cross-Complaint:
Page 7 of 26
Mrs. Louise Crawford with:
(1) racketeering to convert real property across state lines, in
violation of the Racketeering Influenced and Corrupt
Organizations Act ("RICO"), 18 U.S.C. 1962 (one (1) count);
(2) aiding, abetting, and facilitation of grand theft, in
violation of the pertinent Arizona Revised Statutes.
Keven Entzel with:
(1) obstructing correspondence transmitted via first class
United States Mail, in violation of 18 U.S.C. 1702 (sixteen
(16) counts);
(2) tampering with United States mail not directed to him by
opening same without authority, in violation of 18 U.S.C.
1703 (twelve (12) counts);
(3) grand theft of professional services, in violation of the
pertinent Arizona and Montana state criminal statutes (one
(1) count).
Mr. Tim Hay with:
(1) being an accessory after the fact to perjury before the
United States District Court, District of Arizona, in
violation of 18 U.S.C. 3 and 1623 (one (1) count each);
(2) being an accessory after the fact to contempt of the United
States District Court, District of Arizona, in violation of
18 U.S.C. 3 and 402 (one (1) count each);
(3) being an accessory after the fact to deprivation of
Defendant's fundamental Rights as guaranteed by the
Constitutions for the United States of America as lawfully
amended, and for Arizona state, in violation of 18 U.S.C. 3
and 242 (one (1) count each);
(4) being an accessory after the fact to conspiracy to deprive
Defendant's fundamental Rights as guaranteed by the
Constitutions for the United States of America as lawfully
amended, and for Arizona state, in violation of 18 U.S.C. 3
and 241 (one (1) count each);
Mr. Adolf Karl Hoch with:
(1) deprivation of Defendant's fundamental Rights as guaranteed
by the Constitutions for the United States of America as
lawfully amended, and for Arizona and California states, in
violation of 18 U.S.C. 242 (one count);
(2) conspiracy to deprive Defendant's fundamental Rights as
guaranteed by the Constitutions for the United States of
America as lawfully amended, and for Arizona and California
states, in violation of 18 U.S.C. 241 (one count);
[Please continue next page et seq.]
Fourth Verified Criminal Cross-Complaint:
Page 8 of 26
(3) racketeering to convert real property across state lines, in
violation of the Racketeering Influenced and Corrupt
Organizations Act ("RICO"), 18 U.S.C. 1962 (one (1) count);
(4) aiding and abetting grand theft of Defendant's professional
services, in violation of the pertinent Arizona and
California state criminal statutes (one (1) count).
Mr. James Hoey with:
(1) deprivation of Defendant's fundamental Rights as guaranteed
by the Constitutions for the United States of America as
lawfully amended, and for Arizona and California states, in
violation of 18 U.S.C. 242 (one count);
(2) conspiracy to deprive Defendant's fundamental Rights as
guaranteed by the Constitutions for the United States of
America as lawfully amended, and for Arizona and California
states, in violation of 18 U.S.C. 241 (one count);
(3) racketeering to convert real property across state lines, in
violation of the Racketeering Influenced and Corrupt
Organizations Act ("RICO"), 18 U.S.C. 1962 (one (1) count);
(4) aiding and abetting grand theft of Defendant's professional
services, in violation of the pertinent Arizona and
California state criminal statutes (one (1) count).
Mrs. Laura M. Hoey with:
(1) deprivation of Defendant's fundamental Rights as guaranteed
by the Constitutions for the United States of America as
lawfully amended, and for Arizona and California states, in
violation of 18 U.S.C. 242 (one count);
(2) conspiracy to deprive Defendant's fundamental Rights as
guaranteed by the Constitutions for the United States of
America as lawfully amended, and for Arizona and California
states, in violation of 18 U.S.C. 241 (one count);
(3) racketeering to convert real property across state lines, in
violation of the Racketeering Influenced and Corrupt
Organizations Act ("RICO"), 18 U.S.C. 1962 (one (1) count);
(4) aiding and abetting grand theft of Defendant's professional
services, in violation of the pertinent Arizona and
California state criminal statutes (one (1) count).
Mr. Procter Hug with:
(1) corruptly endeavoring to impede and/or obstruct the due
administration of justice by a grand jury, and by officers
of a court of the United States, in the matter of the grand
jury proceedings convened under auspices of the United
States District Court ("USDC") Tucson, In Re Grand Jury Subpoena Served on New Life Health Center Company, docket
number #GJ-95-1-6, and in the matter of the Complaint of
Fourth Verified Criminal Cross-Complaint:
Page 9 of 26
Judicial Misconduct brought against John M. Roll In Re
Charge of Judicial Misconduct, 9th Circuit docket number
#96-80380, which arose therefrom, in violation of 18 U.S.C.
1503 (two counts);
(2) corruptly endeavoring to impede and/or obstruct the due
administration of justice by officers of a court of the
United States in the matter of the Complaint of Judicial
Misconduct brought against William D. Browning In Re Charge
of Judicial Misconduct, 9th Circuit docket number #96-80337,
which arose from the criminal proceedings convened under
auspices of the USDC Tucson in U.S.A. v. Wallen, USDC Tucson
docket number #95-484-WDB, in violation of 18 U.S.C. 1503
(one count);
(3) being an accessory after the fact to obstruction of
registered, certified, and first class United States Mail,
obstruction of justice, jury tampering, perjury, bribery,
and conspiracy to commit all of the above, after knowing
that offenses against the United States had been committed,
by relieving and/or assisting the several offenders in order
to hinder their apprehension, trial, or punishment, in
violation of 18 U.S.C. 3 (one hundred counts as follows:
twenty-five (25) counts each for hindering the apprehension,
trial, and/or punishment of the following individuals:
(a) John M. Roll, (b) Janet Napolitano, (c) Robert L.
Miskell, and (d) Evangelina Cardenas, in the matter of the
federal grand jury proceedings convened under auspices of
the USDC Tucson In Re Grand Jury Subpoena Served on New Life
Health Center Company, docket number #GJ-95-1-6);
(4) impersonating an officer of the United States, in violation
of 28 U.S.C. 453 and 18 U.S.C. 912 (one (1) count each).
Ms. Pamela L. Johnson with:
(1) deprivation of Defendant's fundamental Rights as guaranteed
by the Constitutions for the United States of America as
lawfully amended, and for Arizona and California states, in
violation of 18 U.S.C. 242 (one count);
(2) conspiracy to deprive Defendant's fundamental Rights as
guaranteed by the Constitutions for the United States of
America as lawfully amended, and for Arizona and California
states, in violation of 18 U.S.C. 241 (one count);
(3) racketeering to convert real property across state lines, in
violation of the Racketeering Influenced and Corrupt
Organizations Act ("RICO"), 18 U.S.C. 1962 (one (1) count);
(4) aiding and abetting grand theft of Defendant's professional
services, in violation of the pertinent Arizona and
California state criminal statutes (one (1) count);
(5) impersonating an officer of the United States, in violation
of 5 U.S.C. 3331 and 18 U.S.C. 912 (one (1) count each).
Fourth Verified Criminal Cross-Complaint:
Page 10 of 26
Mr. Todd V. Jones with:
(1) making a false or fraudulent representation concerning a
proceeding under title 11, after the filing of the petition,
and after having devised, or intended to devise, a scheme
and/or artifice to defraud, and for the purpose of executing
or concealing such a scheme and/or artifice, in violation of
18 U.S.C. 157 (one (1) count);
(2) knowingly and fraudulently concealing and making false
entries in recorded information, including books, documents,
records, and papers, relating to the property or financial
affairs of the Debtor, in violation of 18 U.S.C. 152 (one
(1) count).
Mr. Jim Kolbe with:
(1) deprivation of Defendant's fundamental Rights as guaranteed
by the Constitutions for the United States of America as
lawfully amended, and for Arizona state, in violation of 18
U.S.C. 242 (one (1) count);
(2) conspiracy to deprive Defendant's fundamental Rights as
guaranteed by the Constitutions for the United States of
America as lawfully amended, and for Arizona state, in
violation of 18 U.S.C. 241 (one (1) count);
(3) being an accessory after the fact to the act of corruptly
endeavoring to impede and/or obstruct the due administration
of justice by a grand jury, and by officers of a court of
the United States, in the matter of the grand jury
proceedings convened under auspices of the United States
District Court ("USDC") Tucson, In Re Grand Jury Subpoena Served on New Life Health Center Company, number #GJ-95-1-6,
and in the matter of the Complaint of Judicial Misconduct
brought against John M. Roll In Re Charge of Judicial
Misconduct, 9th Circuit docket number #96-80380, which arose
therefrom, in violation of 18 U.S.C. 3 and 1503 (two (2)
counts).
Mr. William D. Keller with:
(1) deprivation of Defendant's fundamental Rights as guaranteed
by the Constitutions for the United States of America as
lawfully amended, and for Arizona and California states, in
violation of 18 U.S.C. 242 (one count);
(2) conspiracy to deprive Defendant's fundamental Rights as
guaranteed by the Constitutions for the United States of
America as lawfully amended, and for Arizona and California
states, in violation of 18 U.S.C. 241 (one count);
(3) racketeering to convert real property across state lines, in
violation of the Racketeering Influenced and Corrupt
Organizations Act ("RICO"), 18 U.S.C. 1962 (one (1) count);
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Fourth Verified Criminal Cross-Complaint:
Page 11 of 26
(4) aiding and abetting grand theft of Defendant's professional
services, in violation of the pertinent Arizona and
California state criminal statutes (one (1) count);
(5) impersonating an officer of the United States, in violation
of 28 U.S.C. 453 and 18 U.S.C. 912 (one (1) count each).
Mr. Jon Kyl with:
(1) deprivation of Defendant's fundamental Rights as guaranteed
by the Constitutions for the United States of America as
lawfully amended, and for Arizona state, in violation of 18
U.S.C. 242 (one (1) count);
(2) conspiracy to deprive Defendant's fundamental Rights as
guaranteed by the Constitutions for the United States of
America as lawfully amended, and for Arizona state, in
violation of 18 U.S.C. 241 (one (1) count);
(3) being an accessory after the fact to the act of corruptly
endeavoring to impede and/or obstruct the due administration
of justice by a grand jury, and by officers of a court of
the United States, in the matter of the grand jury
proceedings convened under auspices of the United States
District Court ("USDC") Tucson, In Re Grand Jury Subpoena Served on New Life Health Center Company, number #GJ-95-1-6,
and in the matter of the Complaint of Judicial Misconduct
brought against John M. Roll In Re Charge of Judicial
Misconduct, 9th Circuit docket number #96-80380, which arose
therefrom, in violation of 18 U.S.C. 3 and 1503 (two (2)
counts).
Mr. Floyd Raymond Looker with:
(1) deprivation of Defendant's fundamental Rights as guaranteed
by the Constitutions for the United States of America as
lawfully amended, and for Arizona and West Virginia states,
in violation of 18 U.S.C. 242 (one (1) count);
(2) conspiracy to deprive Defendant's fundamental Rights as
guaranteed by the Constitutions for the United States of
America as lawfully amended, and for Arizona and West
Virginia states, in violation of 18 U.S.C. 241 (one (1)
count);
(3) aiding and abetting grand theft of Defendant's professional
services, in violation of the pertinent Arizona and West
Virginia state criminal statutes (one (1) count).
Ms. Nora Manella with:
(1) deprivation of Defendant's fundamental Rights as guaranteed
by the Constitutions for the United States of America as
lawfully amended, and for Arizona and California states, in
violation of 18 U.S.C. 242 (one count);
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Fourth Verified Criminal Cross-Complaint:
Page 12 of 26
(2) conspiracy to deprive Defendant's fundamental Rights as
guaranteed by the Constitutions for the United States of
America as lawfully amended, and for Arizona and California
states, in violation of 18 U.S.C. 241 (one count);
(3) racketeering to convert real property across state lines, in
violation of the Racketeering Influenced and Corrupt
Organizations Act ("RICO"), 18 U.S.C. 1962 (one (1) count);
(4) aiding and abetting grand theft of Defendant's professional
services, in violation of the pertinent Arizona and
California state criminal statutes (one (1) count);
(5) impersonating an officer of the United States, in violation
of 5 U.S.C. 3331 and 18 U.S.C. 912 (one (1) count each).
Mr. John McCain with:
(1) deprivation of Defendant's fundamental Rights as guaranteed
by the Constitutions for the United States of America as
lawfully amended, and for Arizona state, in violation of 18
U.S.C. 242 (one (1) count);
(2) conspiracy to deprive Defendant's fundamental Rights as
guaranteed by the Constitutions for the United States of
America as lawfully amended, and for Arizona state, in
violation of 18 U.S.C. 241 (one (1) count);
(3) being an accessory after the fact to the act of corruptly
endeavoring to impede and/or obstruct the due administration
of justice by a grand jury, and by officers of a court of
the United States, in the matter of the grand jury
proceedings convened under auspices of the United States
District Court ("USDC") Tucson, In Re Grand Jury Subpoena Served on New Life Health Center Company, number #GJ-95-1-6,
and in the matter of the Complaint of Judicial Misconduct
brought against John M. Roll In Re Charge of Judicial
Misconduct, 9th Circuit docket number #96-80380, which arose
therefrom, in violation of 18 U.S.C. 3 and 1503 (two (2)
counts).
Ms. Janet Napolitano with:
(1) aiding and abetting the obstruction of correspondence
transmitted via first class, certified, and registered
United States mail, under color of law, in violation of 18
U.S.C. 2 and 1702 (twenty-five (25) counts);
(2) aiding and abetting the act of tampering with a federal
grand jury, in violation of 18 U.S.C. 2 and 1512 (twenty-
five (25) counts);
(3) aiding and abetting obstruction of criminal investigations,
in violation of 18 U.S.C. 2 and 1510 (twenty-five (25)
counts);
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Fourth Verified Criminal Cross-Complaint:
Page 13 of 26
(4) deprivation of fundamental Rights under color of law,
specifically the Right to Petition a lawfully convened
federal grand jury for a formal investigation, in violation
of 18 U.S.C. 242 (twenty-five (25) counts);
(5) conspiracy to commit all of the above, in violation of 18
U.S.C. 241 and 371 (twenty-five (25) counts);
(6) impersonating an officer of the United States, in violation