LEGAL NOTICE

 

RE:  USA v. Hill et al., #2:14-CR-00027-NDF (USDC/DWY)

 

TO:  Hon. Warden et al.

     USMCFP/Springfield

 

Greetings Hon. Warden et al.:

 

In the above entitled case, please be informed that defense Counsels

for two (2) other named Defendants have now identified me

as an "essential witness" for one Defendant, and as "critical to

[the] defense" of another Defendant.

 

At Docket entry #208 supra, I am described as:

 

(1)  "critical to her [Defendant Reeder's] defense in this matter

      and particularly her defense to Count 2"  [Page 1 of 2]

 

At Docket entry #202 supra, I am also described as follows:

 

(2)  "his [Mitchell's] testimony will be 'substantially exculpatory.'

      Mr. Mitchell has unique and direct knowledge of several of the

      issues and many documents in this case."  [Page 2 of 5]

 

(3)  "Mr. Mitchell is an 'essential witness' to Mr. Hill's defense",

      citing 18 USC 3161(h)(3)(A)  (i.e. delay resulting from the absence

      or unavailability of the defendant or an essential witness)

      [Pages 2 of 5 and 3 of 5]

 

(4)  "Mr. Mitchell is certainly capable of remembering events and

      communicating what he observed or performed.  He is certainly

      capable of telling the truth."  [Page 4 of 5]

 

(5)  "Mr. Mitchell is critical to his [Defendant Hill's] defense

      one way or the other."  [Page 4 of 5]

 

(6)  "Resolution of this case 'for all Defendants' does not include

      resolution for Mr. Hill if it means Mr. Mitchell is not able

      to testify on his behalf or appear as a joined defendant."

      [Page 4 of 5]

 

Thank you for your professional consideration.

 

 

Respectfully,

/s/ Paul Andrew Mitchell

Private Attorney General, Civil RICO:  18 USC 1964,

Rotella v. Wood, 528 U.S. 549 (2000)

(objectives of Civil RICO);

Agent of the United States as Qui Tam Relator,

False Claims Act: 31 USC 3729 et seq. (4X)

 

All Rights Reserved (cf. UCC 1-308)