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)