Paul Andrew Mitchell, Sui Juris
Citizen of Arizona state
c/o General Delivery at:
2509 North Campbell Avenue
Tucson, Arizona state
In Propria Persona
All Rights Reserved
Without Prejudice
PIMA COUNTY CONSOLIDATED JUSTICE COURT
Paul Andrew Mitchell, ) Case Number #CV-97-3438
Plaintiff )
) NOTICE AND DEMAND FOR
v. ) MANDATORY JUDICIAL NOTICE:
) Rule 201(d), Arizona Rules
Neil and Evelyn Nordbrock, ) of Evidence
Defendants )
________________________________)
COMES NOW Paul Andrew Mitchell, Sui Juris, Citizen of Arizona
state and Plaintiff in the above entitled matter (hereinafter
"Plaintiff"), to provide formal Notice to all interested parties,
and to demand mandatory judicial notice by this honorable Court,
pursuant to Rule 201(d) of the Arizona Rules of Evidence, of the
several documents which are itemized infra. Copies of said
documents are attached hereto and incorporated by reference as if
set forth fully herein.
Mandatory judicial notice leaves no room for discretion on
the part of this honorable Court, since the legislative intent of
the word "shall" in Rule 201(d) has a compulsory meaning. Confer
at "shall" in Black's Law Dictionary, Sixth Edition.
The attached twenty-three (23) documents include the
following, arranged in chronological order, to wit:
Third Notice and Demand for Mandatory Judicial Notice:
Page 1 of 34
1. INVOICE dated September 16, 1996, from Paul Andrew
Mitchell, B.A., M.S., to Neil & Evelyn Nordbrock, for
total of $325.00.
2. INVOICE dated September 17, 1996, from Paul Andrew
Mitchell, B.A., M.S., to Neil & Evelyn Nordbrock, for
total of $81.86.
3. MEMO dated October 22, 1996, from Paul Andrew Mitchell,
B.A., M.S., to Neil & Evelyn Nordbrock, concerning
"Recent Deposits" total of $360.00.
4. INVOICE dated November 17, 1996, from Paul Andrew
Mitchell, B.A., M.S., to Neil & Evelyn Nordbrock, for
total of $1,080.00.
5. Outstanding invoice dated December 1, 1996, from Paul
Andrew Mitchell, B.A., M.S., to Neil & Evelyn
Nordbrock, for total of $4,061.86.
6. SECOND NOTICE dated December 9, 1996, from Paul Andrew
Mitchell, B.A., M.S., to Neil & Evelyn Nordbrock, for
total of $4,061.86.
7. MEMO dated December 11, 1996, from Paul Andrew
Mitchell, B.A., M.S., to Neil Nordbrock concerning JAZ
drive cartridge.
8. SECOND REQUEST dated December 26, 1996, from Paul
Andrew Mitchell, B.A., M.S., to Neil Nordbrock
concerning JAZ drive cartridge.
9. BONA FIDE OFFER IN COMPROMISE AND OFFER TO HOLD
HARMLESS dated December 26, 1996, from Paul Andrew
Mitchell, B.A., M.S., to Neil Thomas Nordbrock.
10. THIRD NOTICE dated January 3, 1997, from Paul Andrew
Mitchell, B.A., M.S., to Neil & Evelyn Nordbrock
concerning outstanding invoice for total of $4,061.86.
11. CRIMINAL COMPLAINT dated January 7, 1997, by Paul
Andrew Mitchell, B.A., M.S., to Tucson Police
Department, Attention: Officer Garcia, against Neil
Thomas Nordbrock for embezzling $3,000.00.
12. MEMO dated January 11, 1997, from Paul Andrew Mitchell,
B.A., M.S., to Lawrence E. Condit, Attorney [sic],
concerning Neil T. Nordbrock.
13. MEMO dated January 21, 1997, from Paul Andrew Mitchell,
B.A., M.S., to Mr. and Mrs. Neil T. Nordbrock,
concerning gold coin and JAZ disk.
14. MEMO dated February 11, 1997, from Paul Andrew
Mitchell, B.A., M.S., to Mr. and Mrs. Neil T.
Nordbrock, concerning gold coin and JAZ disk.
Third Notice and Demand for Mandatory Judicial Notice:
Page 2 of 34
15. SECOND NOTICE dated February 11, 1997, from Paul Andrew
Mitchell, B.A., M.S., to Lawrence E. Condit, Attorney
[sic], concerning Neil T. Nordbrock.
16. MEMO dated February 12, 1997, from Paul Andrew
Mitchell, B.A., M.S., to Chief of Police, Tucson Police
Department, concerning Case Number #9701050374.
17. NOTICE AND DEMAND dated February 12, 1997, from Paul
Andrew Mitchell, B.A., M.S., to Mr. Neil Thomas
Nordbrock, concerning "Sheryl Smith" [sic].
18. AFFIDAVIT OF PROBABLE CAUSE dated February 12, 1997,
executed under penalty of perjury by Paul Andrew
Mitchell, B.A., M.S., Citizen of Arizona state and
federal witness.
19. MEMO dated February 14, 1997, from Paul Andrew
Mitchell, B.A., M.S., to Detective Robert Soltero,
Tucson City Police Department, concerning Case Numbers
#9701050374 and #9702110162.
20. MEMO dated February 17, 1997, from Paul Andrew
Mitchell, B.A., M.S., to Detective Robert Soltero,
Tucson City Police Department, concerning Case Numbers
#9701050374 and #9702110162.
21. MEMO dated February 23, 1997, from Paul Andrew
Mitchell, B.A., M.S., to Douglas F. Smith, Chief of
Police, City of Tucson, concerning TPD Case Number
#9701050374.
22. THIRD NOTICE dated March 11, 1997, from Paul Andrew
Mitchell, B.A., M.S., to Lawrence E. Condit, Attorney
[sic], concerning Neil T. Nordbrock.
23. MEMO dated March 13, 1997, from Paul Andrew Mitchell,
B.A., M.S., to Detective Robert Soltero, concerning
Case Numbers #9701050374 and #9702110162.
VERIFICATION
I, Paul Andrew Mitchell, Sui Juris, hereby verify, under penalty
of perjury, under the laws of the United States of America,
without the "United States", that the attached documents are true
and correct copies of the originals, with the sole exception of
the original blue-ink signatures, which signatures I hereby apply
to said documents by proxy, to the best of My current
information, knowledge, and belief, so help Me God, pursuant to
28 U.S.C. 1746(1). See Supremacy Clause.
Third Notice and Demand for Mandatory Judicial Notice:
Page 3 of 34
Dated: March 13, 1997
Respectfully submitted,
/s/ Paul Andrew Mitchell
_____________________________________
Paul Andrew Mitchell, Sui Juris
Citizen of Arizona state
All Rights Reserved without Prejudice
Third Notice and Demand for Mandatory Judicial Notice:
Page 4 of 34
PROOF OF SERVICE
I, Paul Andrew Mitchell, Sui Juris, hereby certify, under penalty
of perjury, under the laws of the United States of America,
without the "United States," that I am at least 18 years of age,
a Citizen of one of the United States of America, and that I
personally served the following document(s):
NOTICE AND DEMAND FOR
MANDATORY JUDICIAL NOTICE:
Rule 201(d), Arizona Rules of Evidence
by placing one true and correct copy of said document(s) in first
class United States Mail, with postage prepaid and properly
addressed to the following:
Neil and Evelyn Nordbrock
c/o 6642 E. Calle de San Alberto
Tucson, Arizona state
Executed on March 13, 1997:
/s/ Paul Andrew Mitchell
_____________________________________
Paul Andrew Mitchell, Sui Juris
Citizen of Arizona state
All Rights Reserved without Prejudice
Attachments follow infra.
Third Notice and Demand for Mandatory Judicial Notice:
Page 5 of 34
INVOICE
TO: Neil & Evelyn Nordbrock
6642 E. Calle de San Alberto
Tucson, Arizona state
FROM: Paul Andrew Mitchell, B.A., M.S.
Counselor at Law
c/o 2509 North Campbell Avenue, #1776
Tucson, Arizona state
DATE: September 16, 1996
SUBJECT: Invoice for Professionals Services
This is my invoice for professional services as follows:
Quantity Description Total
12 hours consult with clients;
produce First Amendment Petition to
Congress and Affidavit of Probable
Cause Due to Executive and Judicial
Misconduct;
draft Judicial Complaint form;
prepare Notice and Demand for Judicial
Notice, per Rule 201(d);
order Ninth Circuit Rules for Judicial
Complaint forms, forward to clients
@ $75.00/hour $900.00
1 retainer (pre-paid against condo rent) (575.00)
8 hours stuffing envelopes while being wined
and dined on delicious food in
delightful company; do miscellaneous
research; and research legislative
history of 18 U.S.C. 1513;
begin reviewing case file n/c
-------
TOTAL AMOUNT DUE: $325.00
=======
My terms are total amount due upon receipt of invoice. Thank you
very much for your consideration.
Sincerely yours, P.S. Love to Floyd & the pups.
/s/ Paul Andrew Mitchell
Paul Andrew Mitchell, B.A., M.S.
Counselor at Law, federal witness,
and Citizen of Arizona state
All Rights Reserved without Prejudice
email: supremelawfirm@altavista.net
website: http://supremelaw.com
Third Notice and Demand for Mandatory Judicial Notice:
Page 6 of 34
INVOICE
TO: Neil & Evelyn Nordbrock
FROM: Paul Andrew Mitchell, B.A., M.S.
Counselor at Law
DATE: September 17, 1996
SUBJECT: Invoice for Incidental Expenses Today
This is My invoice for incidental expenses incurred today
expediting legal books and related documentation to Vern Holland
in Tulsa, Oklahoma (see enclosed receipts). These were as
follows:
Quantity Description Total
1 Arizona Rules of Court,
State and Federal, 1996 $ 21.86
1 Survival Course Book,
Pima County Superior Court $ 35.00
1 Express Mail postage and
handling, 6 lbs. weight
(USPS receipt is in error) $ 25.00
-------
TOTAL AMOUNT DUE: $ 81.86
=======
Terms are TOTAL AMOUNT DUE upon receipt of invoice.
Thank you very much for your consideration.
Sincerely yours,
/s/ Paul Andrew Mitchell
Paul Andrew Mitchell, B.A., M.S.
Counselor at Law
c/o 2509 N. Campbell, #1776
Tucson [zip code exempt]
ARIZONA STATE
email: supremelawfirm@altavista.net
website: http://supremelaw.com
enclosures: receipts
Third Notice and Demand for Mandatory Judicial Notice:
Page 7 of 34
MEMO
TO: Neil & Evelyn Nordbrock
FROM: Paul Andrew Mitchell, B.A., M.S.
Counselor at Law
DATE: October 22, 1996
SUBJECT: Recent Deposits
This is to confirm the deposit of $160.00 which I gave you last
night (a commercial money order), and the two enclosed checks: a
private check for $100, and a blank U.S. Postal Money Order for
$100.00.
This should come to:
commercial money order: $160.00
private check, Bank One $100.00
U.S. Postal Money Order (blank) $100.00
-------
Total: $360.00
=======
Thanks so much for handling all these details for me. It really
takes a big load off my mind.
Sincerely yours,
/s/ Paul Andrew Mitchell
Paul Andrew Mitchell, B.A., M.S.
Counselor at Law and federal witness
c/o 2509 N. Campbell, #1776
Tucson, Arizona state
Postal Zone 85719/tdc
email: supremelawfirm@altavista.net
website: http://supremelaw.com
Third Notice and Demand for Mandatory Judicial Notice:
Page 8 of 34
INVOICE
TO: Neil & Evelyn Nordbrock
FROM: Paul Andrew Mitchell, B.A., M.S.
Counselor at Law
DATE: November 17, 1996
SUBJECT: Invoice for Professional Services
This is My invoice for professional services performed for both
of you, since September 17, 1996, as follows:
Quantity Description Total
4 hours computer upgrade and training
(@ $45.00) $180.00
12 hours litigation assistance:
Quiet Title case; buying and
shipping legal books to Holland;
drafting/serving Notice to Ulans;
update judicial complaint form;
email FOIA appeal example;
review Holland pleadings;
general consultation re: above
(@ $75.00) $900.00
---------
TOTAL AMOUNT DUE: $1,080.00
=========
Terms are TOTAL AMOUNT DUE upon receipt of invoice.
Thank you very much for your consideration.
Sincerely yours,
/s/ Paul Andrew Mitchell
Paul Andrew Mitchell, B.A., M.S.
Counselor at Law
c/o 2509 N. Campbell, #1776
Tucson [zip code exempt]
ARIZONA STATE
email: supremelawfirm@altavista.net
website: http://supremelaw.com
enclosures: receipts
Third Notice and Demand for Mandatory Judicial Notice:
Page 9 of 34
MEMO
TO: Neil & Evelyn Nordbrock
FROM: Paul Andrew Mitchell, B.A., M.S.
Counselor at Law
DATE: December 1, 1996
SUBJECT: Outstanding Invoice
Please purchase the requisite number of U.S. Postal Money Orders,
and remit to Me the following TOTAL AMOUNT DUE, itemized as
follows:
Quantity Description Total
1 Invoice dated September 17, 1996 $ 81.86
1 Invoice dated November 17, 1996 $1,080.00
1 Balance Forward (estimated) $3,000.00
1 cash withdrawal (100.00)
----------
TOTAL AMOUNT DUE: $4,061.86
=========
It is My understanding that the U.S. Postal Service now has a
limit of $700.00 per money order. If necessary, please deduct
the U.S. Postal Service fee(s) necessary to purchase the
requisite number of money orders, and remit them to Me, care of
the mailing location shown below.
Thank you for your consideration.
Sincerely yours,
/s/ Paul Andrew Mitchell
Paul Andrew Mitchell, B.A., M.S.
Counselor at Law and federal witness
c/o 2509 N. Campbell, #1776
Tucson, Arizona state
Postal Zone 85719/tdc
email: supremelawfirm@altavista.net
website: http://supremelaw.com
Third Notice and Demand for Mandatory Judicial Notice:
Page 10 of 34
SECOND NOTICE
TO: Neil & Evelyn Nordbrock
FROM: Paul Andrew Mitchell, B.A., M.S.
Counselor at Law
DATE: December 9, 1996
SUBJECT: Outstanding Invoice
Can you please pay me the amount you owe me below? I need
medical/dental attention, and I also need money for other normal
living expenses.
Please purchase the requisite number of U.S. Postal Money Orders,
and remit to Me the following TOTAL AMOUNT DUE, itemized as
follows:
Quantity Description Total
1 Invoice dated September 17, 1996 $ 81.86
1 Invoice dated November 17, 1996 $1,080.00
1 Balance Forward (estimated) $3,000.00
1 cash withdrawal (100.00)
----------
TOTAL AMOUNT DUE: $4,061.86
=========
It is My understanding that the U.S. Postal Service now has a
limit of $700.00 per money order. If necessary, please deduct
the U.S. Postal Service fee(s) necessary to purchase the
requisite number of money orders, and remit them to Me, care of
the mailing location shown below.
Thank you for your consideration.
Sincerely yours,
/s/ Paul Andrew Mitchell
Paul Andrew Mitchell, B.A., M.S.
Counselor at Law and federal witness
c/o 2509 N. Campbell, #1776
Tucson, Arizona state
Postal Zone 85719/tdc
email: supremelawfirm@altavista.net
website: http://supremelaw.com
Third Notice and Demand for Mandatory Judicial Notice:
Page 11 of 34
MEMO
TO: Neil Nordbrock
FROM: Paul Andrew Mitchell, B.A., M.S.
Counselor at Law
DATE: December 11, 1996
SUBJECT: JAZ drive cartridge
Please return the JAZ drive cartridge which you placed in your
son's safe.
Please ship it via parcel post to the mailing location below.
Thanks.
Sincerely yours,
/s/ Paul Andrew Mitchell
Paul Andrew Mitchell, B.A., M.S.
Counselor at Law and federal witness
c/o 2509 N. Campbell, #1776
Tucson, Arizona state
Postal Zone 85719/tdc
email: supremelawfirm@altavista.net
website: http://supremelaw.com
Third Notice and Demand for Mandatory Judicial Notice:
Page 12 of 34
SECOND REQUEST
TO: Neil Nordbrock
FROM: Paul Andrew Mitchell, B.A., M.S.
Counselor at Law
DATE: December 26, 1996
SUBJECT: JAZ drive cartridge
Please return the JAZ drive cartridge which you placed in your
son's safe.
Please ship it via parcel post to the mailing location below.
Thanks.
Sincerely yours,
/s/ Paul Andrew Mitchell
Paul Andrew Mitchell, B.A., M.S.
Counselor at Law and federal witness
c/o 2509 N. Campbell, #1776
Tucson, Arizona state
Postal Zone 85719/tdc
email: supremelawfirm@altavista.net
website: http://supremelaw.com
Third Notice and Demand for Mandatory Judicial Notice:
Page 13 of 34
Serial Number #P-502-472-502 Tucson [zip code exempt]
Return Receipt Requested ARIZONA STATE
Restricted Delivery Requested
December 26, 1996
BONA FIDE OFFER IN COMPROMISE
AND OFFER TO HOLD HARMLESS
Neil Thomas Nordbrock, Accountant
c/o 6642 East Calle de San Alberto
Tucson, Arizona state
Dear Neil,
This is My bona fide offer to compromise with you concerning
the dispute which has arisen over the funds which were entrusted
to your careful accounting and disbursement. Since you have now
refused to return money which does not belong to you, after
presentment of invoices and intervention by a mediator, you could
be charged with embezzling all of it. As you know, this is a
felony, and you and your spouse could go to state prison for
this. If you don't believe Me, then contact the Chief of Police.
Therefore, I offer to hold you harmless of any criminal
charges I might bring against you and your spouse for this,
provided that you pay the amount of four thousand sixty-one
dollars and eighty-six cents ($4,061.86) to Mr. Richard Scully
within five (5) days after you receive this offer. Allowing for
one day to deliver the mail, and an extra day of grace, your
deadline for paying this amount, in full, to Richard Scully is
5:00 p.m. on Thursday, January 2, 1997. I will require that you
pay this amount to Mr. Scully in valid United States Postal Money
Orders which you purchase from the U.S. Postal Service and
forward to Mr. Scully via Registered United States Mail.
Beyond that deadline, I will be entitled to proceed on the
basis of the conclusive presumption that you intend to embezzle
all the personal funds which you are holding for Me, and I will
take appropriate legal action to protect My Rights.
VERIFICATION
I hereby verify, under penalty of perjury, under the laws of
the United States of America, without the "United States", that
the above statements of fact are true and correct, according to
the best of my current information, knowledge, and belief, so
help Me God, pursuant to 28 U.S.C. 1746(1).
Sincerely yours,
/s/ Paul Andrew Mitchell
Paul Andrew Mitchell, B.A., M.S.
Citizen of Arizona state and federal witness
email: supremelawfirm@altavista.net
website: http://supremelaw.com
copies: Richard Scully
Mark Nordbrock
Chief of Police
Third Notice and Demand for Mandatory Judicial Notice:
Page 14 of 34
THIRD NOTICE
TO: Neil & Evelyn Nordbrock
FROM: Paul Andrew Mitchell, B.A., M.S.
Counselor at Law
DATE: January 3, 1997
SUBJECT: Outstanding Invoice
Can you please pay me the amount you owe me below? I need
medical/dental attention, and I also need money for other normal
living expenses.
Please purchase the requisite number of U.S. Postal Money Orders,
and remit to Me the following TOTAL AMOUNT DUE, itemized as
follows:
Quantity Description Total
1 Invoice dated September 17, 1996 $ 81.86
1 Invoice dated November 17, 1996 $1,080.00
1 Balance Forward (estimated) $3,000.00
1 cash withdrawal (100.00)
----------
TOTAL AMOUNT DUE: $4,061.86
=========
It is My understanding that the U.S. Postal Service now has a
limit of $700.00 per money order. If necessary, please deduct
the U.S. Postal Service fee(s) necessary to purchase the
requisite number of money orders, and remit them to Me, care of
the mailing location shown below.
Thank you for your consideration.
Sincerely yours,
/s/ Paul Andrew Mitchell
Paul Andrew Mitchell, B.A., M.S.
Counselor at Law and federal witness
c/o 2509 N. Campbell, #1776
Tucson, Arizona state
Postal Zone 85719/tdc
email: supremelawfirm@altavista.net
website: http://supremelaw.com
Third Notice and Demand for Mandatory Judicial Notice:
Page 15 of 34
c/o 2509 N. Campbell, #1776
Tucson [zip code exempt]
ARIZONA STATE
January 7, 1997
CRIMINAL COMPLAINT
Tucson Police Department
270 South Stone
Tucson, Arizona state
Attention: Officer Garcia
Subject: Police Report #9701050374 in re:
Neil Thomas Nordbrock
6642 E. Calle de San Alberto
Tucson, Arizona state
Postal Zone 85710
telephone: (520) 296-3052
Dear Officer Garcia:
I hereby file My formal Complaint against Neil Thomas Nordbrock
for embezzling $3,000.00 of Mine, which I entrusted to his care
and accounting.
To support this Criminal Complaint, I enclose additional
documentation to substantiate My charges. The untitled ledger is
a copy of the original ledger which Mr. Nordbrock was maintaining
for Me, at My request, to document the balance "on account" and
under his care. The most recent amount showing, after payment of
rent to My landlord, Neal Manning, is $3,071.64 (see enclosed).
Please accept this Criminal Complaint as My written authorization
to apprehend Mr. Nordbrock and press charges against him for
embezzling the sum of $3,000.00 from Me.
Thank you very much for your consideration.
I hereby certify, under penalty of perjury, under the laws of the
United States of America, that the above statements of fact, and
all the attached, are true and correct, to the best of My current
information, knowledge, and belief, so help Me God, pursuant to
28 U.S.C. 1746(1).
/s/ Paul Andrew Mitchell
Paul Andrew Mitchell, B.A., M.S.
Citizen of Arizona state and federal witness
copy: Chief of Police, Tucson, Arizona state
Rich Scully, private mediator
attachments: related documents and further evidence
email: supremelawfirm@altavista.net
website: http://supremelaw.com
Third Notice and Demand for Mandatory Judicial Notice:
Page 16 of 34
MEMO
TO: Lawrence E. Condit, Attorney
c/o 376 South Stone Avenue
Tucson, Arizona state
Postal Zone 85701/tdc
FROM: Paul Andrew Mitchell, B.A., M.S.
Counselor at Law
DATE: January 11, 1997
SUBJECT: Neil T. Nordbrock
I hold material evidence which indicates that you may be in
possession of stolen property.
As of 5:00 p.m. on Thursday, January 2, 1997, Mr. Neil T.
Nordbrock had embezzled $3,000 of Mine which I had entrusted to
his care and accounting.
Attached please find supporting documentation.
At the start of My dispute with Mr. Nordbrock, he indicated to
Me, in the presence of his spouse, that he had decided to pay
your proposed retainer of $10,000, in order to retain your
services on the Nordbrocks' Quiet Title action in state court,
and on other legal matters.
Mr. Nordbrock took the liberty of showing Me your written
proposal, in which the $10,000 retainer was quoted.
If the Nordbrocks have, indeed, retained your services, it is
evident to Me that they paid a portion of your retainer with the
$3,000 which they embezzled from Me.
I hereby request that you return the $3,000 to Me directly, using
blank U.S. Postal Money Orders shipped via Registered United
States Mail to the mailing location shown below. The office
manager at that location has been authorized, in writing, to sign
for Me.
Please also provide Me with written confirmation that you have,
in fact, been retained by the Nordbrocks, and also indicate
thereon if you have power of attorney to represent them in
criminal matters. Finally, I will need a certified copy of your
license to practice law in the State of Arizona.
If you wish to discuss this matter on the telephone, please
contact Mr. Richard Scully, a professional mediator hired by Me
to negotiate an equitable solution with the Nordbrocks. Mr.
Scully's pager is (602) 665-7522. Please do not call Me
concerning this matter; I have better things to do with My time.
Thank you very much for your consideration.
Third Notice and Demand for Mandatory Judicial Notice:
Page 17 of 34
Sincerely yours,
/s/ Paul Andrew Mitchell
Paul Andrew Mitchell, B.A., M.S.
Counselor at Law and federal witness
c/o 2509 N. Campbell, #1776
Tucson, Arizona state
Postal Zone 85719/tdc
email: supremelawfirm@altavista.net
website: http://supremelaw.com
copy: Chief of Police, Tucson, Arizona state
Detective, Tucson Police Department
Office Manager, The Letter Box
Richard Rineer, New Life Health Center Company
Richard Scully, professional mediator
Judge Alex Kozinski, Ninth Circuit Court of Appeals
Third Notice and Demand for Mandatory Judicial Notice:
Page 18 of 34
MEMO
TO: Mr. and Mrs. Neil T. Nordbrock
6642 E. Calle de San Alberto
Tucson, Arizona state
FROM: Paul Andrew Mitchell, B.A., M.S.
Counselor at Law
DATE: January 21, 1997
SUBJECT: gold coin and JAZ disk you have taken
This is to place you on formal Notice that you are now in
unlawful possession of My one ounce minted gold piece, and My
Iomega one gigabyte JAZ disk cartridge. As of the date you
refused to return the $3,000 you embezzled from me, that gold
piece was worth $370. The JAZ disk, on the other hand, now
stores more than 7 years of unique research, in DOS-compatible
format. Using standard paralegal rates of $25 per hour, 8 hours
per day, 5 days per week, 50 weeks per year, and 2 weeks of
vacation per year, I compute the value of that research as
follows:
7 x $25 x 8 x 5 x 50 = $$350,000.00
============
This is the value of My Common Law Copyrights to the numerous
documents which are now stored on that Iomega JAZ disk cartridge.
I hereby demand that you return My JAZ cartridge, intact, within
72 hours, or show cause why you should not be charged with theft
and with violating My Common Law Copyrights for taking unlawful
possession of the research database which is now stored on that
JAZ cartridge.
Sincerely yours,
/s/ Paul Andrew Mitchell
Paul Andrew Mitchell, B.A., M.S.
Counselor at Law and federal witness
c/o 2509 N. Campbell Avenue, #1776
Tucson, Arizona state
Postal Zone 85719/tdc
email: supremelawfirm@altavista.net
website: http://supremelaw.com
copy: Chief of Police, Tucson, Arizona state
Third Notice and Demand for Mandatory Judicial Notice:
Page 19 of 34
MEMO
TO: Mr. and Mrs. Neil T. Nordbrock
6642 E. Calle de San Alberto
Tucson, Arizona state
FROM: Paul Andrew Mitchell, B.A., M.S.
Counselor at Law
DATE: February 11, 1997
SUBJECT: gold coin and JAZ disk you have taken
This is to place you on formal Notice that you are now in
unlawful possession of My one ounce minted gold piece, and My
Iomega one gigabyte JAZ disk cartridge. As of the date you
refused to return the $3,000 you embezzled from me, that gold
piece was worth $370. The JAZ disk, on the other hand, now
stores more than 7 years of unique research, in DOS-compatible
format. Using standard paralegal rates of $25 per hour, 8 hours
per day, 5 days per week, 50 weeks per year, and 2 weeks of
vacation per year, I compute the value of that research as
follows:
7 x $25 x 8 x 5 x 50 = $$350,000.00
============
This is the value of My Common Law Copyrights to the numerous
documents which are now stored on that Iomega JAZ disk cartridge.
I hereby demand that you return My JAZ cartridge, intact, within
72 hours, or show cause why you should not be charged with theft
and with violating My Common Law Copyrights for taking unlawful
possession of the research database which is now stored on that
JAZ cartridge.
Sincerely yours,
/s/ Paul Andrew Mitchell
Paul Andrew Mitchell, B.A., M.S.
Counselor at Law and federal witness
c/o 2509 N. Campbell Avenue, #1776
Tucson, Arizona state
Postal Zone 85719/tdc
email: supremelawfirm@altavista.net
website: http://supremelaw.com
copy: Chief of Police, Tucson, Arizona state
Third Notice and Demand for Mandatory Judicial Notice:
Page 20 of 34
SECOND NOTICE
TO: Lawrence E. Condit, Attorney
c/o 376 South Stone Avenue
Tucson, Arizona state
Postal Zone 85701/tdc
FROM: Paul Andrew Mitchell, B.A., M.S.
Counselor at Law
DATE: February 11, 1997
SUBJECT: Neil T. Nordbrock
I hold material evidence which indicates that you may be in
possession of stolen property.
As of 5:00 p.m. on Thursday, January 2, 1997, Mr. Neil T.
Nordbrock had embezzled $3,000 of Mine which I had entrusted to
his care and accounting.
At the start of My dispute with Mr. Nordbrock, he indicated to
Me, in the presence of his spouse, that he had decided to pay
your proposed retainer of $10,000, in order to retain your
services on the Nordbrocks' Quiet Title action in state court,
and on other legal matters.
Mr. Nordbrock took the liberty of showing Me your written
proposal, in which the $10,000 retainer was quoted.
If the Nordbrocks have, indeed, retained your services, it is
evident to Me that they paid a portion of your retainer with the
$3,000 which they embezzled from Me.
I hereby request that you return the $3,000 to Me directly, using
blank U.S. Postal Money Orders shipped via Registered United
States Mail to the mailing location shown below. The office
manager at that location has been authorized, in writing, to sign
for Me.
Please also provide Me with written confirmation that you have,
in fact, been retained by the Nordbrocks, and also indicate
thereon if you have power of attorney to represent them in
criminal matters. Finally, I will need a certified copy of your
license to practice law in the State of Arizona.
If you wish to discuss this matter on the telephone, please
contact Mr. Richard Scully, a professional mediator hired by Me
to negotiate an equitable solution with the Nordbrocks. Mr.
Scully's pager is (602) 665-7522. Please do not call Me
concerning this matter; I have better things to do with My time.
Thank you very much for your consideration.
Third Notice and Demand for Mandatory Judicial Notice:
Page 21 of 34
Sincerely yours,
/s/ Paul Andrew Mitchell
Paul Andrew Mitchell, B.A., M.S.
Counselor at Law and federal witness
c/o 2509 N. Campbell, #1776
Tucson, Arizona state
Postal Zone 85719/tdc
email: supremelawfirm@altavista.net
website: http://supremelaw.com
copy: Chief of Police, Tucson, Arizona state
Detective, Tucson Police Department
Office Manager, The Letter Box
Richard Rineer, New Life Health Center Company
Richard Scully, professional mediator
Judge Alex Kozinski, Ninth Circuit Court of Appeals
Third Notice and Demand for Mandatory Judicial Notice:
Page 22 of 34
MEMO
TO: Chief of Police
Tucson City Police Department
270 S. Stone Avenue
Tucson, Arizona state
FROM: Paul Andrew Mitchell, B.A., M.S.
Counselor at Law
DATE: February 12, 1997
SUBJECT: Case Number #9701050374
I am writing to request that your office reconsider an
administrative determination which has been made by one of the
crime detectives in your department. I do apologize that I have
failed to get his name, when he called me this morning to discuss
the matter. The enclosed materials should give you a good
overview of my complaint against Mr. Neil Thomas Nordbrock. I am
requesting a reconsideration for the following reasons:
1. The detective failed to obtain any statements from the
private mediator whom I retained to resolve this matter.
When he was called by an officer in your department, I am
told that Mr. Nordbrock alleged that he was in earnest mediation
over the matter. At the time Mr. Nordbrock is reported to have
made this statement, the mediation had already broken off and,
therefore, his statement was a lie. I did not go to the Tucson
City Police until after the mediator had exhausted his efforts,
and only after the mediator had recommended that I go to the
Police instead with this matter. Accordingly, I expect that the
mediator will effectively refute Mr. Nordbrock's lie in this
regard. The mediator is Mr. Richard Scully, living in Phoenix,
telephone number: (602) 234-9640, pager: (602) 665-7522. He has
been expecting a call from someone in your department, because I
told him to expect such a call. I regard Mr. Nordbrock's
willingness to lie in this matter as evidence of his guilt. I
invite you, and your detective(s), to consider Mr. Scully's
statement very carefully, after you have reviewed this request.
2. The detective concluded that I had not given him enough
documentary proof of the embezzlement.
Mr. Nordbrock seems to be a fairly intelligent man, and he
is intelligent enough consciously to avoid giving me conclusive
evidence of embezzling $3,000. I gave the detective everything I
could. Beyond that, I feel that I have been placed in an
impossible situation, and the law does not recognize
impossibilities. (See Lex non cogit impossibilia in any Black's
Law Dictionary,) I offer to you the statements which I have
already made, under penalty of perjury. In late summer, I was
threatened by a man who has been implicated by the Pima County
Sheriffs in a conspiracy to manufacture methamphetamine. I felt
it was wise to get my money out of the house. That was one of
the main reasons why I entrusted that money to Mr. Nordbrock.
Third Notice and Demand for Mandatory Judicial Notice:
Page 23 of 34
3. The detective also admitted that he had trouble
understanding the documentation which I had given him.
I presume that the detective was referring to the photocopy
of the general ledger which Mr. Nordbrock was keeping, and a copy
of which he gave to me before embezzling the balance. It is true
that Mr. Nordbrock was keeping those books in satisfactory order.
It was only when I decided to confront him over his alcohol
abuse, that Mr. Nordbrock retaliated against me. The current
balance on the general ledger was all money which belonged to me,
and which Mr. Nordbrock was required to pay out, according to my
written and verbal orders. If the detective is referring to
other documents which he cannot explain, it would help me a lot
if he could write to me, or call me, with any questions he still
has concerning the documentation which I supplied to him. I can
understand how the detective would have difficulty with
documentation which is not as complete as he would prefer.
Again, I have provided everything I had in my possession and
control.
In summary, please have the detective reconsider the finding
which he has made, in light of the additional information which I
have attempted to provide to you above, and in the enclosed
documents. In particular, I believe it is important that the
detective hear directly from the mediator whom I hired. That
mediator is Mr. Richard Scully of Phoeniz, Arizona state,
telephone number: (602) 234-9640, pager: (602) 665-7522.
And thank you for your time and consideration.
Respectfully submitted,
/s/ Paul Andrew Mitchell
Paul Andrew Mitchell, B.A., M.S.
Counselor at Law and federal witness
c/o 2509 N. Campbell Avenue, #1776
Tucson, Arizona state
Postal Zone 85719/tdc
email: supremelawfirm@altavista.net
website: http://supremelaw.com
Third Notice and Demand for Mandatory Judicial Notice:
Page 24 of 34
NOTICE AND DEMAND
TO: Mr. Neil Thomas Nordbrock
FROM: Paul Andrew Mitchell, B.A., M.S.
Counselor at Law
DATE: February 12, 1997
SUBJECT: "Sheryl Smith"
I now have documentary reasons to believe that one "Sheryl
Smith" is not a human being. My reasons for believing this are
private at the present time. Privacy is a fundamental Right.
Because you recommended the appointment, and because you
have been the accountant to the New Life Health Center Company
("New Life") for some time, you have been implicated in my
appointment to the office of Vice President for Legal Affairs of
New Life under "authority" of this "Sheryl Smith." If "Sheryl
Smith" is not a human being, then it is quite probable that my
appointment to said office was fraudulent, and that you are,
therefore, liable, in whole or in part, for this fraud.
Therefore, this is my formal DEMAND that you produce
evidence of the whereabouts and identity of the real "Sheryl
Smith."
I hereby demand that this evidence be mailed to Me at the
mailing location shown below, on or before 5:00 p.m. on Friday,
February 28, 1997. Beyond that deadline, I will be entitled to
proceed on the basis of the conclusive presumptions that "Sheryl
Smith" is not a real human being; that my appointment to the
office of Vice President for Legal Affairs of New Life was
fraudulent; and that you were a principal agent in committing
this fraud upon Me, upon New Life, upon the United States
District Court in Tucson, Arizona state, and consequently upon
the United States Court of Appeals for the Ninth Circuit, with
headquarters in San Francisco, California state.
Thank you for your prompt attention to this lawful Notice
and Demand.
Third Notice and Demand for Mandatory Judicial Notice:
Page 25 of 34
Sincerely yours,
/s/ Paul Andrew Mitchell
Paul Andrew Mitchell, B.A., M.S.
Counselor at Law and federal witness
c/o 2509 N. Campbell Avenue, #1776
Tucson, Arizona state
Postal Zone 85719/tdc
email: supremelawfirm@altavista.net
website: http://supremelaw.com
copies: New Life Health Center Company
4500 E. Speedway Boulevard and
4841 E. Speedway Boulevard
Tucson, Arizona state
attachment: Affidavit of Probable Cause
Third Notice and Demand for Mandatory Judicial Notice:
Page 26 of 34
AFFIDAVIT OF PROBABLE CAUSE
I, Paul Andrew, Mitchell, B.A., M.S., Citizen of Arizona
state and federal witness, hereby verify, under penalty of
perjury, under the laws of the United States of America, without
the "United States", that the following statement of fact is true
and correct, to the best of my current information, knowledge,
and belief, so help Me God, pursuant to 28 U.S.C. 1746(1).
During the latter half of calendar year 1996, I retained the
accounting services of Neil Thomas Nordbrock, and entrusted him
with the management of at least $3,000.00 of my own money. I
also performed approximately $1,160.00 worth of professional
services to upgrade his office computer.
During several social and business visits to his home
office, I observed Mr. Nordbrock quite inebriated on alcohol; he
consistently slurred his words, stumbled in his own kitchen, and
spilled full drinks with his right hand, as he reached for other
items on the dinner table. He also appeared quite incapable of
understanding the computer training I attempted to give him
concerning the computer upgrades which I had done for him and for
his spouse on their office computer.
I mailed several invoices to Mr. Nordbrock which he refused
to honor. I also mailed a BONA FIDE OFFER IN COMPROMISE AND
OFFER TO HOLD HARMLESS to Mr. Nordbrock, which he refused to
honor. I also retained the services of a private mediator. This
private mediator informed me that he had made numerous good faith
attempts to reach an equitable settlement with Mr. Nordbrock.
This private mediator also informed me that Mr. Nordbrock was
holding me responsible for some contract which Mr. Nordbrock had
entered with one Richard McDonald in Canoga Park, California
state, a contract to which I was not a party in any way. I
subsequently confirmed this by direct telephone conversation with
Mr. McDonald.
After numerous private conversations with the private
mediator, this mediator advised me that he had exhausted his
efforts to recover some or all of the money of mine which Mr.
Nordbrock was managing for me. This was Christmas time, and I
was rendered destitute by Mr. Nordbrock's conduct. I had to
borrow money from the mediator in order to buy food. This same
mediator then recommended that I file a criminal complaint
against Mr. Nordbrock with the Tucson City Police for embezzling
all of the $3,000.00 which I had entrusted to Mr. Nordbrock's
management. I then followed the mediator's advice. Copies of
the Criminal Complaint, and of other supporting documents, are
attached to this Affidavit of Probable Cause, and incorporated by
reference as if set forth fully herein.
Executed on February 12, 1997
/s/ Paul Andrew Mitchell
Paul Andrew Mitchell, B.A., M.S.
Citizen of Arizona state and federal witness
Third Notice and Demand for Mandatory Judicial Notice:
Page 27 of 34
MEMO
TO: Detective Robert Soltero
Tucson City Police Department
FROM: Paul Andrew Mitchell, B.A., M.S.
Counselor at Law
DATE: February 14, 1997
SUBJECT: Case Number #9701050374
(see also case number #9702110162)
I spoke with the private mediator I hired in the case described
above, and we mutually agreed that I should send you copies of
the enclosed.
Please don't hesitate to contact Mr. Richard Scully, the
mediator, at your earliest convenience. His telephone number in
Phoenix is (602) 234-9640; pager: (602) 665-7522.
Thank you very much for your consideration, Detective Soltero. I
desperately need that $3,000 which Neil T. Nordbrock embezzled
from me.
Sincerely yours,
/s/ Paul Andrew Mitchell
Paul Andrew Mitchell, B.A., M.S.
Counselor at Law and federal witness
c/o 2509 N. Campbell Avenue, #1776
Tucson, Arizona state
Postal Zone 85719/tdc
email: supremelawfirm@altavista.net
website: http://supremelaw.com
Third Notice and Demand for Mandatory Judicial Notice:
Page 28 of 34
MEMO
TO: Detective Robert Soltero
Tucson City Police Department
FROM: Paul Andrew Mitchell, B.A., M.S.
Counselor at Law
DATE: February 17, 1997
SUBJECT: Case Number #9701050374
(see also case number #9702110162)
I am providing the enclosed documents to make you aware of
certain additional facts which should be material to your
investigation of Neil Thomas Nordbrock. Mr. Nordbrock is the
contract accountant for the New Life Health Center Company, and
Dr. Eugene A. Burns is that company's General Manager. The
evidence available to me indicates that Dr. Burns is using a
rubber stamp, without authorization, to execute official trust
documents and also to "sign" bank checks to pay normal business
expenses of the company. When Mr. Nordbrock recommended that I
be appointed to the office of Vice President for Legal Affairs,
an "appointment" signed by one "Sheryl Smith" appeared out of
nowhere; I never did get to meet this mysterious individual, and
to this day, I still have not met her. In light of the many
documents which Dr. Burns filed in the United States District
Court to defend that Company against a federal grand jury
subpoena for its records, the use of a bogus rubber stamp on
official trust documents and on regular business checks raises
the specter of fraud, perjury, and contempt of court. One of
those documents was a verified copy of a non-disclosure agreement
which Dr. Burns had allegedly entered with the Trustee ("Sheryl
Smith"). I have reason to believe that "Sheryl Smith" is
actually Dr. Burns' wife, Linda Burns. One of my reasons for
believing this was her resistance to signing the PROOF OF SERVICE
pages on the many pleadings we filed in that case.
Sincerely yours,
/s/ Paul Andrew Mitchell
Paul Andrew Mitchell, B.A., M.S.
Counselor at Law and federal witness
c/o 2509 N. Campbell Avenue, #1776
Tucson, Arizona state
Postal Zone 85719/tdc
email: supremelawfirm@altavista.net
website: http://supremelaw.com
Third Notice and Demand for Mandatory Judicial Notice:
Page 29 of 34
MEMO
TO: Douglas F. Smith
Chief of Police
City of Tucson
270 South Stone Avenue
Tucson, Arizona state
FROM: Paul Andrew Mitchell, B.A., M.S.
Counselor at Law
DATE: February 23, 1997
SUBJECT: TPD Case 9701050374
Dear Chief Smith:
I have received your letter dated February 18, 1997, in the
matter described above. I submit to you that my loss of $3,000
to embezzlement by Neil T. Nordbrock ("Nordbrock") is only the
tip of a larger iceberg.
Nordbrock has been the accountant to the New Life Health Center
Company ("New Life") in Tucson, Arizona, for quite some time now.
At his urging, I was appointed to the office of Vice President
for Legal Affairs last year, under authority of the Trustee, one
"Sheryl Smith."
Subsequent investigations have shown that "Sheryl Smith" is a
mere rubber stamp. I discovered this when I attempted to serve
Registered U.S. Mail upon her at the administrative office of New
Life, and the green receipt returned with the signature of Eugene
A. Burns, the General Manager, not Sheryl Smith. This happened,
despite the fact that I had paid the post office for restricted
delivery services. Moreover, there is no standing delivery order
(USPS Form 3801) on file with the USPS and signed by one named
"Sheryl Smith." This discovery provided me with important
evidence that "Sheryl Smith" is nowhere to be found. A second
such letter was signed by one "Rachel Saull", not by "Sheryl
Smith". I have no idea who "Rachel Saull" is.
What makes this discovery even more important is that, during
1996, Nordbrock and Eugene A. Burns entered documents with the
signature of "Sheryl Smith" into evidence in the United States
District Court in Tucson, In re Grand Jury Subpoena Served on New
Life Health Center Company, GJ-95-1-6. One document, in
particular, figured prominently in the litigation, because it was
a non-disclosure agreement which "Sheryl Smith" had allegedly
executed to bar Burns from disclosing company records without her
prior written authorization.
To represent important trust documents as bona fide, when they
have been executed by a bogus rubber stamp, is to commit fraud
upon me and upon the United States District Court in Tucson,
Arizona state. Nordbrock and Burns are parties to this fraud,
because they conceived and executed it.
Third Notice and Demand for Mandatory Judicial Notice:
Page 30 of 34
When I came too close to this fraud, I was punished; in my case,
I was wrongly discharged from the office of Vice President for
Legal Affairs, at the loss of more than $2,000 (see attached).
This happened despite the fact that termination of officers
requires official action by the Trustee, and I was never
terminated by action of "Sheryl Smith", with or without a rubber
stamp. The New Life trust contract does not allow officers to
terminate other officers; this can only be done by the New Life
Trustee.
One of the documents I wish to bring to your attention is a
confidential memorandum, dated June 22, 1996, which I prepared
for Nordbrock, on the rubber stamp and related questions. I was
terminated about a month afterwards, on July 25, 1996. At no
time during the intervening month did Nordbrock respond in any
way to this important confidential memorandum.
I might add that the same rubber stamp has been endorsing
countless business checks which have issued from the desk of
Eugene A. Burns. Many of these checks have been used illegally
to comingle trust funds with the personal expenses of Eugene A.
Burns. I personally witnessed Burns culling evidence of
comingled checks from his many stacks of cancelled checks, after
he agreed to produce trust records to a federal grand jury. He
did so without first having prior written authorization of the
New Life Trustee, "Sheryl Smith". This was a fraud upon the
federal grand jury which had subpoened New Life's records.
Accordingly, I respectfully request that you re-open your
investigation of Neil T. Nordbrock, to include the matters of
evidence which I have presented above. Allow me to suggest that
you also attempt to send Registered U.S. Mail to "Sheryl Smith"
at New Life Health Center Company, 4500 East Speedway, Suite 27,
Tucson, Arizona state. Be sure to post this mail with restricted
delivery and return receipt services.
Thank you very much for your consideration.
Sincerely yours,
/s/ Paul Andrew Mitchell
Paul Andrew Mitchell, B.A., M.S.
Counselor at Law and federal witness
c/o 2509 N. Campbell Avenue, #1776
Tucson, Arizona state
Postal Zone 85719/tdc
email: supremelawfirm@altavista.net
website: http://supremelaw.com
copy: Sergeant Cook
Third Notice and Demand for Mandatory Judicial Notice:
Page 31 of 34
THIRD NOTICE
TO: Lawrence E. Condit, Attorney
c/o 376 South Stone Avenue
Tucson, Arizona state
Postal Zone 85701/tdc
FROM: Paul Andrew Mitchell, B.A., M.S.
Counselor at Law
DATE: March 11, 1997
SUBJECT: Neil T. Nordbrock
I hold material evidence which indicates that you may be in
possession of stolen property.
As of 5:00 p.m. on Thursday, January 2, 1997, Mr. Neil T.
Nordbrock had embezzled $3,000 of Mine which I had entrusted to
his care and accounting.
At the start of My dispute with Mr. Nordbrock, he indicated to
Me, in the presence of his spouse, that he had decided to pay
your proposed retainer of $10,000, in order to retain your
services on the Nordbrocks' Quiet Title action in state court,
and on other legal matters.
Mr. Nordbrock took the liberty of showing Me your written
proposal, in which the $10,000 retainer was quoted.
If the Nordbrocks have, indeed, retained your services, it is
evident to Me that they paid a portion of your retainer with the
$3,000 which they embezzled from Me.
I hereby request that you return the $3,000 to Me directly, using
blank U.S. Postal Money Orders shipped via Registered United
States Mail to the mailing location shown below. The office
manager at that location has been authorized, in writing, to sign
for Me.
Please also provide Me with written confirmation that you have,
in fact, been retained by the Nordbrocks, and also indicate
thereon if you have power of attorney to represent them in
criminal matters. Finally, I will need a certified copy of your
license to practice law in the State of Arizona.
If you wish to discuss this matter on the telephone, please
contact Mr. Richard Scully, a professional mediator hired by Me
to negotiate an equitable solution with the Nordbrocks. Mr.
Scully's pager is (602) 665-7522. Please do not call Me
concerning this matter; I have better things to do with My time.
Thank you very much for your consideration.
Third Notice and Demand for Mandatory Judicial Notice:
Page 32 of 34
Sincerely yours,
/s/ Paul Andrew Mitchell
Paul Andrew Mitchell, B.A., M.S.
Counselor at Law and federal witness
c/o 2509 N. Campbell, #1776
Tucson, Arizona state
Postal Zone 85719/tdc
email: supremelawfirm@altavista.net
website: http://supremelaw.com
copy: Chief of Police, Tucson, Arizona state
Detective, Tucson Police Department
Third Notice and Demand for Mandatory Judicial Notice:
Page 33 of 34
MEMO
TO: Detective Robert Soltero
Tucson City Police Department
FROM: Paul Andrew Mitchell, B.A., M.S.
Counselor at Law
DATE: March 13, 1997
SUBJECT: TPD Case Number #9701050374
(see also case number #9702110162)
I am providing you herewith with evidence of a phony check,
in the amount of $398,000.00, tendered by Neil Thomas Nordbrock
to the Internal Revenue Service on February 13, 1996.
See the enclosed documentation, which was recently filed in
the Pima County Consolidated Justice Court, civil case number
#CV-97-3438.
Thank you very much for your consideration.
Sincerely yours,
/s/ Paul Andrew Mitchell
Paul Andrew Mitchell, B.A., M.S.
Counselor at Law and federal witness
c/o 2509 N. Campbell Avenue, #1776
Tucson, Arizona state
Postal Zone 85719/tdc
email: supremelawfirm@altavista.net
website: http://supremelaw.com
Third Notice and Demand for Mandatory Judicial Notice:
Page 34 of 34
# # #
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Mitchell v. Nordbrock