Paul Andrew Mitchell, Sui Juris
c/o general delivery at:
2509 North Campbell Avenue, #1776
Tucson [ZIP code exempt]
ARIZONA STATE, USA

In Propria Persona

All Rights Reserved,
without prejudice





                  DISTRICT COURT OF TEXAS STATE

                           HAYS COUNTY


Paul Andrew Mitchell,           )  Case No. #CV-98-0547
                                )
          Plaintiff,            )  VERIFIED CRIMINAL COMPLAINT
                                )
     v.                         )  28 U.S.C. 1746(1);
                                )  Supremacy Clause
City of San Marcos,             )
San Marcos Utility,             )
Community Action, Inc.          )
  of Hays, Caldwell, &          )
  Blanco Counties,              )
Century Telephone, Inc.,        )
and Does 1 thru 25,             )
                                )
          Defendants.           )
________________________________)


COMES  NOW  Paul  Andrew  Mitchell,  Citizen  of  Arizona  state,

expressly not a citizen of the United States ("federal citizen"),

Counselor at Law, qualified Federal Witness, and Private Attorney

General (hereinafter  "Plaintiff"), to  file this,  his  VERIFIED

CRIMINAL COMPLAINT  against the  following individuals,  for  the

corresponding crimes  enumerated infra,  and  to  provide  formal

Notice to all interested Party(s) of same.


            Verified Criminal Complaint:  Page 1 of 8


     Plaintiff hereby formally charges:


Jane Doe #1, a/k/a female arresting officer, with:

     attempting to  compel disclosure of a Social Security Number
     ("SSN") on  the morning  of March  11, 1998  ("3/11/98"), in
     direct violation of Title 42, United States Code ("U.S.C."),
     section 408(a)(8), and of Public Law 93-579, one count;

     retaliating against  a federal  witness and  victim  on  the
     morning of 3/11/98, in direct violation of Title 18, U.S.C.,
     section 1513, one count;

     deprivation of Plaintiff's fundamental Rights on 3/11/98, in
     direct violation  of Title  18,  U.S.C.,  section  242,  one
     count;

     conspiracy to  deprive  Plaintiff's  fundamental  Rights  on
     3/11/98, in  direct violation  of Title  18, U.S.C., section
     241, one count;  and,

     false arrest  and false  imprisonment on  3/11/98, in direct
     violation of  Texas Penal  Code ("P.C.")  section 20.02, one
     count.


John Doe #2, a/k/a male arresting officer, with:

     attempting to  compel disclosure of an SSN on the morning of
     March 11, 1998 ("3/11/98"), in direct violation of Title 42,
     U.S.C., section  408(a)(8), and  of Public  Law 93-579,  one
     count;

     retaliating against  a federal  witness and  victim  on  the
     morning of 3/11/98, in direct violation of Title 18, U.S.C.,
     section 1513, one count;

     deprivation of Plaintiff's fundamental Rights on 3/11/98, in
     direct violation  of Title  18,  U.S.C.,  section  242,  one
     count;

     conspiracy to  deprive  Plaintiff's  fundamental  Rights  on
     3/11/98, in  direct violation  of Title  18, U.S.C., section
     241, one count;  and,

     false arrest  and false  imprisonment on  3/11/98, in direct
     violation of  Texas Penal  Code ("P.C.")  section 20.02, one
     count.


Mrs. Pamela Cook with:

     deadly conduct,  also known  as  reckless  endangerment,  in
     direct violation  of Texas P.C. section 22.05, in connection
     with the  creation and execution of company directives given
     to telephone  answering service  operators, to  dispatch tow
     trucks  before  dispatching  medical  emergency  calls  from
     hospital intensive  care  units  and  emergency  rooms,  one
     count;  and,


            Verified Criminal Complaint:  Page 2 of 8


Mrs. Pamela Cook (continued):

     theft of  material evidence  and other  private property, in
     direct violation  of Texas P.C. section 31.03, in connection
     with the  disappearance of  Plaintiff's household dishes and
     printed  documentary   evidence  (2   volumes)  of  criminal
     copyright violations on the Internet, one count.


Mr. Ronald Holmes with:

     assaulting a  federal witness  and victim  on May  21,  1998
     ("5/21/98"),  in  direct  violation  of  Title  18,  U.S.C.,
     section 1513, one count;

     deprivation of Plaintiff's fundamental Rights on 5/21/98, in
     direct violation  of Title  18,  U.S.C.,  section  242,  one
     count;  and,

     attempted extortion  of cash  money by threatening Plaintiff
     with the  loss of  adequate housing  on 5/21/98,  in  direct
     violation of Texas P.C. sections 31.01 and 31.03, one count.


Mrs. Joyce M. Jones with:

     false statement(s)  to obtain  one hundred dollars ($100.00)
     of property  or credit,  in direct  violation of  Texas P.C.
     section 32.32,  in connection  with Plaintiff's  contract to
     sublet the  apartment at  108 Uhland  Road, Unit  #1, in the
     city of San Marcos, Texas state, one count;

     theft and/or  unlawful conversion  of Plaintiff's  notarized
     Affidavit of  Identification, in  direct violation  of Texas
     P.C. sections 31.01 and 31.03, one count;

     deprivation of  Plaintiff's fundamental  Rights,  in  direct
     violation of  Title 18,  U.S.C., section  242, one  or  more
     counts;

     conspiracy to  deprive Plaintiff's  fundamental  Rights,  in
     direct violation  of Title  18, U.S.C.,  section 241, one or
     more counts;  and,

     civil breach of rental contract, one count.


Mr. David Jordan with:

     theft  of  services,  in  direct  violation  of  Texas  P.C.
     sections 31.01  and 31.03,  in connection  with  Plaintiff's
     failure to  be paid  for one hundred seven dollars ($107.00)
     worth of private contract labor, one count.


            Verified Criminal Complaint:  Page 3 of 8


Mrs. Gwen Norris with:

     deadly conduct,  also known  as  reckless  endangerment,  in
     direct violation  of Texas P.C. section 22.05, in connection
     with the  creation and execution of company directives given
     to telephone  answering service  operators, to  dispatch tow
     trucks  before  dispatching  medical  emergency  calls  from
     hospital intensive  care  units  and  emergency  rooms,  one
     count.


Mr. Tommy Norris with:

     deadly conduct,  also known  as  reckless  endangerment,  in
     direct violation  of Texas P.C. section 22.05, in connection
     with the  creation and execution of company directives given
     to telephone  answering service  operators, to  dispatch tow
     trucks  before  dispatching  medical  emergency  calls  from
     hospital intensive  care  units  and  emergency  rooms,  one
     count;

     impersonating a public servant, in direct violation of Title
     4, U.S.C., section 101, and of Texas P.C. section 37.11, one
     count;

     deprivation of  Plaintiff's fundamental  Rights,  in  direct
     violation of  Title 18,  U.S.C., section  241, in connection
     with wrongful  termination of  Plaintiff from  the  Tellcall
     Answering Service or its successor in interest, one count;

     conspiracy to  deprive Plaintiff's  fundamental  Rights,  in
     direct violation  of  Title  18,  U.S.C.,  section  241,  in
     connection with  wrongful termination  of Plaintiff from the
     Tellcall Answering Service or its successor in interest, one
     count;  and,

     wrongful termination, civil, one count.



Mr. John Polanco, Jr., with:

     impersonating a public servant, in direct violation of Title
     4, U.S.C.,  section 101,  and Texas  P.C. section 37.11, one
     count;

     being an  accessory to  theft, after  the  fact,  in  direct
     violation of  Texas P.C.  sections 7.01, 7.02, and 31.03, in
     connection with  the disappearance  of Plaintiff's household
     dishes and  printed  documentary  evidence  (2  volumes)  of
     criminal copyright violations on the Internet, one count;

     abuse of  official capacity,  in direct  violation of  Texas
     P.C. section 39.02, in connection with Plaintiff's temporary
     detention by  Hays County  Constables, and compelled meeting
     in chambers  to discuss lawful documents served by Plaintiff
     on individuals named herein, one count;


            Verified Criminal Complaint:  Page 4 of 8

Mr. John Polanco, Jr. (continued):

     misuse of  official information,  in direct  information  of
     Texas P.C.  39.06, in  connection with  the disappearance of
     Plaintiff's printed  documentary  evidence  (2  volumes)  of
     criminal copyright  violations on  the Internet, and alleged
     "complaints" [sic]  lodged by  Mr. Tommy Norris and possibly
     other as yet unnamed individuals, one count;  and,

     violation of  Plaintiff's fundamental  Rights, also known as
     "civil  rights"   [sic],  specifically  including,  but  not
     limited to,  due process  of law, while Plaintiff was in the
     custody  of  Hays  County  Constables,  in  connection  with
     alleged "complaints"  [sic] lodged  by Mr.  Tommy Norris and
     possibly other as yet unnamed individuals, one count.


Mr. Andrew Thomas Scott with:

     obstruction and/or  attempted obstruction  of United  States
     Mail deliverable to Plaintiff c/o 508 Uhland Road, Unit 110,
     in the  city of San Marcos, Texas state, in direct violation
     of Title 18, U.S.C., section 1701, one count;  and,

     grand theft  and/or attempted  grand  theft  of  Plaintiff's
     private property  in a high-performance computer network and
     all related  hardware, software,  peripherals, and databases
     loaded on  same, valued  in excess of $350,000.00, in direct
     violation of  Texas  P.C.  sections  31.01  and  31.03,  two
     counts.


Ms. Jennifer Van Alstyne with:

     deadly conduct,  also known  as  reckless  endangerment,  in
     direct violation  of Texas P.C. section 22.05, in connection
     with the  creation and execution of company directives given
     to telephone  answering service  operators, to  dispatch tow
     trucks  before  dispatching  medical  emergency  calls  from
     hospital intensive  care  units  and  emergency  rooms,  one
     count;

     deprivation of  Plaintiff's fundamental  Rights,  in  direct
     violation of  Title 18,  U.S.C., section  242, in connection
     with wrongful  termination of  Plaintiff from  the  Tellcall
     Answering Service or its successor, one count;  and,

     conspiracy to  deprive Plaintiff's  fundamental  Rights,  in
     direct violation  of  Title  18,  U.S.C.,  section  241,  in
     connection with  wrongful termination  of Plaintiff from the
     Tellcall Answering Service or its successor in interest, one
     count.


            Verified Criminal Complaint:  Page 5 of 8


Mr. Ed Worndel with:

     assaulting a  federal witness  and victim on May 6, 1998, in
     direction violation  of Title  18, U.S.C., section 1513, one
     count;

     deprivation of  Plaintiff's fundamental  Rights,  in  direct
     violation of Title 18, U.S.C., section 242, one count;

     conspiracy to  deprive Plaintiff's  fundamental  Rights,  in
     direct violation  of Title  18,  U.S.C.,  section  241,  one
     count;  and,

     civil breach of rental contract.


                        NOTICE OF INTENT


     Plaintiff hereby  provides formal  Notice to  all interested

Party(s) of  Plaintiff's specific  intent to  execute, file,  and

service the  requisite AFFIDAVIT(S)  OF PROBABLE  CAUSE, so as to

substantiate each  and every  charge made  above, as soon as time

and resources permit.


                          VERIFICATION

     I, Paul  Andrew Mitchell,  Plaintiff in  the above  entitled

matter, hereby  verify, under  penalty of perjury, under the laws

of the  United States  of America,  without (outside) the "United

States" (federal  government), that  the above statement of facts

and laws is 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).  See Supremacy Clause.


Dated:  September 24, 1998


Respectfully submitted,

/s/ Paul Andrew Mitchell

Paul Andrew Mitchell, B.A., M.S., Sui Juris
Citizen of Arizona state, expressly not a federal citizen,
Counselor at Law, Federal Witness, Private Attorney General, and
Candidate for the United States House of Representatives


            Verified Criminal Complaint:  Page 6 of 8


                        PROOF OF SERVICE

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"  (federal government), that I am the

Plaintiff in  the above  entitled matter,  that I am a Citizen of

ONE OF  the United  States of America, and that I transmitted the

following document(s):


                   VERIFIED CRIMINAL COMPLAINT


by placing  same in  first class  United States Mail, with proper

postage prepaid, and properly directed to each of the following:


San Marcos Utility              Community Action, Inc.
c/o 630 E. Hopkins St.          c/o 101 Uhland Road, #1
San Marcos, Texas state         San Marcos, Texas state

Century Telephone, Inc.         City of San Marcos
c/o 208 S. Guadalupe Street     c/o 630 E. Hopkins Street
San Marcos, Texas state         San Marcos, Texas state

Mr. John Polanco, Jr.           Mr. David Jordan
c/o 1307 East Uhland Road       2015 Aspen Street
San Marcos, Texas state         San Marcos, Texas state

Mr. Andrew Thomas Scott         (last known address)
c/o 508 Uhland Road, #110
San Marcos, Texas state

Mr. Tommy & Mrs. Gwen Norris    (last known address)
c/o Tellcall Answering Service
423 N. LBJ Drive, Ste. "F"
San Marcos, Texas state

Mrs. Pamela Cook                (last known address)
c/o Tellcall Answering Service
423 N. LBJ Drive, Ste. "F"
San Marcos, Texas state

Mr. Ronald Holmes               (last known address)
c/o 508 Uhland Road, Ste. 110
San Marcos, Texas state

Ms. Jennifer Van Alstyne        (last known address)
c/o Tellcall Answering Service
423 N. LBJ Drive, Ste. "F"
San Marcos, Texas state


            Verified Criminal Complaint:  Page 7 of 8


Mr. Ed Worndel                  (last known address)
c/o 108 Uhland Road, Unit #1
San Marcos, Texas state

Mrs. Joyce M. Jones
c/o Rev. Jim Lanning            (last known address)
1904 Ranch Road 12, Suite 114
San Marcos, Texas state


Courtesy copies to:

Postmaster
United States Post Office
San Marcos, Texas state

Judge Alex Kozinski (supervising)
Ninth Circuit Court of Appeals
c/o P.O. Box 91510
Pasadena, California state

Office of the Attorney General
Civil Rights Division
State of Texas
State Capitol
Austin, Texas state

Detective Scott A. Johnson
San Marcos Police Department
2300 IH 35 South
San Marcos, Texas state


Date:  September 24, 1998


Respectfully submitted,

/s/ Paul Andrew Mitchell

Paul Andrew Mitchell, B.A., M.S., Sui Juris
Citizen of Arizona state, expressly not a federal citizen,
Counselor at Law, Federal Witness, Private Attorney General, and
Candidate for the United States House of Representatives


            Verified Criminal Complaint:  Page 8 of 8


                             #  #  #
      


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Mitchell v. City of San Marcos et al.