Time: Thu Aug 28 07:35:36 1997
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	Thu, 28 Aug 1997 07:34:48 -0700 (MST)
Date: Thu, 28 Aug 1997 10:34:39 -0400
Originator: heritage-l@gate.net
From: Paul Andrew Mitchell [address in tool bar]
To: pmitch@primenet.com
Subject: SLF: OFFER TO PROVE RACKETEERING infra

<snip>
>
>Subject: SLF: OFFER TO PROVE RACKETEERING infra
>
>[This text is formatted in Courier 11, non-proportional spacing.]
>
>
>Paul Andrew Mitchell, Sui Juris
>Citizen of Arizona state
>c/o general delivery at:
>2509 North Campbell Ave., #1776
>Tucson [zip code exempt]
>ARIZONA STATE
>
>In Propria Persona
>
>All Rights Reserved
>without prejudice
>
>
>
>
>          IN THE SUPERIOR COURT OF THE STATE OF ARIZONA
>
>                  IN AND FOR THE COUNTY OF PIMA
>
>
>Swan Business Organization      )  Case Number #315580
>et al.,                         )
>                                )  APPLICANT'S OPPOSITION
>          Plaintiffs,           )  TO PLAINTIFFS' MOTION TO
>                                )  STRIKE NOTICE OF INTENT
>     v.                         )  TO APPLY FOR INTERVENTION:
>                                )
>Leon Ulan et al.,               )  Petition Clause,
>                                )  First Amendment
>          Defendants.           )
>________________________________)
>
>
>COMES NOW  Paul Andrew  Mitchell, Sui  Juris, Citizen  of Arizona
>
>state, expressly  not a  citizen of  the United  States ("federal
>
>citizen"), federal  witness (hereinafter  "Applicant"), and  Vice
>
>President for Legal Affairs of New Life Health Center Company, an
>
>unincorporated business  trust domiciled in Arizona ("New Life"),
>
>to submit  this, Applicant's  formal  OPPOSITION  TO  PLAINTIFF'S
>
>MOTION TO  STRIKE NOTICE OF INTENT TO APPLY FOR INTERVENTION, and
>
>to provide formal Notice of same to all interested party(s).
>
>     Applicant opposes the Plaintiffs' MOTION TO STRIKE NOTICE OF
>
>INTENT TO  APPLY FOR  INTERVENTION ("STRIKE  MOTION"), for all of
>
>the following reasons, to wit:
>
>
>     Applicant's Opposition to Strike Motion:  Page 1 of 20
>
>
>                  STRIKE MOTION IS OUT OF ORDER
>
>     In order  to prepare  Applicant's NOTICE  OF INTENT TO APPLY
>
>FOR INTERVENTION,  Applicant visited  the Clerk  of the  Superior
>
>Court of the State of Arizona, in and for the County of Pima, and
>
>was graciously  permitted to  inspect the official docket file of
>
>the instant  case #315580.  On that day, Applicant witnessed, and
>
>herein testifies  to the fact that, the most recent entry was the
>
>Court's ORDER  placing the  instant case  on inactive  status (or
>
>language to  that effect).   Applicant begs the indulgence of the
>
>Superior Court,  if Applicant's memory is not entirely exact with
>
>respect to said language.  Let substance prevail over form.
>
>     Plaintiffs' STRIKE  MOTION  is,  therefore,  out  of  order,
>
>because the instant case is presently inactive, and would need to
>
>revert to active status, but only by ORDER of the Superior Court.
>
>No such relief has been requested in the STRIKE MOTION.
>
>
>             STRIKE MOTION PETITIONS THE WRONG COURT
>
>     The instant case #315580 was first filed and now proceeds in
>
>the Superior Court of the State of Arizona, in and for the County
>
>of Pima.   The  STRIKE MOTION,  on the  other hand, petitions the
>
>Superior Court  of Arizona, Pima County.  These respective courts
>
>are not one and the same.  See 31 CFR 51.2 and 52.2;  Form II(b),
>
>WARRANT FOR  ARREST (SUPERIOR  COURT) SUPERIOR  COURT OF ARIZONA,
>
>________ County [sic], and Form XXIII, NOTICE OF RIGHTS OF REVIEW
>
>AFTER CONVICTION IN THE SUPERIOR COURT OF THE STATE OF ARIZONA IN
>
>AND FOR  THE COUNTY OF ________ [sic], in Arizona Rules of Court,
>
>State and Federal, West Publishing Company (1994).
>
>     The Superior  Court of  the State  of Arizona  is a de facto
>
>forum convened  pursuant to  federal  municipal  law,  proceeding
>
>under the  presumption that Arizona is a federal territory, not a
>
>Union state.  This presumption is enforceable upon the population
>
>of citizens  of the United States ("federal citizens") who reside
>
>within the  geographic boundaries  of Arizona state, because they
>
>are subject to federal municipal law.
>
>
>     Applicant's Opposition to Strike Motion:  Page 2 of 20
>
>
>     The Superior  Court of  Arizona is  a de jure forum convened
>
>pursuant to  Arizona organic  law,  proceeding  under  the  Tenth
>
>Amendment and  under other notable provisions of the supreme Law,
>
>which admitted Arizona into the Union of several states which are
>
>united by  and under  the Constitution  for the  United States of
>
>America, as lawfully amended ("U.S. Constitution").
>
>     To the  extent that the STRIKE MOTION requests relief of the
>
>wrong forum,  it is  once again out of order and, moreover, fails
>
>to state  a claim upon which relief can be granted.  Accordingly,
>
>the  STRIKE  MOTION  should  be  denied,  or  tabled  for  future
>
>consideration and  possibly also  future amendment by Plaintiffs,
>
>to correct these and other serious errors.
>
>
>                 STRIKE MOTION EXHIBITS A FRAUD
>
>     Applicant  directs  the  attention  of  this  Court  to  the
>
>following published legal definition of the term "fraud", as said
>
>term applies in the instant matter, to wit:
>
>     Fraud.   ... A  false representation of a matter of fact ...
>     by concealment  of that  which should  have been  disclosed,
>     which deceives and is intended to deceive another so that he
>     shall act upon it to his legal injury.      [emphasis added]
>
>Applicant argues that Plaintiffs had an obligation to disclose to
>
>this Court the related litigation which is underway in two cases:
>
>Mitchell v.  Nordbrock, Pima  County Consolidated  Justice  Court
>
>("Justice Court")  case number  #CV-97-3438, and  People ex  rel.
>
>Mitchell v.  Pima County  Consolidated  Justice  Court,  Superior
>
>Court of Arizona, Pima County, case number #320831.
>
>
>     Applicant's Opposition to Strike Motion:  Page 3 of 20
>
>
>     The  latter   case  has  arisen  out  of  the  barratry  and
>
>unprofessional conduct  which Applicant  alleges that  Plaintiffs
>
>and Plaintiffs'  "attorney" have  committed in  the former  case.
>
>Specifically, in Mitchell v. Nordbrock, the named defendants, who
>
>are Plaintiffs  in the  instant case,  filed a counterclaim which
>
>stated a  claim above  the Justice  Court's jurisdictional limit.
>
>Applicant, who  is the  plaintiff in  the latter  case,  followed
>
>immediately with  a DEMAND  to transfer that case to the Superior
>
>Court, pursuant  to ARS  22-201(F).   Contrary to  the imperative
>
>duty imposed  upon the Justice of the Peace in the Justice Court,
>
>said DEMAND was "denied" [sic] by Mr. Walter U. Weber.  Applicant
>
>now claims that said "denial" was ultra vires.
>
>     In  order  to  prove  Applicant's  claim  that  Mr.  Weber's
>
>"denial" was  done ultra vires, Applicant has sought a Peremptory
>
>Writ of  Mandamus from  the Superior  Court of Arizona, to compel
>
>the Justice  Court to  perform  its  duty  under  ARS  22-201(F).
>
>Applicant's PETITION  FOR PEREMPTORY  WRIT OF MANDAMUS ("MANDAMUS
>
>PETITION") is  attached hereto as Exhibit "A" and incorporated by
>
>reference, as if set forth fully herein.
>
>     Despite the  filing of  said MANDAMUS  PETITION and  service
>
>upon them,  Plaintiffs and  their  "attorney"  countered  with  a
>
>motion to  amend their  counterclaim, so  as to  reduce it  to an
>
>amount below  the Justice Court's jurisdictional limit of $5,000.
>
>Said motion to amend their counterclaim was then "granted" by Mr.
>
>Walter U.  Weber.   Applicant argues  that Plaintiffs' "attorney"
>
>knew, or should have known, the upper jurisdictional limit of the
>
>Justice Court.   In  point of  fact, the  Plaintiffs'  "attorney"
>
>attempted to  bluff Applicant  early on, by threatening to file a
>
>counterclaim which would transfer that case to the Superior Court
>
>anyway.  Said bluff was left on Applicant's answering machine.
>
>
>     Applicant's Opposition to Strike Motion:  Page 4 of 20
>
>
>     Applicant now alleges that such unlawful conduct constitutes
>
>barratry.   Confer at "Barratry" in Black's Law Dictionary, Sixth
>
>Edition, and cases cited there.  Barratry is a crime.
>
>     The STRIKE  MOTION  fails  even  to  mention  said  MANDAMUS
>
>PETITION.   Applicant argues  that the  MANDAMUS PETITION  should
>
>have been  mentioned by  Plaintiffs, but  was not.   Accordingly,
>
>their failure  to disclose  what should  have been  disclosed has
>
>worked a  fraud upon this honorable Court by Plaintiffs and their
>
>"attorney", and  has resulted  in inflicting  yet more  fraud and
>
>barratry upon Applicant, for all the reasons state above.
>
>     Nevertheless, Plaintiffs appear to defeat their own argument
>
>by stating,  at line  7 on  page 2,  that "the superior court may
>
>properly take  judicial notice  of its own records and records in
>
>another action tried in the same court."  Citing State v. Camino,
>
>118 Ariz.  89, 574  P.2d 1308  (1977) and  State v.  Astorga,  26
>
>Ariz.App. 252,  526 P.2d 776 (1974) [sic].  Plaintiffs then argue
>
>that the  court "may  not take  judicial notice  of a  particular
>
>legal proceeding pending or transacted in another court."  Citing
>
>In re Henry's Estate, 6 Ariz.App. 183, 430 P.2d 937 (1967).
>
>     Applicant argues  that Plaintiffs  had a duty to disclose to
>
>this Court the records of another action tried in the same court,
>
>because Plaintiffs  do believe  that the  Superior Court  of  the
>
>State of  Arizona, and  the Superior  Court of Arizona state, are
>
>one and  the same.  Applicant argues here that the Full Faith and
>
>Credit Clause  controls in this matter.  See the Supremacy Clause
>
>for authority.    Nevertheless,  this  relatively  complex  issue
>
>should not  be litigated  until after  Applicant formally applies
>
>for intervention, and Applicant is under no obligation to do so.
>
>
>     Applicant's Opposition to Strike Motion:  Page 5 of 20
>
>
>            STRIKE MOTION CHILLS THE PETITION CLAUSE
>
>     To the  extent that  the STRIKE  MOTION seeks  to  argue  to
>
>conclusions which  are based upon Rule 24, Arizona Rules of Civil
>
>Procedure, the  STRIKE MOTION  is entirely moot because Applicant
>
>has not  yet formally  applied for intervention, and may not ever
>
>apply for intervention, depending on future events which have not
>
>yet transpired, and may never happen.
>
>     Moreover, to  the extent  that the  STRIKE MOTION  seeks  to
>
>impair Applicant's  fundamental Right  to Petition Government for
>
>Redress of  Grievances, pursuant  to the  First Amendment  in the
>
>U.S. Constitution, any ORDER from this Court purporting to impair
>
>that Right is necessarily ultra vires ab initio, for chilling and
>
>prior restraint  upon Applicant's Right to Petition the courts of
>
>this  land,  for  intervention  and/or  any  other  relief  which
>
>Applicant seeks  to obtain  from the  courts.  For the benefit of
>
>this honorable  Court, Applicant  attaches,  as  Exhibit  "B",  a
>
>pleading filed  by Applicant  in the Justice Court, detailing the
>
>pertinent cases which have adjudicated the Petition Clause.
>
>     Applicant believes  that  this  Court,  upon  reviewing  the
>
>authorities cited in Exhibit "B", will observe its duty to uphold
>
>the Petition Clause in the First Amendment, either by denying the
>
>STRIKE MOTION  or, in  the alternative, tabling the STRIKE MOTION
>
>until such time as Applicant formally applies for Intervention in
>
>the Superior  Court of  the State  of Arizona,  and  not  in  the
>
>Superior Court of Arizona.
>
>
>     Applicant's Opposition to Strike Motion:  Page 6 of 20
>
>
>               PLAINTIFFS ASSUME FUTURE KNOWLEDGE
>
>     The law  does not  recognize impossibilities.  Lex non cogit
>
>impossibilia.   Plaintiffs have attempted to argue to a straw man
>
>by  predicting  that  Applicant  "will  engage  in  a  calculated
>
>campaign  of   pleadings  harassment   against  the  Nordbrocks."
>
>Plaintiffs should  not be permitted to persuade this Court on the
>
>basis of any special knowledge they might claim about the future.
>
>     Furthermore, Plaintiffs  allege  that  none  of  Applicant's
>
>pleadings filed in Mitchell v. Nordbrock "are remotely related to
>
>the underlying  issues" [in  the instant  case].  Plaintiffs also
>
>allege that  Applicant has made "numerous unfounded challenges to
>
>justice court  jurisdiction and  to  the  justice  of  the  peace
>
>assigned to  [that] case."   In  opposition to  these  false  and
>
>rebuttable claims, Plaintiff testifies as follows:
>
>     1.   Plaintiffs have  embezzled  approximately  $3,000  from
>
>Applicant.   This sum was all the money which Applicant possessed
>
>in the  world, at that point in time.  They did so in retaliation
>
>against Applicant,  because  Applicant  had  exposed  Plaintiffs'
>
>complicity in  perpetrating fraud and mail fraud upon New Life --
>
>by creating and maintaining a fictitious trustee.  Applicant was,
>
>and still is, the Vice President for Legal Affairs of New Life.
>
>     2.   Plaintiffs have  refused to return Applicant's private,
>
>confidential database  which was  stored on  a one  (1)  gigabyte
>
>(billion character)  Iomega JAZ  disk cartridge  and entrusted to
>
>Plaintiffs for  safe keeping.   Plaintiffs  also knew  well  that
>
>Applicant's life  had  been  threatened  by  one  of  Plaintiffs'
>
>business associates  in the fall of 1996, and Applicant concluded
>
>from that  frightening experience  that it was unwise to keep any
>
>money in  Applicant's dwelling unit.  Plaintiffs agreed to manage
>
>
>     Applicant's Opposition to Strike Motion:  Page 7 of 20
>
>
>Applicant's $3,000  and to  keep said  disk cartridge  in a  safe
>
>place  --   a  locked  gun  safe  --  until  receipt  of  further
>
>instructions from Applicant.  Although Applicant has demanded the
>
>return of  this private,  confidential database,  which took more
>
>than seven (7) years of research to assemble, but Plaintiffs have
>
>now refused to return it.  Accordingly, they are in possession of
>
>stolen property  and are  liable  for  damages  to  Applicant  --
>
>actual, consequential,  and  punitive.    Therefore,  Plaintiffs'
>
>estate is now clouded, it is in real jeopardy, and it may need to
>
>be foreclosed  to  discharge  Plaintiffs'  legal  liabilities  to
>
>Applicant.  Plaintiff expressly reserves these Rights.
>
>     3.   Applicant has additional evidence which is essential to
>
>prove: (1)  Swan Business  Organization may,  in fact, be nothing
>
>more than  a nominee,  or alter  ego, for  the private  estate of
>
>Plaintiffs, and  (2) their  respective tax and other liabilities,
>
>if any,  can be  offset by  foreclosing  upon  the  same  estate.
>
>Applicant would,  in that  event, have probable cause formally to
>
>apply for  intervention in  the instant  case, to  adjudicate the
>
>respective priorities of all judgment creditors and claimants.
>
>     More  to  the  point,  Applicant  has  performed  labor  for
>
>Plaintiffs, and  Applicant argues  that  compensation  for  labor
>
>takes precedence over any alleged tax liability(s).
>
>     4.   Plaintiff Neil  T. Nordbrock has also recently insulted
>
>Applicant verbally  in the  lobby of  the Coronado Station of the
>
>U.S. Postal Service;  and prior to that unfortunate incident, Mr.
>
>Nordbrock intentionally startled Applicant by blaring Nordbrock's
>
>truck horn as Nordbrock approached Applicant from the rear, while
>
>Applicant was  walking on  a sidewalk  near Applicant's dwelling.
>
>
>     Applicant's Opposition to Strike Motion:  Page 8 of 20
>
>
>These events are commemorated in Applicant's NOTICE AND DEMAND TO
>
>CEASE  AND   DESIST,  which   is  attached  as  Exhibit  "C"  and
>
>incorporated by reference, as if set forth fully herein.
>
>     5.   Finally,  in   the  event  that  Plaintiffs  should  be
>
>compelled to  seek bankruptcy  protection, the  question of  debt
>
>priorities would inevitably arise in that forum as well.  Debtors
>
>cannot discharge fines and/or penalties that a federal, state, or
>
>local government  has imposed  to punish  debtors for violating a
>
>law.  Specifically, bankrupt debtors cannot discharge restitution
>
>payments that might be imposed in criminal cases.  Restitution is
>
>specifically non-dischargeable  because it is imposed against the
>
>defendant(s) as  rehabilitation, rather  than to  compensate  the
>
>victim.  See Kelly v. Robinson, 107 S.Ct. 353 (1986).
>
>     Applicant  argues   that  Plaintiffs'   retaliation  against
>
>Applicant constitutes  criminal conduct,  quite  apart  from  the
>
>question of  whether, or not, Arizona state prosecutors presently
>
>can, or ever will, prosecute them criminally.  See 18 U.S.C. 1512
>
>and 1513.  Embezzlement of $3,000 is a class 3 felony in Arizona.
>
>See ARS 13-1802(A), in chief.
>
>     Given that  the plaintiff  in Mitchell v. Nordbrock has also
>
>filed a  formal challenge  to the juror qualification statutes in
>
>Arizona, it  may be  a very  long time  before  a  competent  and
>
>qualified state grand jury can be convened to hear evidence which
>
>Applicant has  already  sought  to  bring  before  such  a  jury.
>
>Applicant now refuses to testify to any "grand jury" which is not
>
>a legal  body, and  will oppose  any subpoena(s) from state grand
>
>juries for  the same  reason, pending final review of Applicant's
>
>formal challenge to juror and voter registrant qualifications.
>
>
>     Applicant's Opposition to Strike Motion:  Page 9 of 20
>
>
>           PLAINTIFFS' ARGUMENT CALLS FOR CONCLUSIONS
>
>     Plaintiffs have  charged Applicant with filing a "frivolous,
>
>legally unreasonable,  and factually  unfounded pleading"  [sic].
>
>Applicant submits  that such adjectives call for findings of fact
>
>and conclusions  of  law,  which  can  only  result  from  proper
>
>adjudication,  and   declaratory  relief  from  a  competent  and
>
>qualified trial  jury, after  due  process  has  run  its  proper
>
>course.   Applicant hereby reserves all Rights without prejudice,
>
>including Applicant's  fundamental Right  to trial by jury in all
>
>controversies exceeding  twenty  dollars.    See  the  Fifth  and
>
>Seventh Amendments,  in chief.    Fundamental  Rights  are  never
>
>frivolous, unreasonable, or unfounded.
>
>
>                   OFFER TO PROVE RACKETEERING
>
>     Applicant has  also been  an eyewitness,  during the past 18
>
>months, to  a property conversion racket now being perpetrated by
>
>means of  bogus "commercial  warrants" and  "documentary  drafts"
>
>[sic] urged  upon naive  followers by  the likes  of M. Elizabeth
>
>Broderick ("Broderick"), of Palmdale, California state, and LeRoy
>
>Michael Schweitzer ("Schweitzer"), of Billings, Montana state.
>
>     Broderick was  recently convicted  in  Los  Angeles  federal
>
>court  of  twenty-six  (26)  counts  of  fraud  and  bank  fraud;
>
>Schweitzer is  under indictment  in Billings for similar charges.
>
>Applicant was  retained  by  both  Broderick  and  Schweitzer  to
>
>provide services  as a Counselor at Law in their respective cases
>
>but, after  Applicant submitted  separate invoices to each client
>
>in excess  of $10,000,  both  Broderick  and  Schweitzer  refused
>
>payment for same (approx. $20,000 total).
>
>     Applicant can ill afford such economic retaliation.
>
>
>     Applicant's Opposition to Strike Motion:  Page 10 of 20
>
>
>     Plaintiffs have  promoted the questionable legal theories of
>
>Broderick and  Schweitzer, even  going so far as to tender one of
>
>Schweitzer's commercial warrants to the Internal Revenue Service,
>
>to  discharge  Plaintiffs'  outstanding  federal  tax  liability.
>
>Evidence of  this bogus  warrant has  been filed  in Mitchell  v.
>
>Nordbrock.   Said warrant  by Plaintiffs  is a matter of material
>
>evidence, of which this Court should take formal judicial Notice.
>
>     Applicant is  now  actively  pursuing  more  evidence  which
>
>traces these  bogus commercial  warrants to a property conversion
>
>racket being  orchestrated out  of the U.S. Department of Justice
>
>("DOJ") in downtown Los Angeles, California state.  The "bounced"
>
>warrants  are   delivered  there   by  the   Federal  Bureau   of
>
>Investigation ("FBI"),  after electronic  dossiers are  assembled
>
>which lead FBI and DOJ employees directly to large asset groups.
>
>     These asset  groups are then targeted for foreclosure and/or
>
>forfeiture, under  federal banking  and postal  laws.   Selective
>
>prosecution is then begun against certain individuals, in part to
>
>make examples  out of  them, to  forfeit their  real and personal
>
>properties, and to discourage Americans from utilizing commercial
>
>processes (e.g.  true bills) to perfect claims against government
>
>employees for  systematic and  premeditated violations of federal
>
>and state law.  This is entrapment, and it needs to stop.
>
>     Plaintiffs have,  evidently, been  actively involved  in the
>
>creation, utilization,  and promotion  of these  bogus commercial
>
>warrants and  documentary drafts  [sic].  Applicant is aware that
>
>Mr. Neil  T. Nordbrock,  acting as  New Life's  only  accountant,
>
>urged New  Life management  to tender  one or  more of such bogus
>
>paper instruments  to discharge  New Life's  federal  income  tax
>
>
>     Applicant's Opposition to Strike Motion:  Page 11 of 20
>
>
>liabilities.   A business  associate of M. Elizabeth Broderick --
>
>Adolf Hoch  -- even confided to Applicant, in the Spring of 1996,
>
>that New Life had used several of Broderick's documentary drafts,
>
>"flushing New Life with much additional cash," as Mr. Hoch put it
>
>(or words to that effect).  Hoch was convicted with Broderick.
>
>     Last but  not least,  Applicant  offers  to  prove  that  M.
>
>Elizabeth Broderick  is actually  a DOJ  "front" woman, operating
>
>under deep  cover for  the benefit  of principals within the U.S.
>
>Department of  Justice in Los Angeles, and in other major cities.
>
>Those principals  are actively exploiting the capabilities of the
>
>PROMIS software,  which Applicant  alleges was  stolen  from  the
>
>Inslaw Corporation,  then significantly  enhanced to operate over
>
>the Internet,  in order to assemble the electronic dossiers which
>
>are required  to target asset groups slated for forfeiture and/or
>
>foreclosure.   In  summary,  this  appears  to  be  a  nationwide
>
>property  conversion   racket,  operating  in  violation  of  the
>
>Racketeering and  Corrupt Organizations  Act at  18 U.S.C.  1961.
>
>Compare also 18 U.S.C. 1964(a) and 1964(c), in pari materia.
>
>
>                        REMEDY REQUESTED
>
>     Wherefore, all  premises having been duly considered by this
>
>honorable Court,  Applicant respectfully requests that all Relief
>
>Requested in the STRIKE MOTION be denied.
>
>     In the alternative, Applicant respectfully requests that the
>
>STRIKE MOTION  be tabled,  until  such  time  as  Applicant  does
>
>formally apply  for intervention of Right in the instant case, at
>
>which time  the current STRIKE MOTION, or a substantially amended
>
>version, can  and should be properly considered by this honorable
>
>Court, but only then, and not before then.
>
>
>     Applicant's Opposition to Strike Motion:  Page 12 of 20
>
>
>                          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"  (federal  government),  that  the
>
>attached documents  are true and correct copies of the originals,
>
>with the  sole exception  of the  original  blue-ink  signatures,
>
>which signatures  are hereby  affixed 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.
>
>
>Dated:  August 27, 1997
>
>
>Respectfully submitted,
>
>/s/ Paul Mitchell
>______________________________________________
>Paul Andrew Mitchell, Sui Juris
>Citizen of Arizona state, federal witness
>(expressly not a citizen of the United States)
>
>All Rights Reserved without Prejudice
>
>
>     Applicant's Opposition to Strike Motion:  Page 13 of 20
>
>
>                        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):
>
>          APPLICANT'S OPPOSITION TO PLAINTIFFS' MOTION
>      TO STRIKE NOTICE OF INTENT TO APPLY FOR INTERVENTION:
>                Petition Clause, First Amendment
>
>by placing one true and correct copy of said document(s) in first
>
>class U.S. Mail, with postage prepaid and properly addressed to:
>
>
>Neil and Evelyn Nordbrock
>c/o 6642 E. Calle de San Alberto
>Tucson, Arizona state
>
>Lawrence E. Condit                      VIA FAX TRANSMISSION
>c/o 376 South Stone Avenue              to: (520) 624-8414
>Tucson, Arizona state
>
>Malcolm K. Ryder, Esq.
>c/o 3100 N. Campbell Ave., Ste. 101
>Tucson, Arizona state
>
>
>Executed on August 27, 1997:
>
>/s/ Paul Mitchell
>______________________________________________
>Paul Andrew Mitchell, Sui Juris
>Citizen of Arizona state, federal witness
>(expressly not a citizen of the United States)
>
>All Rights Reserved without Prejudice
>
>
>     Applicant's Opposition to Strike Motion:  Page 14 of 20
>
>
>                          Exhibit "A":
>
>        VERIFIED PETITION FOR PEREMPTORY WRIT OF MANDAMUS
>               People ex rel. Paul Andrew Mitchell
>                               v.
>             Pima County Consolidated Justice Court
>                    Superior Court of Arizona
>                      Tucson, Arizona state
>                       case number #320831
>
>
>     Applicant's Opposition to Strike Motion:  Page 15 of 20
>
>
>                          Exhibit "B":
>
>                 MOTION FOR BILL OF PARTICULARS
>              (citing Petition Clause authorities)
>
>                      Mitchell v. Nordbrock
>             Pima County Consolidated Justice Court
>                      Tucson, Arizona state
>                     case number #CV-97-3438
>
>
>     Applicant's Opposition to Strike Motion:  Page 16 of 20
>
>
>                          Exhibit "C":
>
>              NOTICE AND DEMAND TO CEASE AND DESIST
>
>                              from
>
>                      Paul Andrew Mitchell
>
>                               to
>
>                      Neil Thomas Nordbrock
>
>
>     Applicant's Opposition to Strike Motion:  Page 17 of 20
>
>
>                          Exhibit "D":
>
>             PLAINTIFF'S VERIFIED CRIMINAL COMPLAINT
>
>                      Mitchell v. Nordbrock
>             Pima County Consolidated Justice Court
>                      Tucson, Arizona state
>                     case number #CV-97-3438
>
>
>     Applicant's Opposition to Strike Motion:  Page 18 of 20
>
>
>                          Exhibit "E":
>
>       MOVANT'S VERIFIED COMPLAINT OF CRIMINAL VIOLATIONS
>                  OF THE FEDERAL CRIMINAL CODE
>
>              In Re New Life Health Center Company
>                 United States Bankruptcy Court
>                     Phoenix, Arizona state
>                  case number #93-06051-PHX-GBN
>
>
>     Applicant's Opposition to Strike Motion:  Page 19 of 20
>
>
>                          Exhibit "F":
>
>           AFFIDAVIT OF DEFAULT AND OF PROBABLE CAUSE
>                    IN RE LAWRENCE E. CONDIT
>
>                      Mitchell v. Nordbrock
>             Pima County Consolidated Justice Court
>                      Tucson, Arizona state
>                     case number #CV-97-3438
>
>
>     Applicant's Opposition to Strike Motion:  Page 20 of 20
>
>
>                             #  #  #

========================================================================
Paul Andrew Mitchell                 : Counselor at Law, federal witness
B.A., Political Science, UCLA;  M.S., Public Administration, U.C. Irvine

tel:     (520) 320-1514: machine; fax: (520) 320-1256: 24-hour/day-night
email:   [address in tool bar]       : using Eudora Pro 3.0.3 on 586 CPU
website: http://www.supremelaw.com   : visit the Supreme Law Library now
ship to: c/o 2509 N. Campbell, #1776 : this is free speech,  at its best
             Tucson, Arizona state   : state zone,  not the federal zone
             Postal Zone 85719/tdc   : USPS delays first class  w/o this

As agents of the Most High, we came here to establish justice.  We shall
not leave, until our mission is accomplished and justice reigns eternal.
========================================================================
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