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Date: Sat, 22 Nov 1997 14:39:55 -0800
To: (Recipient list suppressed)
From: Paul Andrew Mitchell [address in toolbar] (by way of Paul Andrew Mitchell [address in tool bar])
Subject: SLS: criminal complaint for mail fraud and bank fraud

[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 Avenue
Tucson, Arizona state

In Propria Persona

Under Protest and Without Prejudice
By Special Visitation Only





             PIMA COUNTY CONSOLIDATED JUSTICE COURT


Paul Andrew Mitchell,      )  Case Number #CV-97-3438
          Plaintiff,       )
                           )  PLAINTIFF'S VERIFIED
     v.                    )  CRIMINAL COMPLAINT AND
                           )  AFFIDAVIT OF PROBABLE CAUSE:
                           )
Neil and Evelyn Nordbrock, )  Rule 201(d),
et al.,                    )  Arizona Rules of Evidence;
          Defendants.      )  28 U.S.C. 1746(1);
                           )  Supremacy Clause;
                           )  Universal Declaration of
                           )  Human Rights;  International
                           )  Covenant on Civil and Political
                           )  Rights, enacted with explicit
___________________________)  reservations by the U.S. Congress


COMES NOW  Paul Andrew  Mitchell, Sui  Juris, Citizen  of Arizona

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

citizen"), federal  witness, Counselor  at Law,  private attorney

general, 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

this, PLAINTIFF'S  VERIFIED CRIMINAL  COMPLAINT AND  AFFIDAVIT OF

PROBABLE CAUSE,  charging the following named individual with the

corresponding crimes enumerated infra.


     Plaintiff hereby formally charges:


       Plaintiff's Verified Criminal Complaint & Affidavit:
                         Page 1 of 23


Mr. Lawrence E. Condit with:

     making a  false entry in a book, report, or statement of the
     Bank of  America, Downtown  Branch, Tucson,  Arizona  state,
     with intent  to injure or defraud Plaintiff, in violation of
     18 U.S.C. 1005 and of 18 U.S.C. 1344 (one count each);

     placing in  a post  office a  fraudulent bank  check  to  be
     delivered by  the United  States Postal Service to Plaintiff
     for the  sole purpose  of executing  a scheme or artifice to
     defraud Plaintiff,  in violation  of  18  U.S.C.  1341  (one
     count).

                   AFFIDAVIT OF PROBABLE CAUSE

I, Paul  Andrew Mitchell,  Sui Juris,  hereinafter "Plaintiff" in

the above entitled matter, hereby testify as follows, to wit:

     On November 18, 1997, I received via general delivery at the

Post Office  located  at  2509  North  Campbell  Avenue,  Tucson,

Arizona state,  a letter  from Sir  Lawrence E.  Condit, Esquire,

(hereinafter "Sir  Condit"), dated November 14, 1997, alleging to

transmit a  bank check drawn on his trust account in satisfaction

of the  final judgment  in the  instant case.  A true and correct

copy of  said letter  is  attached  hereto  and  incorporated  by

reference as if set forth fully herein.  See Exhibit "A".

     On November  18, 1997, in the same envelope from Sir Condit,

I also  received bank  check #7013  dated November  14, 1997, and

drawn on  the Clients  Trust Account [sic] of LAWRENCE E. CONDIT,

ATTORNEY AT LAW P.C. [sic], at the Downtown Office of the Bank of

America, Tucson,  Arizona, account  #007013-122101706-012-293269,

in the  amount of Three Thousand One Hundred Thirteen Dollars and

42/100's ($3,113.42).  A true and correct copy of said bank check

is attached  hereto and incorporated by reference as if set forth

fully herein.  See Exhibit "B".

     On November  18, 1997, in the same envelope from Sir Condit,

I also received a proposed ORDER purporting as follows:


       Plaintiff's Verified Criminal Complaint & Affidavit:
                         Page 2 of 23


     in satisfaction of judgment: See attached check. [sic].

A true and correct copy of said proposed ORDER is attached hereto

and incorporated  by reference as if set forth fully herein.  See

Exhibit "C".

     A true  and correct copy of said envelope is attached hereto

and incorporated  by reference as if set forth fully herein.  See

Exhibit "D".

     Also on  November 18,  1997, immediately after receiving but

not accepting  said envelope, I went straightaway to the Downtown

Office of  the Bank  of America at 33 North Stone Avenue, Tucson,

Arizona state.   There,  I inquired  of the  first available bank

teller, whether  or not  there  were  sufficient  funds  in  said

Clients Trust Account to cash Sir Condit's check #7013.

     Ms.  Linda  Smith  (hereinafter  "Ms.  Smith")  queried  the

computer terminal  at her  teller station and reported to Me that

there were, in fact, sufficient funds in said account.

     After a brief discussion of various negotiable alternatives,

I requested Ms. Smith to prepare a standard cashier's check.

     At that  moment, Ms. Smith asked Me to disclose the sequence

number of  Sir Condit's bank check.  I responded by informing Ms.

Smith that  the sequence  number was  #7013 (number  seven, zero,

one, three).

     Ms. Smith  then informed  Me that  there was  a STOP PAYMENT

order on check number #7013.

     I then  requested Ms.  Smith to disclose to Me what, if any,

reasons were stated for this alleged STOP PAYMENT order.

     Ms. Smith  then informed  Me that her computer was reporting

"wrong amount" [sic] as the reason for the STOP PAYMENT order.


       Plaintiff's Verified Criminal Complaint & Affidavit:
                         Page 3 of 23


     I then requested Ms. Smith to prepare a written confirmation

of this  STOP PAYMENT  order, but she then told Me that she would

need to call her supervisor.

     Within minutes  after calling  her supervisor,  Ms.  Doriann

Foti  ("Ms.  Foti")  came  to  Ms.  Smith's  teller  window,  and

confirmed to  Me that  a STOP PAYMENT order was, in fact, showing

on check number #7013.

     I  then   repeated  to  Ms.  Foti  My  request  for  written

confirmation  of   this  alleged  STOP  PAYMENT  order,  and  she

explained that she needed to call the staff legal counsel of Bank

of America.

     Ms. Foti  then called  the staff  legal counsel  of Bank  of

America and  explained the  situation,  with  Ms.  Smith  and  Me

standing close enough to hear Ms. Foti's half of her conversation

with the staff legal counsel of Bank of America.

     Upon ending that conversation, Ms. Foti explained to Me that

bank policy  prevented Bank  of America from executing and giving

Me any written confirmations of the alleged STOP PAYMENT order.

     At that  point, I  asked Ms. Foti if she was a bank officer,

and she responded by saying that she was not a bank officer.

     I then  requested a bank officer, and Ms. Foti picked up the

phone again  and summoned  Mr. Ken  Binion, Branch Manager of the

Bank of America, Downtown Office, Tucson, Arizona state.

     Upon arriving at Ms. Smith's teller station, Mr. Binion also

confirmed the  alleged STOP  PAYMENT order  on Sir Condit's check

#7013.

     Mr. Binion  also confirmed  that bank  policy  did,  indeed,

prevent Bank  of America from executing and giving Me any written

confirmation(s) of the alleged STOP PAYMENT order by Sir Condit.


       Plaintiff's Verified Criminal Complaint & Affidavit:
                         Page 4 of 23


     At that  point, I  expressed My deep disappointment with the

fact that I could not transact check #7013.

     I also  informed Ms.  Smith, Ms. Foti, and Mr. Binion that I

planned to  subpoena all  three (3) of them as material witnesses

to the  fact that  a STOP  PAYMENT order had been placed on check

#7013 in Sir Condit's Clients Trust Account.

     I also  expressed My  sincere belief  that said STOP PAYMENT

order constituted  probable cause  to charge Sir Condit with bank

fraud and also with mail fraud, both federal offenses.

     I also obtained Ms. Foti's business card.

     To commemorate  that encounter with Ms. Smith, Ms. Foti, and

Mr. Binion  at the  Bank of  America, I  annotated  Sir  Condit's

letter dated  November 14,  1997, with the following statement of

fact, to wit:

     11/18/97  3 Bank of America employees witnessed STOP PAYMENT
     order on  check #7013,  account #007013-122101706, amount of
     $3,113.42,  reason:   "wrong  amount".    Judgment  was  for
     $3,113.42!

     A true and correct copy of said annotated letter is attached

hereto and  incorporated by  reference  as  if  set  forth  fully

herein.  See Exhibit "E".

     I then  exited the Bank of America, Downtown Branch, Tucson,

Arizona state,  and proceeded  next to  the office of Mr. Charles

"Bud" Miltenberger  ("Mr. Miltenberger"),  Program Director,  Bad

Check Program,  in the  office of  the Pima County Attorney, 1400

Legal Services  Building, 32  North Stone Avenue, Tucson, Arizona

state.

     I then  met briefly  with Mr.  Miltenberger and proceeded to

explain what  had happened,  up to  that point  in time, with Sir

Condit's check #7013.


       Plaintiff's Verified Criminal Complaint & Affidavit:
                         Page 5 of 23


     Mr.  Miltenberger   sympathized  with   My  situation,   but

explained that  he required  exhibition of  a copy of check #7013

which was  annotated by the Bank of America with the nomenclature

"STOP PAYMENT ORDERED", or words to that effect.

     I obtained Mr. Miltenberger's business card.

     True and  correct copies of Ms. Foti's business card, and of

Mr.  Miltenberger's   business  card,  are  attached  hereto  and

incorporated by reference as if set forth fully herein.

     After receiving  said business  cards, I  mounted same  on a

single sheet of paper and annotated said sheet with the following

text, to wit:

      Witnesses to probable bank fraud and mail fraud [sic]

See Exhibit "F".

     I then  exited Mr.  Miltenberger's office and proceeded next

to the  public  counter  of  the  Clerk  of  Court,  Pima  County

Consolidated Justice  Court, located  at 115 North Church Avenue,

Tucson, Arizona state.

     When it  came My  turn to  approach the  Clerk's  window,  I

explained what  had transpired  that day  with Sir Condit's check

#7013.  At first, the counter clerk appeared to Me to be somewhat

dubious about the story I had just told her.

     However, said  counter clerk  did agree  to query the docket

computer and,  after doing  so, searched  the docket file for the

final judgment entry in the instant case.

     At that  moment, the  counter clerk verbally confirmed to Me

that the  final judgment, as found in the docket computer, showed

an amount of $3,113.42.  This was the exact amount, to the penny,

showing on Sir Condit's check #7013.


       Plaintiff's Verified Criminal Complaint & Affidavit:
                         Page 6 of 23


     On November 19, 1997, I prepared and executed a CONSTRUCTIVE

NOTICE AND  DEMAND and  mailed same  to Sir  Lawrence E.  Condit,

Esquire, c/o 376 South Stone Avenue, Tucson, Arizona state.

     I also  transmitted said  CONSTRUCTIVE NOTICE  AND DEMAND to

Sir Condit via facsimile to fax number: (520) 624-8414.

     A true  and correct  copy of  said CONSTRUCTIVE  NOTICE  AND

DEMAND is attached hereto and incorporated by reference as if set

forth fully herein.  See Exhibit "G".

     On November 21, 1997, I received, but did not accept, a two-

page  (2-page)  pleading  from  Sir  Condit  entitled  NOTICE  OF

WITHDRAWAL OF ORDER INDICATING SATISFACTION OF JUDGMENT.

     True and  correct copies  of said pleading, and of the first

class United  States Mail  envelope in  which it was transmitted,

are attached hereto and incorporated by reference as if set forth

fully herein.  See Exhibit "H".

     After receiving but not accepting said NOTICE OF WITHDRAWAL,

I prepared and transmitted via facsimile to Sir Condit a one-page

(1-page) message with the following text, to wit:

                     5:00 p.m. Condit! [sic]

     A true and correct copy of said one-page message is attached

hereto and  incorporated by  reference  as  if  set  forth  fully

herein.  See Exhibit "I" ("eye").

     After transmitting  said one-page  message to Sir Condit via

fax, I  annotated Sir  Condit's letter  dated November  14, 1997,

with  the   following  nomenclature:    REFUSED  FOR  FRAUD,  and

transmitted same  to Sir Condit via fax.  A true and correct copy

of said  annotated letter  is attached hereto and incorporated by

reference as if set forth fully herein.  See Exhibit "J".


       Plaintiff's Verified Criminal Complaint & Affidavit:
                         Page 7 of 23


     I also  annotated Sir Condit's alleged ORDER in Satisfaction

of judgment  with the following nomenclature:  REFUSED FOR FRAUD,

and transmitted  same to  Sir Condit via fax.  A true and correct

copy of  said annotated ORDER is attached hereto and incorporated

by reference as if set forth fully herein.  See Exhibit "K".

     I also annotated the first class U.S. Mail envelope in which

Sir Condit  had transmitted  said letter dated November 14, 1997,

and  said   proposed  ORDER,  with  the  following  nomenclature:

REFUSED FOR FRAUD, and transmitted same to Sir Condit via fax.  A

true and  correct copy  of said  annotated envelope  is  attached

hereto and  incorporated by  reference  as  if  set  forth  fully

herein.  See Exhibit "L".

     I also  annotated the pleading entitled NOTICE OF WITHDRAWAL

OF ORDER  INDICATING SATISFACTION  OF JUDGMENT, and the U.S. Mail

envelope in  which it  was delivered  via  U.S.  Mail,  with  the

following nomenclature:   REFUSED FOR FRAUD, and transmitted same

to Sir Condit via fax.  True and correct copies of said annotated

pleading, and  of the  first class U.S. Mail envelope in which it

was delivered,  are attached hereto and incorporated by reference

as if set forth fully herein.  See Exhibit "M".


                          VERIFICATION

     I, Paul  Andrew Mitchell,  Sui  Juris,  Citizen  of  Arizona

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

the  United  States  of  America,  without  the  "United  States"

(federal government),  that the  above statement of facts 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).


       Plaintiff's Verified Criminal Complaint & Affidavit:
                         Page 8 of 23


Dated:  November 21, 1997

Respectfully submitted,

/s/ Paul Mitchell
_____________________________________
Paul Andrew Mitchell, Sui Juris
Citizen of Arizona state
(expressly not a citizen of the United States)

All Rights Reserved without Prejudice


       Plaintiff's Verified Criminal Complaint & Affidavit:
                         Page 9 of 23


                        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):

                   PLAINTIFF'S VERIFIED CRIMINAL COMPLAINT
                AND AFFIDAVIT OF PROBABLE CAUSE:
                Rule 201(d), Arizona Rules of Evidence;
              28 U.S.C. 1746(1);  Supremacy Clause;
             Universal Declaration of Human Rights;
      International Covenant on Civil and Political Rights,
               enacted with explicit Reservations

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         (fax line disconnected)
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

Mr. Walter U. Weber                Carl R. Davison III
c/o 115 N. Church Avenue           c/o 270 S. Stone Avenue
Tucson, Arizona state              Tucson, Arizona state

James B. Martin                    Timothy J. Cranshaw
c/o 270 S. Stone Avenue            c/o 103 E. Alameda, 1st Floor
Tucson, Arizona state              Tucson, Arizona state

Hon. Robert J. Gibson, C.J.        Clerk of Court [sic]
c/o 115 N. Church Avenue           c/o 103 E. Alameda, 1st Floor
Tucson, Arizona state              Tucson, Arizona state


Executed on November 21, 1997:

/s/ Paul Mitchell
_____________________________________
Paul Andrew Mitchell, Sui Juris
Citizen of Arizona state
(expressly not a citizen of the United States)

All Rights Reserved without Prejudice


        Plaintiff's Verified Criminal Complaint & Affidavit:
                         Page 10 of 23


                          Exhibit "A":

        Plaintiff's Verified Criminal Complaint & Affidavit:
                         Page 11 of 23


                          Exhibit "B":

        Plaintiff's Verified Criminal Complaint & Affidavit:
                         Page 12 of 23


                          Exhibit "C":

        Plaintiff's Verified Criminal Complaint & Affidavit:
                         Page 13 of 23


                          Exhibit "D":

        Plaintiff's Verified Criminal Complaint & Affidavit:
                         Page 14 of 23


                          Exhibit "E":

        Plaintiff's Verified Criminal Complaint & Affidavit:
                         Page 15 of 23


                          Exhibit "F":

        Plaintiff's Verified Criminal Complaint & Affidavit:
                         Page 16 of 23


                          Exhibit "G":

        Plaintiff's Verified Criminal Complaint & Affidavit:
                         Page 17 of 23


                          Exhibit "H":

        Plaintiff's Verified Criminal Complaint & Affidavit:
                         Page 18 of 23


                          Exhibit "I":

        Plaintiff's Verified Criminal Complaint & Affidavit:
                         Page 19 of 23


                          Exhibit "J":

        Plaintiff's Verified Criminal Complaint & Affidavit:
                         Page 20 of 23


                          Exhibit "K":

        Plaintiff's Verified Criminal Complaint & Affidavit:
                         Page 21 of 23


                          Exhibit "L":

        Plaintiff's Verified Criminal Complaint & Affidavit:
                         Page 22 of 23


                          Exhibit "M":

        Plaintiff's Verified Criminal Complaint & Affidavit:
                         Page 23 of 23


                             #  #  #

===========================================================================
Paul Andrew Mitchell, Sui Juris      : Counselor at Law, federal witness 01
B.A.: Political Science, UCLA;   M.S.: Public Administration, U.C.Irvine 02
tel:     (520) 320-1514: machine; fax: (520) 320-1256: 24-hour/day-night 03
email:   [address in toolbar]        : using Eudora Pro 3.0.3 on 586 CPU 04
website: http://supremelaw.com       : visit the Supreme Law Library now 05
ship to: c/o 2509 N. Campbell, #1776 : this is free speech,  at its best 06
             Tucson, Arizona state   : state zone,  not the federal zone 07
             Postal Zone 85719/tdc   : USPS delays first class  w/o this 08
_____________________________________: Law is authority in written words 09
As agents of the Most High, we came here to establish justice.  We shall 10
not leave, until our mission is accomplished and justice reigns eternal. 11
======================================================================== 12
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