MOTION TO COMPEL DISCOVERY AND TRANSCRIPTS

Case 2:14-cr-00027-NDF Document 102 Filed 06/16/14 Page 1 of 4

NOTICE OF MOTION AND

MOTION TO COMPEL DISCOVERY AND TRANSCRIPTS

#2:14-CR-00027-NDF-2 (USDC/DWY) [sic]

(“SEALED”)

TO: Office of Chief Judge (duly credentialed)

U.S. District Court

2120 Capitol Ave., 2^nd Floor

Cheyenne 82001

Wyoming, USA

DATE: June 4, 2014

Greetings Your Honor,

Now comes the United States [28 USC 1345] ex rel. Paul Andrew Mitchell, B.A., M.S., Citizen of Washington State and Private Attorney General [18 USC 1964], to move this honorable Court for an ODER compelling disclosure of all discovery documentation and all grand jury transcripts to the Undersigned personally under 28 U.S.C. 1654, for all of the following meritorious reasons:

(1) the Office of U.S. Attorney [OUSA/DWY] has already been ordered, once before, to produce timely discovery documents and grand jury transcripts for examination by Relator [see Docket records];

(2) so-called “stand-by counsel” Mark C. Hardee (Hardlee?) totally abandoned Relator between the two (2) hearings on 3/21/2014 and 6/3/2014, in violation of the Sixth Amendment;

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(3) a formal Complaint is now pending against Mr. Hardee at the Wyoming State Bar, Board of Professional Responsibility, for abandonment and other related attorney malpractices [cf. NOTICE OF TERMINATION (filed)];

(4) A table of Delegations of Authority in the IRS Internal Revenue Manual [“IRM”] still shows awards of $25,000 CASH and up to “$35,000 to the President, through Treasury”; on the Internet, see www.irs.gov/irm/ .

(5) the latter Performance Management and Recognition System (“PMRS”) was repealed by Act of Congress in 1993, 21 years ago as of 2014 A.D.; still “on the books” [i.e. “Kickback Racket”];

(6) it now appears quite probable that the IRS continues to award Federal prosecutors $25,000 CASH for every “indictment” issued by Federal grand juries against “tax protesters or any similar designation” [cf. “RRA98” (112 Stat.)], and against State Citizens wrongly identified as “sovereign citizens” and/or “extremists” [sic]; [see attached article: “Inside the DHS,” Pgs. 2 of 6, 5 of 6];

(7) Relator is an eyewitness to a written admission, on IRS letterhead, that no PMRS records exist because all such awards were paid in CASH; see FOIA Request;

(8) such CASH awards also raise the real possibility that recipients have failed to report same on their IRS Forms 1040 “U.S. Individual Income Tax Return(s)” [felony tax evasion];

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(9) failing to report such CASH awards on their Forms 1040 also implicates all recipients in felony tax evasion and felony perjury; see IRS, subtitle F [felony perjury: 28 USC 1746(2)];

(10) IRS Forms 1040 must be executed under penalty of perjury in conformity to 28 U.S.C. 1746(2) i.e. within (inside) the “United States” [28 USC 1345] and without (outside) the United States of America (50 States of the Union) [cf. Preamble]; latter are NOT “Plaintiffs” in this case;

(11) given the sheer volume of “indictments” required to enlarge the Federal prison population to its current inflated size [U.S. BOP], it is also reasonable to suspect, and prove, that no grand juries were ever convened for many such “indictments”, that is, the latter were merely “signed” by a “FOREPERSON” [“Debra Halthus”?] and a “U.S. ATTORNEY” or “ASSISTANT U.S. ATTORNEY” under color of compliance with FRCrP Rule 7;

(12) if no lawful grand jury was ever convened in the instant cases, that fact by itself would serve to explain the “government’s” contempt of the previous discovery orders at (1) above i.e. there are no transcripts because there were no grand jury hearings, in point of FACT!

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(13) it necessarily follows that no exculpatory (favorable) evidence was, or even could be, presented to a lawful grand jury in the instant cases, obviously if no such hearings were ever conducted; [see Brady v. Maryland re: Brady Hearing];

(14) Relator has already demonstrated that the Federal Jury Selection and Service Act [28 USC 1865] expressly discriminates against State Citizens aka Citizens of ONE OF the 50 States, by requiring all Federal jurors to be federal citizens; cf. “Federal citizenship” in Black’s Law Dictionary, Sixth Edition; Pannill v. Roanoke; People v. De la Guerra; “The Federal Zone”!!;

(15) a panel of federal citizens was not, and could not be, a lawful Federal grand jury [28 USC 1865] in the instant cases, further proving that no valid “subpoenas” and no valid “indictments” could ever issue from any such panel(s), in point of Law and fact.

REMEDY

This Court should ORDER the Office of the U.S. Attorney in Cheyenne to show cause why it should not be sanctioned for contempt of all prior discovery ORDERs.

Respectfully submitted,

Paul Andrew Mitchell, B.A., M.S. (chosen name)

Relator In Propria Persona, 28 U.S.C. 1654;

Private Attorney General, 18 U.S.C. 1964

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