Case
2:14-cr-00027-NDF Document 111 Filed 06/25/14 Page 1 of 4
CROSS-COMPLAINT FOR DECLARATORY AND
INJUNCTIVE RELIEF AND DAMAGES:
42 U.S.C. 1986, 18 U.S.C. 1964(a), 5 U.S.C. 552
Re: #2:14-CR-00027-NDF-2
TO: Office of Presiding Judge (duly credentialed)
District Court of the United States (“DCUS”)
2120 Capitol Ave., 2nd Floor
Cheyenne 82001
Wyoming, USA
DATE: June 21, 2014 A.D.
Greetings Your Honor:
Comes now the United States (28 U.S.C. 1345) ex rel. Paul Andrew Mitchell, B.A., M.S., Citizen of Washington State and Private Attorney General (18 U.S.C. 1964(a)), to petition this honorable DCUS for declaratory and injunctive relief and damages arising from:
(a) neglect to prevent and failure to remedy multiple violations of equal protection of the law,
(b) multiple RICO “predicate acts”, and
(c) multiple attempts to prevent discovery of documents properly requested under the Freedom of Information Act (5 U.S.C. 552).
JURISDICTION
This DCUS has original jurisdiction under 18 U.S.C. 1964(a), 5 U.S.C. 552(a)(4)(B), and Federal questions arising under 42 U.S.C. 1985, 1986.
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INCORPORATION
OF DOCKET
So as to leave no doubt about the full extent, and severity, of all damages inflicted to date upon Relator, all entries in the Docket number supra are hereby incorporated by reference, as if set forth fully here without exception, “SEALED” or not “SEALED”.
PARTIES
The United States expressly names Ms. Nancy Dell Freudenthal as the first Civil Cross-Defendant, in addition to as yet unnamed Does 1 thru 100, until such time as proper discovery shall justify the substitution of additional named Cross-Defendants for one or more Does 1 thru 100.
PRELIMINARY
ALLEGATIONS
Cross-Defendant Freudenthal has repeatedly violated Relator’s right to equal protection of the law chiefly by neglecting to prevent and failing to remedy multiple violations of: Article VI, Clauses 2 and 3 in the Constitution for the United States of America, as lawfully amended; 28 U.S.C. 453, 544, and 951; 5 U.S.C. 2104, 2903, 2906, 3331, 3332, 3333 and 5507; 44 U.S.C. 3501 et seq. and 3512; and, the implementing Regulation at 5 CFR 1320.5 in connection with the COUNTERFEIT U.S. Office of Personnel Management Standard Form 61 APPOINTMENT AFFIDAVITS recently published at OPM’s Internet website.
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Relator claims a “Right to Inspect” all such SF-61 credentials for proper compliance with the Paperwork Reduction Act supra, and a related right to ignore, and timely object to, all such forms which clearly fail to display a valid OMB control number and the paragraph citing 5 U.S.C. 2903 (Authority to administer). See Supremacy Clause.
At a 2-hour hearing [3/21/2014] in the “criminal case” of USA v. Hill et al., Freudenthal ultimately apologized on the record for attempting to mis-characterize Relator’s “credential investigation” as some sort of pathological obsession. Then, instead of repairing the damages caused by such obvious slander, e.g. by recusing herself for bias and prejudice, Freudenthal commenced to conspired with Does 1 thru 100 to libel Relator as “delusional”. The latter conspiracy is now evident in a “MOTION FOR PSYCHIATRIC OR PSYCHOLOGICAL EVALUATION” that was concealed from Relator; no NOTICE of any such MOTION was timely served on Relator; no NOTICE of any hearing on any such MOTION was ever served on Relator; and, Relator was never allowed to attend any hearing(s) on any such MOTION. Plain error!
Notice and hearing are the minimal, essential prerequisites of due process of law: see Fifth Amendment.
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INITIAL
REMEDIES
On behalf of Relator as a damaged Party, the United States ex rel. hereby requests a PRELIMINARY INJUNCTION barring Nancy Dell Freudenthal from presiding any further on the “criminal” case of USA v. Hill et al.; and, a preliminary ORDER granting leave for Relator: to amend this CROSS-COMPLAINT with adequate technical assistance of Harris & Harris, P.C., and to proceed In Forma Pauperis with all reasonable attorney fees paid to Harris & Harris, P.C. by the United States (Federal government), pursuant the “personal” option for Relator to proceed In Propria Persona under 28 U.S.C. 1654 (personally or by counsel) and 18 U.S.C. 1964(a) (Civil RICO liberally construed).
Thank you for your professional consideration.
Respectfully submitted June 21, 2014 A.D.,
/s/ Paul Andrew Mitchell (chosen name)
Paul Andrew Mitchell, B.A., M.S.
Citizen of Washington State, Pannill v. Roanoke;
Relator In Propria Persona, 28 U.S.C. 1654;
Private Attorney General, 18 U.S.C. 1964(a),
Rotella v. Wood, 528 U.S. 549 (2000)
(objectives of Civil RICO)
All Rights Reserved (cf. UCC 1-308):
Petition Clause is the Right conservative of all Rights!
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