Case
2:14-cr-00027-NDF Document 97 Filed 06/16/14 Page 1 of 3
Case
No. #2:14-CR-00027-NDF-2
(“SEALED”) [sic]
NOTICE OF MOTION AND
MOTION FOR CHANGE OF VENUE:
TO: Office of Presiding Judge (duly
credentialed)
U.S. District Court (“USDC/DWY”)
2120 Capitol Avenue, 2nd
Floor
Cheyenne 82001
Wyoming
Comes now 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 a proper change of venue to the Western District
of Washington at Seattle [“WDWA”], pursuant to Rule 18 of the
Federal Rules of Criminal Procedure (“FRCrP”). Venue is not proper in the District of
Wyoming [“DWY”] for the following well established reasons:
(1)
Relator has
repeatedly raised the issue of venue at several hearings, beginning
1/28/2014 e.g. identity hearing;
(2)
no rebuttals have been forthcoming from any authorized
personnel of the United States; see 28 U.S.C. 544, 5 U.S.C. 3331-3333;
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(3) Relator has stated verbally, and in writing, that he
did not step foot anywhere in Wyoming between a college ski trip to
Jackson Hole in December 1968, and the false arrest on 1/28/2014;
(4) no evidence contradicting the latter statements has been
forthcoming from any authorized personnel of the United States; see 28 U.S.C. 1345, 1346;
(5) the
forty-two (42) discrete moves Relator has had to
endure, at the hands of the U.S. Marshals Service (“USMS”), appear to be
motivated by a specific intent to separate Relator
from his Seattle apartment and the extensive legal and patent research Relator had accumulated there, chiefly to assist Relator’s private clients;
and,
(6) said
42 moves also appear to be motivated by criminal intents [18 USC 1513] to
inflict cruel and unusual summary punishment on Relator
[8th Amendment],
also in connection with defamation per se
of Relator by libeling Relator
as an “Extremist Montana Freeman Associate” [sic] e.g. in booking
records.
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Venue is proper in the Western District of
Washington [“WDWA”], at Seattle, for the following well established reasons:
(7) Relator lived and worked in Seattle, and no where else, between his arrival there on 6/18/2009, and
the false arrest on 1/28/2014, ~4˝ years;
(8) during the latter period, Relator
did not travel outside the State of Washington;
and,
(9) one of Relator’s five (5) meetings
with a Deputy U.S. Marshal [“USMS”] occurred in Relator’s
private Seattle apartment; as such, said
Deputy was an eyewitness to the residential situs of Relator’s consulting practices, performed under 18 U.S.C. 1964.
REMEDY REQUESTED
In light of all the above, this Court should
ORDER a routine change of venue from the District of
Wyoming [“DWY”] to the Western District of Washington at Seattle [“WDWA”],
pursuant to FRCrP Rule 18, and to
honor Relator’s fundamental Rights.
Respectfully submitted, All
Rights Reserved,
/s/ 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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