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:

Rule 18

 

 

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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