Paul Andrew Mitchell, Sui Juris
Citizen of Arizona state, federal witness,
and Vice President for Legal Affairs
c/o General Delivery at
2509 North Campbell, #1776
Tucson, Arizona state

In Propria Persona

All Rights Reserved
without prejudice




                 UNITED STATES BANKRUPTCY COURT

                       DISTRICT OF ARIZONA


In Re:                          ) Case No. #93-06051-PHX-GBN
                                )
New Life Health Center Company, ) MOVANT'S AFFIDAVIT OF
Debtor                          ) PROBABLE CAUSE, TESTIFYING
                                ) AS TO EVIDENCE OF FRAUD AND
                                ) PERJURY ON THE COURT:
________________________________)
                                ) 18 U.S.C. 152, 157;
Paul Andrew Mitchell,           ) 28 U.S.C. 1746(1)
          Movant,               )
     v.                         )
                                )
New Life Health Center Company  )
et al.,                         )
          Respondents.          )
________________________________)


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

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

witness (hereinafter  "Movant"), and  Vice  President  for  Legal

Affairs of  New Life  Health Center  Company,  an  unincorporated

business trust  domiciled in  the Arizona  Republic  (hereinafter

"Debtor"), to present this, MOVANT'S AFFIDAVIT OF PROBABLE CAUSE,

TESTIFYING AS  TO EVIDENCE  OF FRAUD  AND PERJURY ON THE COURT by

Dr. Eugene A. and Mrs. Linda H. Burns.


              Movant's Verified Criminal Complaint:
                          Page 1 of 6


                   AFFIDAVIT OF PROBABLE CAUSE

     I, Paul  Andrew Mitchell,  hereinafter Movant  in the  above

entitled case, hereby verify that:


     On July  29, 1997,  I visited  the OK  Feed and Supply store

located at 3701 E. Fort Lowell in the city of Tucson, Arizona.

     There, I  visited for approximately thirty (30) minutes with

Ms. Alta  Caillet, who gave me a business card which shows titles

of Bird Consultant and Assistant Manager.

     Ms. Caillet  provided me with three (3) complimentary copies

of "AFA  Fast News  -- The  Official Newsletter  of the  American

Federation of Aviculture," dated February, March, and April 1997.

These newsletters  contained numerous  advertisements for  a wide

variety of  pet birds  including, in particular, the rare variety

of South American Macaw birds known as the Hyacinth [sic].

     I located the following specific asking prices for the Macaw

birds listed in the March 1997 issue of "AFA Fast News", to wit:

Page 4 of 8, column 2:

     HYACINTH MALE  6 yrs  old, complete cultures & blood panels,
     perfect feather $6,500.  [bold emphasis added hereinafter]

     Hyacinth proven pair, female plucked by male $15,000.


Page 5 of 8, column 3:

     PROVEN PAIRS: 2pr Hyacinth $20,000pr [sic]

     Hyacinth $15,000.


Page 6 of 8, column 1:

     HYACINTH: 8yr  old domestic  male.  He's beautiful, healthy,
     tame &  talking.    Avian  medical  exam  provided.    Micro
     chipped.  $8,800 [name redacted].


Page 6 of 8, column 2:

     FEMALE HYACINTH, 5yrs old $8,500.

     Hyacinth Macaw pairs $18,000 per pair.


              Movant's Verified Criminal Complaint:
                          Page 2 of 6


     During the  period of  time when  I worked  in the  Debtor's

administrative offices  at 4500  E. Speedway Boulevard, Suite 27,

in Tucson, Arizona state, I witnessed Dr. Eugene A. Burns come to

work almost  every day with one (1) South American Hyacinth Macaw

bird with  all blue  feathers, and  two (2)  multi-colored  South

American Macaw  birds which Ms. Caillet identified as the Scarlet

variety.

     Upon arriving at said offices, Dr. Burns always placed these

birds in  a special  indoor cage on the floor adjacent to two (2)

interior glass  windows which separated Dr. Burns' private office

from a  larger storage  room.   This  storage  room  had  shelves

mounted on the walls running the length of this rectangular room;

numerous bottles  of vitamin  and mineral supplements were stored

on these  shelves.   A stand-alone  Canon fax  machine  was  also

located in this same room.

     These three  South American  Macaw birds  were very noisy at

particular times  of the  day, most  often in the late afternoon.

Their shrieks  were so  loud, that  the noise  would often  cause

sharp pain in my ear drums, and interfere with conversations.

     After being  bothered quite  often by  these loud, shrieking

sounds, I  persuaded Dr.  Burns to  hire the company's carpenter,

Mr. Larry  Stevens, to  install a  permanent wall,  doorway,  and

operating interior door to separate my office from the bird cage.

     The new wall and door, which Mr. Stevens constructed, helped

to attenuate  the loud  noises made by these Macaw birds, but the

noise continued to reach my office space by traveling through the

lobby area,  where there  were no  doors or  walls to  block  the

noise.


              Movant's Verified Criminal Complaint:
                          Page 3 of 6


     The original  VOLUNTARY PETITION  executed and  filed by Dr.

and Mrs.  Eugene A.  Burns in the United States Bankruptcy Court,

District  of   Arizona,  case   number   #95-10472-PHX-GBN,   and

subsequently transferred to case number #96-1624-TUC-LO, contains

the following information in the SUMMARY OF SCHEDULES, to wit:

          Schedule                 Assets
          ---------------------    ----------
          A - Real Property        130,000.00
          B - Personal Property      6,650.00  [emphasis added]
                                   ----------
          Total Assets             136,650.00


The Personal  Property Schedule  B contains the following, listed

under Schedule B-29 -- Animals, to wit:

Description of Prop.  : 2 Dogs, 3 Cats, 4 Birds   Market: $250.00
Street Address        : 7150 E. River Canyon Rd.          =======
City, State, Zip Code : Tucson, AZ 85712
Husband, Wife, Joint? : Property is owned Jointly


                          VERIFICATION

I, Paul  Andrew Mitchell, Sui Juris, hereby verify, under penalty

of perjury,  under the  laws of  the United  States  of  America,

without the  "United States" (federal government), that the above

statements of fact are true and correct, according to the best of

My current  information, knowledge,  and belief,  so help Me God,

pursuant to 28 U.S.C. 1746(1).


Dated:  July 29, 1997


Respectfully submitted,

/s/ Paul Andrew Mitchell

Paul Andrew Mitchell, B.A., M.S.
Citizen of Arizona state, federal witness
(expressly not a citizen of the United States)

All Rights Reserved without prejudice


              Movant's Verified Criminal Complaint:
                          Page 4 of 6


                        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" (federal government), 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):

              MOVANT'S AFFIDAVIT OF PROBABLE CAUSE,
               TESTIFYING AS TO EVIDENCE OF FRAUD
                    AND PERJURY ON THE COURT:
             18 U.S.C. 152, 157;  28 U.S.C. 1746(1)

by placing one true and correct copy of said document(s) in first

class U.S. Mail, with postage prepaid and properly addressed to:


Creditors' Committee               Christopher H. Bayley
In re: New Life Health Center Co.  Todd V. Jones
c/o United States Trustee          400 E. Van Buren
P.O. Box 36170                     One Arizona Center
Phoenix 85067-6170/tdc             Phoenix 85004-0001/tdc
ARIZONA STATE                      ARIZONA STATE

Internal Revenue Service [sic]     AZ DEPARTMENT OF REVENUE [sic]
Attn: Bankruptcy Unit              Bankruptcy Unit Field 1011
c/o 210 E. Earll Drive             c/o 1600 W. Monroe, 7th Floor
Phoenix 85012/tdc                  Phoenix 85007/tdc
ARIZONA STATE                      ARIZONA STATE

United States Trustees             New Life Health Center Company
c/o P.O. Box 36170                 c/o 4500 E. Speedway, #27
Phoenix 85067-6170/tdc             Tucson 85712/tdc
ARIZONA STATE                      ARIZONA STATE

Bank One Arizona                   INTERNAL REVENUE SERVICE [sic]
c/o P.O. Box 29620 Z-490           Spec. Proc. MS-5085
Phoenix 85038-9620/tdc             c/o 210 E. Earll Drive
ARIZONA STATE                      Phoenix 85012/tdc
                                   ARIZONA STATE

Wells Fargo Bank                   Wells Fargo Bank
c/o P.O. Box 85071                 c/o 401 W. 24th Street
San Diego 92186/tdc                National City 91950/tdc
CALIFORNIA STATE                   CALIFORNIA STATE

Frederick C. Hickle                Dianne C. Kerns
c/o P.O. Box 31807                 c/o 1645 W. Valencia, #109-C
Tucson 85751-1807/tdc              Tucson 85746/tdc
ARIZONA STATE                      ARIZONA STATE


[See USPS Publication #221 for addressing instructions.]


              Movant's Verified Criminal Complaint:
                          Page 5 of 6


Executed on July 29, 1997:


/s/ Paul Andrew Mitchell

Paul Andrew, Mitchell, Sui Juris
Citizen of Arizona state, federal witness
(expressly not a citizen of the United States)

All Rights Reserved without Prejudice


              Movant's Verified Criminal Complaint:
                          Page 6 of 6


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