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 VERIFIED COMPLAINT
Debtor                          ) OF CRIMINAL VIOLATIONS OF THE
                                ) FEDERAL CRIMINAL CODE:
                                )
________________________________) 18 U.S.C. 152, 157;
                                ) 28 U.S.C. 1746
Paul Andrew Mitchell,           )
          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  provide formal  Notice to  all interested parties,

and to  demand mandatory judicial notice by this honorable Court,

pursuant to  Rule 201(d)  of the  Federal Rules  of Evidence,  of

this, MOVANT'S  VERIFIED COMPLAINT  OF CRIMINAL VIOLATIONS OF THE

FEDERAL CRIMINAL  CODE, specifically  for violations of Title 18,

United States Code, sections 152 and 157.


              Movant's Verified Criminal Complaint:
                          Page 1 of 5


     Movant  hereby   formally  charges   the   following   named

individuals, both  jointly and  severally, with the corresponding

crimes enumerated infra:


Mr. Todd V. Jones with:

(1)  making a  false or  fraudulent representation  concerning  a
     proceeding under title 11, after the filing of the petition,
     and after having devised, or intended to devise, a scheme or
     artifice to  defraud, and  for the  purpose of  executing or
     concealing such  a scheme  or artifice,  in violation  of 18
     U.S.C. 157;


Mr. Christopher H. Bayley with:

(1)  making a  false or  fraudulent representation  concerning  a
     proceeding under title 11, after the filing of the petition,
     and after having devised, or intended to devise, a scheme or
     artifice to  defraud, and  for the  purpose of  executing or
     concealing such  a scheme  or artifice,  in violation  of 18
     U.S.C. 157;


Dr. Eugene A. Burns with:

(1)  making a  false or  fraudulent representation  concerning  a
     proceeding under title 11, after the filing of the petition,
     and after having devised, or intended to devise, a scheme or
     artifice to  defraud, and  for the  purpose of  executing or
     concealing such  a scheme  or artifice,  in violation  of 18
     U.S.C. 157;

(2)  knowingly  and  fraudulently  concealing  and  making  false
     entries in recorded information, including books, documents,
     records, and  papers, relating  to the property or financial
     affairs of the Debtor, in violation of 18 U.S.C. 152;


Mrs. Linda H. Burns with:

(1)  making a  false or  fraudulent representation  concerning  a
     proceeding under title 11, after the filing of the petition,
     and after having devised, or intended to devise, a scheme or
     artifice to  defraud, and  for the  purpose of  executing or
     concealing such  a scheme  or artifice,  in violation  of 18
     U.S.C. 157;

(2)  knowingly  and  fraudulently  concealing  and  making  false
     entries in recorded information, including books, documents,
     records, and  papers, relating  to the property or financial
     affairs of the Debtor, in violation of 18 U.S.C. 152;


              Movant's Verified Criminal Complaint:
                          Page 2 of 5


Mr. Neil T. Nordbrock with:

(1)  making a  false or  fraudulent representation  concerning  a
     proceeding under title 11, after the filing of the petition,
     and after having devised, or intended to devise, a scheme or
     artifice to  defraud, and  for the  purpose of  executing or
     concealing such  a scheme  or artifice,  in violation  of 18
     U.S.C. 157.


                INCORPORATION OF PRIOR PLEADINGS

     In  support   of  this  VERIFIED  COMPLAINT,  Movant  hereby

incorporates all  pleadings previously  filed by  Movant  in  the

instant case, as if all were set forth fully herein, with special

emphasis  on   MOVANT'S  REBUTTAL   TO  ATTORNEYS'   RESPONSE  TO

APPLICATION FOR  INTERVENTION OF  RIGHT,  RELIEF  FROM  AUTOMATIC

STAY,  AND   DECLARATORY  JUDGMENTS;   MOVANT'S   OPPOSITION   TO

ATTORNEYS' MOTION  TO DISMISS,  and Movant's  5th  SUPPLEMENT  TO

APPLICATION FOR  INTERVENTION  OF  RIGHT,  FOR  RELIEF  FROM  THE

AUTOMATIC STAY AND DEMAND FOR MANDATORY JUDICIAL NOTICE.


                          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 19, 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 3 of 5


                        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 VERIFIED COMPLAINT OF
        CRIMINAL VIOLATIONS OF THE FEDERAL CRIMINAL CODE:
               18 U.S.C. 152, 157;  28 U.S.C. 1746

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 4 of 5


Executed on July 19, 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 5 of 5


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