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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