c/o 2509 N. Campbell, #1776 Tucson [zip code exempt] ARIZONA REPUBLIC May 20, 1997 VERIFIED COMPLAINT OF FRAUD, MAIL FRAUD, CONSPIRACY, OBSTRUCTION OF MAIL, AND LIBEL WITH INTENT TO INJURE James A. Crawford Postal Inspector U.S. Postal Inspection Service P.O. Box 26320 Tucson, Arizona state Postal Zone 85726-6320/tdc Dear Mr. Crawford: This is My verified complaint against Dr. and Mrs. Eugene A. Burns for fraud, mail fraud, conspiracy, obstruction of mail, and libel with intent to injure Me in My private and in My professional reputation in the city, county, state, and nation. For your information, I have commenced litigation against Dr. and Mrs. Eugene A. Burns in two (2) United States Bankruptcy Courts, and in the Superior Court of Arizona, Pima County. In the latter case, We are awaiting an ORDER, required by state law, to remove the case from the Pima County Consolidated Justice Court into the Superior Court, which should be forthcoming. At that time, I fully intend to amend the original complaint against Mr. and Mrs. Neil T. Nordbrock for embezzling approximately $3,000, so as to name Dr. and Mrs. Eugene A. Burns and others also as co-defendants on charges of fraud, mail fraud, conspiracy, obstruction of mail, perjury, contempt of court, theft of professional services, libel, breach of contract, and invasion of privacy (a fundamental Right). In support of My complaints herein of fraud, mail fraud, conspiracy, obstruction of mail, and libel, brought here against Dr. and Mrs. Eugene A. Burns, I submit to you the following table, which summarizes the legal mail which Dr. Burns has refused in recent months. True and correct copies of the refused envelopes are attached. Date Contents Reason Returned 2/12/97 NOTICE AND DEMAND to Neil Thomas Refusal for Cause Nordbrock concerning "Sheryl Smith", Without Dishonor mailed to New Life Health Center Co. 2/25/97 AFFIDAVIT OF DEFAULT AND OF PROBABLE Refusal for Cause CAUSE, #GJ-95-1-6, mailed to Without Dishonor Eugene A. Burns Complaint of Fraud, Mail Fraud, Conspiracy, Obstruction, Libel: Page 1 of 5 3/ 4/97 NOTICE AND DEMAND BY AFFIDAVIT to Refusal for Cause Richard H. Weare, Clerk of Court, USDC Without Dishonor Tucson, mailed to Eugene A. Burns 3/ 5/97 NOTICE AND DEMAND to Eugene A. Burns Refusal for Cause concerning "Sheryl Smith", Without Dishonor, mailed to Eugene A. Burns Marked "ILLEGAL" 3/ 5/97 NOTICE AND DEMAND to Richard Rineer Refusal for Cause concerning "Sheryl Smith", Without Dishonor mailed to Eugene A. Burns 3/ 5/97 NOTICE AND DEMAND to Rachel Saull Refusal for Cause [sic] concerning "Sheryl Smith", Without Dishonor mailed to Eugene A. Burns 3/ 5/97 NOTICE AND DEMAND to Tim Hay Refusal for Cause concerning "Sheryl Smith", Without Dishonor mailed to Eugene A. Burns 3/ 5/97 NOTICE AND DEMAND to Susan Shew Refusal for Cause concerning "Sheryl Smith", Without Dishonor mailed to Eugene A. Burns 3/ 5/97 NOTICE AND DEMAND to Linda Burns Refusal for Cause concerning "Sheryl Smith", Without Dishonor mailed to Eugene A. Burns 3/ 7/97 NOTICE OF DEFAULT to Henry J. Bauman Refusal for Cause concerning judge John M. Roll, USDC, Without Dishonor, mailed to Eugene A. Burns Marked "ILLEGAL" 4/10/97 AFFIDAVIT OF DEFAULT AND OF PROBABLE Refusal for Cause CAUSE IN RE DR. AND MRS. EUGENE A. Without Dishonor, BURNS, #CV-97-3438, mailed to Marked "ILLEGAL" Dr. & Mrs. Eugene A. Burns 4/18/97 APPLICATION FOR INTERVENTION OF RIGHT, Refusal for Cause RELIEF FROM AUTOMATIC STAY, AND FOR Without Dishonor, DECLARATORY JUDGMENTS, #CV-97-3438, Marked "ILLEGAL" mailed to New Life Health Center Co. -and- returned, yellow post-it attached bearing message: "Postmaster -- Do Not Send this Material to Recipient -- This Sender is using the mails to Harrass the Recipients --" [sic] 4/30/97 NOTICE AND DEMAND FOR MANDATORY Refused/Returned JUDICIAL NOTICE, #CV-97-3438, to Sender mailed to Dr. & Mrs. Eugene A. Burns 4/30/97 NOTICE OF MOTION AND MOTION FOR BILL Refused/Returned OF PARTICULARS, #CV-97-3438, to Sender, mailed to Dr. & Mrs. Eugene A. Burns Marked "ILLEGAL" Complaint of Fraud, Mail Fraud, Conspiracy, Obstruction, Libel: Page 2 of 5 5/ 1/97 update to NOTICE OF MOTION AND MOTION Refusal for Cause FOR BILL OF PARTICULARS, #CV-97-3438, Without Dishonor, mailed to Dr. & Mrs. Eugene A. Burns Marked "ILLEGAL" 5/ 7/97 MOTION TO RECONSIDER MINUTE ENTRY Refusal for Cause OF 5/1/97, #CV-97-3438, mailed Without Dishonor, to Dr. & Mrs. Eugene A. Burns Marked "ILLEGAL" -and- returned, yellow post-it attached bearing message: "Postmaster -- This nit wit is harrassing us through the mail -- Do Not Send this crap to me -- Burns" [sic] 5/ 7/97 NOTICE OF MOTION AND MOTION TO MODIFY Refusal for Cause ORDER OF REFERRAL TO MEDIATION AND TO Without Dishonor, NAME ANOTHER DEFENDANT, #CV-97-3438, Marked "ILLEGAL" mailed to Dr. & Mrs. Eugene A. Burns 5/10/97 NOTICE OF FILING OF MOTION FOR RELIEF Refused/Returned FROM AUTOMATIC STAY AND OF REQUIREMENT to Sender, TO FILE OBJECTION, #93-06051-PHX-GBN, Marked "ILLEGAL" mailed to New Life Health Center Co. 5/12/97 OBJECTION TO JUDGE PRO TEMPORE; Refused/Returned APPLICATION FOR LEAVE TO AMEND to Sender ORIGINAL COMPLAINT; NOTICE OF INTENT TO REMOVE CASE TO SUPERIOR COURT, #CV-97-3438, mailed to Dr. & Mrs. Eugene A. Burns 5/12/97 NOTICE AND DEMAND FOR MANDATORY Refusal for Cause JUDICIAL NOTICE, #CV-97-3438, Without Dishonor, mailed to Dr. & Mrs. Eugene A. Burns Marked "ILLEGAL" -and- returned, yellow post-it attached bearing message: "Postmaster -- Do Not Return this Mail to Recipients -- this Idiot is Harrassing us by way of the Mail" [sic] Please take note of the fact that most of this mail is legal in nature, because it relates either directly, or indirectly, to litigation in which I am presently, or was, involved as a litigant. I now draw your attention to the following specific evidence, some of which you should already have in your possession: 1. Dr. Burns is, evidently, refusing mail which has been addressed to other parties (e.g. mail dated 3/5/97 to several other parties concerning "Sheryl Smith" [sic]); 2. Dr. Burns libels the sender by falsely modifying the mail to read "ILLEGAL MAIL" [sic], when the contents are legal in nature (i.e. "LEGAL MAIL") and according to law (see First Amendment); 3. Dr. Burns libels the sender by falsely modifying the mail to read that the sender is using the mails to harrass [sic] the recipients (e.g. see mail dated 4/18/97 and 5/7/97); Complaint of Fraud, Mail Fraud, Conspiracy, Obstruction, Libel: Page 3 of 5 4. Dr. Burns has demanded that legal mail not be sent to him, in an effort to obstruct its delivery to him and the New Life Health Center Company (e.g. mail dated 4/18/97 and 5/7/97); 5. Dr. Burns has resorted to libel in an effort to defame the sender, by referring to the sender as a "nit wit" [sic] and an "idiot" [sic] (e.g. mail dated 5/7/97 and 5/12/97); and, 6. Dr. Burns has committed perjury and contempt of court by filing false documents in the United States District Court, including, but not limited to, a false non- disclosure agreement, and a false appointment of Me to the position of Vice President for Legal Affairs of the New Life Health Center Company, in a conspiracy involving Mrs. Linda H. Burns and Neil T. Nordbrock, and possibly also other unnamed individuals. These same false documents were served on other parties via first class United States Mail (see PROOF's OF SERVICE in #GJ-95-1-6). INCORPORATION OF RELATED EVIDENCE I hereby incorporate into this VERIFIED COMPLAINT all other material evidence which I have heretofore transmitted to your office during the past twelve (12) months, and I incorporate the same as if all other material evidence were set forth fully herein. 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 statement of fact and law is true and correct, to the best of My current information, knowledge, and belief, so help Me God, pursuant to 28 U.S.C. 1746(1). See Supremacy Clause. Dated: May 20, 1997 Respectfully submitted, /s/ Paul Andrew Mitchell ______________________________________________ Paul Andrew Mitchell, Sui Juris Citizen of Arizona state (expressly not a citizen of the United States) All Rights Reserved without Prejudice Complaint of Fraud, Mail Fraud, Conspiracy, Obstruction, Libel: Page 4 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," 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): VERIFIED COMPLAINT OF FRAUD, MAIL FRAUD, CONSPIRACY, OBSTRUCTION OF MAIL, AND LIBEL WITH INTENT TO INJURE by placing one true and correct copy of said document(s) in first class United States Mail, with postage prepaid and properly addressed to the following: James A. Crawford Postal Inspector U.S. Postal Inspection Service c/o P.O. Box 26320 Tucson, Arizona state Chief of Police Tucson Police Department c/o 270 South Stone Avenue Tucson, Arizona state Neil and Evelyn Nordbrock c/o 6642 E. Calle de San Alberto Tucson, Arizona state Lawrence E. Condit c/o 376 South Stone Avenue Tucson, Arizona state Dr. and Mrs. Eugene A. Burns c/o 4500 E. Speedway, #27 Tucson, Arizona state Executed on May 20, 1997: /s/ Paul Andrew Mitchell ______________________________________________ Paul Andrew Mitchell, Sui Juris Citizen of Arizona state (expressly not a citizen of the United States) All Rights Reserved without Prejudice Complaint of Fraud, Mail Fraud, Conspiracy, Obstruction, Libel: Page 5 of 5 # # #
Return to Table of Contents for
New Life Bankruptcy