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 REBUTTAL TO
Debtor                          )  ATTORNEYS' RESPONSE TO
                                )  APPLICATION FOR INTERVENTION
                                )  OF RIGHT, RELIEF FROM
                                )  AUTOMATIC STAY, AND
________________________________)  DECLARATORY JUDGMENTS;
                                )  MOVANT'S OPPOSITION TO
Paul Andrew Mitchell,           )  ATTORNEYS' MOTION TO DISMISS:
                                )
          Movant,               )  Full Faith and Credit Clause
     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  rebut all  issues raised  in DEBTOR'S  RESPONSE TO

APPLICATION FOR INTERVENTION OF RIGHT, RELIEF FROM AUTOMATIC STAY

AND DECLARATORY JUDGMENTS AND MOTION TO DISMISS SAME, served upon

Movant by  persons alleging  to be  authorized counsel for Debtor

(hereinafter "Debtors' attorneys").


     Rebuttal to Attorneys' Response and Motion to Dismiss:
                          Page 1 of 15


     For  the   convenience  of   this  honorable  Court,  Movant

addresses the  issues in  the order  of their  appearance in said

RESPONSE, as follows (quotes in bold):

     1.   Debtor's  attorneys   allege   that   Movant   was   an

independent consultant  [sic] for an extremely brief period [sic]

prior to June, 1996 [sic].  Quoting:

     Applicant was, for an extremely brief period, an independent
     consultant who  did perform  certain  services,  on  an  "as
     needed basis", for Debtor prior to June, 1996.


     Movant will  now show that this claim is false, constructs a

fraudulent  misrepresentation,  and  should  be  disregarded  for

attempting to mislead this honorable Court, and for violating the

prohibition against same at 18 U.S.C. 157: bankruptcy fraud.

     First, Movant  was appointed to the office of Vice President

for Legal Affairs by means of an appointment which was witnessed,

and represented to be bona fide, by Dr. and Mrs. Eugene A. Burns,

by Mr.  Neil T.  Nordbrock, and  by  other  accessories  and  co-

conspirators who  thereby aided  and abetted  an act  of outright

fraud upon  Movant and  upon the  United States  District  Court,

Judicial District of Arizona.  See 28 U.S.C. 82, 132.

     Acting in  Movant's capacity  as Debtor's Vice President for

Legal Affairs,  Movant prepared  and either filed, or assisted in

filing, at  least twenty-five  (25) separate  pleadings and other

documents In  Re Grand  Jury Subpoena  Served on  New Life Health

Center Company,  USDC Arizona,  Tucson,  case  number  #GJ-95-1-6

(hereinafter "grand  jury case").   One  of  these  25  documents

contained a verified copy of Movant's appointment to said office,

in the form of an exhibit.  See 28 U.S.C. 1746(1).


     Rebuttal to Attorneys' Response and Motion to Dismiss:
                          Page 2 of 15


     At the second hearing on that matter, United States District

Judge John  M. Roll  admitted said appointment into evidence and,

on the  strength of same, permitted Movant to address the USDC in

Movant's capacity  as Vice  President for  Legal Affairs.    Said

second hearing occurred on May 3, 1996.

     Moreover, Movant's  work for Debtor continued well into July

of 1996,  and well  beyond the  false and  misleading termination

date implied  by Debtor's  attorneys when they allege that Movant

did perform  certain services  prior to  June, 1996.   This would

necessarily imply  that all pleadings submitted in the grand jury

case were  prepared on,  or before,  May 31, 1996.  The record is

quite otherwise, as will now be demonstrated.

     As proof  that the  pleadings prepared  and filed  by Movant

necessitated work  which was performed after May 31, 1996, Movant

attaches a true and correct copy of Movant's AFFIDAVIT OF DEFAULT

AND OF  PROBABLE CAUSE,  signed, dated, served, and filed in said

case, and  incorporates same  as if  set forth  fully herein (see

Exhibit "A").   This  honorable Court  will  please  take  formal

judicial notice  of the  numerous entries  which begin in Exhibit

"A" at  page 7  of 10, line 15, showing a date of "06/03/96", and

which end at page 9 of 10, line 12, showing a date of "06/18/96".

Said AFFIDAVIT OF DEFAULT was executed by Movant on July 3, 1996.

     Moreover, Movant  continued to  perform additional  services

for Debtor,  as evidenced  by the draft PETITION FOR REHEARING EN

BANC which  was completed  pursuant to  a verbal authorization by

Dr. Eugene  A. Burns.   Said PETITION was originally completed on

July 10,  1996, but Dr. Burns experienced an unexpected change of

heart and  decided, at  the last  possible moment, against filing

said PETITION  with the  United States  Court of  Appeals for the

Ninth Circuit.  Said PETITION is attached hereto and incorporated

by reference as if set forth fully herein (see Exhibit "B").


     Rebuttal to Attorneys' Response and Motion to Dismiss:
                          Page 3 of 15


     July 25, 1996, was Movant's last working day on the premises

of the  Debtor's administrative  offices at  4500 East  Speedway,

Suite 27,  Tucson, Arizona  state.   This date  is  exhibited  on

Movant's NOTICE  AND DEMAND  to Dr.  Eugene A.  Burns, a verified

copy of  which has  already been  filed in the official record of

the instant case.  See Movant's 3rd SUPPLEMENT TO APPLICATION FOR

INTERVENTION OF  RIGHT, FOR  RELIEF FROM  THE AUTOMATIC  STAY AND

DEMAND FOR MANDATORY JUDICIAL NOTICE.

     Accordingly, the  record before  this Court exhibits a clear

preponderance of documentary evidence which refutes the false and

misleading implication  by Debtor's attorneys that Movant did not

perform any services for Debtor after May 31, 1996.

     Furthermore, it  is a gross distortion and misrepresentation

by Debtor's  attorneys to  state that  Movant  performed  certain

services  as   an  "independent   consultant"  [sic].    Movant's

appointment to  the office  of Vice  President for  Legal Affairs

gave Movant  good cause to assume much greater responsibility for

the legal  affairs of Debtor, than would ever be assumed, or even

implied, by the position of an "independent consultant" [sic].

     On the  other hand,  if their  use of  the term "independent

consultant" is  an oblique  admission by  Debtor's attorneys that

Movant was  not lawfully  appointed to  the position  of Debtor's

Vice President  for Legal  Affairs, Movant  respectfully requests

this honorable  Court to take specific judicial Notice of such an

important admission.  Movant argues that such an admission should

figure centrally  in future and final declaratory judgments which

this honorable Court has been requested to issue in the matter of

Movant's appointment to said office.


     Rebuttal to Attorneys' Response and Motion to Dismiss:
                          Page 4 of 15


     2.   As  Vice   President  for  Legal  Affairs,  Movant  was

specifically retained  by Debtor to counsel Debtor in the conduct

of Debtor's  legal affairs, and Movant continues to serve others,

and to  be retained  by others, in His capacity as a Counselor at

Law.   Confer at  "Counsellor at Law" in Bouvier's Law Dictionary

(1856);  at "Attorn" in Black's Law Dictionary, Sixth Edition.

     The Virginia  Legislature was  the last Union state required

to ratify  the original  Thirteenth  Amendment  (1819),  and  the

Commonwealth of  Virginia did,  in fact,  approve that  proposal.

See Full Faith and Credit Clause.  The U.S. Secretary of State is

prohibited from  ignoring facts  in evidence,  and  from  issuing

declarations which  presume facts  which  are  not  in  evidence.

Movant believes,  based on  7+ years  of intensive constitutional

research, that Movant would forfeit His state Citizenship and His

eligibility to  serve in  any public  office anywhere in America,

should Movant  accept a bar license of any kind.  See Legislative

History of the original Thirteenth Amendment.

     3.   Debtor's attorneys  make an  even more absurd statement

by misreading  the pleadings  which Movant has already filed in a

related civil case in the Pima County Consolidated Justice Court,

Mitchell v. Nordbrock, #CV-97-3438.  Said statement reads:

     ... Applicant  has filed  certain  papers  ...    apparently
     seeking to  have  certain  Arizona  federal  judges,  United
     States attorneys (including Janet Reno and Janet Napolitano)
     and others  (including one of the undersigned) involuntarily
     committed to an unspecified alcohol rehabilitation program.


     Rebuttal to Attorneys' Response and Motion to Dismiss:
                          Page 5 of 15


     Movant now  briefly demonstrates to this honorable Court why

the statement immediately above is totally and completely false.

     Because Movant  has  witnessed  habitual  alcohol  abuse  by

Debtor's accountant,  one Neil  T.  Nordbrock,  and  because  Mr.

Nordbrock embezzled  approximately $3,000  which Movant entrusted

to Mr.  Nordbrock's care and management, Movant sued Mr. and Mrs.

Neil T.  Nordbrock for  embezzlement and other specified damages.

See   Mitchell v. Nordbrock,  Pima  County  Consolidated  Justice

Court, Tucson, case number #CV-97-3438.

     After filing  and serving  the original  complaint  in  that

case, Movant  filed in  said Justice  Court a  PETITION TO  ORDER

DEFENDANTS INTO  INVOLUNTARY ALCOHOL  REHABILITATION, AND TO SEAL

THE CASE  FILE FOR  REASONS OF PRIVACY.  Movant thereby sought an

order instructing  Mr.  and  Mrs.  Neil  T.  Nordbrock  to  enter

involuntary alcohol  rehabilitation, supervised  by  Pima  County

Adult Probation  Services.   A true  and  correct  copy  of  said

PETITION is  attached hereto  and incorporated by reference as if

set forth fully herein (see Exhibit "C").

     At no  time has  Movant  ever  petitioned  the  Pima  County

Consolidated Justice  Court,  or  any  other  court  in  America,

"seeking to  have certain  Arizona federal  judges, United States

attorneys (including  Janet Reno [sic] and Janet Napolitano), and

others ...  involuntarily committed  to  an  unspecified  alcohol

rehabilitation program" [sic].  This is a lie!

     On the  contrary, Movant  has been rather specific about the

two  (2)   individuals  whom   Movant  wished  to  enter  alcohol

rehabilitation, namely,  Mr. and  Mrs. Neil  T. Nordbrock, and no

others.


     Rebuttal to Attorneys' Response and Motion to Dismiss:
                          Page 6 of 15


     Moreover, Movant  was also  specific by  requesting an order

instructing same  to enter  an involuntary alcohol rehabilitation

program, supervised by Pima County Adult Probation Services.

     4.   Debtor's attorneys  allege  that  they  are  unable  to

respond to  Movant's application  for relief  from the  automatic

stay and  for declaratory  relief, because  the relief  sought is

largely unintelligible.  The statement in question now follows:

     While  Applicant's   request  for   intervention  is   self-
     explanatory, the  Debtor is unable to respond to Applicant's
     motion for  relief from  stay and  request  for  declaratory
     relief because the relief sought is largely unintelligible.


     Movant is  truly perplexed  by this  statement, because  the

relief sought  is  rather  clear  and  straightforward.    Movant

intends to  sue Debtor,  and  all  of  its  officers,  employees,

trustees, co-workers,  subcontractors, counsels, accessories, and

co-conspirators,  for  a  number  of  specified  and  unspecified

damages which  were inflicted  upon Movant  prior to vacating the

Debtors' administrative offices on July 25, 1996, and afterwards,

continuing right  up to  the present time.  The automatic stay is

usually presumed  to bar  any legal  action against  the  Debtor,

unless the automatic stay is lifted by order of this Court.

     Accordingly, Movant  intends to amend the original complaint

in  Mitchell v. Nordbrock  supra, so  as to  name the  Debtor and

others including,  but not  limited to,  Ms.  Sheryl  Smith,  Ms.

Rachel Saull,  Dr. and Mrs. Eugene A. Burns, Dr. and Mrs. Sheldon

C. Deal,  Mr. Tim Hay, and Ms. Susan Shew, who were previously or

are presently  associated with  the Debtor in one way or another,

as additional  co-defendants in  a case  now required  by Arizona

state law to be transferred to the Superior Court of Arizona.


     Rebuttal to Attorneys' Response and Motion to Dismiss:
                          Page 7 of 15


     Therefore, Movant respectfully requests this honorable Court

to lift  the automatic  stay, so  as to  allow  such  an  amended

complaint to  proceed in  the Superior  Court of Arizona.  Such a

goal should  be rather  intelligible, particularly to persons who

claim  to  be  licensed  attorneys,  and  possibly  also  college

graduates.  Movant presumes Debtor's attorneys went to college.

     5.   Debtor's attorneys make an important admission, namely,

that Movant  is a  "party of  interest"  pursuant  to  11  U.S.C.

1109(b).   By now,  that should  obvious to this honorable Court,

and to all other interested party(s).

     6.   Debtor's attorneys  perform the  obligatory denials, as

follows:

     To the  extent relevant, the Debtor denies that Cheryl Smith
     is  a  fictitious  person  whose  name  has  been  used  for
     fraudulent purposes.   Debtor  further denies that Applicant
     has incurred  any damages  or that  Applicant has  any claim
     against the Debtor.


     Movant  submits  that  Debtor's  attorneys  have  made  this

statement, because it is the only way Debtor can avoid inevitable

summary judgments  which Movant  will respectfully  request  this

Court to  issue, in  the face  of the  preponderance  of  adverse

evidence which Movant has already filed in the instant case.

     To this end, Movant provides formal Notice to all interested

party(s), and demands mandatory judicial Notice by this honorable

Court, of  Movant's intent  to issue a proper and lawful subpoena

to "Sheryl  Smith" [sic],  to compel  her appearance  before this

honorable Court  and to  compel her  sworn  testimony  concerning

Movant's claims, but only after obtaining leave of this honorable

Court formally to intervene in the instant case.


     Rebuttal to Attorneys' Response and Motion to Dismiss:
                          Page 8 of 15


     Further  on,  Debtor's  attorneys  made  another  false  and

misrepresentative statement concerning the docket fee:

     Finally, upon  information and  belief, Applicant has failed
     to pay  the requisite filing fee and, therefore, Applicant's
     request for relief from the automatic stay should be denied.


     Movant wishes this honorable Court to take special notice of

another lie  from Debtor's attorneys.  Their Response to Movant's

Application is  dated May 27, 1997.  Movant's filing fee was paid

via United  States Postal  Money Order  purchased and  mailed  on

April 26, 1997, one whole month before their Response was signed.

     Accordingly, this  honorable  Court  should  order  Debtor's

attorneys to  show cause  why they  should not  be  charged  with

barratry, for  demonstrating negligence  and unethical conduct by

failing to make a simple telephone call to the Clerk of Court, to

confirm whether  or not  Movant's filing fee had been paid before

May 27,  1997.   Confer at  "Barratry" in Black's Law Dictionary,

Sixth Edition (with pronunciations).

     7.   Debtor's   attorneys    also   allege   that   Movant's

application for  declaratory relief  is procedurally improper, in

that it  can only  be brought as an adversary proceeding pursuant

to Rule 7001 et seq.  Quoting now:

     With respect  to Applicant's apparent motion for declaratory
     relief, such  relief is  procedurally improper  in  that  it
     could only be brought as an adversary proceeding pursuant to
     Federal Rule of Bankruptcy Procedure 7001 et seq.


     By  simultaneously   requesting   intervention   of   Right,

declaratory judgments, and relief from the automatic stay, Movant

by no means intends to imply that Movant has any procedural Right

to prosecute an adversary proceeding, until and unless this Court

should grant  Movant's applications for relief from the automatic

stay and  for intervention of Right, in the first instance.  Only

then could  this Court  properly consider  granting, or  denying,

Movant's application for declaratory judgments and other relief.


     Rebuttal to Attorneys' Response and Motion to Dismiss:
                          Page 9 of 15


     Specifically, should  this honorable  Court  grant  Movant's

application to  lift the  automatic stay,  there is no procedural

reason known  to Movant  why this  Court could  not then consider

Movant's applications  for intervention of Right, for declaratory

judgments, and  for all  other relief which this Court deems just

and  proper,   including,  but   not  limited   to,  requests  to

consolidate the  instant case with the personal bankruptcy of Dr.

and Mrs.  Eugene A.  Burns, #96-01624-TUC, and/or to dismiss both

bankruptcy cases with prejudice, for their having committed fraud

upon both courts (U.S. Bankruptcy Courts, Phoenix and Tucson).

     In  summary,  this  Court  should  first  rule  on  Movant's

applications to  lift the  automatic stay and for intervention of

right.   Assuming that  the automatic  stay  is  lifted  and  the

intervention of right is granted, this Court should then consider

Movant's application  for declaratory  judgments  and  all  other

relief which this Court deems just and proper.


                        REMEDY REQUESTED

     Wherefore,  all  premises  having  been  considered,  Movant

respectfully requests this honorable Court to enter orders:

     (1)  denying the request by Debtor's attorneys that Movant's
          Application be dismissed;

     (2)  lifting the automatic stay;

     (3)  granting Movant  leave to  intervene by  Right  in  the
          instant case;  and,

     (4)  requiring Debtor's  attorneys to  show cause  why  they
          should not  be charged  with barratry  and  fraud,  for
          their unethical,  false, and  fallacious statements now
          filed in the instant case.  See Article VI, Clause 3.


     Rebuttal to Attorneys' Response and Motion to Dismiss:
                          Page 10 of 15


                          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:  May 30, 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


     Rebuttal to Attorneys' Response and Motion to Dismiss:
                          Page 11 of 15


                        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 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:
                  Full Faith and Credit Clause

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:


New Life Health Center Company     Christopher H. Bayley
c/o 4500 E. Speedway, #27          Todd V. Jones
Tucson 85712/tdc                   c/o 400 E. Van Buren
ARIZONA STATE                      One Arizona Center
                                   Phoenix 85004-0001/tdc
                                   ARIZONA STATE
United States Trustees
c/o P.O. Box 36170
Phoenix 85067-6170/tdc
ARIZONA STATE

Creditors' Committee
In re:  New Life Health Center Company
c/o United States Trustee
P.O. Box 36170
Phoenix 85067-6170/tdc
ARIZONA STATE


[See USPS Publication #221 for addressing instructions.]


Executed on May 30, 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


     Rebuttal to Attorneys' Response and Motion to Dismiss:
                          Page 12 of 15


                          Exhibit "A":

           AFFIDAVIT OF DEFAULT AND OF PROBABLE CAUSE
               In Re Grand Jury Subpoena Served on
                 New Life Health Center Company
                USDC Arizona, Tucson, #GJ-95-1-6


     Rebuttal to Attorneys' Response and Motion to Dismiss:
                          Page 13 of 15


                          Exhibit "B":

                 PETITION FOR REHEARING EN BANC:
                  U.S.A. v. Eugene Arthur Burns
            Ninth Circuit Court of Appeals, #96-16145

                       [draft: not filed]


     Rebuttal to Attorneys' Response and Motion to Dismiss:
                          Page 14 of 15


                          Exhibit "C:"

                PETITION TO ORDER DEFENDANTS INTO
               INVOLUNTARY ALCOHOL REHABILITATION,
                    AND TO SEAL THE CASE FILE
                     FOR REASONS OF PRIVACY:
                     Mitchell v. Nordbrock,
             Pima County Consolidated Justice Court
                       Tucson, #CV-97-3438


     Rebuttal to Attorneys' Response and Motion to Dismiss:
                          Page 15 of 15


                             #  #  #
      


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