Paul Andrew Mitchell, Sui Juris
Citizen of Arizona state
c/o General Delivery at:
2509 North Campbell Avenue
Tucson, Arizona state
In Propria Persona
All Rights Reserved
Without Prejudice
PIMA COUNTY CONSOLIDATED JUSTICE COURT
Paul Andrew Mitchell, ) Case Number #CV-97-3438
Plaintiff )
) NOTICE AND DEMAND FOR
v. ) MANDATORY JUDICIAL NOTICE:
) Rule 201(d), Arizona Rules
Neil and Evelyn Nordbrock, ) of Evidence
Defendants )
________________________________)
COMES NOW Paul Andrew Mitchell, Sui Juris, Citizen of Arizona
state and Plaintiff in the above entitled matter (hereinafter
"Plaintiff"), 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 Arizona Rules of Evidence, of the
official court record of representation of the criminal defendant
Charles Levis Taylor by the office of the Pima County Public
Defender in the case of State of Arizona v. Charles Levis Taylor,
Superior Court case number #CR-50321.
Mandatory judicial notice leaves no room for discretion on
the part of this honorable Court, since the legislative intent of
the word "shall" in Rule 201(d) has a compulsory meaning. Confer
at "shall" in Black's Law Dictionary, Sixth Edition.
Sixth Notice and Demand for Mandatory Judicial Notice:
Page 1 of 4
Plaintiff submits the following as proof of the relevance of
said record of representation by the Public Defender's office:
In a letter dated December 10, 1996, Defendant Neil Thomas
Nordbrock made the following libelous statement, to wit:
"According to what I know, of those you have assisted with
legal problems since coming to Tucson, here are the results:
"Charles Taylor, convicted." [sic]
Plaintiff submits, for the benefit of this honorable Court, and
of all interested party(s), the Pima County Superior Court's
MINUTE ENTRY dated March 11, 1996, quoted in part as follows:
"The defendant moves to dismiss the Public Defender from his
case and argues to the Court for the dismissal. ...
"The Court will not grant new counsel. Mr. Bowman is
directed to be present at the time of sentencing. If the
defendant does not want him to speak, the defendant can do
so himself.
"Mr. Bowman is directed to file a notice of appeal after
sentencing for the defendant if the defendant desires one so
that this may be done before he is relieved from
representing the defendant." [emphasis added]
[MINUTE ENTRY, Hon. John S. Leonardo]
[Arizona Superior Court, Pima County]
[Case No. CR-50321, March 11, 1996]
The plain fact of the matter is that Mr. Ken Bowman represented
Charles Levis Taylor throughout said case; Mr. Ken Bowman and
Plaintiff were both present at the hearing scheduled for
sentencing on March 28, 1996, which hearing Charles Levis Taylor
did not attend. Mr. Nordbrock's statement is libelous, and
constitutes defamation of Plaintiff's character, because it
insinuates that Plaintiff's action(s) resulted in the conviction
of Charles Levis Taylor for conspiracy to kidnap in said case.
This is a lie, because Plaintiff did not meet Mr. Taylor until
after Mr. Taylor's conviction in said case.
Sixth Notice and Demand for Mandatory Judicial Notice:
Page 2 of 4
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", that the above statement(s) of fact
are 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: March 14, 1997
Respectfully submitted,
/s/ Paul Andrew Mitchell
_____________________________________
Paul Andrew Mitchell, Sui Juris
Citizen of Arizona state
All Rights Reserved without Prejudice
Sixth Notice and Demand for Mandatory Judicial Notice:
Page 3 of 4
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):
NOTICE AND DEMAND FOR
MANDATORY JUDICIAL NOTICE:
Rule 201(d), Arizona Rules of Evidence
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:
Neil and Evelyn Nordbrock
c/o 6642 E. Calle de San Alberto
Tucson, Arizona state
Pima County Public Defender
Attention: Mr. Ken Bowman (courtesy copy)
32 North Stone Avenue, 4th Floor
Tucson, Arizona state
Executed on March 14, 1997:
/s/ Paul Andrew Mitchell
_____________________________________
Paul Andrew Mitchell, Sui Juris
Citizen of Arizona state
All Rights Reserved without Prejudice
Attachments follow infra.
Sixth Notice and Demand for Mandatory Judicial Notice:
Page 4 of 4
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Mitchell v. Nordbrock