c/o 2509 N. Campbell, #1776 Tucson [zip code exempt] ARIZONA STATE May 23, 1997 SECOND SUPPLEMENT TO 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 the SECOND SUPPLEMENT to 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. The original VERIFIED COMPLAINT has already been executed and served upon you and others (see PROOF OF SERVICE infra). 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 weeks. True and correct copies of the refused envelopes are attached. Date Contents Reason Returned ------- ------------------------------------- ---------------- 4/ 4/97 NOTICE OF INTENT TO PETITION FOR Refused/Returned LEAVE TO AMEND ORIGINAL COMPLAINT AND to Sender TO NAME NEW DEFENDANTS, #CV-97-3438, mailed to "Sheryl Smith" [sic] 4/ 4/97 NOTICE OF INTENT TO PETITION FOR Refused/Returned LEAVE TO AMEND ORIGINAL COMPLAINT AND to Sender TO NAME NEW DEFENDANTS, #CV-97-3438, mailed to "Rachel Saull" [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: Amend Complaint of Fraud/Mail Fraud/Conspiracy/Obstruction/Libel: Page 1 of 4 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 petition clause); 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); 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 SECOND SUPPLEMENT TO 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 by reference, 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. Amend Complaint of Fraud/Mail Fraud/Conspiracy/Obstruction/Libel: Page 2 of 4 Dated: May 23, 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 Amend Complaint of Fraud/Mail Fraud/Conspiracy/Obstruction/Libel: 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): SECOND SUPPLEMENT TO 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 23, 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 Amend Complaint of Fraud/Mail Fraud/Conspiracy/Obstruction/Libel: Page 4 of 4 # # #
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Mitchell v. Nordbrock