Paul Andrew Mitchell, Sui Juris c/o general delivery at: 2509 North Campbell Avenue, #1776 Tucson [ZIP code exempt] ARIZONA STATE, USA In Propria Persona All Rights Reserved, without prejudice DISTRICT COURT OF TEXAS STATE HAYS COUNTY Paul Andrew Mitchell, ) Case No. #CV-98-0547 ) Plaintiff, ) VERIFIED CRIMINAL COMPLAINT ) v. ) 28 U.S.C. 1746(1); ) Supremacy Clause City of San Marcos, ) San Marcos Utility, ) Community Action, Inc. ) of Hays, Caldwell, & ) Blanco Counties, ) Century Telephone, Inc., ) and Does 1 thru 25, ) ) Defendants. ) ________________________________) COMES NOW Paul Andrew Mitchell, Citizen of Arizona state, expressly not a citizen of the United States ("federal citizen"), Counselor at Law, qualified Federal Witness, and Private Attorney General (hereinafter "Plaintiff"), to file this, his VERIFIED CRIMINAL COMPLAINT against the following individuals, for the corresponding crimes enumerated infra, and to provide formal Notice to all interested Party(s) of same. Verified Criminal Complaint: Page 1 of 8 Plaintiff hereby formally charges: Jane Doe #1, a/k/a female arresting officer, with: attempting to compel disclosure of a Social Security Number ("SSN") on the morning of March 11, 1998 ("3/11/98"), in direct violation of Title 42, United States Code ("U.S.C."), section 408(a)(8), and of Public Law 93-579, one count; retaliating against a federal witness and victim on the morning of 3/11/98, in direct violation of Title 18, U.S.C., section 1513, one count; deprivation of Plaintiff's fundamental Rights on 3/11/98, in direct violation of Title 18, U.S.C., section 242, one count; conspiracy to deprive Plaintiff's fundamental Rights on 3/11/98, in direct violation of Title 18, U.S.C., section 241, one count; and, false arrest and false imprisonment on 3/11/98, in direct violation of Texas Penal Code ("P.C.") section 20.02, one count. John Doe #2, a/k/a male arresting officer, with: attempting to compel disclosure of an SSN on the morning of March 11, 1998 ("3/11/98"), in direct violation of Title 42, U.S.C., section 408(a)(8), and of Public Law 93-579, one count; retaliating against a federal witness and victim on the morning of 3/11/98, in direct violation of Title 18, U.S.C., section 1513, one count; deprivation of Plaintiff's fundamental Rights on 3/11/98, in direct violation of Title 18, U.S.C., section 242, one count; conspiracy to deprive Plaintiff's fundamental Rights on 3/11/98, in direct violation of Title 18, U.S.C., section 241, one count; and, false arrest and false imprisonment on 3/11/98, in direct violation of Texas Penal Code ("P.C.") section 20.02, one count. Mrs. Pamela Cook with: deadly conduct, also known as reckless endangerment, in direct violation of Texas P.C. section 22.05, in connection with the creation and execution of company directives given to telephone answering service operators, to dispatch tow trucks before dispatching medical emergency calls from hospital intensive care units and emergency rooms, one count; and, Verified Criminal Complaint: Page 2 of 8 Mrs. Pamela Cook (continued): theft of material evidence and other private property, in direct violation of Texas P.C. section 31.03, in connection with the disappearance of Plaintiff's household dishes and printed documentary evidence (2 volumes) of criminal copyright violations on the Internet, one count. Mr. Ronald Holmes with: assaulting a federal witness and victim on May 21, 1998 ("5/21/98"), in direct violation of Title 18, U.S.C., section 1513, one count; deprivation of Plaintiff's fundamental Rights on 5/21/98, in direct violation of Title 18, U.S.C., section 242, one count; and, attempted extortion of cash money by threatening Plaintiff with the loss of adequate housing on 5/21/98, in direct violation of Texas P.C. sections 31.01 and 31.03, one count. Mrs. Joyce M. Jones with: false statement(s) to obtain one hundred dollars ($100.00) of property or credit, in direct violation of Texas P.C. section 32.32, in connection with Plaintiff's contract to sublet the apartment at 108 Uhland Road, Unit #1, in the city of San Marcos, Texas state, one count; theft and/or unlawful conversion of Plaintiff's notarized Affidavit of Identification, in direct violation of Texas P.C. sections 31.01 and 31.03, one count; deprivation of Plaintiff's fundamental Rights, in direct violation of Title 18, U.S.C., section 242, one or more counts; conspiracy to deprive Plaintiff's fundamental Rights, in direct violation of Title 18, U.S.C., section 241, one or more counts; and, civil breach of rental contract, one count. Mr. David Jordan with: theft of services, in direct violation of Texas P.C. sections 31.01 and 31.03, in connection with Plaintiff's failure to be paid for one hundred seven dollars ($107.00) worth of private contract labor, one count. Verified Criminal Complaint: Page 3 of 8 Mrs. Gwen Norris with: deadly conduct, also known as reckless endangerment, in direct violation of Texas P.C. section 22.05, in connection with the creation and execution of company directives given to telephone answering service operators, to dispatch tow trucks before dispatching medical emergency calls from hospital intensive care units and emergency rooms, one count. Mr. Tommy Norris with: deadly conduct, also known as reckless endangerment, in direct violation of Texas P.C. section 22.05, in connection with the creation and execution of company directives given to telephone answering service operators, to dispatch tow trucks before dispatching medical emergency calls from hospital intensive care units and emergency rooms, one count; impersonating a public servant, in direct violation of Title 4, U.S.C., section 101, and of Texas P.C. section 37.11, one count; deprivation of Plaintiff's fundamental Rights, in direct violation of Title 18, U.S.C., section 241, in connection with wrongful termination of Plaintiff from the Tellcall Answering Service or its successor in interest, one count; conspiracy to deprive Plaintiff's fundamental Rights, in direct violation of Title 18, U.S.C., section 241, in connection with wrongful termination of Plaintiff from the Tellcall Answering Service or its successor in interest, one count; and, wrongful termination, civil, one count. Mr. John Polanco, Jr., with: impersonating a public servant, in direct violation of Title 4, U.S.C., section 101, and Texas P.C. section 37.11, one count; being an accessory to theft, after the fact, in direct violation of Texas P.C. sections 7.01, 7.02, and 31.03, in connection with the disappearance of Plaintiff's household dishes and printed documentary evidence (2 volumes) of criminal copyright violations on the Internet, one count; abuse of official capacity, in direct violation of Texas P.C. section 39.02, in connection with Plaintiff's temporary detention by Hays County Constables, and compelled meeting in chambers to discuss lawful documents served by Plaintiff on individuals named herein, one count; Verified Criminal Complaint: Page 4 of 8 Mr. John Polanco, Jr. (continued): misuse of official information, in direct information of Texas P.C. 39.06, in connection with the disappearance of Plaintiff's printed documentary evidence (2 volumes) of criminal copyright violations on the Internet, and alleged "complaints" [sic] lodged by Mr. Tommy Norris and possibly other as yet unnamed individuals, one count; and, violation of Plaintiff's fundamental Rights, also known as "civil rights" [sic], specifically including, but not limited to, due process of law, while Plaintiff was in the custody of Hays County Constables, in connection with alleged "complaints" [sic] lodged by Mr. Tommy Norris and possibly other as yet unnamed individuals, one count. Mr. Andrew Thomas Scott with: obstruction and/or attempted obstruction of United States Mail deliverable to Plaintiff c/o 508 Uhland Road, Unit 110, in the city of San Marcos, Texas state, in direct violation of Title 18, U.S.C., section 1701, one count; and, grand theft and/or attempted grand theft of Plaintiff's private property in a high-performance computer network and all related hardware, software, peripherals, and databases loaded on same, valued in excess of $350,000.00, in direct violation of Texas P.C. sections 31.01 and 31.03, two counts. Ms. Jennifer Van Alstyne with: deadly conduct, also known as reckless endangerment, in direct violation of Texas P.C. section 22.05, in connection with the creation and execution of company directives given to telephone answering service operators, to dispatch tow trucks before dispatching medical emergency calls from hospital intensive care units and emergency rooms, one count; deprivation of Plaintiff's fundamental Rights, in direct violation of Title 18, U.S.C., section 242, in connection with wrongful termination of Plaintiff from the Tellcall Answering Service or its successor, one count; and, conspiracy to deprive Plaintiff's fundamental Rights, in direct violation of Title 18, U.S.C., section 241, in connection with wrongful termination of Plaintiff from the Tellcall Answering Service or its successor in interest, one count. Verified Criminal Complaint: Page 5 of 8 Mr. Ed Worndel with: assaulting a federal witness and victim on May 6, 1998, in direction violation of Title 18, U.S.C., section 1513, one count; deprivation of Plaintiff's fundamental Rights, in direct violation of Title 18, U.S.C., section 242, one count; conspiracy to deprive Plaintiff's fundamental Rights, in direct violation of Title 18, U.S.C., section 241, one count; and, civil breach of rental contract. NOTICE OF INTENT Plaintiff hereby provides formal Notice to all interested Party(s) of Plaintiff's specific intent to execute, file, and service the requisite AFFIDAVIT(S) OF PROBABLE CAUSE, so as to substantiate each and every charge made above, as soon as time and resources permit. VERIFICATION I, Paul Andrew Mitchell, Plaintiff in the above entitled matter, hereby verify, under penalty of perjury, under the laws of the United States of America, without (outside) the "United States" (federal government), that the above statement of facts and laws is 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). See Supremacy Clause. Dated: September 24, 1998 Respectfully submitted, /s/ Paul Andrew Mitchell Paul Andrew Mitchell, B.A., M.S., Sui Juris Citizen of Arizona state, expressly not a federal citizen, Counselor at Law, Federal Witness, Private Attorney General, and Candidate for the United States House of Representatives Verified Criminal Complaint: Page 6 of 8 PROOF OF SERVICE 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 I am the Plaintiff in the above entitled matter, that I am a Citizen of ONE OF the United States of America, and that I transmitted the following document(s): VERIFIED CRIMINAL COMPLAINT by placing same in first class United States Mail, with proper postage prepaid, and properly directed to each of the following: San Marcos Utility Community Action, Inc. c/o 630 E. Hopkins St. c/o 101 Uhland Road, #1 San Marcos, Texas state San Marcos, Texas state Century Telephone, Inc. City of San Marcos c/o 208 S. Guadalupe Street c/o 630 E. Hopkins Street San Marcos, Texas state San Marcos, Texas state Mr. John Polanco, Jr. Mr. David Jordan c/o 1307 East Uhland Road 2015 Aspen Street San Marcos, Texas state San Marcos, Texas state Mr. Andrew Thomas Scott (last known address) c/o 508 Uhland Road, #110 San Marcos, Texas state Mr. Tommy & Mrs. Gwen Norris (last known address) c/o Tellcall Answering Service 423 N. LBJ Drive, Ste. "F" San Marcos, Texas state Mrs. Pamela Cook (last known address) c/o Tellcall Answering Service 423 N. LBJ Drive, Ste. "F" San Marcos, Texas state Mr. Ronald Holmes (last known address) c/o 508 Uhland Road, Ste. 110 San Marcos, Texas state Ms. Jennifer Van Alstyne (last known address) c/o Tellcall Answering Service 423 N. LBJ Drive, Ste. "F" San Marcos, Texas state Verified Criminal Complaint: Page 7 of 8 Mr. Ed Worndel (last known address) c/o 108 Uhland Road, Unit #1 San Marcos, Texas state Mrs. Joyce M. Jones c/o Rev. Jim Lanning (last known address) 1904 Ranch Road 12, Suite 114 San Marcos, Texas state Courtesy copies to: Postmaster United States Post Office San Marcos, Texas state Judge Alex Kozinski (supervising) Ninth Circuit Court of Appeals c/o P.O. Box 91510 Pasadena, California state Office of the Attorney General Civil Rights Division State of Texas State Capitol Austin, Texas state Detective Scott A. Johnson San Marcos Police Department 2300 IH 35 South San Marcos, Texas state Date: September 24, 1998 Respectfully submitted, /s/ Paul Andrew Mitchell Paul Andrew Mitchell, B.A., M.S., Sui Juris Citizen of Arizona state, expressly not a federal citizen, Counselor at Law, Federal Witness, Private Attorney General, and Candidate for the United States House of Representatives Verified Criminal Complaint: Page 8 of 8 # # #
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Mitchell v. City of San Marcos et al.