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.