MEMO

TO:       Hon. William H. Tinney
          Attn:  Secretary in Chambers
          c/o 110 West Congress
          Tucson 85701/tdc
          ARIZONA STATE

FROM:     Paul Andrew, Mitchell, B.A., M.S.
          Counselor at Law

DATE:     September 2, 1997

SUBJECT:  Hearing scheduled for today in:
          Swan Business Organization v. Ulan et al.
          Superior Court case number #315580


Dear Judge Tinney:

I regret  to inform  you that  I will not be at liberty to attend
the hearing  which has  been scheduled for 9:00 a.m. today in the
matter described above.

Despite my  best efforts  to arrange  adequate security,  it  now
appears that the private security and investigations firm which I
hired, will  not be  permitted to provide an armed escort between
the parking structure and the front door of the courthouse.

We have  been told that we must leave our firearms in the parking
structure, rather  than to  surrender them  to the  guards at the
front door  -- for  temporary storage  in the gun lock mounted on
the wall, just inside the entrance.  This leaves us vulnerable.

I would  not normally  consider  this  to  be  a  major  problem.
However, there  have now  been threats, and attempts, on my life,
and these  threats are quite obviously connected with the matters
which I  have already  documented in  the pleading transmitted to
you last Wednesday evening, and also filed by the Clerk.

In closing,  I would  ask the  Court to regard the filing of this
pleading to  be an  appearance in writing.  It is well known that
"appearances"  can   be  made   in  writing,  because  an  answer
constitutes an  "appearance."   Wieser v.  Richter, 247 Mich. 52,
225 N.W.  542, 543.   See the several definitions of "appearance"
in  Black's   Law  Dictionary,   Fourth  Edition  with  Guide  to
Pronunciation.


Respectfully yours,

/s/ Paul Andrew Mitchell

Paul Andrew, Mitchell, B.A., M.S.
Counselor at Law and federal witness
c/o 2509 N. Campbell Avenue, #1776
Tucson 85719/tdc
ARIZONA STATE (See USPS Publication #221.)

copies:   Michael Brown, Presiding Judge
          Division Commander, private security
          Lawrence E. Condit (via fax)

email:    supremelawfirm@altavista.net

website:  http://supremelaw.com


                             #  #  #

      

Return to Table of Contents for

Swan v. Ulan