Paul Andrew Mitchell, Sui Juris
Citizen of Arizona state
c/o general delivery at:
2509 North Campbell Ave., #1776
Tucson [zip code exempt]
ARIZONA STATE
In Propria Persona
All Rights Reserved
without prejudice
IN THE SUPERIOR COURT OF THE STATE OF ARIZONA
IN AND FOR THE COUNTY OF PIMA
Swan Business Organization ) Case Number #315580
et al., )
) NOTICE OF INTENT TO
Plaintiffs, ) APPLY FOR INTERVENTION:
)
v. ) Rule 201(c),
) Arizona Rules of Evidence
Leon Ulan et al., )
)
Defendants. )
________________________________)
COMES NOW Paul Andrew Mitchell, Sui Juris, Citizen of Arizona
state, expressly not a citizen of the United States ("federal
citizen"), and federal witness (hereinafter "Applicant"), to
provide formal Notice to all interested party(s), and
respectfully to request discretionary judicial Notice by this
honorable Court, pursuant to Rule 201(c) of the Arizona Rules of
Evidence, of this, Applicant's NOTICE OF INTENT TO APPLY FOR
INTERVENTION in the instant case.
Applicant wishes to inform this Court, and all interested
party(s), that Applicant has sued Mr. and Mrs. Neil T. Nordbrock
("Nordbrocks") in the Pima County Consolidated Justice Court,
Tucson, Arizona state, in civil case number #CV-97-3438.
Notice of Intent to Intervene:
Page 1 of 4
A pending related case is People ex rel. Mitchell v. Pima
County Consolidated Justice Court, in the Superior Court of
Arizona, Tucson, case number #320831, first docketed on July 16,
1997. The latter case is a VERIFIED PETITION FOR PEREMPTORY WRIT
OF MANDAMUS, to compel said Justice Court to transfer #CV-97-3438
to the Superior Court of Arizona, pursuant to ARS 22-201(F).
Depending on the outcome of Mitchell v. Nordbrock and the
nature and extent of any damages that may be awarded in said
case, the outcome of the instant COMPLAINT TO QUIET TITLE, and of
any related counterclaim(s), will most likely be affected
directly by the final judgment(s) in Mitchell v. Nordbrock.
By way of establishing probable cause to justify Applicant's
anticipated formal application to intervene in the instant case,
Applicant attaches a true and correct copy of Applicant's
CONSTRUCTIVE NOTICE AND FORMAL DEMAND TO CEASE AND DESIST,
prepared by Applicant on behalf of the Nordbrocks for their
signature on October 25, 1996. On or about that day, Applicant
also assisted Mr. Neil T. Nordbrock in serving said NOTICE upon
Mr. and Mrs. Leon Ulan at 2735 North Paseo Tierra Verde, Tucson,
Arizona state.
Applicant was never compensated for said professional
services by either of the Nordbrocks. One of Applicant's claims
against the Nordbrocks -- breach of contract -- arises in part
from their failure to pay Applicant's proper and lawful invoice
for said services.
A true and correct copy of said CONSTRUCTIVE NOTICE AND
FORMAL DEMAND TO CEASE AND DESIST is attached hereto and
incorporated by reference, as if set forth fully herein.
Notice of Intent to Intervene:
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 attached document is a true
and correct copy of the original, with the sole exception of the
original blue-ink signatures, which signatures were affixed to
the original of said document by Mr. and Mrs. Neil T. Nordbrock,
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: July 22, 1997
Respectfully submitted,
/s/ Paul Andrew Mitchell
______________________________________________
Paul Andrew Mitchell, Sui Juris
Citizen of Arizona state, federal witness
(expressly not a citizen of the United States)
All Rights Reserved without Prejudice
Notice of Intent to Intervene:
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 OF INTENT TO APPLY FOR INTERVENTION:
Rule 201(c), Arizona Rules of Evidence
by placing one true and correct copy of said document(s) in first
class U.S. Mail, with postage prepaid and properly addressed to:
Neil and Evelyn Nordbrock VIA FAX TRANSMISSION
c/o 6642 E. Calle de San Alberto to: (520) 296-6544
Tucson, Arizona state
Lawrence E. Condit VIA FAX TRANSMISSION
c/o 376 South Stone Avenue to: (520) 624-8414
Tucson, Arizona state
Malcolm K. Ryder, Esq.
c/o 3100 N. Campbell Ave., Ste. 101
Tucson, Arizona state
Executed on July 22, 1997:
/s/ Paul Andrew Mitchell
______________________________________________
Paul Andrew Mitchell, Sui Juris
Citizen of Arizona state, federal witness
(expressly not a citizen of the United States)
All Rights Reserved without Prejudice
Notice of Intent to Intervene:
Page 4 of 4
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Swan v. Ulan