NOTICE OF INTENT TO SUE AND

CONSENT TO NON-BINDING ARBITRATION

 

TO:       All Recipients

      c/o last known addresses

         (via email initially)

 

FROM:     Paul A. Mitchell, B.A., M.S.

          Citizen of Washington State and

          Damaged Party

 

DATE:     September 23, 2015 A.D.

 

SUBJECT:  pending administrative claim and INVOICE for damages

         (actual, consequential and exemplary)

 

 

Greetings to All Recipients:

 

This is my formal NOTICE OF INTENT TO SUE AND CONSENT TO NON-BINDING ARBITRATION in the matters of my pending administrative claims, and my outstanding and now past due INVOICE, to the University of Washington (“UW”), Attention: Risk Management department.

 

To date, I have been deprived of routine access to proof of insurance and proof of compliance with all applicable University Complaint Investigation and Resolution (“UCIRO”) regulations and required procedures in the matter of said claims.  I continue to reserve the right to examine all applicable insurance contracts in order to determine if they do indemnify criminal conduct, or not.

 

I believe I am being reasonable to presume, absent the requested proof, that UW’s liability insurance contracts do not indemnify criminal conduct.  From prior professional experience, I can safely say that most if not all insurance underwriters routinely decline to indemnify criminal conduct as a feature of their general liability insurance policy(s).

 

As such, it is my specific intent to sue the Regents of the University of Washington in their official capacities, and the following UW personnel in their individual capacities, including but not limited to former Prof. James A. Landay, Prof. James A. Fogarty, Crystal Eney, Virjean Hanson Edwards, Prof. John M. Lee, and former President Michael K. Young.

 

The documentary evidence submitted in support of my pending administrative claims constitutes probable cause that mail fraud, wire fraud, attempted extortion, witness retaliation, and bank fraud have already occurred, beginning at least in June 2009.  Please be informed hereby that the Federal RICO statute at 18 U.S.C. 1961(5) expressly authorizes a ten (10) year discovery window;  and, those RICO statutes also authorize a liberal construction rule, which was never codified anywhere in the United States Code.  See 84 Stat. 947, Sec. 904, Oct. 15, 1970.

 

Pursuant to the decision of the Washington State Supreme Court in Rice v. Janovich, 742 P.2d 1230 (Wash. 1987), State Courts such as the King County Superior Court also enjoy original jurisdiction of Civil RICO actions arising under 18 U.S.C. 1964.  In particular, 18 U.S.C. 1964(c) expressly authorizes automatic TRIPLE DAMAGES.

 

Because acquired evidence calls for the conclusion that a fraudulent PERSONAL MONEY ORDER was transmitted via U.S. Mail, the RICO “predicate acts” mentioned above do involve a financial institution:  as such, the statutes prohibiting mail fraud, wire fraud and bank fraud separately authorize a fine of $1,000,000 (one million USD) for each such violation.  See 18 U.S.C. 1341, 1343 and 1344, respectively.

 

I also reserve my right to discover all relevant UW records which concern any and all past, present and future investigations which administrators of UW’s contracts and grants (e.g. Financial Accounting Staff) may have conducted, or will conduct, into all funds awarded to the past and present UW faculty, administrators, staff and students named above.

 

I sincerely regret that the instant NOTICE is now necessary.  However, it appears to me that all available administrative remedies have now been exhausted e.g. by withholding proof of valid and collectible liability insurance and the liability account required by RCW 4.92.130;  by stubbornly refusing to lift the false and fraudulent “hold” on my prior Application for UW Summer Sessions;  by official misconduct, tortious conduct and tortiously interfering with my lawful business and educational plans;  and, by conspiring to infringe my Fundamental Rights to freedom of expression and association as guaranteed by Article 19 in the International Covenant on Civil and Political Rights and by Article 26 in the Universal Declaration of Human Rights, and to my good name and reputation as guaranteed by the common law of Washington State (cf. RCW 4.04.010).

 

Thank you for your consideration.

 

Sincerely yours,

 

/s/ Paul Andrew Mitchell, B.A., M.S.

 

Private Attorney General, Civil RICO: 18 U.S.C. 1964;

Agent of the United States as Qui Tam Relator (4X),

Federal Civil False Claims Act: 31 U.S.C. 3729 et seq.

 

All Rights Reserved (cf. UCC 1-308 https://www.law.cornell.edu/ucc/1/1-308)

 

Attachments (incorporated by reference):

 

http://supremelaw.org/cc/uw/risk.management/claim.form.2015-03-28/TOC.htm

http://supremelaw.org/cc/uw/risk.management/invoices/invoice.2015-08-01.htm

http://supremelaw.org/cc/uw/risk.management/letter.2015-08-27/demand.for.proof.htm