Donald E. Wishart, Sui Juris

Citizen of California State

and Federal Witness [sic]

c/o 5150 Graves Avenue, Suite 12-C

San Jose [ZIP code exempt]

CALIFORNIA, USA

 

In Propria Persona and

by Special Appearance Only

 

All Rights Reserved

without Prejudice

 

 

 

UNITED STATES DISTRICT COURT

 

NORTHERN DISTRICT OF CALIFORNIA

 

 

UNITED STATES OF AMERICA [sic], )  Case Number CR-00-20227-JF

                                )

          Plaintiff [sic],      )  NOTICE OF MOTION AND

                                )  MOTION TO DISCLOSE

     v.                         )  INDICTING PANEL’S

                                )  RECORD OF PROCEEDINGS

DONALD E. WISHART [sic],        )

                                )  Rule 6(e)(3)(C): Federal Rules

          Defendant [sic]       )  of Criminal Procedure (“FRCrP”)

                                )

________________________________)

 

COMES NOW Donald E. Wishart, Sui Juris, Citizen of California State, expressly not a “citizen of the United States” [sic], and Defendant in the above entitled matter (hereinafter “Defendant”), to move this honorable Court for an ORDER compelling the Office of the United States Attorney to serve upon Defendant a certified copy of any recording, or reporter’s notes, or any transcript prepared therefrom, of all proceedings of the panel alleged to be a lawfully convened federal grand jury in the instant case, and to provide formal NOTICE to all interested Party(s) of this MOTION TO DISCLOSE.

Pursuant to FRCrP Rule 6(e)(1), “The recording or reporter’s notes or any transcript prepared therefrom shall remain in the custody or control of the attorney for the government unless otherwise ordered by the court in a particular case.”  [bold emphasis added]

Furthermore, pursuant to FRCrP Rule 6(e)(3)(C)(ii), “Disclosure … may also be made … when permitted by a court at the request of the defendant, upon a showing that grounds may exist for a motion to dismiss the indictment because of matters occurring before the grand jury.”  [bold emphasis added]

Defendant hereby testifies that grounds do exist for a motion to dismiss the instant indictment, with prejudice, because of matters which occurred before the panel of federal citizens alleged to be a lawfully convened federal grand jury in the instant case.

The grounds for a motion to dismiss include, but are not limited to, probable fraud, perjury, and misprision of perjury by omission upon the panel, by one or more witnesses and attorneys for the government.

Also, conspiracy, deprivation of Defendant’s fundamental Rights, retaliation against a Federal Witness, and racketeering have already occurred, prior to their testimony, all of which were systematically and fraudulently concealed from said panel.

Last but not least, Defendant hereby offers to prove major fraud against the United States, by the witness(es) who allegedly testified before said panel, and/or by the attorney(s) for the government.

To illustrate just a few of the many reasons why fraud upon the panel was probable, Defendant offers the following as proof:

(1)                                   Defendant is charged with violating four separate federal statutes, to wit:  (a) 18 U.S.C. 287,  (b) 18 U.S.C. 1341, (c) 26 U.S.C. 7203, and (d) 26 U.S.C. 7212.  There are no substantive, legislative regulations in the Parallel Table of Authorities and Rules implementing the statutes (a), (b), and (c) above.  See attached Exhibit “A”.  Moreover, Defendant has conducted His own extensive analysis, and search, of the Code of Federal Regulations (“CFR”) for any substantive, legislative regulations implementing the above statutes.  The following summarizes that analysis.

 

(2)                                   As for 26 U.S.C. 7212, Defendant confirmed that regulations have been published only for Title 27, Parts 170 (Miscellaneous Regulations Relating to Liquor), 270 (Manufacture of Tobacco Products), 275 (Importation of Tobacco Products, Cigarette Papers and Tubes), 290 (Exportation of Tobacco Products and Cigarette Papers and Tubes, without Payment of Tax, or with Drawback of Tax), 295 (Removal of Tobacco Products and Cigarette Papers and Tubes, without Payment of Tax, for Use of the United States), and 296 (Miscellaneous Regulations Relating to Tobacco Products and Cigarette Papers and Tubes).  During the calendar years in question, Defendant was not involved in any of these activities.  It is highly likely that the panel was not informed of this fact;  nor was the panel informed that Title 27 activities were necessary to trigger a filing requirement.  This is fraud upon the panel.

 

(3)                                   Defendant has studied the CFR for the Internal Revenue Code, and discovered that there are no substantive, legislative regulations implementing IRC section 7203.  However, under the CFR for Title 27 of the United States Code, at Section 70.42, i.e. Returns Prepared or Executed by Regional Directors (Compliance) or by other ATF Officers, at subsection (c), i.e. Cross References, subsection (9), it is stated:  “For criminal penalties for willful failure to make returns, see sections 7201, 7202, and 7203 of the Internal Revenue Code.”  27 CFR 70.42(c)(9).  There are, evidently, no implementing regulations for said IRC sections (see Exhibit “A”).

 

(4)                                   At IRC 7806(a), the point is made that “cross references to other provisions of law, where the word ‘see’ is used, are made only for convenience, and shall be given no legal effect.”  Note the use of the word “see” at 27 CFR 70.42(c)(9) supra (which is also headed “Cross references”).  Therefore, Defendant is entitled to conclude that IRC sections 7201, 7202, and 7203 have no legal effect whatsoever in the instant case.

 

(5)                                   There are very clear public protection provisions in the Administrative Procedures Act, in the Federal Register Act, and also in pertinent case law, which make it impossible for any penalty to be imposed upon Defendant, when a positive showing has been made that the required regulations have never been promulgated, either in the Federal Register, or in the CFR (which is legally considered a Supplement to the Federal Register).  See 5 U.S.C. 552(a)(1), and 44 U.S.C. section 1505 and 1507, in chief.  The transcript of testimony given to the panel, under oath, is very likely to show that none of the above facts and laws was ever presented to that panel.  Accordingly, the allegation that Defendant was involved in alcohol, tobacco, or firearms, assumes facts not in evidence, and is hereby formally rebutted by Defendant;  or, in the alternative, perjury has been committed in the presence of the panel by one or more witnesses, and/or the attorneys for the government.  Misprision of perjury by omission is actionable, as is any conspiracy to commit misprision, whether or not in the presence of a lawfully convened federal grand jury.  See 18 U.S.C. 4.

 

(6)                                   For the edification of this Court, Defendant hereby requests discretionary judicial notice of the pertinent discussion entitled “Types of Rules,” at 2 Fed. Proc. L.Ed., section 2:75, to wit:  “The Administrative Procedure Act (APA) recognizes the existence of legislative rules (sometimes referred to as substantive rules), interpretive rules, procedural rules, and general statements of policy.  However, these various types of rules are not defined in the APA, and we are forced to rely on judicial definitions of these terms” citing Chrysler Corp. v. Brown. 441 U.S. 281, 60 L.Ed.2d 208, 99 S.Ct. 1705 (1979).  “A legislative rule has the force and effect of law if promulgated in accordance with a delegation of power by Congress.”  op cit., page 87.  Moreover, many statutes in IRC Subtitle F fall within the category of Housekeeping Statutes, i.e.:  “… rules relating to agency employees and records promulgated under the Housekeeping Statute are rules of agency organization, procedure, or practice, and are not intended to be substantive.”  op cit., page 88.

 

(7)                                   Defendant hereby offers to prove that He has been frequently mis-classified as an “Illegal Tax Protester” [sic], via a “TC-148” designation in Defendant’s Individual Master File (“IMF”).  Pursuant to the 6209 Manual from the IRS, Defendant also offers to prove that such a designation results in prejudicial and discriminatory treatment by the government and its alleged agents.  This honorable Court is hereby respectfully requested to take formal judicial notice of the IRS Restructuring and Reform Act of 1998, at section 3707 (Illegal Tax Protester (“ITP”) Designation), by which the IRS was mandated to remove existing ITP designations from the IMF.  IRS personnel must also disregard any such designations as of the date of enactment of that law.  Finally, as of the date of enactment, IRS personnal cannot describe people in written documents as “illegal tax protesters”.  It is a fundamental Right, protected by the First Amendment, to protest any government action.  Defendant demands to know if the panel which issued the instant indictment was deliberately misinformed that Defendant properly belonged to such a suspect class.  The premeditated and protracted misuse of this suspect classification constitutes probable cause to charge the responsible parties with one or more violations of 18 U.S.C. 242, and 241, for depriving, and conspiring to deprive, Defendant of His fundamental Rights to freedom of expression, as guaranteed by the First Amendment, and to due process of law, as guaranteed by the Fifth Amendment.  See also pertinent provisions in the Universal Declaration of Human Rights and the International Covenant on Civil and Political Rights, both rendered supreme Law by the Supremacy Clause in the U.S. Constitution.

 

(8)                                   Defendant could never have been compelled to testify against Himself, in violation of the Fifth Amendment.  A completed federal tax return, of any kind, has been recognized by many courts as testimony admissible in civil and criminal proceedings.  As such, a completed tax return cannot be compelled without also violating the Fifth Amendment guarantee against self-incrimination.  The panel was not presented with this constitutional guarantee, immunizing Defendant from being a witness against Himself.

 

(9)                                   The only known statutes which create a specific liability for taxes imposed by Subtitle A of the IRC are those which are imposed upon federal employees and upon withholding agents.  See list of statutes itemized at IRC 7701(a)(16), e.g. IRC 1461.  Defendant was not a federal employee nor a withholding agent [sic] during the calendar years in question.  Section 1 of the IRC does not create a specific liability for taxes imposed by Subtitle A.  The regulations at 26 CFR 1.1-1(b) are overly broad extensions of the underlying statutory authority, because they do create a specific liability, when no such liability is created by the underlying statute.

 

CONCLUSION

Provided that any can be confirmed by careful inspection of the record of proceedings, all of the above constitute grounds to file criminal complaints of tampering, and/or intent to tamper, with a federal grand jury;  conspiracy to tamper, and/or being an accessory to tampering, with a panel of federal citizens alleged to be a federal grand jury, all in violation of the pertinent statutes in 18 U.S.C.

 

VERIFICATION

I, Donald E. Wishart, Sui Juris, hereby verify, under penalty of perjury, under the laws of the United States of America, without the “United States” (federal government), that the above statement of facts 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 in pari materia with all provisions of Title 28, U.S.C. (Constitution, Laws and Treaties).

 

Dated:  September 10, 2000 A.D.

 

 

Respectfully submitted,

 

/s/ Donald E. Wishart

 

Donald E. Wishart, Sui Juris

Citizen of California State and

Federal Witness (18 U.S.C. 1512, 1513)

(expressly not a “citizen of the United States” [sic])

 

All Rights Reserved without Prejudice

 

 

PROOF OF SERVICE

I, Donald E. Wishart, Sui Juris, hereby certify, under penalty of perjury, under the laws of the United States of America, without the “United States” (federal government), 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 MOTION AND

MOTION TO DISCLOSE INDICTING PANEL’S

RECORD OF PROCEEDINGS:

Rule 6(e)(3)(C):

Federal Rules of Criminal Procedure

by placing one true and correct copy of said document(s) in first class United States Mail, with postage prepaid and properly addressed to the following:

 

Robert S. Mueller III              John S. Gordon

Office of the U.S. Attorney        Office of the U.S. Attorney

280 South First Street, Suite 371  312 North Spring Street

San Jose [ZIP code exempt]         Los Angeles [ZIP code exempt]

CALIFORNIA, USA                    CALIFORNIA, USA

 

Thomas S. DiLeonardo               Ronald A. Cimino

U.S. Department of Justice         U.S. Department of Justice

Western Criminal Enforcement Sec.  West. Criminal Enforcement Sec.

P.O. Box 972, Ben Franklin Stn.    P.O Box 972, Ben Franklin Stn.

Washington [ZIP code exempt]       Washington [ZIP code exempt]

DISTRICT OF COLUMBIA, USA          DISTRICT OF COLUMBIA, USA

 

John Paul Reichmuth

Federal Public Defender’s Office

160 West Santa Clara Street, Suite 575

San Jose [ZIP code exempt]

CALIFORNIA, USA

 

 

Executed on September 10, 2000 A.D.

 

/s/ Donald E. Wishart

 

Donald E. Wishart, Sui Juris

Citizen of California State and

Federal Witness (18 U.S.C. 1512, 1513)

(expressly not a “citizen of the United States” [sic])

 

All Rights Reserved without Prejudice

 

 

Exhibit “A”:

 

Excerpts from Parallel Table of Authorities and Rules