Registered U.S. Mail No. ________________________________________
Return Receipt Requested
Restricted Delivery Requested


TO:                             FROM:
-----------------------------   ---------------------------------
Grand Jury Foreperson           Paul Andrew Mitchell, B.A., M.S.
In re: New Life Health Center   Counselor at Law
Grand Jury Room, Fourth Floor   c/o 2509 N. Campbell, #1776
U.S. DISTRICT COURTHOUSE        Tucson, Arizona state
55 E. Broadway                  Postal Code 85719/tdc
Tucson, AZ 85701

DATE:     March 20, 1996

Dear Foreperson:

We have  been retained  for the limited purpose of reviewing and
responding in  writing to  your SUBPOENA TO TESTIFY BEFORE GRAND
JURY, dated March 5, 1996, and served on "New Life Health Center
Company", a  copy of  which is  attached hereto and incorporated
herein as EXHIBIT "A".

This is to inform you that there are no officers or workers with
the "New  Life Health  Center Company" in Tucson, Arizona state,
who are  authorized by contract to divulge the records and other
information which  you have  requested.  Your SUBPOENA failed to
specify the  proper names  of any human beings who work for said

Accordingly, even  if you  had properly  served said SUBPOENA on
one or  more human  beings who  work for  the Company in Tucson,
Arizona state, none would have been able to provide you with the
information you  requested because  criminal sanctions attach to
any  unauthorized   disclosure(s)  by   them    of  any  Company
information, books  and records, or any other property belonging
to the Company, to any person, agency, or government entity.  By
Law, please  understand that  this  response  to  your  SUBPOENA
should  not,  and  cannot,  be  construed  as  an  admission  or
acknowledgement of  the existence  of any of the books, records,
or other information requested by said SUBPOENA.

Furthermore, the  Company has  never been properly served with a
Notice from either the Assistant Commissioner (International) or
any District  Director, under authority of Order No. 24 (Rev. 1)
as found  in the  Handbook of  Delegation Orders,  page 1229-14,
instructing any  Company officers  or workers to keep any of the
books, records,  and other  information which you have requested
in your  SUBPOENA.   Delegation Order  No. 24 is attached hereto
and incorporated herein as EXHIBIT "B".

If  this   Grand  Jury   is  investigating  a  tax  matter,  the
investigation is limited by law to investigating possible excise
tax violations relating to ... alcohol, narcotics, gambling, and
firearms violations,  as  evidenced  by  28  C.F.R.  Chapter  1,
Section 0.70(a), and criminal proceedings arising under internal
revenue  laws   pertaining  to   taxes  on  alcohol,  narcotics,
firearms, coin-operated  gambling  and  amusement  machines,  as
evidenced by  28 C.F.R.  Chapter 1,  Section 0.70(b),  a copy of
which is attached hereto and incorporated herein as EXHIBIT "C".

              Response to Grand Jury:  Page 1 of 3

To further  substantiate the excise tax allegation, the Attorney
General has  provided specific instructions that a U.S. Attorney
has limited authority to prosecute tax cases investigated by the
alleged Internal  Revenue Service  ("IRS").  Those offenses are:
excise violations  involving alcohol  tax, narcotics, stamp tax,
firearms,  wagering,   coin-operated   gambling   and   wagering
machines, etc.,  as evidenced  by the  U.S.  Attorney's  Manual,
Volume II,  6-4.270, a  copy of  which is  attached  hereto  and
incorporated herein as EXHIBIT "D".

We would like to take this opportunity to draw your attention to
Article I,  Section 10,  Clause 1,  in the  Constitution for the
United States  of America,  as  lawfully  amended,  wherein  all
parties to  that Constitution, including Grand Juries, are bound
by It  to refrain  from impairing  the Obligations of Contracts,
and from  granting  Titles  of  Nobility,  e.g.  "Esquire"  (see
EXHIBIT "E").   See also Article I, Section 9, Clause 7 (EXHIBIT
"E") and Amendment 13 (see EXHIBIT "F").

Before any Company officers or workers could consider responding
to any future SUBPOENAS from you in the future, we will need you
to provide  us with  a verified  copy of  your Oath  of  Office,
whereby you  affirmed your  solemn commitment,  under penalty of
perjury, to  uphold and  defend the  Constitution for the United
States of America, as lawfully amended.

Moreover, in  order to  make sure  that you  are not  proceeding
ultra vires,  NOTICE AND  DEMAND  are  hereby  made  of  you  to
recognize and  obey the  court holding  that "the indiscriminate
summoning of witnesses in a spirit of meddlesome inquiry, on the
mere chance  that some  crime may  be discovered,  is  forbidden
under the  rules of  the common  law."   See Hale v. Henkel, 201
U.S. 43,  50 L.Ed  652, 26 S.Ct 370.  Please also take notice of
the following pertinent holdings:

     The most  valuable function  of the  grand jury is not
     only to  examine into the commission of crimes, but to
     stand between  the prosecutor  and the  accused;  that
     is,  to   protect  the   citizen   against   unfounded
     accusations, whether  they come from the government or
     are prompted by partisan passion or private enmity.

                          [38 Am Jur 2d, Sec. 26, Page 971]
                                           [emphasis added]

     When the  investigation is  one required to be ordered
     by the  court, under restrictions on the powers of the
     grand jury,  the general  rule that  the investigation
     may not  be a  mere "fishing  expedition" or a blanket
     inquiry for  speculative purposes  is applicable.   It
     has been  so held in respect of an investigation where
     it appears  that a system of crime exists among public
     officials.   McNair's Petition,  324 Pa 48, 187 A 498,
     106 ALR 1373.
                          [38 Am Jur 2d, Sec. 28, Page 973]
                                           [emphasis added]

              Response to Grand Jury:  Page 2 of 3

     While the  phrase  "ultra  vires"  has  been  used  to
     designate,  not  only  acts  beyond  the  express  and
     implied  powers   of  a  corporation,  but  also  acts
     contrary to  public policy or contrary to some express
     statute prohibiting  them, the latter class of acts is
     now termed  illegal, and the "ultra vires" confined to
     the former class.

                   [Black's Law Dictionary, Fourth Edition]
                                           [emphasis added]

     The United  States government is a foreign corporation
     with respect  to a  state.  [citing  In  re  Merriam's
     Estate, 36  N.E. 505,  141 N.Y.  479, affirmed U.S. v.
     Perkins, 16 S.Ct. 1073, 163 U.S. 625, 41 L.Ed 287]

                            [19 C.J.S. 883, emphasis added]

Thank you very much for your consideration.

Sincerely yours,

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

Counselor at Law, all rights reserved

copies:   "New Life Health Center Company"

              Response to Grand Jury:  Page 3 of 3

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In Re Grand Jury Subpoena