REQUEST FOR STATEMENT OF INTENT
TO: Hon. Rob McKenna
Attorney General
State of Washington
P.O. Box 40100
Olympia 98504
WASHINGTON STATE, USA
FROM: Paul Andrew Mitchell, B.A., M.S.
Private Attorney General, 18 U.S.C. 1964(a)
DATE: July 31, 2012 A.D.
SUBJECT: NOTICES OF DEFAULT AND NOTICES OF INTENT, BY AFFIDAVIT
filed by United States ex rel. in Internal Licensing, LLC
v. Google, Inc., USDC/Seattle Case No. 2:11-cv-00711 MJP
Greetings Attorney General McKenna:
Please be informed hereby that the People of Washington State and the United States (Federal Government) ex rel. Paul Andrew Mitchell, Private Attorney General, now request a statement of intent from your good offices concerning verified allegations of conspiracy to engage in a pattern of racketeering activities committed by certain named “members” of The State Bar of California during the preceding ten (10) calendar years. See 18 U.S.C. 1961(5) (10-year statute of limitations for discovery in RICO cases).
Under separate cover we have recently forwarded to the Consumer Protection Division of your office in downtown Seattle a key subset of relevant documentation, in part to supplement our prior administrative complaint number #359316 as previously assigned by that Division.
We believe your office has legal authority and jurisdiction to commence a formal investigation and appropriate prosecution in this matter, because all available evidence calls for the conclusion that all named suspects are engaging in RICO “predicate acts” across State lines that separate California, Oregon, Washington and other unnamed States of the Union. See 18 U.S.C. 1341, 1343 and 1961 et seq.
Further to substantiate our request for a statement of intent from your office, we have attached a summary of pertinent authorities which clearly confer concurrent original jurisdiction upon State Courts to prosecute Civil RICO actions. For example, see 18 U.S.C. 1964 and Tafflin v. Levitt, 493 U.S. 455 (1990).
The attached authorities also confer limited authority upon Private Attorneys General to investigate and prosecute such organized crime rackets, in the event that public prosecutors decline to do so. See, for example, Rotella v. Wood et al., 528 U.S. 549 (2000), and Agency Holding Corp. v. Malley-Duff & Associates, 483 U.S. 143, 151 (1987).
NOTICE OF DEADLINE AND
NOTICE OF INTENT
Please respond with a written statement of your intent in the matters discussed above, no later than 5:00 p.m. Friday, August 31, 2012 A.D. Beyond that reasonable deadline, we will assume from your silence that you have thereby declined to exercise jurisdiction; and, my office then intends to exercise all lawful authorities conferred upon Private Attorneys General for achieving the specific legislative intents of the Racketeer Influenced and Corrupt Organizations Act (“RICO”), as lawfully amended and codified at 18 U.S.C. 1961 et seq.
Thank you very much for your timely professional consideration, Attorney General McKenna.
Sincerely yours,
/s/ Paul Andrew Mitchell
Paul Andrew Mitchell, B.A., M.S.
Private Attorney General, 18 U.S.C. 1964(a)
Criminal Investigator and Federal Witness: 18 U.S.C. 1510, 1512-13
Courtesy Copies:
Office of Chief Clerk, Washington State House of Representatives
Office of Secretary, Washington State Senate
Office of the Governor, State of Washington
Chief Justice, Washington State Supreme Court
Enclosures