THIS DOCUMENT IS CONFIDENTIAL AND SUBJECT TO INVESTIGATIVE PRIVILEGES. IT IS INTENDED ONLY FOR THE INDIVIDUAL OR ENTITY TO WHICH IT IS ADDRESSED. DO NOT COPY, FORWARD, DISSEMINATE OR RELEASE TO THE PUBLIC OR DEFENDANTS THIS DOCUMENT OR ANY ATTACHMENTS WITHOUT OBTAINING PRIOR APPROVAL FROM THE SENDER. IF YOU ARE NOT THE NAMED RECIPIENT OR HAVE RECEIVED THIS DOCUMENT OR COMMUNICATION IN ERROR, PLEASE NOTIFY THE SENDER IMMEDIATELY BY TELEPHONE, AT 1-865-577-3746 AND RETURN THE ORIGINAL MESSAGE. THANK YOU.

 

                                                                                                                   June ____, 2005

 

TO:

 

Knox County Judicial Commissioner

Knoxville, Tennessee

 

Knox County Attorney General Randy Nichols

Knoxville, Tennessee

 

United States Magistrate

Knoxville, Tennessee

 

United States Attorney General

Knoxville, Tennessee

 

Federal Trade Commission

Knoxville, Tennessee

 

TN Supreme Court

Knox Disciplinary District

 

Tennessee Court of the Judiciary

Attention: Disciplinary Counsel

P.O. Box 1216

Murfreesboro, TN 37133-1216

(615) 904-1600

 

ATTN: ICE

U.S. Department of the Treasury

Internal Revenue Service

 

FROM: John Davis Lee II

7486 Chapman Highway #104

Knoxville, Tennessee 37920

865-577-3746

 

 

 

AFFIDAVIT OF PROBABLE CAUSE FOR CRIMINAL COMPLAINT

FOR REQUEST TO ISSUE ARREST WARRANTS FOR

FELONY THEFT OF MOTOR VEHICLES

 

 

STATE OF TENNESSEE

COUNTY OF KNOX

 

            1.         I, John Davis Lee II, a private person, citizen-informant, victim-witness, complainant, after first being duly sworn, do hereby declare that I am over the age of eighteen (18) years, and that I have personal knowledge of the facts and information contained herein.

 

On or about May 7, 2003 to May 9, 2003, and January 15, 2000 in Knox County, Tennessee,

 

·        “Billy” Mullins Jr. (a/k/a “Smokey”?)

·        “Billy” Mullins Sr. (a/k/a “Moon”)

·        Sue Mullins

·        Yvonne Mullins

·        “Eddy”

·        Sutherland Avenue Wrecker Service Corporation

·        “Moon’s Towing” (a/k/a Sutherland Avenue Wrecker Service)

·        “Moons Used Parts” (a/k/a Sutherland Avenue Wrecker Service)

·        “Billy” Stokes

·        Shawna Williams

·        Ryan Flores

·        H’ea D’Allesandro

·        “Tony” Mullet

·        “Ricky” Ferguson

·        Mark Presley

·        “Bob” Woldridge

·        “Ed” Cummings

·        Phil Keith

·        Jack Barnes

·        Michael Martin

·        John Rossen

·        Victor Ashe

·        Samyah Jubran

·         And other persons unidentified

 

Committed the offense(s) and/or violation(s) of:

 

 

·        Theft under §39-14-103

                        (two Class D felonies; 12 years maximum each; $5,000 fine maximum                           each; $125,000 maximum organizational fine each;)

·        TCA §40-2-101. Felonies.

Prosecution for a felony offense shall begin within:

(3) Four (4) years for a Class C or Class D felony;

(tolled as a continuing criminal enterprise)

·        Burglery under TCA §39-14-402

·        Possession of Burglery Tools under TCA §39-14-701

·        Possession of Burlery Tools under TCA §39-14-408

·        Criminal Trespass under TCA §39-14-405

·        Extortion under under TCA §39-14-112

·        Antitheft provisions of Title and Registration and “Chop Shop” Sale of Motor Vehicle Parts under TCA §55-5-101 et seq.

·        Vandalism under TCA §39-14-408

·        Deceptive Business Practices under TCA §39-14-127

·        Fraudulent Transfer of Motor Vehicle 3 under TCA §9-14-147

·        Mail Fraud under US Code

·        Antitrust law under state and US Code

·        Fraudulent Concealment of Cause of Action under TCA §28-3-104

·        Solicitation under TCA §39-12-102

·        Criminal Conspiracy under TCA §39-12-103

·        Money Laundering under TCA §39-14-903

·        Organized Crime – Unlawful Activities under TCA §39-12-204

·        Racketeer-Influenced and Corrupt Organizations Act (RICO) under TCA §39-12-101 et seq., and under US Code, 18 USCS §1961, et seq.

·        Official Misconduct under TCA §39-16-401 (Class E felony)

·        Official Oppression under TCA §39-16-403, et seq.

·        Civil Rights Intimidation under TCA §39-17-309

·        Misuse of Official Information under TCA §39-16-404

·        False Reports under TCA §39-16-502

·        Destruction of and Tampering with Governmental Records under TCA §39-16-504

·        Coercion of a Witness under TCA §39-16-507

·        Purchasing Property Sold Through Court under TCA §39-16-405

·        Obstruction of Justice under TCA §39-16-602

·        Compounding under TCA §39-16-604

·        Fraudulent misrepresentations on “federal income tax” contracts

 

FELONY CAR THEFT #1

 

I further state under oath, that the essential facts constituting the offense(s), the sources of my information and the reasons why this information is believable and reliable are as follows:

 

            2.         I declare, under penalty of perjury, that am the rightful and legal owner of the 1984 Volvo Turbo, identified by VIN YV1AX4747E2999321, license tag number NTG309 (expiration 5-31-2004, validation number 2580309, former title number 67229600), Bill of Sale dated May 5, 2003. I declare that I have no valid liens for debt against me regarding this vehicle. Approximate retail value was $3,500 at the time of the theft. At no time have I abandoned this property.

 

            3.         I declare that my vehicle was stolen on or about May 7, 2003 to May 9, 2003, a Class D Felony. It was lawfully parked in a public parking lot at CARMAX Corporation, a “used car” dealership, located at 11225 Parkside Drive, Concord, Tennessee, County of Knox (865-218-7800), headquartered in the state of Virginia. I demand that this vehicle be immediately listed as “STOLEN” in all applicable governmental databases.

 

4.                  After my personal investigation, I determined my motor vehicle was illegally stolen by Sutherland Avenue Wrecker Service Corporation, alias/DBA Moon’s Towing Service, alias/DBA Moon’s Used Parts chop shop, and its individual agents (including Billy “Moon” Mullins Sr., Billy Mullins Jr. (alias “Smokey” Mullins?), Sue Mullins (wife of Moon), “Yvonne Mullins”, et al.), aided and abetted by agents Billy Stokes attorney-at-law and/or attorneys-at-law Stokes, Rutherford, Williams, Sharp & Davies, 920 Volunteer Landing, Knoxville, Tennessee, County of Knox, 37915, phone 865-544-3833 (jointly “SAWS”).

 

5.                  As of last week, my Volvo was located SAWS/Moon’s, 2607 Sutherland Avenue, Knoxville, Tennessee, County of Knox, phone 865-525-0597 and 865-522-0503. “Smokey” (Mullins?) and “Yvonne Mullins”, on two occasions, refused to provide me paperwork/invoices/bill for this vehicle, and refused to allow me to recover this vehicle from their illegal possession. Yvonne Mullins verbally told me the tow bill was approximately $1,500, but refused to provide me with a written copy of that alleged bill (neither in-person nor by mail), and instead wrote down the name of SAWS’ attorney, “Billy” Stokes, in Knoxville, written on a notepad identified by the printed name of SAWS. This confession by Yvonne Mullins was made on videotape, which I have a copy of.

 

Sutherland Avenue Wrecker Service

 

            VIDEOTAPE AND AUDIOTAPE RECORDINGS (July 15, 2003, 4:17 PM, SAWS, 2607 Sutherland Avenue, Knoxville, Tennessee, County of Knox, phone 865-525-0597 and 865-522-0503):

 

John Lee: I’m here to pick up my Volvo.

 

Yvonne Mullins: Okay, on the Volvo, that will be $1,573.93.

 

JL: Excuse me?

 

YM: That’s the bill, today, on the Volvo.

 

JL: Who’s paying that?

 

YM: You are.

 

JL: Where’s my contract with you, that I signed to agree to that?

 

YM: It was on private property, and it was towed away.

 

JL: And where’s the name of the person who had it towed away?

 

YM: I don’t know.

 

JL: You don’t have a name of a person?

 

YM: [No]

 

JL: Give me the name of the person who towed away my car.

 

YM: [No]

 

JL: Are you’re refusing to give me the name of the person who towed away my car?

 

YM:

 

JL: That’s a pretty dumb question, isn’t it?

 

YM:

 

JL: So you are refusing to tell me who towed the car?

 

YM: I’ve been through this game with you before [on the Honda Accord], I’m not going there again.

 

JL: You are refusing to let me have my car, with no contract?

 

YM:

 

JL: Did Carmax tell you to tow it?

 

YM: Yes, they did.

 

JL: Then send the bill to them. If so, they have the contract with you, not me.

 

YM:

 

JL: Carmax told me they did not have the car towed. They told me they did not have it towed. There is nobody in that dealership that said they had it towed.

 

YM:

 

JL: So you towed this car without any authorization whatsoever, from anybody?

 

JL: But you are refusing to give that to me, which means there is nobody.

 

YM:

 

JL: They are denying that, so it’s your word against theirs. Are you trying to extort me into paying you a debt I do not owe?

 

YM: What I’m trying to do is… I don’t have to answer any questions. I’m not going to…

 

JL: So you are telling me you burglerized my car, then you stole my car, and now you want me to enter into a contract with you, so you won’t go to jail, is that correct?

 

YM: I’m not going to jail.

 

JL: There’s a lot of people going to jail this time.

 

JL: I showed up here a few days ago to pick up my car, and nobody would even give me any paperwork. Where’s the notice that you mailed to me saying that you towed my car?

 

YM: It’s in that pack right there.

 

JL: May I see it?

 

YM: No.

 

No? Because it doesn’t exist, does it? You have never mailed me any notice that you have this car. Now what’s wrong with my title? Why can I not get my title at the DMV? Why is that?

 

YM: [I don’t know?]

 

JL: Why do they say that Sutherland Avenue has a lien on this car?

 

YM: Because that’s where I sent the information, all the information I had on the car. We put a lien on it until you pay that bill.

 

JL: Well, who is the person who contacted the title clerk’s office?

 

YM: I don’t contact that title clerk. I do that straight through the State of Tennessee.

 

JL: And what address is that? Who did you speak with down there?

 

YM: I don’t know. They send me the forms. I send them the forms.

 

JL: And may I see that form?

 

YM: No.

 

JL: You won’t give me any paperwork for my car?

 

YM: No.

 

JL: How can you say that’s an honest business move?

 

YM: [my money]

 

JL: I looks like we’re going to the grand jury. And citizen’s arrest is coming up.

 

YM: If you are not going to pick up your car, then you need to go on out.

 

JL: So you have stolen my car?!

 

YM: You can talk to our lawyer. You can speak to our lawyer. I’m not going…

 

JL: Are you going to give us that name, or is that top-secret, too?

 

YM: I’ll be glad to - Billy Stokes.

 

(YM handed JL a note naming Billy Stokes as accessory to SAWS felony car theft and fraud)

 

JL: So you are confessing that you stole my car? So you are refusing me all paperwork on my car?

 

(YM ran out of the room to the back of SAWS’ building, presumably to avoid a citizen’s arrest.)

 

[END]

 

Carmax, 2003

 

John Lee: I need to speak with the general manager.

 

John Doe Greeter: Go to the front desk right there, they can help you.

 

John Lee: Thank you.

 

Jane Doe Receptionist: Hi. Can I help you?

 

John Lee: Yes. I need to speak with the general manger, please.

 

Jane Doe Receptionist: Do you have an appointment with him?

 

John Lee: Is he in?

 

John Doe Sales Manager: No. He is currently out of the store.

 

John Lee: He’s coming right back

 

John Doe Sales Manager: We just don’t know when.

 

John Lee: Okay. Is there somewhere I can wait?

 

John Doe Sales Manager: There’s a waiting area right there.

 

John Lee: Okay. Will you guys page me?

 

John Doe Sales Manager: Yeah.

 

John Lee: It’s John Lee. What’s his name again? I keep forgetting.

 

John Doe Sales Manager: Joe. His first name is Joe. What is this in reference to?

 

John Lee: I spoke to you about it. It’s a stolen car, from your parking lot. I need to talk to him about the legal situation, how he wants to handle it. If he wants to do a statement, or whatever.

 

John Doe Sales Manager: Okay.

 

John Lee: I’m sure he will be interested to know about that.

 

John Doe Sales Manager: I’ll let him know.

 

John Lee: Thank you.

 

[Service Department waiting room]

 

John Doe Sales Manager: He would like to set up an appointment.

 

John Lee: I know. I’m disabled, and it’s real hard for me to come in at set times. What I want to talk to him about is what we [you and I] already cleared up. You said the car was not ordered towed by Carmax, from your parking lot.

 

John Doe Sales Manager: I don’t remember saying that.

 

John Lee: Yeah, it was a white Volvo. You had a customer come in and was trying to trade it. You caoldn’t work out a deal, and before he could pick the car up, it disappeared. I came in, you didn’t know where the car was. I didn’t know where the car was. But you knew who to call, and you said Sutherland Avenue Wrecker had it. And I asked, “Did you order it towed”, and you said “No”.

 

John Doe Sales Manager: I said I didn’t [know]. But there may have been an associate at Carmax who did.

 

John Lee: Right. I talked to Sutherland, and they refused to provide any paperwork on the car. They refused to say who ordered it towed from here. They refused to give a towing invoice, saying there’s a $1,500 tow bill on it. They refused to give me any paperwork, and refused to allow me to pick up the car. If you don’t get an invoice, you can’t pay the invoice. They have stolen the car. It’s felony car theft, at this point. This is a criminal investigation, and I need to fax something to Joe, for him to give to the lawyers, just an affidavit, just stating those two things: Carmax did not order Sutherland to tow the car, and that Carmax does not want to pay the bill. That’s all it needs to say. I just need an affidavit, and your lawyers can clear it. If not okay, that’s fine.

 

John Doe Sales Manager: It sounds to me like Joe is going to need to talk to you.

 

John Lee: Okay.

 

John Doe Sales Manager: We do have a Carmax Customer Service Center, on this card.

 

John Lee: Where is this?

 

John Doe Sales Manager: It’s in Virginia.

 

John Lee: I’m sure they will have to come down to here and do their own investigation.

 

John Doe Sales Manager: I don’t know what they’ll do. But I’m sure they will direct you to our legal department to talk to them.

 

John Lee: I’m hoping to talk to Joe, and see if there’s anything he can check out. I realize he has to clear everything with them.

 

[END]

 

“Moons Used Parts”

 

“Moon’s Used Parts” (junk yard and “chop shop”), 9922 Hall Road, Knoxville, Tennessee, County of Knox, phone 865-693-7106, (within the gated compound and residence of Billy “Moon” Mullins, Sr., adjacent to Cedar Bluff 24-Hour Towing, and Webb High School, off Pellissippi Parkway), August 13, 2003.

 

John Lee: I need to know if you guys have a Honda Acord, 4-door DX, 1990, burgundy, same color as this one out here, 4-door, with the hubcaps. Sutherland said you had it down here.

 

John Doe: Yeah.

 

JL: Can I look at it?

 

JD: Yeah. I’s back in the corner.

 

JL: Can I drive around there?

 

JD: No you can’t.

 

[walked back to the car, past the office]

 

JL: How many acres have you got out here?

 

JD: [unintelligible]

 

JL: How many cars? Ever try to count them?

 

JD: Nope.

 

JL: There’s got to be a couple thousand, at least.

 

JL: There’s one right there, a 1990. Yeah, it looks like that might be it. You ever get any flat tires driving around this thing?

 

JD: [yes]

 

JL: That looks like it. [uncovered and exposed to rain (paint oxidated and body rusted), doors and trunk open (interior and trunk exposed to rain), flat tires, seat removed, dashboard removed, CD player and speakers missing]

 

JD: You got the VIN number?

 

JL: I’m going to get the VIN number.

 

JD: Okay. It’s 1HG…

 

JL: “1HGCB7641LA001703”. I used to sell cars, and it used to be impossible to get these things spelled right. Yeah, that’s got to be it. Yup, that’s it. You all got any paperwork on this car?

 

JD: No. It’s all at the wrecker office. They’ve got the paperwork.

 

JL: Who’s that, Yvonne?

 

JD: Shirley.

 

JL: Shirley Mullins? Oh, she’s Moon Sr’s wife?

 

JD: Yeah.

 

JL: Or is that Sue Mullins?

 

JD: No, Shirley Mullins is Moon’s wife.

 

JL: Okay. Yvonne is Billy Jr’s wife?

 

JD: Yeah.

 

JL: She’s up there, usually. I think that’s who I spoke with.

 

6.                  To the best of my knowledge, SAWS does NOT have a valid Warehouse Receipt, nor valid Bill of Lading, nor any other valid contract, for towing, winching or storage of my Volvo, neither with me, nor with any other person or entity.

 

7.                  To the best of my knowledge, this crime (and other crimes) are Class D felonies under Tennessee Code, for SAWS’ continued ongoing pattern of racketeering conduct, among other state and federal criminal charges. The statutes of limitations have not expired for these crimes.

 

8.                  To the best of my knowledge, the senior owner of SAWS, Billy “Moon” Mullins Sr., was previously arrested by Knox County Sheriffs Department for the (former) crime of “concealing stolen property” (today codified as “theft”), (BILLY A. (MOON) MULLINS, v. HUBERT WELLS, 60 Tenn. App. 675; 450 S.W.2d 599; 1969 Tenn. App., http://www.geocities.com/towcrime/mullinsarrest.html. At the time of his arrest, “Moon” Mullins was also employed as a part-time constable. Knoxville Police Department Internal Affairs Division previously determined that SAWS stole another motor vehicle from Vehicle Impound Lot owned by City of Knoxville Municipal Corporation. SAWS has previously committed federal felony mail fraud in similar car theft, according to federal court documents.

 

            9.         This particular crime of felony theft of my Volvo occurred at CARMAX Corporation’s ungated public parking lot in Knoxville. The vehicle was not illegally parked and was not blocking traffic in the parking lot. This parking lot is open to the public 24 hours, 7 days a week, and is not signposted with “No Trespassing” signs.

 

            10.       To the best of my knowledge, CARMAX and its agents deny knowledge of this crime, and agents of CARMAX declare it did not enter into a pretow civil contract with SAWS for towing of this vehicle. CARMAX is a national franchise for used car sales, headquartered in the state of Virginia. Tennessee Attorney General Opinion 00-14, dated September 19, 2000, declares that it is illegal for any property owner to enter into “blanket authorization” nonconsentual towing contracts, and requires “an express written authorization for the towing of each vehicle.”

 

            11.       To the best of my knowledge, SAWS has no voluntary/consentual nor involuntary/nonconsentual pretow contract for towing/winching/storage services for this vehicle from any other person, agent, corporation, nor governmental law enforcement agency. According to governmental Teleserve agents and visual inspection of the vehicle, no “parking tickets” nor “tow-in reports” nor “vehicle impoundment forms” exist against this vehicle from Knox County Sheriffs Department, Knoxville Police Department, Knoxville Codes Enforcement, nor City of Knoxville Vehicle Impoundment Lot.

 

            12.       I did not enter into a voluntary/censentual pretow civil contract with SAWS for towing of my Volvo. I have not (and will not) enter into a valid voluntary/censentual post-tow civil contract with SAWS for towing of my Volvo.

 

            13.       To the best of my knowledge, SAWS has never mailed to myself, nor to the previous owners (nor contacted by phone), notification of SAWS’ post-tow actions, in violation of Tennessee law.

 

            14.       To the best of my knowledge, SAWS failed to comply with notification laws for reporting “unclaimed or abandoned vehicles” to any law enforcement agency, in violation of TCA §55-16-101 et seq., and TCA §66-19-101 et seq., which destroys any valid claim of debt for breach of contract alleged by SAWS. Federal Aviation Administration Authorization Act (FAAA Act), 49 USCA §14501 specifically requires providers of towing services to comply with all state and local laws regulating nonconsentual towing, winching and storage of motor vehicles.

 

            15.       SAWS, and its lawyers/agents at Stokes, Rutherford, Williams, Sharp and Davies have repeatedly refused demands from me to provide ANY written paperwork on its illegal theft of this vehicle, including refusal of providing me ANY written invoice for “billing” (which was verbally alleged to me that the current fraudulent “debt” is over $1,500) or “abandoned” title application. SAWS illegal actions are preserved on video and audio tape, and by testimony of credible eyewitnesses.

 

            16.       State of Tennessee Department of Safety refused to send to me certified copies of all paperwork available for my Volvo, including all computer printouts (including “GENERAL INQUIRY AND RESPONSE” and “STOP INQUIRY”), specifically including the application of “Abandoned Vehicle Title”, “Lien” (allegedly “abandoned”), (or whatever it is called) made by SAWS or its agents, including all exhibits, affidavits, powers of attorney and/or court orders pertaining to SAWS’ application. I specifically demanded the name(s) and personal home addresses of individuals and their supervisors employed (or later terminated) by State of Tennessee who processed SAWS’ title/lien” application (June 2, 2003) and/or the “STOP” on my application/registration of title (May 30, 2003).

 

            17.       I also demanded certified copies of all title applications for alleged “abandoned”, “salvage” or “non-repairable” vehicles submitted by SAWS, its DBAs or its agents (including Billy Stokes attorney-at-law and/or all other attorneys-at-law at Stokes, Rutherford, Williams, Sharp & Davies) during the past six (6) years.

 

5.                  I declare, under penalty of perjury, that I am also the rightful and legal owner of a 1990 Honda Accord, identified by VIN 1HGCB7641LA001703, current Tennessee title number 60510616, which was previously reported as stolen on January 15, 2000 (Knoxville Police Department stolen vehicle report # 000000002925), and allegedly “recovered” approximately six (6) weeks later (I do NOT consider a stolen vehicle “recovered” when it remains in the illegal possession of the thief). This Honda had an approximate retail value of $5,500 at the time of the theft.

 

6.                  I demand that this vehicle be immediately relisted as “STOLEN” in all applicable governmental databases.

 

7.                  This vehicle was initially stolen from my residence at 422 S. Gay Street, Knoxville, TN, in Knox County, and immediately “restolen” from the KPD Impoundment Lot (in violation of KPD General Order 3.3, http://www.geocities.com/knoxvillegreenparty/towcrime/kpdregulationtow.gif). SAWS (and KPD Teleserve, KPD (Wrecker) Inspections, and KPD Detective division) repeatedly denied that it towed or possessed my vehicle for six weeks. SAWS then committed federal mail fraud by mailing a fraudulent invoice for $753.62 (maximum contract price was $15 per SAWS contract with City of Knoxville), in an attempt to feloniously extort money. I declare that I have no valid liens for debt against me regarding this vehicle. This vehicle was also burglerized, vandalized and stolen by SAWS from Knoxville Police Department Vehicle Impound Lot, and was improperly removed from the stolen-vehicle database. When I initially telephoned SAWS on the day my car was reported stolen, SAWS checked their lot on Sutherland Avenue, and declared to me they did not have any knowledge of my Honda. Apparently, my Honda was apparently towed to the chop shop located on the private property of Moon Mullins Sr., on Hall Road in Knox County, also known as “Moon’s Used Parts”, where its CD player and speakers were stolen by its unnamed employees, causing additional damage to the interior of the vehicle.

 

8.                  SAWS perpetrated mail fraud by sending me a fraudulent invoice in an attempt to extort over $700, through the United States mails, after denying for approximately six (6) weeks that it possessed or towed this vehicle. This was an attempt to fraudulently convert SAWS’ nonconsentual crime into a unconscionable “consentual” contract, using illegal threats, extortion and duress in its attempt to force me into signing a “voluntary” “consentual”, towing contract, or, in the alternative, to force me into “voluntarily”, “abandoning” my claim of title to that vehicle (and to thus attempt to fraudulently enforce an “abandoned vehicle lien”, and unvalidated debt, under the Fair Debt Collections Practices Acts). To the best of my knowledge, I immediately refused to “accept” SAWS’ fraudulent “offer”, both verbally in person (on audiotape), and in writing.

 

9.                  Upon viewing this vehicle in SAWS’ illegal possession (it was later towed to SAWS’ lot on Sutherland Avenue), I observed the CD player and speakers were stolen out of it, and this was also reported to Teleserve unit of Knoxville Police Department (stolen property report #000000019098). Flores’ KPD Tow-In Report # 00-002147 proved the CD player and speakers were installed at the time of the initial tow. As of July 2003, my Honda (with additional parts chopped out of it and additional damage inflicted) was illegally located at “Moon’s Used Parts”, home of Billy “Moon” Mullins Sr and Sue Mullins, at 9922 Hall Road, Knoxville, Tennessee, County of Knox, phone 865-693-7106. “Smokey” (Billy Mullins Jr?) and Yvonne Mullins, on two recent occasions in approximately July 2003, refused to provide me paperwork/invoices for this vehicle, and refused to allow me to recover this vehicle from their illegal possession. Prosecution of the theft of this vehicle is still within the criminal statute of limitations for felonies, as a continuing crime and pattern of racketeering activity. It is unknown by me whether SAWS/Moon’s profit on the theft of this vehicle has been declared on its federal income tax return(s).

 

KNOX COUNTY 911 DISPATCH

 

Jan 15, 2000

03:07am

 

[Frequency 1-A: Central Sector]

 

Dispatch [Hea D'Allesandro]: 43.

 

KPD CAR 43 [Ryan Flores]: 43.

 

Dispatch: Check a [10-] 24 [traffic problem], State and Union Promenade alley, maroon Honda, in the alleyway. Service department can't get through.

 

43: 10-4.

 

03:29 am

 

Dispatch: 43, Did you speak to service department at State and Union?

 

43: Yeah. 10-4. He said he didn't call.

 

Dispatch: Well, could you go back there though and talk to him?

 

43: Go to Foxtrot. [Go to Frequency 1-F]

 

03:30 am

 

Dispatch: Car 30 Golf to car 43 Hotel.

 

Dispatch: Car 43 to 30 Golf. Go ahead. Can you go Hotel?

 

Frequency Change Channel 1-F

 

03:30 am

 

43: 43 Dispatch.

 

Dispatch: Go ahead.

 

43: Yeah. There's a car in the alley but it's not blocking anything. You can pass all the way through there.

 

Dispatch: He said it was right there behind the Promenade building that burned down in that Promenade alley. It's blocking something they need to get through with the service truck.

 

43: I was down there. There's a service guy was there in his little orange truck and he advised there was no problem. I'll be back around. [resignation in voice]

 

[Back to regular frequency.]

 

03:49

 

43: 43 [10-] 97 [arrived at scene]

 

Dispatch: 10-4.

 

43: 43.

 

Dispatch: Go ahead.

 

43: Call the service department. Find out where they're at. I'm at State and Union and they're not in the alley.

 

Dispatch: 10-4.

 

03:50

 

Dispatch: 43.

43: Go ahead.

Dispatch: They're out there by the mall. They'll be there in a few.

 

43: [mike click]

 

03:53

 

43: 43.

 

Dispatch: Go ahead.

 

43: [10-] 48 [send wrecker], 48 pound pull please.

Dispatch: 10-4.

 

Dispatch: 43, Sutherland enroute.

 

43: 10-4. We're in the alley East of Gay Street, down there by the brewing company.

 

Dispatch: 10-4. Do you need a pull in number?

 

43: Just a second. I'm turning here.

 

Dispatch: 10-4.

 

03:56

 

43: 43. Tell the time and number please.

 

Dispatch: 43. Time is 3 o'clock. Pull in number is 002147. 002147. Beat 43. Grid 1.

 

43: 10-4.

 

04:07

 

Dispatch: Car 43.

 

43: 43.

 

Dispatch: Do you know what kind of car that is out there at State and Union?

 

43: Honda Accord burgundy in color.

 

Dispatch: Thank you.

 

34: 10-9. [repeat thank you]

 

Dispatch: 10-4.

 

04:11

 

Dispatch: All units be on the lookout for a 10-44 [stolen] vehicle. Taken from 500 State Street. 1989 Eagle Premier maroon 4-door. No tag information at this time. Taken some time tonight. [unintelligible] Teleserve.

 

[see exhibit map of Fire Street]

 

 

 

 

 

 

            10.       Upon discovering the car was missing, I called KPD Impound [from the number in the phone book]. Impound said that they didn't have it, but that Sutherland Avenue Wrecking has the city contract for downtown. I called Sutherland and they said they didn't have it. Just to be safe I called Cedar Bluff Towing which has the contract for UT area. They didn't have it either.

 

KPD TELESERVE

 

Jan 15, 2000

5:35 pm.

 

Teleserve: Knoxville Police Department, Officer Gallop.

 

John Lee: Yeah, I'm calling to see if you may have towed a car. Cedar Bluff Towing gave me this number.

 

Teleserve: What kind of car was it?

 

JL: It was a 1990 Honda Accord, 4 door, burgundy.

 

Teleserve: Let's see here. Hang on a moment. Do you have your tag number?

 

JL: Yeah.

 

Teleserve: What is it?

 

JL: 695-QBL.

 

Teleserve: OK. One moment. Where would it have been towed from?

 

JL: An alley behind Gay Street, where my house is. It was parked in my loading dock.

 

Teleserve: What was your tag number?

 

JL: 695-QBL.

 

Teleserve: There's a blue Honda Civic?

 

JL: Nope.

 

Teleserve: I'm not showing one.

 

JL: OK. That means it's stolen. Appreciate it. Thanks.

 

10.              To the best of my knowledge, this felony theft occurred in violation of Knox County District Federal Court “unpublished” order in Hale v. Tyree, 491 F. Supp. 622 (E.D. Tenn. (1979), (http://www.geocities.com/towcrime/unconstitutional.html), and represents civil contempt of that court order, and fraud before the courts.

 

11.              To the best of my knowledge, the Federal Aviation Administration Authorization (FAAA Act) exemption of city ordinances (Knoxville “Wrecker Ordinance”, Section 26, Vehicles for Hire), and state law regulating “interstate” commerce of consentual towing contracts (TCA §55-16-101 et seq.) specifically does NOT apply to NONconsentual towing/winching/storage operations, as stipulated in the full-text order by Eastern District Federal Court in Cedar Bluff 24-Hour Towing, Inc. v. City of Knoxville, 78 F. Supp. 2d 725 (E.D. Tenn. 1999).

 

12.              To the best of my knowledge, Cedar Bluff 24-Hour Towing (“CB24T”), A/k/a Cedar Bluff Wrecker Service (“owned” by Ben McGovern in Knoxville, County of Knox), violates state and federal antitrust laws by illegally conspiring with SAWS to illegally set nonconsentual towing regions, fees, and government contract bids, along with its $40-billion/year partners Miller Indistries (8503 Hilltop Drive, Ooltewah, Tennessee, 37363, 423-238-4171), RoadOne (8503 Hilltop Drive, Ooltewah, Tennessee, 37363, 423-238-4171), Browing-Ferris Indistries (BFI), Waste Management (WM), “owned” and managed by its agent William Miller (living in Loudon County, Tennessee), recently partnered with Allied Waste Industries (15880 N. Greenway-Hayden Loop, Suite 100, Scottsdale, AZ 85260, 480-627-2700). This allegation of antitrust crimes was made against CB24T by agents of SAWS (on audiotape), who were complaining about losing money in this scam.

 

13.              To the best of my knowledge and information, William Miller is related to Joe T. Miller, a tow-truck owner, scrap-metal dealer and former garbage-dump contractor for Knox County. In December 2000, Miller pled guilty to multiple felonies for car thefts and bootlegging of moonshine, after he used his tow trucks to steal multiple cars in Seymour (Sevier County), and transporting them to his chop shop in West Knox County, at 11645 Snyder Drive (Knox County Generals Sessions Court docket # 97-6857, 97-5692, 97-5693, 97-4058, 97-6686). Miller’s tow-truck driver Freddie Letsinger also pled guilty to felony car thefts (Knox County Generals Sessions Court docket # 97-5694 and 97-5695). Miller and Letsinger paid $3720 restitution to Rhonda Rauton for felony theft of her vehicle (Knox County Criminal Court docket # 66085 and 66081). Rhonda Rauton had made citizen’s arrests on Joe Miller and his gang, after she telephoned him to ask if he towed her car, then Miller falsely alleged he did not have her car, then Rauton went to that location on Snyder Road, where again Miller denied possessing her car, but Rauton walked to his chop shop and discovered her car on a forklift getting chopped for parts, and she immediately telephoned Knox County Sheriff’s Department to pick up her prisoners. Deputies discovered a loaded firearm “behind every door and under every desk”, according to my conversation with Rauton.

 

14.               To the best of my knowledge (according to videotape recordings), A&E TV network, Investigative Reports with Bill Curtis, “Modern Mobs” (http://www.aande.com/tv/shows/billkurtis/), named BFI/WM as “cooperating” with prosecutors in New York City in the recent criminal convictions of 25 of its employees for membership in the Gambino and Genovese Mafia crime “familes”, which resulted in “the largest tax cut in New York history,” when the garbage contracts for the former World Trade Center were reduced from $1.5-million to $100,000 per year. Controlled Demolition Inc. (its owners are engineering graduates of University of Tennessee Knoxville), working with BFI/WM, was awarded a $9-billion government contract to blow up with explosives (“demolish”) and to destroy scrap-metal evidence from the World Trade Center after the “terror” massacre on 9-11-2001, just as CDI/BFI/WM was awarded a similar contract after the “terror” bombings of the Oklahoma City Federal Building, as videotaped by the History Channel TV network in its report on “Demolition”. History Channel also produced a news report that Italian gangster Lucky Luciano blew up and sunk a freighter ship in New York Harbor as an act of terrorism to blame Nazi Germany, then extorted a job from the FBI and other law enforcement agencies, to provide “protection” (rackets) of the New York docks during World War 2. History Channel also reported that the Jewish mafia has always controlled the Italian Mafia, since the Jewish mafia immigrated to America first. To the best of my knowledge, William Miller is Jewish, and lives in “Chapman Manor” in Loudon, Tennessee, off US Highway 11 (Kingston Pike), just across the Knox County border. His mansion is known locally as “The House that Garbage Built”, and provides an annual extravagant “Christmas/Hannuka Lights Display”.

 

15.              To the best of my knowledge, the 9-11-2001 victims’ families are currently suing by class action (in US District Court in San Francisco, with attorney Stanley Hilton, Senator Bob Dole’s former chief of staff, www.SueTheTerrorists.net, and in Pennsylvania US District Court, by Phillip Berg, a former US prosecutor, www.911ForTheTruth.com), United States president George Walker Bush (a/k/a “Junior”), et alia, for perpetrating the 9-1-2001 “terror” massacres of U.S. residents, in conspiracy with his Saudi business partners the Bin Ladens (partners in Arbusto Oil, Carlyle Group, defended by the law firm of Bushes’ White House trial lawyer James Baker). Coincidentally, my family’s law firm of Lee, Lee & Lee, located in Knoxville, are currently suing by trillion-dollar class action (in Washington D.C Federal Court), the Saudi bankers and Saudi royalty for their alleged role in the 9-11-2001 “terror” conspiracy (Ness-Motley law firm at www.September11ClassAction.com). Note that Knoxville mayor Victor Ashe, a contracting partner with BFI/WM/CB24T/SAWS, is a member of Yale University’s Skull and Bones Senior Secret Society, a/k/a “The Brotherhood of Death”, that performs its ritual serial killings and weddings inside coffins, ate off Nazi chancellor Adolf Hitler’s silverware, and recently was videotaped performing a ritual human sacrifice of a screaming woman with blood spurting from her slit throat, as broadcast on TV in America by Australian multinational FOX/Murdock News, MSNBC/GE News and CNN/AOL News (http://secretsofthetomb.com). Georges Bush, and the owners of Knoxville’s Scripps-Howard media cartel, are confessed members of the Bohemian Club that meets at Bohemian Grove presidential retreat in Monte Rio, California, near San Francisco, where world leaders meet every July to perform a “mock” human sacrifice to a 30-foot-tall concrete god (a/k/a “Molech”), and to run around naked with 3,000 of their closest “homosexual” associates (http://infowars.com). It is suspected that Victor Ashe is also a member of Satanic Bohemian Grove, since he gave Knoxville News-Sentinel/ATT/COMCAST/Scripps-Howard $20-million in taxpayer-funded corporate welfare, and attempted to give it $1-billion in welfare for its “Universe Knoxville” downtown-demolition “theme park” (that city council member Carlene Malone told me would “bankrupt the city for generations to come – it will never recover”).

 

16.              This affidavit of criminal complaint for car theft by me is not concerning Lee, Lee & Lee in any manner, other than to note that attorney David Craig Lee, my brother, was the previous title-holder of both vehicles named in this complaint.

 

17.              To the best of my knowledge, my father J.D. Lee was recently mugged (approximately August 2001) at gunpoint by a gang of four, who threatened him, “We will blow your brains out unless you do what we say.” This crime is currently uninvestigated and “unsolved” by KPD. Within three months, he “voluntarily dismissed without prejudice” two “slam-dunk” class actions pending against SAWS and CB24T (John Lee vs. City of Knoxville Municipal Corporation, Sutherland Avenue Wrecker Service, et al., US District Court in Knoxville docket # 3:00-CV-693 (non-consentual tow under contract with law-enforcement); and a 2nd class action in Knox County Circuit Court docket # 1-63-01, Ronald Fagan vs. Cedar Bluff 24-Hour Towing, Miller Industries, et al. (non-consentual private tow on private property without contract with governmental law enforcement). The CBT case was defended by current U.S. ambassador to Japan, Howard Baker Jr., owner of “The Firm” (Baker, Donelson, Bearman and Caldwell, world headquarters at 165 Madison Avenue, Memphis, TN, 38103, and 2200 Riverview Tower, Knoxville, TN, 37902), rumored to by John Grisham’s model for his mafia racketeer-influenced law firm in Memphis, Tennessee (The Firm), portrayed by Hollywood actor Tom Cruise in the movie coincidentally titled “The Firm”. Baker was formerly White House chief of staff for Sir George Bush Sr., Knight of the British Empire, during the criminal convictions relating to narcoterrorist bombings perped by Bush and “his” CIA (MI6) during “Iran-Contra” (35 volume report by U.S. Senate, chaired by Bush’s royal cousin, John Kerry, are publicly available in the University of Tennessee Law Library, and over a dozen White House staffers were criminally convicted (and pardoned), including many current White House staffers). My family’s law firm worked the RICO civil class action by Christic Insitute (National Council of Churches of Christ, et al.), prosecuting the Bush Sr. White House and its business partner Pablo Escobar, for narcoterrorism for murdering US citizens by terrorist bombings, in Avirgan v. Hull and U.S., et al., 112 S.Ct. 913 (Mem) U.S.,1992, during Iran-Contra, and took the deposition of U.S. ambassador to Costa Rica, Lewis Tambs, who was expelled by Costa Rica for importing/exporting narcotics via the U.S. embassy. In a related Iran-Contra wrongful-death civil tort case, Jennifer K. Harbury vs. United States, US Supreme Court, No. 01-394. argued March 18, 2002, decided June 20, 2002, US solicitor general Ted Olson argued that the White House and US government, via Central Intelligence Agency (CIA), has the legal right to perpetrate terrorist bombings to murder US citizens. (Mr. Olson’s wife, Barbara Olson, allegedly died abord America Airlines Flight 77 that allegedly crashed into the Pentagon on September 11, 2001,a claim unsupported by the photographic evidence that proves an unmanned robotic US Navy A3 Skywarrior nuclear bomber, owned by CIA contractor Hughes Aerospace, is the actual aircraft to impact the Pentagon). A similar scheme of using substitute robotic airliners, faked crash debris, and faked passenger lists, is detailed in the Pentagon/CIA Operation NORTHWOODS memorandum (declassified by Congressional order in 2000, available from US National Security Archives, George Washington University, Washington DC), from Pentagon Joint Chiefs of Staff to Secretary of Defense, to US Secretary of Defense Robert McNamara, under orders from the White House, to perpetrate large-scale terrorist attacks against USA to blame a foreign enemy to falsely “justify” invasion and war. It is alleged by Ellen Mariani, who sued George Bush Jr. et al., for perping the terrorist murder of her husband aboard United Airlines Flight 175 that allegedly crashed into World Trade Center, that the families of the majority of alleged “passengers” aboard the airliners on September 11, 2001 have NOT filed claims for payment from the victims funds, as of January 2005, and that the majority of these “victims” are NOT listed as dead by Social Security Administration).

 

18.              To the best of my knowledge, the previous sheriff of Knox County, Joe Jenkins (now reportedly deceased), was convicted of stealing over $1-million worth of motor vehicles, and the current sheriff of Knox County, Tim Hutchison (convicted of six (6) counts of perjury; confessed to renting an airport from a convicted narcoterrorist drug kingpin; confessed to building 400 houses with his unlicensed convicted felon business partner) confessed to “crusing” and stealing specific parked cars with convicted cop-killer Roy Lee Clark (http://knoxville.fbi.gov/hist.htm), from the parking lot at West Town Mall, by towing cars to Clark’s chop shop. Hutchinson alleged he worked “undercover” as lookout, driving his patrol car and wearing his police uniform. It is alleged by a former Knox County deputy that Roy Clark was not the “trigger man”, who was allegedly Clark’s nephew. The former deputy alleged the nephew was hunted down by an extrajudicial police “Death Squad”, gunned down and hung by the neck, and that the coroner ruled this a “suicide”. It is alleged for current and former Knox County deputies that Sheriff Hutchison’s department illegally requires deputies pay $15,000 bribes for promotion to sergeant, and $25,000 bribes for promotion to lieutenant. A similar conspiracy was confessed by Victor Ashe, John Rossen, and Michael Martin, that court administrator Martin extorted “bonus” paychecks from his subordinates, as condition for employment, and Martin was not terminated for this felony for over one year, until I personally subpoenaed him to testifyy in city court regarding his illegal Top Secret court docket, that promotes a felony car-theft conspiracy to flourish inside Knoxville City Court.

 

FELONY CAR THEFT #2

 

19.              To the best of my knowledge, this is an identical crime to KPD officer Ryan Flores, Flores’ KPD supervisor sergeant Shawna “Williams” (husband with a different name employed by University of Tennessee Police Department), E911 dispatcher H’ea D’Allesandro, and others, working under illegal orders of SAWS/BFI/WM government contractors, et al., to steal my legally parked Honda Accord (as stipulated by Flores on official E911 tape recording, in possession of named parties), on January 15, 2000, and then conspired to deny their possession of this vehicle for six weeks (nor to “locate” it during “investigation” of its own stolen vehicle reports). LT Virgil Hubbard in KPD Internal Affairs division, KPD chief Phil Keith (appointed by mayor Victor Ashe, who was fired by the Tennessee Supreme Court in 1974 for election fraud and purjury, removed from his elected job in the Tennessee Senate (Jack Comer v. Victor H. Ashe, et al., Supreme Court of Tennessee, Oct. 10, 1974, http://www.geocities.com/towcrime/victorashunderageelection.html), and City of Knoxville Municipal Corporation Law Department stipulated in their written public reports and correspondance to my attorney that my Honda was illegally towed, illegally impounded and that they were legally liable for this crime.

 

20.              To the best of my knowledge, SAWS has never offered restitution to me for this crime or unconsionable “voluntary” “contract”. To the best of my knowledge, SAWS does NOT have a valid Warehouse Receipt, nor valid Bill of Lading, nor any other valid contract, for towing, winching or storage of my Honda Accord, neither with me, nor with any other person or entity.

 

21.              This theft of my Honda Accord occurred approximately six (6) hours after the Knoxville Journal phoned my residence to ask permission to use by byline on a freelance article to be published the next week (“Internet site not flattering to local officials,” "Speak Out" section of the Knoxville Journal, published on January 20-26, 2000 -  (http://www.geocities.com/cop_killers_knoxville_tn)), regarding the “unsolved” and unprosecuted murder of unarmed, off-duty KPD officer Tony Williams, despite videotaped confessions by the two arrested killers, and recovery of the murder gun on the night of the murder (by Lake City PD, in Tennessee). Former Knox County sheriff Joe Jenkins (later convicted for million-dollar car theft) was also visiting with these cop killers on the night of the murder of Tony Williams, according t