April 9, 2009 Barbaralette G. Davis 125 North Main, Room 336 Memphis, TN 38103 Re: Stanley Green v. Larry A. Godwin & MPD File No. : 09-007 Dear Attorney Davis: I have received Larry Godwin and Memphis Police Department’s Motion to Dismiss along with the Memorandum in Support with attachments. Please find enclosed my Response to the Defendants’ Motion to Dismiss & Memorandum in Support with Attachments. February 3, 2009 I have filed the following discovery items with Shelby County Circuit Court Clerk: My U.S. Postal Certified Mail Receipt shows Lakenya A. Kirkwood has signed for delivery on February 4, 2009. 1. First Set of Interrogatories Rule 33 2. Production of Documents Rule 34 3. Admissions of Facts Rule 36
The Defendants are in default of the 30-day time period to respond. In my opinion it may be disingenuous for the Defendants to ask the Court to uphold Rule 12.02(6) failure to state a claim that relief may be granted. My claim is that the Defendants have oppressed enforcement of TCA 39-17309 Civil Rights Intimidation. The Defendants have acted under color of office to enforce TCA 40-39-201 enacted August 1, 2004 ex post facto to my June 2, 1994 felony. I am seeking a Writ of Mandamus to compel enforcement of TCA 39-17-309. I have delayed to file my Motion to Compel with Sanctions. Your assistance is greatly appreciated to advise your clients to cooperate with my discovery effort. Respectfully submitted,
Stanley Green Enclosures: As Stated