IN THE CRIMINAL COURT OF SHELBY COUNTY, TENNESSEE

30TH JUDICIAL DISTRICT AT MEMPHIS

STANLEY GREEN )

Petitioner, )

VS. ) Case No. 92-09915

STATE OF TENNESSEE )

Respondent: )

MOTION TO RE-OPEN POST-CONVICTION RELIEF AND AUTHORITIES IN SUPPORT THEREOF OR IN THE

ALTERNATIVE CONSTRUE THIS MOTION AS TO BE A PLEADING FOR A WRIT OF ERROR CORAM NOBIS

__________________________________________________________________

Comes now, the Petitioner Stanley Green who moves this

Honorable Court to allow Petitioner to amend his original filed

pro se petition in order to Re-Open his petition for Post-

Conviction Relief, pursuant to the Post Conviction Procedure Act,

T.C.A. §40-30-101 et. seq., or in the alternative construe this

motion as a pleading for a Writ of Error Coram Nobis pursuant to

T.C.A. §40-26-105. In support of this motion, the Petitioner would

like to respectfully submit the following statement:

1

1. The Petitioner has previously filed his original petition for

Post-Conviction Relief in Shelby County Criminal Court Div

IX.

2. This is the first motion filed with Shelby County Criminal

Court Clerk to re-open the Petitioner’s petition for Post-

Conviction Relief.

3. Petitioner seeks to reveal to Shelby County Criminal Court

the whole truth that District Attorney Edgar Peterson has

unconstitutionally enforced T. C. A. §39-15-302 under color

of office, whereas Tennessee Supreme Court has upheld

the right to privacy in Davis v. Davis 1992 for cases

involving sodomy.

4. Judge William Crawford has written his opinion “It is

consistent with this State’s Constitution and constitutional

jurisprudence to hold that an adult’s right to engage in

consensual and noncommercial sexual activities in the

privacy of that adult’s home is a matter of intimate personal

concern which is at the heart of Tennessee’s protection of

the right to privacy, and that this right should not be

2

diminished or afforded less constitutional protection when

the adults engaging in that private activity are of the same

gender”.

5. Petitioner contends that the State of Tennessee recognizes

the custodial parent as having legal authority to render

consent for a minor age child to marry or engage in

intercourse prior to attaining the legal age of adulthood (i.e.

18).

6. The Petitioner will prove Shelby County Criminal Court has

withheld to uphold T. C. A. §39-17-309 in order to sentence

Petitioner to serve three (3) probation sentences for

indictment 92-09915 whereby Post-Conviction Relief or Writ

of Error Coram Nobis may be the only alternative to correct

judgment.

7. The Petitioner in no shape or form is seeking a re-trial of

indictment 92-09915. Rather, Petitioner is seeking

correction from Shelby County Criminal Court for ordering

Petitioner to serve three probation sentences under color of

law. Whereby, Shelby County Criminal Court has failed its

3

judiciary obligation to exercise oversight over Tennessee

lawmakers for passing the Tennessee Sex Offender Registry

(TSOR) in flagrant breach of T. C. A. §39-17-309.

8. The Petitioner respectfully requests that all claims and

information set forth in the original Petition be incorporated

with the claims and information brought by this motion to

re-open this petition for Post-Conviction Relief.

9. Your Honorable Court has found grounds to dismiss said

original petition on the legal basis that said petition is

outside the limitation period and no allegations have been

raised to suggest that the limitation is not applicable.

10. Further, Your Honorable Court is under the false and

misleading impression that the probation sentence for 92-

09915 has expired. The latter is untrue.

11. Probation sentence in respect to docket 92-09915 has

not expired as the Court may wish to contend. Rather,

Petitioner is serving added probation sentences that have

been ordered by the Tennessee Legislative Branch.

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12. The City of Memphis Police Department (MPD)

Tennessee Sex Offender Registry (TSOR) serves as his

supervisory site. Petitioner has reported annually 10 days

prior to or after Petitioner’s birthday.

13. MPD has charged $100 to $150 annually to monitor

supervision. The police have searched Petitioner’s home

once a year without a warrant to make sure Petitioner is

living at Petitioner’s registered home address. Docket 92-

09915 is the basis of said unwarranted searches.

14. Petitioner hopes to furnish evidentiary proof that the

statute of limitation does not apply to the Petitioner. The

Petitioner is seeking Post-Conviction Relief on the premise

that his conviction has breached The Spirit of Laws

whereby, Edgar Peterson has acted under color of office to

prosecute the Petitioner, who was in lawful pursuit to

promulgate his 1990 Nationwide Alert.

15. The Petitioner has prepared My Paper Trail journal as

evidentiary proof to corroborate persistent efforts to voice

grievances to Disciplinary authorities in a timely fashion for

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the 13th Judicial District for the Western Division of

Tennessee. Each Disciplinary authority has dismissed

investigation.

16. See My Paper Trail attachment http://mypapertrail2.underwriterweb.com

A. Court of the Judiciary (See p. 2089-2094)

B. Board of Responsibility (See p. 2075-2088)

C. U.S. District Court (See p. 2111)

17. Petitioner registered January 1995 with the Tennessee

Bureau of Investigation. (TBI) Petitioner has remained on

the TSOR for ten years without violation.

18. Attached is a letter dated July 31, 2006 from Pam Beck

sent to the Petitioner stating that TBI has not credited

Petitioner for time-served on the TSOR since January 1995.

Rather, 10-years time-served shall commence from June 2,

2000 and expire June 2, 2010. Petitioner must appear

before a Judge in Shelby County Criminal Court to

terminate his probation sentence from the TSOR.

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19. District Attorney Tom Hoover has enforced TSOR ex

post facto law to indict the Petitioner May 2005 docket 05

03092 on the charge of Failure to Register.

20. Judge Fred Axley Div VI has heard Tom Hoover’s ex

post facto case. Petitioner acted pro se to submit 6 motions

which DA Tom Hoover didn’t answer. Petitioners motions

have sought to bring attention to Shelby County Criminal

Court that the DA has suppressed enforcement of T.C.A.

§39-17-309.

21. Ozment Law Firm has sent threatening letters August

4, 2005 and June 13, 2005 (See p. 65-66)

http://myupdates.underwiterweb.com to Petitioner’s

home to blackmail Petitioner to hire its attorney to

represent his defense. In lieu of its blackmail Petitioner

refused to hire an attorney from said law firm.

22. Judge Axley has appointed Attorney Larry Copeland of

Ozment Law Firm to represent Petitioner. Attached is a

letter dated May 20, 2006 that Attorney Copeland has sent

to the Petitioner to explain the additional statutory

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probationary requirements that Tennessee lawmakers have

passed.

23. Petitioner has filed an affidavit of complaint against

Esquire Larry Copeland with James Vick Deputy Chief

Board of Professional Responsibility (BPR). Petitioner has

alleged that Larry has collected $500 from Petitioner under-

the-table for D.A. Tom Hoover to dismiss his case docket #

05 03092.

24. Petition is alleging that Attorney Copeland has

breached T. C. A. §39-16-703 to falsify his report to Judge

Riley in respect to an official proceeding. Attached are 2

letters (i.e. date omitted) Larry has written to Judge Jo G.

Riley. He has misled Judge Riley to believe that he would

furnish him with a copy of a Guilty Plea transcript. Instead,

he has submitted a Dismissal transcript of 05 03092.

25. Attached is a letter dated Jan 10, 2008 that Esquire

Copeland has written to James Vick. Larry admits to James

Vick that D.A. Tom Hoover has offered to drop charges in

lieu of a $500 donation to a nonprofit organization.

8

26. William L. Keys hasn’t furnished the Petitioner with a

Court receipt to document the business transaction that

Martha Jackson Shelby County Court Reporter has recorded

in her official transcript for February 7 and 9 2007.

27. Petitioner filed affidavit of complaint against Judge

Axley (File No. 07-3074) with Presiding Judge Joe G. Riley

Court of the Judiciary. Attached is a letter dated March 26,

2007 that Judge Axley has written to Judge Joe G. Riley to

deny charges of Judge Axley accepting payment under-the-

table.

28. Attached is a letter dated June 29, 2007 from J. Steven

Stafford Disciplinary Counsel Investigation Panel. His letter

has dismissed file no. 07-3074 on the basis Judge W. Fred

Axley has resigned from Shelby County Criminal Court.

29. Attached is a letter dated May 18, 2007 from Mayor

W.W. Herenton. He has returned a packet of information to

the Petitioner pertaining to said complaint that Petitioner

had filed against Judge Axley and Esquire Larry Copeland.

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30. Petitioner has written a letter to Mayor Herenton to

voice grievances against the City of Memphis Police

Department (MPD) for constant harassment. Petitioner has

alleged that Larry A. Godwin Police Director has ordered his

staff under color of office to refrain from enforcing T. C. A.

§39-17-309.

31. Attached is a letter dated May 5, 2008 from Larry A.

Godwin Police Director sent to Petitioner. Larry has

submitted a false police report to mislead Mayor Herenton

to believe that Petitioner has been convicted of rape for

indictment 92-09915. Godwin’s staff has direct access to

Petitioner’s police records.

32. Attached is a letter dated May 25, 2008 from William

L. Gibbons District Attorney General. He confirms that

Director Godwin has filed a false police report concerning

indictment 92-09915. D.A. Gibbons has not brought criminal

charges against Larry in Petitioner’s behalf as the

victimized party.

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33. Mayor Herenton is the Chief Law Enforcement Officer

for the City of Memphis. Pursuant to T. C. A. §39-16-502 a

violation of subdivision (a) (2) is a Class E felony. Director

Godwin has knowingly placed Petitioner in serious imminent

danger by filing a false police report of a rape conviction.

34. The City of Memphis Police Department (MPD) over

the past 14 years has processed criminal background

checks (CBC) to inform personnel managers, and/or HUD

etc. that the Petitioner has been lawfully convicted of rape.

35. Petitioner has been registered with the Vocational

Rehabilitation Services (VRS) of the Tennessee Department

of Human Services (TDHS) since 1994.

36. In year 2000 the Petitioner has graduated from

Tennessee Technology to earn his CDL license. MPD has

issued false police reports of rape to each personnel

manager. It has been impossible for Petitioner to secure

employment.

37. HUD has been responsible for furnishing Petitioner

public housing. Petition has applied for Section 8 housing,

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high-rise or other available housing for Disabled Veterans.

Petitioner’s application has been rejected. Petitioner has

lived with elderly parents for a number of years in lieu of

said rejection.

38. Shelby County Tax Assessor has charged Mr. and Mrs.

Willie V. Green, Sr. to pay County property taxes. The TSOR

has required Petitioner to post the home address of his

elderly parents on the internet.

39. New Nations News Reporters Newsroom has reported

a news article entitled, Tennessee 34-year-old son of nigger

mayor arrested for raping 13-year old girl. This article is

about the son of Shelby County Mayor A C Wharton, Jr.

40. Any crack pot lunatic could utilize the TSOR website to

obtain the address to mail biological agents to Petitioner’s

home address in attempt to harm his parents for

accommodating Petitioner with housing in our local

community.

41. Mayor Herenton has awarded Mr. and Mrs. Willie V.

Green, Sr. for their 65th Wedding Anniversary (See p. 382).

12

Petitioner’s parents have demonstrated outstanding

citizenship throughout their 65 plus years city residency.

42. The MPD has constantly harassed the Petitioner’s ex-

wife Sandra K. Green # 2 at 970 Galloway Ave. 38105. The

MPD has made it virtually impossible for the Petitioner to

live in our community without fear of police harassment

and/or intimidation. The latter has exacerbated the

Petitioner’s divorce. The MPD justify the new ex post facto

law as its legal authority for harassment.

43. T. C. A. §39-17-309 is an ipso facto law that makes the

TSOR null and void in the State of Tennessee. Whereby,

Tennessee General Assembly has determined that

Tennessee State Constitution may not support any

legislation that may seek to incite fear, harassment and/or

intimidation against citizens of our community to exercise

his or her Civil Rights.

13

OBSTRUCTION OF JUSTICE

1. Petitioner has testified under oath before Judge H.T.

Lockard Div IV to announce his lawful pursuit to

promulgate his 1990 Nationwide Alert. His preliminary

court transcripts may serve as proof of his sworn

testimony.

2. January 9, 1989 (See p. 1896) Gentry Crowell former

Tennessee Secretary of State has officially date stamped

Petitioner’s charter of incorporation to organize the

National Bureau of Criminal Justice Research, Inc.

(NBCJR).

3. January 1990 (See p. 1897) Minister Bill Paul has

designated NBCJR as an official chapter of the Ministry

for Economic Development (MED). As a member of MED

Petitioner’s nonprofit organization has become exempted

from paying Federal and/or State income taxes.

4. June 27, 1990 (See p. 1899) Charles W. Brown Director

State Clearinghouse has duly approved Petitioner’s Plan

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Proposal (CHTN62790-043) entitled, Nationwide Alert

pursuant to Presidential Executive Orders 12372 and

12416 and Gubernatorial Executive Order 58.

5. July 19, 1990 (See p. 1900) Maynard Pate Executive

Director Greater Nashville Regional Counsel (GRNC) has

reviewed and seconded his approval of Petitioner’s Plan

Proposal to secure Federal Grant assistance.

15

6. July 24, 1990 (See p. 1991) Eugene H. Dzikiewicz

Director Discretionary Grant Program Division Bureau of

Justice Assistance (BJA) has rejected Petitioner’s

application for Federal grant money which had already

been cleared by Tennessee State Clearinghouse for

Federal Grant Assistance.

7. Judge H. T. Lockard has committed a flagrant error by

neglecting to investigate Petitioner’s sworn testimony.

Judge Lockard has committed an obstruction of justice to

impede Petitioner’s lawful pursuit that has been

authorized by Presidential Executive and Gubernatorial

Executive Orders.

8. Nationwide Alert (See p. 1829 – 1893) had sought to

erect a Humanitarian Observatory (HNO) in Shelby

County. HNO has been tailor-made to train police how to

apply Petitioner’s Binary Math Course to predict and

prevent the outburst of random violence in public

workplaces and/or schools.

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9. Petitioner’s HNO has been purposed to serve as a major

tourist attraction to generate billions of dollars for the

State of Tennessee and Shelby County.

10. Petitioner’s HNO would have spared the lives of the

child victims that have been senseless murdered during

the decade of the 1990’s school massacres:

A. Michael Carneal December 1, 1997 Paducah, KY

B. Luke Woodham October 1, 1997 Peal, MS

C. Mitchell Johnson and Andrew Golden March 24, 1998

Jonesboro, AR

D. Eric Harris and Dylan Klebold April 20, 1999 Columbine,

CO

FACTS ABOUT PETITIONER’S CASE 92-09915

1. October 8, 1992 Edgar Peterson had indicted Petitioner on

the charge or rape and incest of his daughter Barbara

Green. Pretrial had set his bond at $5000 for his release.

17

Petitioner’s family paid Brisco Bonding Company $500 as

security.

2. Petitioner’s case was assigned to Judge Joseph B. Dailey Div

V. Judge Dailey appointed Attorney Sherrye J. Brown to

serve as his Public Defender. Petitioner met with Attorney

Brown in her office. She has advised Petitioner to plead

guilty. Petitioner rejected her legal advice. In the

alternative she advised Petitioner to pursue an insanity or

mentally incompetent defense. Petitioner rejected her

alternate legal advice. Petitioner informed Attorney Brown

that he wished to exercise his legal right to bring charges

against Shelby County Sex Crime Squad Division (SCSCSD)

and Tennessee Department of Human Services (TDHS) for

criminal negligence to investigate his Mandatory Child

Abuse Report that Petitioner has filed in 1986 against his

next door neighbor Jeremiah Allen for sexual assault against

his daughter Barbara Green. Attorney Brown has advised

Petitioner that he could not bring counter charges against

SCSCSD or TDHS. She has stated that Judge Dailey would

18

not allow the jurors to hear Petitioner’s criminal charges as

counter criminal complaint.

3. Attorney Brown advised Petitioner that Judge Daily may

revoke his bond if he were to miss his appointment with Dr.

Andrea L. Nichols Midtown Mental Health (MTMH) for a

preliminary psychiatric evaluation. Petitioner met with Dr.

Nichols. She interviewed Petitioner. Dr. Nichols has written

a letter dated March 8, 1993 to Judge Dailey (See p. 1965).

She has recommended Shelby County Criminal Court

transfer Petitioner to Memphis Mental Health Institute.

4. Judge Joseph B. Dailey Div V. had convened a bond hearing

in March 1993. District Attorney Edgar Peterson served as

prosecutor in behalf of the People. Peterson had presumed

from the outset that the Petitioner was guilty.

5. D.A. Edgar Peterson introduced an anonymous letter that

Petitioner’s ex-wife Sandra Green # 1 had brought to Court.

Sandra has testified under oath to allege that Petitioner was

the author of her anonymous letter. Judge Dailey read her

anonymous letter in open Court. Judge Dailey has asserted

19

Sandra’s letter as his legal basis to justify revocation of the

Petitioner’s $5000 criminal bond.

6. Judge Dailey had ordered Shelby County Sheriff to

involuntarily commit Petitioner to Middle Tennessee Mental

Health Institute (MTMHI) in Davidson County, TN to

undergo a 30-day psychiatric evaluation at taxpayers’

expense. Yet, Dr. Nichols had recommended Judge Dailey to

transfer the Petitioner to Memphis Mental Health Institute

(MMHI) of Shelby County.

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7. Petitioner’s psychiatrist Melvin Golden of Charter Lakeside

Hospital of Memphis in May 1992 had referred Petitioner to

VA Hospital and U.T. Medical Group for follow up therapy

and psychiatric examinations. Judge Dailey had committed a

gross legal error. He has waste Shelby County taxpayers’

money to involuntarily commit the Petitioner to MTMHI in

Davidson County.

8. Visit the following website as evidential proof of Petitioners

testimony:

http://www.globalsecurity.org/military/library/congress

/2004_hr/040225-rau.pdf. Dr. Terri J. Rau is a clinical

psychologist for the Armed Forces.

9. Veterans Affairs has contracted Dr. Terri J. Rau to

administer a comprehensive psychosexual examination to

experiment in Shelby County. September 1992 Dr. Rau has

enrolled the Petitioner to serve as a guinea pig at UT

Medical Group for her psychosexual experiment (See p.

1944). Her staff has attached electrodes to the penis of the

Petitioner to measure his erections. Petitioner was

21

instructed to view pornographic audio/visual stimuli. Dr.

Rau has reported her findings to the Subcommittee on

Personnel of the Senate Services Committee.

10. Dr. Rau has recorded the Petitioner’s interview on

page 5 (See p. 1957) of her psychosexual evaluation. He

told her about his former friend Jeremiah Allen raping his

daughter Barbara Green. Pursuant to Child Abuse

Prevention and Treatment Act (CAPTA) Dr. Rau should have

filed a Mandatory Child Abuse Report with Shelby County

District Attorney General to prosecute Mr. Allen.

11. Shelby County Criminal Court doesn’t have on file any

indictment to prosecute Jeremiah Allen for sexual assault of

Barbara Green. Yet, Shelby County Sex Crime Squad

Division (SCSCSD) does have a police report that Petitioner

has filed in 1986 against Mr. Allen for child sexual

molestation of Barbara Green.

12. Petitioner has informed Attorney Sherrye Brown and

Mark McDaniel concerning Mr. Allen’s sexual assault of his

daughter Barbara Green. Each attorney has advised

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Petitioner to pursue an insanity defense rather than to plead

his mitigating circumstance to jurors as his counter criminal

complaint.

13. Petitioner has equal right to bring counter criminal

charges against Jeremiah Allen for sexual molestation

and/or rape of Barbara Green. Each Public Defender has

breached his 14th Amendment Right to equal protection.

14. Dr. Larry Southhard of MTMHI reported to Judge

Dailey Petitioner’s clean bill of health. He has informed

Judge Dailey that Petitioner was not a danger to himself or

others. He wasn’t insane at the time his offense had

occurred. He was mentally competent to stand trial. In lieu

of said report, Judge Dailey refused to reinstate his $5000

bond. Instead, he raised Petitioner’s bond to $20,000. His

only justification was Sandra Green’s # 1 anonymous letter.

15. Petitioner has promptly filed affidavits with the Court

of Judiciary to discipline Judge Dailey for depriving him due

process. Presiding Judge Sheila Jordan Cunningham has

dismissed Petitioner’s affidavits (See p. 2090 & 2094).

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16. Public Defender Sherrye J. Brown had recused herself

of representing Petitioner in lieu of his affidavit against her

with Lance Bracey (See p. 2077-2078). Petitioner had

alleged Attorney Brown of pursuing an insanity or mentally

incompetent defense strategy against his vehement protest.

17. Judge Dailey has appointed Attorney Mark S. McDaniel

to represent him in lieu of Attorney Brown’s recusal. Mark

cross-examined Petitioner’s ex-wife. Mark committed a

gross legal error by neglecting to ask Judge Dailey to allow

him to physically examine the handwriting and/or signature.

The letter had been type- written and didn’t have an

opening salutation or closing signature. It was his word vs.

Mrs. Green as to who the true author of her anonymous

letter. Judge Dailey denied his right to testify under oath.

Sandra’s word has prevailed.

18. Petitioner had hoped to testify under oath during his

bond hearing that he has 4 licensed psychiatrists who have

treated his psychosexual disorder. Attorney McDaniel failed

to summon either psychiatrist to testify for the Petitioner.

24

A. Dr. Melvin Golden Charter Lakeside Hospital

B. Dr. Anne Ayres VA Hospital of Memphis

C. Dr. Kent Cox VA Hospital of Memphis

D. Dr. Terri J. Rau U.T. Medical Group

25

19. Judge Dailey has stated in Petitioner’s March 8, 1993

transcript that he had heard enough. He denied Petitioner

the right to testify at his own bond hearing. He has elected

to revoke Petitioner’s $5000 bond and ordered Shelby

County Sheriff Deputies to transport Petitioner to

Murfreesboro of Davidson County in shackles and handcuffs

for involuntary commitment into MTMHI.

20. Pursuant to T. C. A. §36-6-105 & 106 Judge Dailey had

committed a gross legal error. He has neglected to obtain a

Certificate of Need prior to involuntary commitment into a

State owned and/or operated hospital.

21. Dr. Larry Southhard MTMHI has communicated 4

letters (See p. 1971-1978) dated March 12, 1993; May 13,

1993; April 22, 1994 and March 28, 1994 to Attorney

McDaniel to discuss Petitioners medical records without

consent.

22. Attorney McDaniel has written two letters (See p.

2070-2071) dated April 13 & 14, 1993 to Petitioner while

restrained at MTMHI. His April 13th letter was belligerent

26

telling Petitioner that he would decide the defense strategy

to defend his case. His April 14th letter refused to file a Writ

of Habeas Corpus in behalf of the Petitioner in lieu of his

complaints towards Sheriff Deputies in SCJC.

23. Petitioner has testified under oath to Judge H.T.

Lockard Div IV that Attorney McDaniel was misrepresenting

Petitioner’s defense. Mark has misled Judge Lockard to

believe Petitioner was mentally incompetent to stand trial.

Later, Mark has allowed the Petitioner to stand trial to

enter a guilty plea.

24. Judge Lockard has committed a gross legal error.

Petitioner had asked Judge Lockard to dismiss Attorney

McDaniel. He demanded Judge Lockard to allow him to

represent himself pro se. Judge Lockard laughed it off and

quoted Mark Twain, “A client who represents himself for a

lawyer has a fool as a client”.

25. Petitioner has spent 450 days incarcerated in SCJC to

undergo a 1st and 2nd 30-day psychiatric examinations at

27

MTMHI without a Certificate of Need being signed. Judge

Lockard had ordered a 3rd psychiatric evaluation at MTMHI.

26. Judge Lockard was inflicted by a stroke. Judge Doran

was appointed as substitute of Div IV. Attorney McDaniel

persuaded Judge Doran to allow the Petitioner to stand trial

to plead guilty. Yet, Mark had argued for 15 months before

Judge Lockard that the Petitioner was mentally incompetent

to stand trial. Mark has misrepresented the truth to Shelby

County Criminal Court.

27. Judge Doran has convicted Petitioner June 2, 1994 of

incest. He has issued a Court Order for Petitioner to serve

six-year State Probation with the Tennessee Department of

Probation and Parole (TDPP). He has denied Petitioner

diversion as a first-time felony offense. Also he has failed to

credit Petitioner for 15 months time –served in SCJC to

undergo 2 psychiatric evaluations. Instead, Judge Doran

fined the Petitioner for nearly $6000 Court cost. He

neglected to order Brisco Bonding Company to refund the

28

$500 that the Petitioner had paid for a criminal bond that

Judge Dailey had revoked.

28. Judge Doran has included in his Court Order for

Petitioner to attend psychiatric counseling. Tennessee

General Assembly has determined that each felon that has

been convicted of any sexual offense may suffer from

psychiatric illness. Tennessee Lawmakers have spelled out

precise medical procedures for the Tennessee Department

of Corrections (TDOC) and/or TDPP to administer medical

supervision of convicted felons for sexual offenses.

A. T. C. A. §38-6-802 Examination Upon Conviction

B. T. C. A. §38-6-803 Certificate for Treatment

C. T. C. A. §38-6-804 Examination Prior to Release

D. T. C. A. §38-6-805 Post-Plea Treatment

29. Judge Doran and/or Shelby Criminal Court have been

clearly in error not to exercise judiciary oversight over

TDPP in respect to Petitioner’s felony conviction. TDPP

probation officers have grossly neglected to administer

29

Court ordered supervision of the Petitioner for psychiatric

counseling.

30. TDPP is unable to furnish Shelby County Criminal

Court any record to show its staff has fulfilled the legal

requirements of §38-6-802 thru §38-6-805.

31. June 3, 1994 Petitioner visited the Social Security

Administration (SSA) to file for his disability benefits.

Petitioner claimed on his application that Shelby County

Criminal Court has violated his Civil Rights to involuntarily

commit Petitioner into MTMHI without proof of a Certificate

of Need.

32. Willie Henry, TDPP probation officer has neglected to

file a Restoration Form for Shelby County Election

Commission to restore Petitioner’s Voting Rights.

33. Attached are two letters dated June 12, 2008 and Nov

22, 2007 from James H. Johnson Shelby County Election

Commission sent to the Petitioner in respect to

reinstatement of Voting Rights.

30

34. Attached is a letter dated August 20, 2007 from Mayor

A C Wharton, Jr. sent to the Petitioner that proves the

Petitioner has contacted Mayor Wharton of to protest unjust

disenfranchisement of his Voting Rights as a U. S. Veteran.

35. Attached is a letter date March 17, 2008 from Brian L.

Kuhn Shelby County Attorney sent to the Petitioner in

respect to Restoration of Voting Right.

36. Attorney Mark S. McDaniel has written a letter dated

November 7, 1994 (See p. 2074) addressed to the

Petitioner. Mark’s letter has enclosed Petitioner’s discovery

information 5 months after Petitioner’s June 2, 1994 felony

conviction. Petitioner alleges that Mark has purposefully

withheld his discovery information to coerce the Petitioner

to enter a guilty plea.

37. Petitioner has filed multiple complaints with the BPR

and/or COJ to investigate his grievances against Judge

Dailey, Judge Lockard, Judge Axley, Attorney Sherry J.

Brown, Attorney McDaniel et al. for ethical misconduct.

Each ethical complaint has been dismissed without any

31

investigation. As a result, the Petitioner had no other choice

but to plead guilty to incest.

32

38. 38. Petitioner motions for Shelby County Criminal

Court to over turn Petitioner’s guilty plea entered for docket

92-09915 on the following:

A. Judge Dailey denied Petitioner to testify at his March 8,

1993 bond hearing

B. D.A. Edgar Peterson introduced an anonymous letter to

revoke bond

C. Judge Dailey revoked Petitioner’s bond without sufficient

evidence

D. Judge Dailey and Lockard failed to prove author of

anonymous letter

E. Judge Dailey and Lockard failed to obtain a Certificate of

Need

F. Judge Dailey and Lockard wrongfully committed

Petitioner to MTMHI

G. Attorney Brown and McDaniel pursued a fraudulent

defense strategy

33

H.Attorney McDaniel withheld discovery evidence from the

Petitioner

I. Judge Doran denied Petitioner right to diversion first-time

felony offense

J. Tennessee lawmakers added probation sentence to

indictment 92-09915

K. MPD has charged Petitioner annual fees to supervise

added probation

L. MPD has harassed Petitioner by enforcing unwarranted

searches

M. MPD has issued false police reports of rape for

indictment 92-09915

N.MPD has withheld legal enforcement of T. C. A. §39-17-

309

O.Tom Hoover has prosecuted docket # 05 03092 ex post

facto

P. Judge Axley has extorted $500 from Petitioner in docket

# 05 03092

X ______________________________ DATE _________________

34

Petitioner

ATTACHMENTSOFFICIAL OFFICE DOCUMENT

Phil Bredesen TN Governor Oct 19, 2007 LetterPam Beck TBI July 31, 2006 Letter

A C Wharton, Jr. Shelby County Mayor

Aug 20, 2007 Letter

Brian L. Kuhn Shelby County Attorney

March 17, 2008 Letter

James H. Johnson Shelby County Election

June 12, 2008 Letter

William L. Gibbons District Attorney General

May 27, 2008 Letter

Mark H. Luttrell, Jr. Shelby County Sheriff

May 1, 2008 Letter

W.W. Herenton Memphis Mayor May 18, 2007 LetterLarry A. Godwin Memphis Police

DirectorMay 5, 2008 Letter

Sgt. L. Pride MPD SOR May 30, 2006 LetterJoseph S. Ozment Ozment Law Firm June 13, 2005 LetterLarry E. Copeland,

Jr.Ozment Law Firm May 20, 2006

LetterLarry E. Copeland,

Jr.Ozment Law Firm Feb 7, 2007 Receipt

Larry E. Copeland, Jr.

Ozment Law Firm No Date Letter (2)

Larry E. Copeland, Jr.

Ozment Law Firm Jan 10, 2008 Letter

Martha A. Jackson Official Court Reporter

Feb 7, 2007 Transcript

Martha A. Jackson Official Court Reporter

Feb 9, 2007 Transcript

W. Fred Axley SCJC Div VI March 26, 2007 Letter

Joe G. Riley TN Court of June 19, 2007 Letter

35

JudiciaryJ. Steven Stafford TN Court of

JudiciaryJune 29, 2007 Letter

James A. Vick TN BPR June 24, 2008 Letter

36