IN THE CRIMINAL COURT OF SHELBY COUNTY, TENNESSEE 30TH JUDICIAL DISTRICT AT MEMPHIS

STANLEY GREEN Petitioner, VS. STATE OF TENNESSEE Respondent:

) ) ) ) ) Case No. 92-09915

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. §4030-101 et. seq., or in the alternative construe this motion as a pleading for a Writ of Error Coram Nobis pursuant to T.C.A. §40-26105. In support of this motion, the Petitioner would like to respectfully submit the following statement:

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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 PostConviction 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 diminished or afforded less constitutional protection when

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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 judiciary obligation to exercise oversight over Tennessee

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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 reopen 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 9209915 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.
12. The

City of Memphis Police Department (MPD) Tennessee Sex

Offender Registry (TSOR) serves as his supervisory site.

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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 9209915 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 the 13th Judicial District for the Western Division of Tennessee. Each Disciplinary authority has dismissed investigation.
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16. See

My Paper Trail http://mypapertrail2.underwriterweb.com
A. B. C.

attachment

Court of the Judiciary (See p. 2089-2094) Board of Responsibility (See p. 2075-2088) U.S. District Court (See p. 2111) registered January 1995 with the Tennessee

17. Petitioner

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, 10years 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.
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
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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 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
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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. 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
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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.
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 9209915. 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
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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, high-rise or other available housing for Disabled Veterans. Petitioner’s
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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). Petitioner’s parents have demonstrated outstanding citizenship throughout their 65 plus years city residency.

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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.

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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 Proposal (CHTN62790-043) entitled, Nationwide Alert

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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.

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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. 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

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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 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

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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 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,

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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/congres s/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 instructed to view pornographic

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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 Petitioner to pursue an insanity defense rather than to plead
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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).
16. Public

Defender Sherrye J. Brown had recused herself of

representing Petitioner in lieu of his affidavit against her with
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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 crossexamined 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. A. Dr. Melvin Golden Charter Lakeside Hospital B. Dr. Anne Ayres VA Hospital of Memphis C. Dr. Kent Cox VA Hospital of Memphis
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D. Dr. Terri J. Rau U.T. Medical Group

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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 ownbond 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 telling Petitioner that he would decide the defense strategy to defend his
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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 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
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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 $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.
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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 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
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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.
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.
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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 investigation. As a result, the Petitioner had no other choice but to plead guilty to incest.

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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
H.

Attorney McDaniel withheld discovery evidence from the Petitioner

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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 ______________________________ Petitioner

DATE _________________

ATTACHMENTS
OFFICIAL Phil Bredesen Pam Beck
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OFFICE TN Governor TBI

DOCUMENT Oct 19, 2007 Letter July 31, 2006 Letter

A C Wharton, Jr. Brian L. Kuhn James H. Johnson William L. Gibbons Mark H. Luttrell, Jr. W.W. Herenton Larry A. Godwin Sgt. L. Pride Joseph S. Ozment Larry E. Copeland, Jr. Larry E. Copeland, Jr. Larry E. Copeland, Jr. Larry E. Copeland, Jr. Martha A. Jackson Martha A. Jackson W. Fred Axley Joe G. Riley J. Steven Stafford James A. Vick

Shelby County Mayor Shelby County Attorney Shelby County Election District Attorney General Shelby County Sheriff Memphis Mayor Memphis Police Director MPD SOR Ozment Law Firm Ozment Law Firm Ozment Law Firm Ozment Law Firm Ozment Law Firm Official Court Reporter Official Court Reporter SCJC Div VI TN Court of Judiciary TN Court of Judiciary TN BPR

Aug 20, 2007 Letter March 17, 2008 Letter June 12, 2008 Letter May 27, 2008 Letter May 1, 2008 Letter May 18, 2007 Letter May 5, 2008 Letter May 30, 2006 Letter June 13, 2005 Letter May 20, 2006 Letter Feb 7, 2007 Receipt No Date Letter (2) Jan 10, 2008 Letter Feb 7, 2007 Transcript Feb 9, 2007 Transcript March 26, 2007 Letter June 19, 2007 Letter June 29, 2007 Letter June 24, 2008 Letter

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