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

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

3
 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.

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 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

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 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.

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

6
 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

8
 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 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

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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

14
 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

17
 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

18
 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,

19
 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

21
 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

22
 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

23
 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.

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

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 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

26
 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

27
 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.

28
 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

29
 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.

30
 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.

31
 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

32
 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 _________________

Petitioner

ATTACHMENTS
OFFICIAL OFFICE DOCUMENT
Phil Bredesen TN Governor Oct 19, 2007 Letter
Pam Beck TBI July 31, 2006 Letter
33
 A C Wharton, Jr. Shelby County Aug 20, 2007 Letter
Mayor
Brian L. Kuhn Shelby County March 17, 2008
Attorney Letter
James H. Johnson Shelby County June 12, 2008 Letter
Election
William L. Gibbons District Attorney May 27, 2008 Letter
General
Mark H. Luttrell, Jr. Shelby County May 1, 2008 Letter
Sheriff
W.W. Herenton Memphis Mayor May 18, 2007 Letter
Larry A. Godwin Memphis Police May 5, 2008 Letter
Director
Sgt. L. Pride MPD SOR May 30, 2006 Letter
Joseph S. Ozment Ozment Law Firm June 13, 2005 Letter
Larry E. Copeland, Jr. Ozment Law Firm May 20, 2006 Letter
Larry 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 Feb 7, 2007
Reporter Transcript
Martha A. Jackson Official Court Feb 9, 2007
Reporter Transcript
W. Fred Axley SCJC Div VI March 26, 2007
Letter
Joe G. Riley TN Court of Judiciary June 19, 2007 Letter
J. Steven Stafford TN Court of Judiciary June 29, 2007 Letter
James A. Vick TN BPR June 24, 2008 Letter

34
35