IN THE CIRCUIT COURT OF SHELBY COUNTY TENNESSEE

STANLEY GREEN

Plaintiff

Vs. Docket No. CF000343.09

___________________

Larry Godwin &

Memphis Police Department (MPD)

Defendant(s)

SECOND INTERROGATORIES ADMISSIONS OF FACTS AND

PRODUCTION OF DOCUMENTS

Comes now, Stanley Green pursuant to Tennessee Rules of Civil

Procedure 33, 34, and 36, and submits the following Second Set

of Interrogatories, Admissions of Facts, and Production of

Documents.

Response to the Interrogatories, Admissions of Facts and

Production of Documents should be made under oath within thirty

(30) days from date of services.

Send requested responses and/or documents as stipulated above

to Stanley Green 1953 Goodhaven Dr. Memphis, TN 38116 for

inspection and copying. Documents produced should include

everything in the possession, custody or control of MPD, and all

those in privity with it, relating to the following requests.

DEFINITIONS AND INSTRUCTIONS:

The following definitions shall apply to each request for

interrogative, production of documents or admission of facts and

are deemed incorporated in each by reference:

A. Admit means to state the truth in clear language

B. Produce means to submit through certified mail

C. Documentation means official police records

D. Possession means in possession of the MPD

E. Custody means under custody of the MPD

F. Control means under the control of the MPD

INSTRUCTIONS

A. Plaintiff requests that each response be preceded by the

identification and verbatim quote of the Interrogatory or

Admission of Fact.
B. Please specify if necessary whether Interrogatories,

Admissions of Facts or Production of Documents may appear

too vague or ambiguous to comply.

C. Provide all related documents in possession, control or

custody of the MPD.

INTERROGATORIES

1. Did Anita Spinetta discuss Stanley Green’s 1994 Shelby

County Criminal Court Judgment Sheet Docket 92-09915 with

Director Godwin?

Response

2. Did Anita Spinetta advise Director Godwin that Shelby

County Criminal Court has convicted the Plaintiff of rape and

incest in respect to Docket 92-09915?

Response

3. Did Anita Spinetta give Director Godwin bad advice by

stating that the Plaintiff has been convicted of rape?

Response

4. Did Anita Spinetta advise Director Godwin that Judge Will

Doran has ordered the Tennessee Division of Probation to

supervise the Plaintiff for six years?

Response
5. Did Anita Spinetta advise Director Godwin that Judge Will

Doran has failed to order the Plaintiff to enroll with

Tennessee Sexual Offender Registry (TSOR)?

Response

6. Did Anita Spinetta advise Director Godwin that the Plaintiff

on June 2, 2000 has fully disposed of his six-year probation

sentence without violations?

Response

7. Did Anita Spinetta advise Director Godwin that T.C.A. 40-39-

201 became effective August 31, 2204 ten years post

Plaintiff’s June 2, 1994 conviction?

Response

8. Did Anita Spinetta advise Director Godwin that any ex post

facto laws passed after June 2, 1994 constitutes an

egregious violation of Plaintiff’s Civil Rights?

Response
9. Did Anita Spinetta advise Director Godwin that Sgt. Gilliam

had acted under color of office by visiting the Plaintiff’s

home on 11/16/2007?

Response

10.Did Anita Spinetta advise Director Godwin that the MPD has

a lawful duty to enforce T.C.A. 39-17-309 Civil Rights

Intimidation to protect the Plaintiff?

Response
 ADMISSIONS OF FACTS

1. Please admit that Anita Spinetta is equally a Co-Defendant of

Larry A. Godwin or Memphis Police Department in respect to

Plaintiff’s general averments.

Response

2. Please admit that Director Godwin has trusted Anita

Spinetta’s legal advice relevant to Judgment Sheet 92-09915

as being reliable or trustworthy.

Response

3. Please admit that Anita Spinetta has misled Director Godwin

to believe that the Plaintiff been convicted of rape relevant

to Judgment Sheet 92-09915.

Response

4. Please admit that Anita Spinetta should explain how or why

she has falsely advised Director Godwin that the Plaintiff has

been convicted of rape?

 Response

5. Please admit that Anita Spinetta should be subject to

disciplinary actions for falsely advising Director Godwin in

respect to Judgment Sheet 92-09915.

Response
PRODUCTION OF DOCUMENTS

1. Please submit any financial receipt paid by the Plaintiff and

collected by the Memphis Police Department to enforce T.C.A. 40-
39-201 under color of office.

2. Please submit Shelby County Criminal Court Order that has

legally justified the Memphis Police Department enforcing
supervision over the Plaintiff post his six-year State Probation. (If
said Court Order is not available, then please explain why not?)

Respectfully submitted

Stanley Green

1953 Goodhaven Dr.

Memphis, TN 38116

(901) 653-6243

CERTIFICATE OF SERVICE

I Stanley Green certify that a true and exact copy of the foregoing
has been served upon Defendants at attorney’s address 125
North Main Street Room 336 Memphis, TN 38103 by U. S. Mail,
First Class postage thereon, this _____Day of April, 2009.

________________________

Stanley Green