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JOHN D. LEE II, and for all
Defendant-Appellant-Counterclaimant John Lee, pro se and in forma pauperis ("Petitioner"), propounds the following Interrogatories and Requests to Produce to the Respondents, employees of City of Knoxville Municipal Corporation ("Corporation"), to be answered fully, in writing, under oath within thirty (30) days of service, and in accordance with Rules 1, 26, 33 and 34 of the Tennessee Rules of Civil Procedure (TRCP), notwithstanding Local Rule 5 limits to 30 questions without prior leave of the Court. Unless otherwise indicated, these interrogatories refer to the time, place and circumstance of the occurrence mentioned or complained of in the pleadings. "You" and "your" refer to the respondents and any agents of the respondents. If you object to answering any interrogatory, state the legal grounds for the claimed objection in sufficient detail to permit the Court to adjudicate the validity of the claim or objection, and identify all documents which relate to the information requested. INTERROGATORIES
1. How did Richard Graham ("Complainant #1"), Wayne Bell ("Complainant #2"), and John Rossen ("Complainant #3"), comply with statutes, court rules and ordinances regarding proof and service of notice(s) and process, and for sworn affidavit(s) of complaint(s) in the "parking ticket(s)" they filed against Petitioner, before, during and after the bench trial, ex parte hearing and final judgment by Corporation's Department of Court? ANSWER:
2. What procedures and evidence did Complainant #1, Complainant #2, and Complainant #3 use determine what traffic and parking ordinances were in effect, what signs were installed, and what property boundaries existed, at the time and location of their multiple "complaints" against Petitioner, on multiple dates, before, during and after the bench trial, ex parte hearing and final judgment by Corporation's Department of Court? ANSWER:
3. Who was assigned with Complainant #1, and who was his immediate supervisor, on the date he filed his original complaint against Petitioner? ANSWER:
4. What are the names, addresses and telephone numbers of the persons who made the videotape entered into evidence by Ryan Flores at bench trial in Department of Court, currently on appeal to the Court, pertaining to Complainants' prosecutions of this matter? ANSWER:
5. What are the names, addresses and telephone numbers of the employee or employees of Corporation who, in December of 1999, committed the crime of hit-and-run and damaged a vehicle owned by Petitioner and parked at same location as Petitioner's vehicle involved in the current dispute, for which Corporation's Department of Risk Management paid Petitioner's claim, and what criminal charges were filed against those individuals, and why was no "parking ticket" issued against Petitioner? ANSWER:
6. What are the names, addresses and telephone numbers of the employee or employees of Corporation who, on January 15, 2000, reported an oral complaint of "blocking a street" to Emergency E911 Dispatchers Angela Johnson and/or Hea D'Allesandro, involving a vehicle owned by Petitioner and parked at same location as Petitioner's vehicle involved in the current dispute? ANSWER:
7. What was the date, and what are the names, addresses and telephone numbers of the individuals who requested or ordered Corporation's Department of Engineering to install signs advising, "Do Not Block Alley", adjacent to Petitioner's parking space and along side the street involved in the current dispute, and why does Department of Engineering refuse Petitioner's verbal and written requests to conduct an engineering survey and install signs for "Private Parking", "No Parking", One Way", "Do Not Enter", and for the historic street name of "Fire Street"? ANSWER:
8. What was the date in 2001, and what are the names, addresses and telephone numbers of the individuals who requested, ordered, inspected and/or approved the installation of a "fire-suppression sprinkler system drain plug" (or similar jargon), located on private property adjacent to Petitioner's parking space and along side the street involved in the current dispute? ANSWER:
9. How much money did Corporation's former "court clerk" and/or "court administrator", Michael Martin, steal, embezzle, and/or extort during his tenure at Department of Court, and from whom and/or from what sources, and was this stolen money recovered in restitution, and were criminal charges filed, and if so, what was the outcome? ANSWER:
10. What changes in rules, regulations, policies or practices were implemented after the "firing", or "forced resignation in lieu of firing", of Michael Martin and/or after Corporation's self-audit of Department of Court? ANSWER:
11. What are Department of Court's "bonus paycheck" scheme and how are/were these bonus paychecks calculated, and which of Corporation's and/or Department of Court's employees were paid these salary increases in each of the past six years? ANSWER:
12. Where are the Department of Court's and Better Building Board's public dockets kept, and what are the rules, regulations, policies and/or procedures for citizens to view these public dockets? ANSWER:
13. In policy and practice, how does Corporation's departments "serve process" and "notice" for parking tickets and/or complaints as required by Tennessee Rules of Court, Tennessee Code and Corporation's ordinances, and how does it record "waiver of service"? ANSWER:
14. What are the minimum number of "parking tickets" required to be issued daily for Department of Police cadets and officers, including for those assigned to downtown and to public streets within boundary of University of Tennessee Knoxville Municipal Corporation, and what are the minimum number of citations and/or "contacts" required to be issued daily by Department of Police officers and Department of Development Codes Enforcement employees? ANSWER:
15. State the names, telephone numbers, addresses and/or last known telephone numbers and/or addresses and places of employment of all persons who have knowledge of any facts or who allege knowledge of any facts pertaining to the allegations made in complaint, answer or counterclaim or amendments. ANSWER:
16. State the names, telephone numbers, addresses and/or last known telephone numbers and/or addresses and places of employment of all persons whom you intend to call as witnesses at trial, including the nature of their testimony. ANSWER:
17. State the name, address, and telephone number of each and every expert witness which you have consulted and/or contracted with, in connection with this litigation and indicate which experts you do and do not intend to call as witnesses in the instant litigation and, identify all documents, writings, videotapes, audiotapes or other tangible evidence which you have furnished to expert witnesses you intend to call as witnesses and describe in detail any tests, simulations or calculations performed by said experts. ANSWER:
18. State the name, title, address and telephone number(s) of all persons assisting in the answering of these Interrogatories. ANSWER:
REQUESTS TO PRODUCE 1. Please produce copies of all "parking tickets" issued by Richard Graham during his career, up to and including the date he filed his complaint against Petitioner. Please produce the videotape, with audio track, from his patrol car from that 24-hour period, including a minimum of his entire shift on that date, and the repair log and/or repair orders for his vehicle applicable to that date. RESPONSE:
2. Please include the videotape, with audio track, taken of said street on approximately January 2001, as displayed in evidence during the bench trial in Department of Court in said case. Please include the names of the individuals who participated in the making of said videotape. Please produce the repair logs and orders for the vehicle and video equipment applicable to that date. RESPONSE:
3. Please produce all "traffic tickets" issued by Bradley Anders on the day he issued a traffic citation to Petitioner. Please include the entire videotape, with audio track, including a minimum of his entire shift on that day. Please produce all notes taken in relation to said traffic citation. Please produce the repair logs and orders for his vehicle and video equipment applicable to that date. RESPONSE:
4. Please produce all "traffic or parking tickets" issued by Ryan Flores on January 15, 2000, and/or on his shift when he and others ordered the seizure of Petitioner's vehicle. Please produce the parking citation issued in that incident. Please produce the videotape, with audio track, of said incident, including a minimum of his entire shift on that day. Please produce the repair logs and orders for his vehicle and video equipment applicable to that date. RESPONSE:
5. Please produce the videotape from Shawna Williams' vehicle on January 15, 2000, including her entire shift when she and others ordered the seizure of Petitioner's vehicle. Please produce the repair logs and orders for her vehicle and video equipment applicable to that date. RESPONSE:
6. Please produce all correspondence and reports regarding the criminal and/or civil allegations against Michael Martin, specifically correspondence involving Michael Kelly and John Rossen. RESPONSE:
7. Please produce the Corporation's "audit(s)" of Department of Court, conducted after the firing of Michael Martin. Please produce the Department of Police Internal Affairs file in said investigation. RESPONSE:
8. Please produce the "court dockets", "tow-in lists", "motor vehicle title applications", "motor vehicle bills of sale", and accounts for Department of Court, Better Building Bureau, Department of Finance and any other department, regarding filing and disposition of all "parking tickets", all "vehicle impoundments" for "parking tickets", and all "vehicle forfeitures" for "parking tickets". RESPONSE:
9. Please produce the "Local Rules of Court" for Corporation's Department of Court and Better Building Board. RESPONSE:
10. Please produce the "citation records" of Department of Police and Department of Development Codes Enforcement, for the past six years, approximately 125,000 citations per year, including 50,000 annual "misdemeanor" citations and 75,000 annual "parking tickets". RESPONSE:
11. Please produce the accounts and contracts pertaining to "parking meters", within the past six years. RESPONSE:
12. Please produce copies the names, addresses and telephone numbers of every "cadet" employed by Department of Police and assigned to "parking ticket patrol" (or also known as any other name or title), during the past six years. RESPONSE:
13. Please produce the Corporation's rules and codes pertaining to "parking clearances", "set backs", and/or "easements" near the installation of a "fire-suppression sprinkler system drain plug" (or similar jargon), located on private property? RESPONSE:
14. Please produce work orders, building permits and building inspection forms pertaining to the "fire-suppression sprinkler system drain plug" (or similar jargon), located on private property adjacent to Petitioner's parking space in the year 2001, and along side the street involved in the current dispute. RESPONSE:
15. Please produce the videotape and transcript from the last public hearing, in year 2000, regarding Department of Police's reaccreditation by Commission on Accreditation for Law Enforcement Agencies, Inc. (CALEA). Please produce a copy of the Corporation's contract with CALEA. RESPONSE:
16. Please produce all rules, regulations, general orders, policies, and memorandums pertaining to Department of Police. RESPONSE:
17. Please produce all files alleging "retaliation" against "civilian" journalists and/or "civilian political enemies", from Department of Police Internal Affairs and/or Police Advisory and Review Committee (PARC), or from any other department or agency. RESPONSE:
18. Please produce the personnel and payroll records, Internal Affairs and PARC complaint files, Department of Law investigation or audit files, federal income tax returns, banking statements of Richard Graham for the past six years, and his cell phone records for the date of his complaint against Petitioner. RESPONSE:
19. Please produce the personnel and payroll records, Internal Affairs and PARC complaint files, Department of Law investigation or audit files, federal income tax returns, banking statements, of Shawna Williams for the past six years. Please produce her cell phone records for the date of Complainant #1's complaint against Petitioner, and for the date of Ryan Flores' complaint(s) and seizure of Petitioner's vehicle on January 15, 2000. RESPONSE:
20. Please produce the personnel records, payroll records, Internal Affairs and PARC complaint files, Department of Law investigation or audit files, federal income tax returns and banking statements of Wayne Bell, for the past six years. RESPONSE:
21. Please produce the personnel and payroll records, Internal Affairs and PARC complaint files, Department of Law investigation or audit files, Criminal Intelligence Unit investigation files, Supreme Court Board of Professional Responsibility and Bar Association complaint files, federal income tax returns, and banking statements of John Rossen, for the past six years. RESPONSE:
22. Please produce the personnel and payroll records, Internal Affairs and PARC complaint files, Department of Law investigation or audit files, Criminal Intelligence Unit investigation files, Criminal Investigations Unit files, federal income tax returns, and banking statements of Victor Ashe for the past six years. RESPONSE:
23. Please produce the personnel and payroll records, Internal Affairs and PARC complaint files, Department of Law investigation or audit files, federal income tax returns, and banking statements of Michael Martin for the past six years. RESPONSE:
24. Please produce the personnel and payroll records, and banking statements of current clerk of Department of Court, "Dotti" Martin for the year 2001. RESPONSE:
25. Please produce the personnel and payroll records, Internal Affairs and PARC complaint files, Department of Law investigation or audit files, Criminal Intelligence Unit investigation files, federal income tax returns, and banking statements of Phil Keith for the past six years, both personal and business, and all contracts he and/or his business(es) held with the Corporation during past six years. RESPONSE:
26. Please produce the personnel and payroll records, Internal Affairs and PARC complaint files, Department of Law investigation or audit files, federal income tax returns, and banking statements of Ed Cummings for the past six years. RESPONSE:
27. Please produce the personnel and payroll records, Internal Affairs and PARC complaint files, Department of Law investigation or audit files, homicide and/or shooting and/or "use of force" investigation records, federal income tax returns, and banking statements of Bob Wooldridge for the past six years. RESPONSE:
28. Please produce the personnel and payroll records, Internal Affairs and PARC complaint files, Department of Law investigation or audit files, federal income tax returns, and banking statements of Mark Pressley for the past six years. RESPONSE:
29. Please produce the personnel and payroll records, Internal Affairs and PARC complaint files, Department of Law investigation or audit files, federal income tax returns, and banking statements of Ricky Ferguson for the past six years. RESPONSE:
30. Please produce the personnel and payroll records, Internal Affairs and PARC complaint files, Department of Law investigation or audit files, federal income tax returns, and banking statements of Bradley Anders for the past six years. RESPONSE:
31. Please produce any and all Department of Police "criminal intelligence files" and/or "criminal investigation files" and/or "surveillance files" and/or any similar "files" that mention Petitioner, either by name or by code, or by any allegedly "subversive group" that Petitioner was allegedly associated with, whether such files are stored on Corporation's property or stored on personal property. RESPONSE:
32. Please produce any and all Department of Police "criminal intelligence files" and/or "criminal investigation files" and/or "surveillance files" and/or any similar "files" that mention Jimmy Rippon and Charles Daniel "Danny" Gray, as well as any Department of Police employees who associated with these individuals, whether such files are stored on Corporation's property or stored on personal property. RESPONSE:
33. Please produce complete telephone logs and transcripts from "City Watch System", operated by Department of Police Crime Analysis Unit, that included four telephone calls to Petitioner's unlisted number, utilizing prerecorded transmissions from Phil Keith and Victor Ashe. RESPONSE:
34. Please produce any and all complaints by Corporation's employees filed against Phil Keith and Victor Ashe regarding "political retaliation" and/or "whistleblower retaliation" and/or "stalking", including complaints alleging threats or acts of physical violence. RESPONSE:
35. Please produce all investigative files involving the homicide of Department of Police Officer Mark Anthony Williams, which occurred on July 7, 1989. RESPONSE:
Respectfully submitted, ____________________ John D. Lee II, pro se and in
forma pauperis
CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and exact copy of this pleading has been served upon counsel for all parties at interest in this case by delivering a true and exact copy of said pleading to the offices of said counsel, or by placing a true and exact copy of said pleading in the United States Mail, addressed to said counsel at his office, with sufficient postage thereon to carry it to its destination. City of Knoxville Municipal Corporation
This ______ day of ____________, 2001. _________________________
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