Defendant's Response and Objection to Plaintiff's First Request for Production of Documents

    i^hs

IN THE UNITED STATES DISTRICT COURT 
FOR THE WESTERN DISTRICT OF TENNESSEE 

WESTERN DIVISION

CLEAMTEE GARNER, father and 
next of kin of EDWARD EUGENE 
GARNER, a deceased minor.

Plaintiff,
VS.
MEMPHIS POLICE DEPARTMENT;
CITY OF MEMPHIS, Tennessee; 
WYETH CHANDLER, Mayor of 
Memphis; JAY W. HUBBARD, 
Director of Police of Memphis, 
and E. R. HYMON, Police Officer 
of the City of Memphis,

Defendants.

X
X
X
X
X
X
X
X
X

CIVIL ACTION 
No. C-75-145

DEFENDANT'S RESPONSE AND OBJECTION TO 
PLAINTIFF'S FIRST REQUEST FOR 

PRODUCTION OF DOCUMENTS

COME NOW the Defendants, Memphis Police Department, City 
of Memphis, Tennessee, Wyeth Chandler, Mayor of Memphis, Jay W. 
Hubbard, Director of Police of Memphis, and E. R. Hymon, Police 
Offi.cer of the City of Memphis, and in response and in objection 
to Plaintiff's First Request For Production Of Documents, state 
as follows:

1. Defendants object to producing material requested 
in Item 1, Page 2 of Plaintiff's Request on the grounds that 
the investigation of the Memphis Police Department on or about 
October 3, 1974, is privileged.

2. Defendants object to producing the material requested 
in Item 2, Page 2 of Plaintiff's Request on the grounds that the 
personnel file on Defendant, E. R. Hymon, is privileged and further
that said file is immaterial and irrelevant to this cause of 
action.

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3. Defendants object to producing the material requested 
in Item 3, Page 2 of Plaintiff's Request on the grounds that the 
directives referred to are privileged and further that they are 
not material or relevant to this cause of action.

4. Defendants object to producing the material requested 
in Item 4, Page 2 of Plaintiff's Request on the grounds that the 
directives referred to are privileged and further that they are 
immaterial and irrelevant to this cause of action.

5. Defendants object to producing the material requested 
in Item 5, Page 3 of Plaintiff's Request on the grounds that it
is too vague, too broad, privileged and further that it is irrelevant 
and immaterial to this cause of action.

6. Defendants object to producing the material requested 
in Item 6, Page 3 of Plaintiff's Request on the grounds that this 
information is privileged and the request is too broad.

7. Defendants object to producing the material set out 
in Item 7, Page 3 of Plaintiff's Request on the grounds that it 
is too broad.

8. Defendants object to producing the material requested 
in Item 8, Page 3 of Plaintiff's Request on the grounds that it
is too broad and further that it is immaterial and irrelevant in 
this cause of action.

9. Defendants object to producing the material set out 
in Item 9, Page 3 of Plaintiff's Request on the grounds that it 
is privileged and further that it is immaterial and irrelevant 
to this cause of action.

10. Defendants object to producing the material set out 
in Item 10, Page 3 of Plaintiff's Request on the grounds that it is 
privileged and further that it is immaterial and irrelevant to this 
cause of action.

11. Defendants object to producing the material set out 
in Item 11, Page 3 of Plaintiff's Request on the grounds that it is

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privileged and that it is immaterial and irrelevant to this cause 
of action.

12. Defendants object to producing the material set out 
in Item 12, Page 3 of Plaintiff's Request on the grounds that it 
is privileged, too broad, and further that it is irrelevant and 
immaterial to this cause of action.

13. Defendants object to producing the material set out 
in Item 13, Page 3 of Plaintiff's Request on the grounds that it 
is privileged, too broad, and further that it is irrelevant and 
immaterial to this cause of action.

14. Defendants object to producing the material set out 
in Item 14, Page 4 of Plaintiff's Request on the grounds that it 
is too broad, it is privileged, and further that it is immaterial 
and irrelevant to this cause of action.

15. Defendants object to producing the material set out 
in Item 15, Page 4 of Plaintiff's Request on the grounds that it 
is immaterial and irrelevant to this cause of action.

16. Defendants object to producing the m.aterial set out 
in Item 16, Page 4 of Plaintiff's Request on the grounds that it 
is privileged, too broad, and further that it is immaterial and 
irrelevant to this cause of action.

17. Defendants object to producing the material set out 
in Item 17, Page 4 of Plaintiff's Request on the grounds that it 
is privileged, and immaterial and irrelevant to this cause of 
action.

Dated the / A day of November, 19 75,

Henry L. Klein
Staff Attorney, City of Memphis 

Attorney for Defendants 
Suite 3500, 100 North Main Bldg. 

Memphis, Tennessee 38103

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