Notice of Intent to Take Deposition

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Impact area
- Criminal Justice
Topic
- Police Accountability
LDF Attorneys
Cooperating Attorneys
Organization
- LDF
Matter
- Garner v. Memphis Police Department
Case
- Garner v. Memphis Police Department
U.S. state
- Tennessee
Collection
- Case Files
Taxonomy
Identifier
- 2550c7db-24a8-f011-bbd3-000d3a151b15

Cite this item

Case Files, Garner Hardbacks. Notice of Intent to Take Deposition, 1976. 2550c7db-24a8-f011-bbd3-000d3a151b15. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/7e7b31ce-7608-42dd-8558-a3b378545ae7/notice-of-intent-to-take-deposition. Accessed February 12, 2026.

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

CLEAMTEE GARNER, 
vs.
MEMPHIS POLICE DEPARTMENT, et al,

CIVIL ACTION 
No. C-75-145

NOTICE OF INTENT TO TAKE DEPOSITION

PLEASE TAKE NOTICE that plaintiff will take the 
deposition upon oral examination pursuant to Rule 30 of the 
Federal Rules of Civil Procedure of T. H. Smith # 7772 and 
S. E. Chambers of the Memphis Police Department, Memphis, 
Tennessee at the offices of Bailey, Higgs & Bailey, Suite 901, 
Tenoke Building, 161 Jefferson Avenue, Memphis, Tennessee, at 
2i00 P.M. on Monday, April 26, 1976, before a Notary Public or 
other qualified officer and deposition shall continue until 
ccmipleted as taking thereof may be from time to time adjourned.

Drew S. Days, III 
10 Columbus Circle 
New York, New York 10019

CERTIFICATE OF SERVICE
I hereby certify that I mailed a copy of the foregoing 

Notice of Intent to Take Deposition to Henry L. Klein, Esq., 
Staff Attorney, City of Memphis, Suite 3500, 100 North Main 
Building, Memphis, Tennessee 38103, on this of April,
1976 by United States mail, postage prepaid.

Drew S. Days, III
Attorney for Plaintiff



\ 4
IN THE UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OP TENNESSEE

CLEAMTBE GARNER.
V0.

MEMPHIS POLICE DEPARTMENT, et al.
CIVIL ACTION 
No. C-75-145

NOTICE OF INTENT TO TAKE DEPOSITION 
PLEASE TAKE NOTICE that plaintiff will taka tha deposition 

upon oral axarnination pursuant to Rule 30 of the Federal Rules 
of Civil Procedure of J. A. Coletta ©f the Memphis Police 
Department. Memphis. Tennessee at the offices of Bailey. Higgs 
& Bailey. Suite 901. Tenoke Building. 161 Jefferson Avenue.
Memphis Tennessee at 9s00 A.M. on Wednesday. May 5. 1976. before 
a Notary Public or other qualified officer and deposition shall 
continue until completed as taking thereof may be from time, j 
time adjourned.

PLEASE TAKE FURTHER NOTICE that the above-named person is 
hereby requested, pursuant to Rule 30(b)(5) F.R.C.P.. to produce 
upon such examination the it«»ns specified in the attached schedule

Drew S. Days. Ill 
10 Columbus Circle 
New York. New York 10019

CERTIFICATE OF SERVICE
I hereby certify that I mailed a copy of the foregoing 

Notice of Intent to Take Deposition to Henry L. Klein. Esq.. 
Staff Attorney. City of Memphis. Suite 3500, 100 North Main 
Building. Memphis. Tennessee 38103, on this o f April,
1976 by United States mail, postage prepaid.

Drew S. Days, III 
Attorney for Plaintiff



Schedule of Items to Be Produced 
at Depoeition of J. A. ColettlT

All firearms performance records of B. R. Hymon # 3441;

All films (and suitable projector for showing) made in 
connection with tests conducted by the Memphis Police 
Department of ammunition and firearms since January 1, 
1973;

All photographs or photographic slides (with suitable 
projector for showing) taken in connection with tests 
conducted by the Memphis Police of ammunition and firearms 
since January 1, 1973;

A copy of the film "Shoot or Don’t Shoot" (and suitable 
projector for showing).



# jgv (

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

CLEAMTEE GARNER, 
vs.

MEMPHIS POLICE DEPARTMENT, et al.
CIVIL ACTION 
No. C-75-145

NOTICE OF INTENT TO TAKE DEPOSITION 
PLEASE TAKE NOTICE that plaintiff will take the deposition 

upon oral examination pursuant to Rule 30 of the Federal Rules of 
Civil Procedure of R. T. Montgomery # 5227, W. G. Ball # 0246 and 
C. A. Russell # 7119 of the Memphis Police Department, Memphis, 
Tennessee at the offices of Bailey, Higgs & Bailey, Suite 901, 
Tenoke Building, 161 Jefferson Avenue, Memphis, Tennessee, at 
4:00 P.M. on Monday, April 26, 1976, before a Notary Public or 
other qualified officer and deposition shall continue until com
pleted as taking thereof may be from time to time adjourned.

PLEASE TAKE FURTHER NOTICE that the above-named persona are 
herriay requested, pursuant to Rule 30(b)(5), F.R.C.P., to produce 
upon such examination the items specified in the attached schedule.

Drew S. Days, III
10 Columbus Circle
New York, New York 10019

CERTIFICATE OF SERVICE
I hereby certify that I mailed a copy of the foregoing 

Notice of Intent to Take Deposition to Henry L. Klein, Esq., 
Staff Attorney, City of Memphis, Suite 3500, 100 North Main 
Building, Memphis, Tennessee 38103, on this T^^^Jay of April, 
1976 by United States mail, postage prepaid.

Drew S. Days, III
Attorney for Plaintiff



i (

Schedule of Items to Be Produced 
at Deposition of R. T. Montgomery 
» 5227, W, G, Ball # 0426 ai^
C.A. Rugsell, # 71I9 :

All photograph* (or copies thereof) at the scene,
739 Volllntine, Memphis, Tennessee on or after October 
3, 1974.

All photographs (or copies thereof) of the deceased 
Edward Eugene Garner taken at the scene of his death, 
739 Vollintine, Memphis, Tennessee or at any other 
location on or after October 3, 1974.

ist' ■



4 #

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

CLEAMTEE GARNER, 
vs.
MEMPHIS POLICE DEPARTMENT, et al.

CIVIL ACTION 
No. C-75-145

NOTICE OF INTENT TO TAKE DEPOSITION

PLEASE TAKE NOTICE that plaintiff will take the 
deposition upon oral examination pursuant to Rule 30 of the 
Federal Rules of Civil Procedure of F. J. Wheeler #9141, J. C. 
Peel # 1525 and G. E. Jordan # 4195 of the Memphis Police 
Department, Memphis, Tennessee at the offices of Bailey, Higgs 
& Bailey, Suite 901, Tenoke Building, 161 Jefferson Avenue, 
Memphis, Tennessee, at lliOO A.M. on Monday, April 26, 1976, 
before a Notary Public or other qualified officer and deposition 
shall continue until ccwnpleted as taking thereof may be from time 
to time adjourned.

Drew S. Days, III
10 Columbus Circle
New York, New York 10019

CERTIFICATE OF SERVICE

I hereby certify that I mailed a copy of the foregoing 
Notice of Intent to Take Deposition to Henry L. Klein, Esq., 
Staff Attorney, City of Memphis, Suite 3500, 100 North Main 
Building, Memphis, Tennessee 38103, on this \!^^Wday of April, 
1976 by United States mail, postage prepaid.

Drew S. Days, III 
Attorney for Plaintiff

D



TOTICE OF IMTENT TO TAKE DEPOSITION ^
PLEASE TAKE NOTICE that plaintiff will take the deposi

tion upon oral examination pursuant to Rule 30 of the Federal :; ‘ -i 
Rules of Civil Procedure of the Custodian Records Relating to 
Citizen Complaints of Police Misconduct, of the Memphis PoliceV^-^;^; 
Department, Memphis, Tennessee at the offices of Bailey, Higgs 
& Bailey, Suite 901, Tenoke Building, 161 Jefferson Avenue,
Memphis, Tennessee, at 9t00 A.M. on Monday, April 26, 1976, 
before a Notary Public or other qualified officer and deposition 
shall continue until completed as taking thereof may be from time 
to time adjourned.

PLEASE TAKE FURTHER NOTICE that the above-mentioned per
son is hereby requested, pursuant to Rule 30(b)(5), F.R.C.P. to 
produce upon such examination the items specified in the attached 
schedule.

Drew s. Days, III
10 Columbus Circle
New York, Now York 10019

CERTIFICATE OF SERVICE
I hereby certify that I mailed a copy of the foregoing 

Notice of Intent to Take Deposition to Henry L. Klein, Esq., 
Staff Attorney, City of Memphis, Suite 3500, 100 North Main 
Building, Memphis, Tennessee 38103, on this day of April,
1976 by United States mail, postage prepaid.

Drew S. Days, III
Attorney for Plaintiff



Schedule of Iteros to Be Produced 
at Deposition of CustodTan, Records 
Relating to Citizen Complaints of 
Police Miaconduct of the Memphiig 
Police Department.

1. All records relating to a complaint lodged by a Lorenzo 
Phillips on March 12, 1974 (your file # 024-74) against 
E, R. Hymon # 3441;

2. All records relating to a complaint lodged by a Roy C. Coin 
on March 15, 1974 (your file # 026-74) against E. R. Hymon 
# 3441.

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Notice of Intent to Take Deposition

Impact area

Topic

LDF Attorneys

Cooperating Attorneys

Organization

Matter

Case

U.S. state

Collection

Taxonomy

Identifier

Cite this item

Copyright notice

Additional info

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