Memo from Days to Thibodeaux Re: Analysis of Defendants' Answers

Working File
December 31, 1975

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  • Case Files, Garner Working Files. Memo from Days to Thibodeaux Re: Analysis of Defendants' Answers, 1975. 2b5fbaa2-33a8-f011-bbd3-000d3a53d084. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/b7e56342-52ac-49ac-bd6a-d49e1afff256/memo-from-days-to-thibodeaux-re-analysis-of-defendants-answers. Accessed November 11, 2026.

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    M E M O R A N D U M

TO: DREW S. DAYS, III
FROM: GENE THIBODEAUX
RE: ANALYSIS OF DEFENDANTS' ANSWERS TO PLAINTIFF'S

FIRST SET OF INTERROGATORIES IN GARNER v. MEMPHIS 
POLICE DEPT., ET AL.

DATE: December 31, 1975

Defendant Wyeth Chandler, Mayor of Memphis, Tennessee 
INTERROGATORY NO. __COMMENTS

1
2
3

Answer satisfactory.
Answer satisfactory.
.3(b) asked for the Mayor's 
particular responsibilities 
and authority with respect to 
Memphis' Police Dept. Al­
though he specifically mentioned 
responsibility for the appoint­
ment of the Director of Police, 
the remainder of his response 
stated only that he had "general 
authority" over the police 
department, without attempting 
to specifically delineate the 
extent to which this "general 
authority extends.

4 Answer satisfactory.
5 Answer satisfactory.
6 Answer satisfactory.
7 Answer satisfactory.
8 Answer satisfactory.
9 1 Answer satisfactory.
10 Answer satisfactory.
11 Answer satisfactory.
12 Answer satisfactory.
13 Answer satisfactory.
14 Answer satisfactory.
15 Answer satisfactory.
16 Answer satisfactory.
17 Answer satisfactory.
18 Answer satisfactory

-Continued-



Drew S . Days, III
December 31, 1975
Page Two

INTERROGATORY NO,
19
20 
21 
22
23
24
25

COMMENTS

26
27

Answer satisfactory.
Answer satisfactory.
Answer satisfactory.
Answer satisfactory.
Answer satisfactory.
Answer satisfactory.
Answer unsatisfactory & evasive.
In response to the substance 
of defendant Chandler's expressed 
support on the use of lethal force, 
the answer inartfully asserted 
that on January 19, 1972 Mayor 
Chandler issued a statement concern­ing an incident involving members 
of the Memphis Police Dept. No 
mention is made as to what was 
communicated, the details of the 
precipitating incident, etc.
This statement was communicated to 
the press on January 19, 1972. There­
fore, in lieu of compelling a more 
complete response from Chandler, a 
copy of this statement can be obtain­
ed from the local press or from the 
Mayor's office which has a copy of 
Chandler's statement.
Answer satisfactory.Answer satisfactory.

Defendant E. R. Hymon - Police Officer
1
2
3
4
5
6
7
8 
9

10
11

Answer
Answer
Answer
Answer
Answer
Answer
Answer
Answer
Answer
Answer
Answer

satisfactory. 
satisfactory. 
satisfactory. 
satisfactory. 
satisfactory, 
satisfactory. 
satisfactory. 
satisfactory. 
satisfactory, 
satisfactory. 
satisfactory.

-Continued-



Drew S. Days, III
December 31, 1975Page Three

INTERROGATORY NO, COMMENTS

12
13
1415
16 
17

18
19
20 
21 
22
23
24
25
26

27
28
29
30
3132
33
34
35
36
37
38

Answer satisfactory.
Answer satisfactory.
Answer satisfactory.
Answer satisfactory.
Answer satisfactory.
Answer insufficient. Defendant 
admits being a defendant in a 
prior lawsuit charging him with 
abuse of authority, but does 
not provide the designation of the 
court involved, the name of the 
complaint, or the termination date 
of the proceedings.
Answer
Answer
Answer
Answer
Answer
Answer
Answer
Answer
Answer

satisfactory, 
satisfactory, 
satisfactory. 
satisfactory. 
satisfactory. 
satisfactory. 
satisfactory, 
satisfactory. 
satisfactory.

Nos. 25 & 26 answers were "I do not 
know" in response to whether the 
defendant and/or his employer were 
insured against judgments of personal 
liability arising from the discharge 
of his official duties. Smacks of 
evasion.
Answer
Answer
Answer
Answer
AnswerAnswer
Answer
Answer
Answer
Answer
Answer
Answer

satisfactory. 
satisfactory, 
satisfactory, 
satisfactory. 
satisfactory, satisfactory, 
satisfactory, 
satisfactory. 
satisfactory, 
satisfactory, 
satisfactory. 
satisfactory.

-Continued-



Drew S. Days, III
December 31, 1975
Page Four

INTERROGATORY NO.
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59

COMMENTS
Answer
Answer
Answer
Answer
Answer
Answer
AnswerAnswer
Answer
Answer
Answer
Answer
Answer
Answer
Answer
Answer
Answer
Answer
Answer
Answer
Answer

satisfactory. 
satisfactory. 
satisfactory, 
satisfactory, 
satisfactory, 
satisfactory. 
satisfactory. satisfactory, 
satisfactory. 
satisfactory. 
satisfactory, 
satisfactory. 
satisfactory. 
satisfactory. 
satisfactory. 
satis factory. 
satisfactory. 
satisfactory, 
satisfactory. 
satisfactory, 
satisfactory.

Defendant,Jay W. Hubbard, Director of Memphis Police Depart­
ment, has not answered the interrogatories directed to him. 
Reasons for his neglect are not indicated by his attorney.

GT: jrm

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