PAUL GRANT
LAWYER-COUNSELOR
6426 S. Quebec Street
Englewood CO 80111
(303) 771-1908 (phone)
(303) 741-5619 (fax)

March 22, 2002

J. Wallace Wortham, Jr. via fax: 720-913-8010
City Attorney's Office
303 W. Colfax Avenue, #500
Denver CO 80204

Re: Denver v. Richard Stanley
Case No. 01GS606306, Ctrm 151P, 4th Discovery Request, DPD Intell Files

Dear Mr. Wortham:

I have submitted three prior written requests for discovery materials to your office in this case. I have yet to be provided Denver Police Department Intelligence files related to my client, Richard Stanley, files which I believe will contain relevant information for his case.

Denver Police Chief Whitman publicly stated earlier this week that he provided a copy of all the so-called "intelligence files", or "spy files," to the City Attorney. I can't see any reason why your office would not provide to me Mr. Stanley's file in conjunction with this case, since I know Intelligence Officers were involved in the arrest, and I am certain that Stanley's intelligence files will contain relevant information, including information relevant to impeaching police witnesses.

Please let me know if your office will obtain and provide to me the requested discovery materials or, if not, why not.

Regards,

Paul Grant (Signed)