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

March 22, 2002

Chief Gerald Whitman
Denver Police Department
1331 Cherokee Street
Denver CO 80204

Re: DPD "Intelligence" or "Spy" Files

Dear Chief Whitman::

I represent two defendants currently facing charges related to arrests by your intelligence officers. I am confident that your department maintains "spy" files on both individuals. Their names and Denver General Sessions cases are:

Duncan Philp, Case No. 01GS606305, Ctrm 150F;

Richard Stanley, Case No. 01GS606306, Ctrm 151P

I believe that Captain DiManna of the "Intell Bureau" was involved in both cases. I am requesting that you provide me with the intelligence files on both individuals, as I believe there is relevant information in their files which I will need to impeach your officers and defend my clients.

I am also requesting that you provide me with a copy of my own file so that I can ascertain how DPD is dealing with me and with my clients.

Please let me know if you do not intend to furnish the information I am requesting. These court cases will be coming up for trial very soon and I will seek Court intervention should you not furnish what I am seeking.

Regards,

Paul Grant (Signed)