Letters Can Be Used for Many of the Same Purposes 
As Motions 
 |  
| 
 This example 
letter of introduction provided an opportunity for either a resolution that 
provided dispositional fairness at an early stage or it would be used to set the 
stage for the beginning of extensive litigation.  This letter, with an unfiled 
draft of the AMENDED AND CONSOLIDATED MOTION SEEKING RELIEF FROM THE DECEPTION, 
INCOMPETENCE, CORRUPTION, CONCEALMENT OF FRAUD AND OTHER MISDEEDS OF THE STATE 
OF TEXAS, was sent to the prosecutor.  A copy of the letter and draft of the 
motion was also sent to the trial judge. (copying the judge is questionable) 
 Local counsel and the prosecutor  in this case had been involved in heated 
disputes about Brady material before we became counsel of record in the case. 
 This letter was sent before we filed any motions, and the letter was the first 
communication we had with the prosecutor or the trial judge.     
  |   
 
 
 
 
 
 
 
 
 
 
 
  
 |  
| 
     In this 
particular case, the end result was a life sentence for the client, a prison 
sentence for the pathologist and a district attorney who entered private 
practice after being voted out of office.   |   
 |  
| 
 The case was 
 resolved only after federal civil litigation which resulted in exposure of the 
wrongdoings of both the pathologist and the district attorney, who was defeated 
in the following election.  The case is written about in Bill Hubbard's 1998 
book, Substantial Evidence.    |   
 
     
  
  
  
  
        
Note: A copy of this letter of 
introduction was sent to the judge.
 
 
 
 
 
 
 
 
 
 
 
  
 
 | 
  | 
  | 
Millard Farmer | 
  |    
  | 
Attorney at Law | 
  |    
  | 
P.O. 
Box 1728 | 
  |    
  | 
Atlanta, GA  30301-1728 | 
  |     
  | 
  March 25, 
1992 | 
  |    
  | 
Randall 
Sherrod, Esq. | 
  |   
  | 
District 
Attorney | 
  |   
  | 
Courts 
Building | 
  |   
  | 
16th Street and 
4th Avenue | 
  |   
  | 
Canyon, Texas 
 79015 | 
  |    
  | 
Re:  State of 
Texas v. Douglas Nathan Palmer,       In the 251st District Court in and for 
  Randall County, No. 6985-C | 
  |    
  | 
Dear Mr. 
Sherrod, | 
  |   
| 
 
   | 
   I am 
enclosing a draft copy of an amended and consolidated motion that we will be 
filing next week in the Palmer case.     We have not met before.  I would like 
to greet you and say hello by this letter before we begin this litigation.  I 
must say to you from the outset that my interest in this litigation is that Doug 
Palmer not be executed by the State of Texas.  | 
 
   |   
| 
 
   | 
   I am very 
open to discussing any differences that exist between the prosecutors and 
counsel for Doug Palmer.  I feel the courtroom is greatly overused in dispute 
resolution.  The purpose of this letter is to resolve as many of our differences 
as possible before the amended and consolidated motion is filed.  | 
 
   |   
| 
 
   | 
   Please give 
me or anyone at my office, in the event of my absence, a call any time Thursday 
or Friday.  If you prefer, my fax number is (404) XXXXXXX.  I will be available 
to meet with you or anyone from your office at any location in Texas anytime on 
Monday, March 30.  We can then discuss any inaccuracies or differences about the 
facts in the amended and consolidated motion; additionally, we can  discuss 
differences about the law and any other matter that could resolve our 
differences before or without the April 2 hearing.  We will change anything that 
is wrong before we file the amended and consolidated motion.  | 
 
   |   
| 
 
   | 
   I hate to end 
what is intended as a friendly letter with a stern ending, however, I must say 
if you wish to continue stonewalling counsel for the defense about these autopsy 
problems, we will litigate that stonewalling as well as the issues.  | 
 
   |   
| 
 
   | 
   Please accept 
this letter as an offer for a friendly and open beginning on my part and a new 
beginning to the end of this case on the part of everyone else.  | 
 
   |   
| 
 
   | 
   Give us a 
call to arrange a time and location for a meeting with Bill and me to correct 
any misunderstanding about the subject of this issue and we will be off to a 
good start.  We need to talk before we file the amended and consolidated motion 
on Tuesday.  | 
 
   |   
| 
 
   | 
   
                                 Sincerely,  | 
 
   |   
| 
 
   | 
   
                             s/ Millard Farmer  | 
 
   |   
| 
 
   | 
   cc: Honorable 
Patrick A. Pirtle      | 
 
   |   
   |