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16. That their have been publicized allegations that, Judge Mctae, is acre conceraed with the political effects of his decisions than the . * law. fee, EX--6. . ° , 17. That the clerk of the court defendant, Pellicctotts, wherein said evidentiary hearing was conducted acted in concert with, Judge ‘icRae, fm declining to prepare and forward tr. material, described in paragraph 1g-b above, to the U.S, sixth circuit thus contributing substantially * to the sixth circuit denying Plaintiff? relief under said evidentiary hearing. - . 18, That defendant, Haile, who was the State's chief counsel in the afore=- mentioned evidentiary hearing, but is now in private practice, has libel- ed Plaintif? by aiding & abetting defendant, MeMilijzen, in McMillian's preparing & authoring the aforenentioned artilce for defendant, TIME. © ‘ke 19. That defendant, NcMillian, inforzed Plaintiff's brather, Jerry Ray, of bis (Meviliten’s) relationship with defendant, Haile. .., 0 - = ve 20. That in 1975 defendant, Haile, appeared with defendant, McHillian, at the Tenneszee State penitentiary--vashvilie Branch--vherein McMillian requested warden, Jones EH, Rose, a personal friend of Haile, to contact ” Plaintirt and ask if he would consent to an interview by, NcMillian. Werden Rose did forward said interview request to Plaintiff which Plaintiff declined and, thereafter, Haile & McMillian viewed the solitary confinanent | building wherein Plaintiff wae housed. <2. That defendant, Haile, while asst. att. gen. for the State of Tenn- ; easee several times publicly criticised court decisions unfevorable to hig " ina soenner guggestizng he wae attespting to intimidate Judges, acta for which he subsequently was di aniased fron the a.G.'s office by the Att~- erney General for the State of Tennessee. 22. That in the January 26, 1976, isaue of TINE magazine (£X—~p) under the title of "The King Assasaination Revisited", defendant, MeMillion, anthored a salicious article subtitled "I'm gonna kil) that nigger King" and alleged aaid subtitle to be a statezent made by Plaintirf. Said article ia littered with deliberate fabrications, and while of a hollywood. sh charagter they are delivered with aealice intent, begining -186- ua at ean *