charging that Defendants engaged in an illegal hazardous waste dumping

in the City of Chattanooga and a conspiracy to wrongfully

terminate Plaintiff/Appellant from his employment with Defendant/Appellee

Hydro-Vac Services, Inc.,  and to deprive him of constitutionally

protected rights, in violation of 42 U.S.C. § 1983 & 1985.  When the

investigation of Plaintiff/Appellant's allegations revealed that

Defendant/Appellee Hydro-Vac Services, Inc.  and its owner William

Foxworth had been illegally commingling the wastes of over 80 companies

and had contaminated the unlined Chattanooga Summit Landfill with at least

13 hazardous wastes in huge amounts, the conspiracy  to cover-up the

problem began.  Foxworth had been operating Hydro-Vac Services, Inc. for

over 18 months in direct violation of orders from the Air Pollution Board,

and in direct violation of regulations of the City of Chattanooga, and the

State and Federal environmental protection agencies, when the violations

were discovered.

    Defendant/Appellee, State Solid Waste Manager Guy M. Moose,

conspired  with attorneys William Colvin, Frederick Hitchcock, and James

W. Gentry representing the Appellees herein, to cover-up the facts in this

case and to defraud the Courts and the American Public as to the damage

to the Landfill and the threat to the health and welfare of the general

public.


    When the case came before State Circuit Court Judge Samuel H. Payne,

Plaintiff/Appellant tape recorded a conversation with Judge Payne in order

to prove the overwhelming conspiracy and abuse of the justice system in

Tennessee.  This tape recording and transcript  has been placed before

this Honorable Court in Plaintiff/Appellant's Petition For Writ Of

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