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Motion To Suppress Fulton County Grand Jury Report
Motion To Suppress Fulton County Grand Jury Report
HN OR
IN THE SUPERIOR COURT OF FULTON COUNTY = +++ HV
STATE OF GEORGIA
INRE: SPECIAL PURPOSE ) CaseNo.:2022-EX-000034FILED IN OFFICE
GRAND JURY ) =
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MOTION TO QUASH THE SPECIAL PURPOSE GRAND JURY REPORT. TO
PRECLUDE THE USE OF ANY EVIDENCE DERIVED THEREFROM, AND TO
RECUSE THE FULTON COUNTY DISTRICT ATTORNEY'S OFFIC]
Comes now, President Donald J. Trump, by and through undersigned counsel and files
this Motion to Quash the Special Purpose Grand Jury Report and Preclude any State prosccuing
agency from presenting or utilizing any evidence or testimony derived by the Special Purpose
Grand Jury (hereinafter “SPGJ) in the above-referenced matter. Movant additionally requests
that the District Attorneys Office be disqualified from any further involvement in this matter.
“This motion is based on the Fifth and Fourteenth Amendments to the United States Constitution
and Ga. Const. Art. 1,§ I, Paras. 1 and XVI, and all other applicable federal and state laws."
By agreementofthe Fulton County Superior Court bench, Chief Judge Christopher
Brasher authorized the impaneling of the special purpose grand jury, assigned its supervision to
Judge Robert McBurney (hereinafter “Supervising Judge”), and the SPGI was subsequently
dissolvedon January 9, 2023. Because this motion raises issues as to the governanceofthe SPGJ
and the proprietyofthe Supervising Judge’s conduct, Movant respectfully requests this motion
be heard by the judicial officer responsible for impancling the SPGJ, theChief Judge, or a duly
assigned Fulton County Superior Court judge other than the Supervising Judge. Undersigned
Counsel requests a hearing on the matters set forth below.
2
i. The FCDA’s Statementsto the Press Violate Prosecutorial
Standards and Constitute Forensic Misconduct.....................37
i . The FCDA’ Online Activity Violates Prosecutorial Standards
and Creates the Appearanceof IMPIOPHEty..............-ver--rc......39
Vv. "THE PUBLIC COMMENTS MADE BY THE FOREPERSON AND GRAND
JURORS REVEAL THAT THE GRAND JURY PROCEEDING WAS TAINTED
BY IMPROPER INFLUENCES, INCOMPLETE OR INACCURATE
INSTRUCTIONS, AND UNCONSTITUTIONAL INFERENCES.....................43
3
INDEX OF EXHIBITS
‘Exhibit 1: January 24, 2021 Order Approving Request for Special Purpose Grand Jury, In re 2
May 2022 Special Purpose Grand Jury, Case No. 2022-EX-000024 (Fulton Co. Sup. Court).
Exhibit 2: January 20, 2021 Letter Requesting Special Purpose Grand Jury.
Exhibit 3: Transcriptof January 24, 2023 Special Purpose Grand Jury Hearing
before the Honorable Robert C.I. McBurney, Atlanta Georgia, In re 2 May 2022
Special Purpose Grand Jury, Case No. 2022-EX-000024 (Fulton Co. Sup. Cour).
Exhibit 4: July 25, 2022 Order Disqualifying District Attomey’s Office as to Senator Jones
Only, In re 2 May 2022 Special Purpose Grand Jury, Case No. 2022-EX-000024 (Fulton Co.
Sup. Court).
Exhibit 5: List of Fulton County District Attomey’s Media Appearances and Social Media Posts.
Exhibit 6: January 9, 2023 Order Dissolving Special Purpose Grand Jury and
Setting Hearing on Publication, In re 2 May 2022 Special Purpose Grand Jury,
Case No. 2022-EX-000024 (Fulton Co. Sup. Court).
Exhibit 7: February 13, 2023 Order Re: Special Purpose Grand Jury's Final Report, In re 2 May
2022 Special Purpose Grand Jury, Case No. 2022-EX-000024 (Fulton Co. Sup. Cour).
Exhibit 10: August 29, 2022 Order Denying Motion to Quash (Governor Kemp), In re 2 May
2022 Special Purpose Grand Jury, Case No. 2022-EX-000024 (Fulton Co. Sup. Court).
Exhibit 11: TranscriptofAugust 25, 2022 Special Purpose Grand Jury Hearing ‘
4
before the Honorable Robert C.1 McBurney, Atlanta Georgia, In re 2 May 2022
Special Purpose Grand Jury, Case No. 2022-EX-000024 (Fulton Co. Sup. Court)
Exhibit 12: Transcriptof July 25, 2022 Special Purpose Grand Jury Hearing
before the Honorable Robert C.1. McBurney, Atlanta Georgia, In re 2 May 2022
‘Special Purpose Grand Jury, Case No. 2022-EX-000024 (Fulton Co. Sup. Court).
Exhibit 13: August 25, 2022 Order Denying Motion to Reconsider Disqualification Request, In
re 2 May 2022 Special Purpose Grand Jury, Case No. 2022-EX-000024 (Fulton Co. Sup. Cour).
Exhibit 14: July 11, 2022 Certificate ofMaterial Witness Pursuant to the Uniform Act to Secure
the Attendance of Witnesses from Without the State, Codified in the Stateof Georgia as OCGA
24-13-90etseq (Lindsey Graham), In re 2 May 2022 Special Purpose Grand Jury, Case No.
2022-EX-000024 (Fulton Co. Sup. Court).
Exhibit 15: August 25, 2022 Certificateof Material Witness Pursuant to the Uniform Act to
Secure the AttendanceofWitnesses from Without the State, Codified in the StateofGeorgia as
OCGA 24-13-90 et seq (Mark Meadows), In re 2 May 2022 Special Purpose Grand Jury, Case
No. 2022-EX-000024 (Fulton Co. Sup. Court).
Exhibit 16: January 16, 2023 Ordering Entering Portions of Special Purpose Grand Jury's Final
Report into Court Record, In re 2 May 2022 Special Purpose Grand Jury, Case No. 2022-EX-
000024 (Fulton Co. Sup. Court).
5
1 INTRODUCTION
On January 24, 202, theChief Judge of the Fulton County Superior Court entered an
order approving therequestmade by the Fulton County District Attorneys Office (hereinafter
the “FCDA’s Office”) to impanela special purpose grandjury pursuant to O.C.G.A. § 1512-100
et. seq. Ex. 1. The orderofthe Court merely echoed the recitation of need outlined by the
FCDA’s Office in their letterto the Court which specified:
[A] special purpose grandjury [should] be impaneledfor the purposeof investigating
thefacts and circumstances relating directly or indirectly topossible attempts to disrupt the
lawful administrationof the 2020 elections in the State ofGeorgia. Ex. 2.
‘The letter informed the Court that this rarely used investigative body was necessary
because the FCDA’s Office anticipated that the investigation would be a lengthy, complex
process which aregular sitting grandjury wouldn't be able to complete in addition to their
regular duties. Jd. In the letter, the FCDA’s Office made it abundantly clear that they understood
that this SPGY would be without authority to retum an indictment. Jd.
‘The laws that authorized this special purpose grand jury have existed in the Georgia Code
since 1974 but have rarely been utilized and even more rarely litigated. The statutes themselves
are vague and have left much to interpretation; further, the case law regarding the process and
functionofthe special purpose grand jury is similarly scant, unclear and sometimes
contradictory. This is the framework within which the FCDA’s Office has chosen to undertake
this investigationof undoubtedly historic and national significance. This is the framework which
has been revealed through this process to be erroneous and, more importantly, unconstitutional.
6
For approximately eight months, the SPGY met at the directionof the FCDA's Office.
Pursuant to the impaneling order, the Supervising Judge was tasked with overseeing and
assisting the SPGJ as well as charging seid grandjury and receiving its reports. Ex. 1. The SPGJ
considered evidence and heard from over 75 witnesses all within the wallsofthe Fulton County
Justice Center. Ex. 3 at 6 (special purpose grand jury heard testimony from 75 witnesses). Over
those eight months, movant President Donald J. Trump remained a non-witness as he was never
subpoenaed nor asked to testify. Throughout
the investigation, the elected District Attomey of
Fulton County Fani Willis (hereinafter referred toas “FCDA”) was the “very publicfaceofthis
investigation” and routinely sat for interviews with various media outlets regarding the matter.
Ex.4at3, see also Ex. 5.
‘The Supervising Judge dissolved the SPGJ on January 9, 2023. Ex. 6. In his order of
dissolution, the Supervising Judge, recognizing that the next stepsofthis process were unclear,
invited briefing from the FCDA’s Office and the media (notably excluding any other parties
including witnesses and targets), and set 2 hearing on the issueof publication. Ex. 3 at 2. While
stating the statute directed him to release the report, the Supervising Judge cited due process
concerns in ultimately ruling that only a small portion of the report would become public at that
time. Ex. 7 at 5 (“{TJhe consequence of these due process deficiencies is not that the special
‘purpose grand jury’s final report i forever suppressed or that ts recommendations for or against
indictment are in any way flawed or suspect. Rather, the consequence is that those
recommendations are for the District Attorney’ eyes only ~ for now. Fundamental faimess
requires this[]").
However, on February 21, 2023, in contravention of the order of the Supervising Judge,
the nation was givena view inside the SPGI process when, in a bizarre turnofevents, the SPGJ
7
foreperson engaged in a media tour where she shared the specifics of her experience publicly.”
Ex. 8. The foreperson’s public comments reveal thatboththe procedures set forth for the SPG,
as well as the applicationofthose procedures by the Supervising Judge and the FCDA’ Office,
failed to protect the most basic procedural and substantive constitutional rightsofall individuals
discussed by this investigative body. Compounding the harm inflicted by the foreperson’s public
comments, the Supervising Judge then gave numerous media interviews despite still presiding
over this pending matter. EX. 9.
“This motion addresses the following issues which violate the principles of fundamental
faimess and due process: (1) the unconstitutionalityofthe special purposegrand jury statutes as
set forth in O.C.G.A. § 15-12-10 et. seq., both facially and as applied in this case, (2) the
existing, actual conflict suffered by the FCDA's Office (specifically the FCDA) which has been
exacerbated by instancesofforensic misconduct and improper extrajudicial activity such that the
FCDA’s Office must be disqualified from this matter, (3) the unconstitutional taint infecting the
‘grandjury proceeding and the corresponding taint on the potential grandjury (and petitjury)
pool, and (4) the unconstitutional taint inflicted on thegrandjury proceedings and potential
‘grandjury (and petitjury) pool by the in-court as well as the extrajudicial statements made by
the Supervising Judge
First, the special purpose grand jury statutes are unconstitutionally vague, resulting in
disparate application. The statutes are silent as to key powers and dutiesofthe grand jury, and
they do not prescribe what shall be included in the report, nor do they specify how orifit should
2 Since that time, additional grand jurors have also spoken out. Ex. 8 at No. 11
2 The concept of fundamental faimess is “essential to the very concept ofjustice,” and is the
comerstoneofdue process. Lisenba v. California, 314 U.S. 219 (1941).
8
be disseminated. The failures in the statutory framework directly impact the fundamental fairness
ofthe proceedings and violate the due process rightsofthe individuals involved
Second, the Supervising Judge applied the statutes in a way that violated the du process
sightsof the individuals involved when he held, contrary to Georgia precedent, that this SPJ
was a criminal grandjury. That determination had a negative ripple effect on the constitutional
integrityofthe entire process as it permittedthe compulsion of testimony from out-of-state.
witnesses and impacted the applicationofcore constitutional privileges such as the Fifth
Amendment and sovereign immunity.
Third, the Supervising Judge improperly disqualified the FCDA’s Office from
investigating a singular target when it was instead required to exclude the FCDA’s Office from
the entire investigation. The resulting prejudicial taint cannot be excised from the resultsofthe
investigation or any future prosecution by the FCDA’s Office. Additionally, the FCDA’s media
interviews violate prosecutorial standards and constitute forensic misconduct, and her social
‘media activity creates the appearanceof impropriety compounding the necessity for
disqualification.
Fourth, the foreperson’s and grand jurors’ comments illuminate the lackofproper
instruction and supervision over the grand jury relating to clear evidentiary matters which
violates the notions of fundamental fairness and due process. The resultsofthe investigation
cannot be relied upon and, therefore, must be suppressed given the constitutional violations. The
foreperson’s public comments in andof themselves likewise violate notionsoffundamental
faimess and due process and taint any future grand jury pool.
9
Finally, the Supervising Judge's improper conduct tainted the proceeding and similarly
violated notions of fundamental fairmess and due process. The Supervising Judge made
inappropriate and prejudicial comments relating to the conduct under investigation as well as
potential witnesses” invocationofthe Fifth Amendment. He improperly applied the law and
subsequently denied appellate review while knowing his applicationofthe law in that manner
had vast implications on the constitutionality ofthe investigation. His nexus to certain aspects of
the SPGY and subsequent draftingofthe report, in combination with his prior rulings, necessitate
review by theChief Judge ofthe Fulton County Superior Court.
Accordingly, President Donald J. Trump hereby moves to quash the SPGY’s report and
preclude the use ofany evidence derived therefrom, a it was conducted under an
unconstitutional statute, through an illegal and unconstitutional process, and by a disqualified
District Attomey’s Office who violated prosecutorial standards and acted with disregard for the
gravityofthe circumstances and the constitutional rightsofthose involved. Movant further
requests that this Court disqualify the FCDA from any further proceedings in this matter,
including any indictments and/or prosecutions, as her disqualifying conflict already found by the
Supervising Judge commanded and commands this result.
IL STANDING
‘Although Movant, President Donald J. Trump, was not a witness who appeared before
the SPGJ, his constitutional rights are clearly implicated in this matter. Georgiajurisprudence
broadly recognizes standing of non-parties whose rights have or may be infringed upon by the
illegal actsofthe State or unconstitutional statutes to challenge the same: “(Ithasbeen
recognized that the only prerequisite to attacking the constitutionality ofa statute ‘i a showing
that it is hurtful to the attacker.” Bo Fancy Prods. V. Rabun Cty. Bd. OfComm'rs, 267 Ga. 341,
10
344 (1996) (quoting Stewart v. Davidson, 218 Ga. 760, 764 (1963)). “In orderto challenge a
statute or an administrative action taken pursuant to a statute, theplaintiffmust normally show
that it has interests or rights which are or will be affected by the statute or the action.” Atlanta
Taxicab Co. Owners Ass'n v. Cityof Atlanta, 281 Ga. 342, 345 (2006) (quoting Preservation
Alliance ofSavannah v. Norfolk Southern Corp., 202 Ga. App. 116, 117 (1991) (emphasis
added). Additionally, under Georgia law, parties impacted by grand jury reports have standing
to challenge the releaseofthose reports. See Ii re Floyd CountyGrand Jury Presenimentsfor
May Term 1996, 225 Ga. App. 705 (1997) (Attorney General entitled to expungement ofgrand
jury report; In re July-August, 2003 County Grand Jury, 265 Ga. App. 870 (2004) (DeKalb
County CEO entitled to expungement of ultra vires portionsofreport); Kelley v. Tanksley, 105
Ga. App. 65 (1961) (Solicitor entitled to partial expungementofreport whichby implication and
innuendo accused himofmalpractice).
President Trump was inextricably intertwined with this investigation since its inception.
“The efforts under investigation squarely relate to his bid for a second term as Presidentof the
United States. The investigation began asa result ofa conference call amongst numerous parties
including SecretaryofState Raffensperger and President Trump, and the call was the first piece
of evidence reviewed by the SPGI.* President Trump was mentioned in every news report and
virtually every filing related to this mater and has remained acentral figure, both in public
perception and the court record, throughout this investigation.® Each time the FCDA and
“ See The Fulton County District Attorney ’s Letter, NEW YORK TIMES (Feb. 20, 2021),
hitps:/iwww. nytimes.com interactive/202 02/ Ofus/polities/letters-to-georgia-officials-from-
fulton-district-attoney html; See also, Ex. 8 at No. 2.
5 See Docket, Fulton County Clerk Superior & Magistrate Courts,
hitp:/fwww.fultonclerk.org/DocumentCenter/Index/947GridorderBy=LastModifiedDate-desc:
(last visited Mar. 17, 2023).
un
Supervising Judge subpoenaed an out-of-state witness, President Tramp or the Trump Campaign
was mentioned in the languageof the certificateofneed as well as the order compelling that
‘witness's testimony; the same was true for most motions filed in the matter. fd.
Furthermore, the FCDA has spoken to the media nearly forty times regarding this
investigation and each news report references President Trump. Ex. 5. In interviews, the FCDA
directly responded when asked about President Trump and personally referred to him by name.
Id. at No. 20. On multiple occasions, she discussed subpoenaing President Trump and intimated
he was the targetofthe investigation. See Ex. 5. In response to the question of whether President
Tramp would be subpoenaed, FCDA responded, “it is foreseeable that I would subpoena the
targetof this investigation... A target.” Id. at No. 27. Even when not referring to him by name,
she implied she was speaking about President Trump. Id. at No. 7 (“Nobody is above the
Iaw...”); Id at No. 25 (“It's not much consequence what ttle they wore....”); Id. at No. 22
(“Everybody is equal before the law no matter what position they hold, no matter how much
wealth...”); Id at No. 25 (“I'm not taking on a former president. We're not adversaries. I don’t
know him personally. He does not know me personally.”). In her frst interview live on national
television, FCDA opined about President Trump's mens rea during his call with Secretary of
State Brad Raffensperger. ©
“When any prosecutor throughout this country is interviewing people trying to determine ifa
crime was committed, and ifthey understood what they were doing, the mens rea is always
important. So you look at facts to see, ‘did they really have intent?” [or] ‘did they really
understand what they were doing?” Detailed facts become important like, asking for a specific
numberand then going back 10 investigate and understand that that number isjust one more than
the number that is necded. It le’s you know that someone had a clear mind. They understood
what they were doing, and so when you are pursuing the investigation, facts like that that may
not seem so important, become very important.” EX. § at No. 4.
12
‘The forepersonofthe SPGJ likewise spoke freely (and directly) about President Trump in
eachofher interviews:
Twill tell you that it was a process where we heard his name a lot. We definitely heard a
lot about former President Trump, and we definitely discussed him a lot in the room.
And 1will say that when this list comes out... there are no major plot twists waiting for
you....We heard a lotofrecordingsofPresident Trump on the phone... It is amazing how
many hours of footage you can findof that man on the phone... I could see how getting
the former president to talk to us would have been a year in negotiation by itself...I'd be
fascinated by what he [Trump] said, but do you think he would come in and say anything
groundbreaking orjust the same kinda thing we've heard?
Ex.8atNos.3,4,5.
‘The investigation began as a resultofthe phone call between Secretary of State:
Raffensperger, President Trump, and others, but came to encompass a varietyofactions related
to President Trump’s candidacy in the 2020 Election. He was mentioned in nearly every
interview given by the FCDA as well as the foreperson, and President Trump himselforthe 2020
Election was referenced in virtually every court filing. In short, President Trump's rights have
been implicated pursuant to the Fifth and Fourteenth Amendments to the United States
Constitution as well as Ga. Const. Art. I,§I, Paras. I and XVI and, therefore, he has standing to
make these constitutional, legal, and procedural challenges.
II. THE GEORGIA STATUTES AUTHORIZING THE USE OF A SPECIAL
PURPOSE GRAND JURY ARE UNCONSTITUTIONAL.
‘The Georgia legislature enacted the special purpose grand jury statutes in 1974. See
O.C.GA. § 15-12-100 et. seq. These statutes authorize the creation ofa county-wide special
purpose grand jury for the purpose of investigating any alleged violationofthe lawsofthis state
3
orany other matter subject to investigation by grand juries, and the statutes grant special purpose
‘grand juries compulsory subpoena power.” Additionally, O.C.G.A. § 15-12-101 states in part:
7 “While conducting any investigation authorized by this part investigative grand juries may
compel evidence and subpoena witnesses; may inspect records, documents, correspondence, and
booksofany department, agency, board, bureau, commission, institution, or authorityofthe state
or anyof ts political subdivisions; and may require the productionofrecords, documents,
correspondence, and booksofany person, firm, or corporation which relate directly or indirectly
10 the subjectof the investigation being conducted by the investigative grand jury.” 0.C.G.A. §
15-12-10.
Special Purpose Grand Jury Final Report, CHAMPION NEWSPAPER (August 21, 2013), Civil
Action No. 13CV1024, https:/Athechampionnewspaper.com/wp-
content/uploads/2013/08/000S pecialPurposeGrandJuryFinalReport pdf (DeKalb County SPGI
investigated allegations ofpublic corruption surounding the awardingofcontracts within the
Watershed Management Department); Cobb County, Ga. Laptop Plan to Be Probed by Grand
Jury, MACDAILYNEWS (October 10, 2005), Civil Action No. 05-1-8242,
hitps:/www.edweek.org/policy-politics/cobb-county-ga-aptopplan-to-be-probed-by-grand-
jury/2005/10 (Cobb County SPGJ investigated alleged bias and deception in the bidding ofa
computer laptop program); State v. Lampl, 296 Ga. $92 (2015) (Clayton County SPGJ
investigating public corruption and various crimes allegedly committed by currently or
previously elected county officials and county employes); Keerly v. State, 311 Ga. App. 190
(2011) (Gwinnett SPGJ investigating suspected criminal activity surrounding the acquisition of
real property at fraudulently inflated prices).
1“
their enactment, no appellate court has examined the constitutionalityofthe special purpose
grandjury statutes.
A.TheStatutesAre
Unconstitutional
DuetoVagueness.
tis well-established that “a law fails to meet the requirementsof the Due Process Clause:
ifitis 50 vague and standardless that it leaves the public uncertain as to the conduct it prohibits
or leaves judges and jurors free to decide, without any legally fixed standards, what is prohibited
‘and what is not in each particular case.” Giaccio v. Pennsylvania, 382 U.S. 399, 403 (1966)
(Citing Lanzetta v. New Jersey, 306 U.S. 451 (1939). In Giaccio, the Supreme Court reviewed a
Pennsylvania statute that governed the procedure by whichjurors determined court coststo be.
paid by an acquitted defendant. See 382 U.S. at 401. The Court held that “the law must be one.
that carries an understandable meaning with legal standards that courts must enforce.” Id. at 403.
Accordingly, the Court found the statute unconstitutionally vague because it invited arbitrary
enforcement. Id. (statue allowed jurors to “make determinationsofthe crucial issue upon their
‘own notionsofwhat the law should be insteadof what it s.”). Similarly, in JekyllIslandState
Park Civic Auth. v. Jekyll Island Citizens Ass'n., 266 Ga. 152 (1996), the Georgia Supreme
‘Court held thata portion ofa civil statute was unconstitutional because it was vague and
indefinite, as it contained “insufficient objective standards and guidelines to meet the
requirementsof Due Process.” Jekyll Island, 266 Ga. at 153.
The statutes governing the special purpose grand jury, O.C.G.A. § 1512-100, et. seq,, are
50 standardless that they have invited arbitrary, amorphous enforcement by the FCDA’s Office
and the Supervising Judge. First, they fail to specify whether a SPG is a criminal or civil
proceeding (or whether a SPGY can be either depending on its scope and purpose). Second, the
statutes lack specificity as to the form and substanceofthe report, the rightsof individuals
1s
named inthereport, and the publicationofthe SPGI's final report. Third, they fai to identify
with adequate specificity the roles and responsibilitiesofthe Supervising Judge versus the body
requesting the investigation, here the FCDA.
i. The Statutes are Vague as to Whether the SPGJ is a Civil or Criminal Body.
The central constitutional concern at issue here is the conflicting interpretation ofthe
statute- whether the SPGJ is a criminal or civil investigative body. This issue has been argued
‘and repeated by numerous parties during the courseofthis proceeding with inconsistent and/or
unsupported holdings by the Supervising Judge as well as courts in other jurisdictions. The fact
that sucha foundational aspectofthis procedure is unclear under the law is definitive evidence
that the statutes are overly vague and unconstitutionalontheir face.
Even though the Supervising Judge declared that this SPGJ was a criminal investigative
‘grand jury, he offered no basis for this conclusion other than asserting that the impaneling order
and scopeofthe investigation determined the nature of the grand jury proceeding.” There is no
Georgia authority that supports the Supervising Judge's theory that the stated purposeof the
investigation determines the natureofthe body. The decision as to whether the SPGJ is a civil or
criminal body is of the utmost significance, as it impacts whether the SPGI can compel the
attendance of out-of-state witnesses, what (if any) inferences can be made upon assertions of
privilege, the applicabilityofsovereign immunity, and more. On these issues, the statutes are
silent which renders them unconstitutionally vague.
19 For example, see In Re Jacki L. Pick, WR-94, 066-01 (Tex. App. 2022).
1% In Re Jacki L. Pick, WR-94, 066-01 (Tex. App. 2022) (Yeary, J. dissenting). The majority
opinion did not address the applicabilityofthe Uniform Act to the SPGJ because the subpoena at
issue was moot.
17
subpoena which sought to compel the appearanceof Deason in the SPGI was void because,
although Texas has adopted the Uniform Act, it only applies “when the proceedings to be
attended are ‘criminal’ in nature, or where they are conducted by an actual ‘grand jury.” Id. at 3.
‘TheTexas Court further interpreted Georgia case law, finding that the SPGJ “at least according
10 present interpretations of the law from that state’s own courts, conducts only civil
investigations and may not tself present an indictment or initiate a criminal prosecution.” Id.
The statutes’ vagueness as to whether this is a criminal or civil body has similarly caused
problems for witnesses claiming sovereign immunity. Specifically, United States Senator
Lindsey Graham'? and Georgia Governor Brian Kemp both raised sovereign immunity claims in
response to their subpoenas to testify. See Ex. 11; see also August 17, 2022 Motion to Quash
Subpoena Issued to Governor Brian P. Kemp. Counsel for Governor Kemp argued that he could
not be compelled to testify before the civil SPGI because he was protected from the subpoena by
sovereign immunity. Id. While the Supervising Judge agreed that sovereign immunity would
apply toa civil special purpose grandjury, he denied the motionandheld that the SPGI is a
criminal investigative grand jury. Ex. 10 at 5 (“Put simply, there is nothing about this special
purpose grand jury that involved or implicates civil practice.) As explained below, see infra
Section 1I(B)(0), this ruling was contrary to established Georgia precedent, but the fact that the
issue was raised by multiple witnesses points to the lackofstatutory clarity on the subject.
‘The Supervising Judge's unilateral decision to declare the SPGJ a criminal body (despite:
its inability to indict and Georgia precedent to the contrary) created a litanyofconstitutional
InreGraham, 2022 U.S. Dist. LEXIS 194033 (N. Dist. Ga.) (2022) (Civil Action No. 1:22-cv-
03027-LMM).
18
violations for the witnesses called before it.** However, because the statutes are devoidofany
language that may guide a court in interpreting its meaning, its use, and its application to real-life
proceedings, such a determination is arbitrary. The statutes are so vague that they lack the
“objective standards and guidelines to meet the requirementofdue process.” Jekyll Ise, 256 Ga.
at 153. This double-bind cannot stand, as the distinction between criminal and civil has pertinent
implications on the permissible testimony and evidence which may come before this, and any
other, SPGJ body.
il. The Statutes are Vague as to the Contents and Releaseofthe Repor(s).
Pursuant to a majority voteofthe Fulton County Superior Court bench, the SPGJ was
dissolved on January 9, 2023. Ex. 6. In the orderofdissolution, the Supervising Judge,
recognizing that the next stepsofthis process were unclear, invited briefing from the FCDA's
Office and the media (notably excluding any other parties including witnesses as well as targets),
and set a hearing on the issueofpublication. Jd. at 2. While stating the statute clearly directed
him to release the report, the Supervising Judge cited due process concerns in ultimately ruling
that only a small portionof the report should be made public.'* The parties raised issues as to
whether the report was a court record under Rule 21, whether it was a general presentment under
13 The Supervising Judge insulated himself from appellate review of this critical and otherwise-
unreviewable issue by denying acertificateof immediate review. See Ex. 10 FN § (“The Court
also declines to issue a certificate of immediate reviewofthis decision because itis clear that
sovereign immunity does not apply to criminal matters. See Rivera v. Washington, 298 Ga. 710,
777 (2016) (recommending issuanceofcertificateof immediate review when resolution of
immunity issue is not clear).”)
Ex. 7 at4 (“(TJhus, facially, the final report should be published in fofo pursuant
to O.C.G.A §
15-12-80.%); Jd. at 5 (*[T]he consequenceof these due process deficiencies is not that the special
‘purpose grand jury’ final report is forever suppressed or that its recommendation for or against
indictment are in any way flawed or suspect. Rather, the consequence is that those
recommendations are for the District Attorey’s eyes only for now. Fundamental fairmess
requires this[]).
19
O.C.G.A. § 15-12-80, and whether a balancing test is required when renderinga decision
regarding publication based upon the due process rightsof the named individuals. Id. see also,
Ex. 3. Unfortunately, the issueofpublicly releasing the special grandjury’ final report was also
not contemplated by the statute. O.C.G.A. § 15-12-10 et. seq. Now, posed with such a question,
the Supervising Judge wes lef to make his own decisions, create his own standards and, thus,
carve out an entirely unique scopeof the SPGJ which may or may not have been originally
intended by the Georgia legislature.
Upon further analysis, the special purpose grandjury statutes fal to address any aspect of
the report; they are completely silent other than to say the Supervising Judge “shall require
periodic reports of the special grand jury's progress as well as a final report” 0.C.G.A. § 15-12-
101). The statutes do not specify whether the reports should be oral or written, nor do they
prescribe whether the reports should include substantive information such as summaries of
evidence or formal recommendations. Id. Assuming arguendo the report stobewritten, the
statutes are silent as to whether the SPGJ writes the report alone or with the assistanceofeither
the Supervising Judge or the body requesting the investigation, here the FCDA. Id.
Relevant to the due process rightsofall those who may be mentioned in the report, the
Statutes are silent as to ts public release. Jd. tis unclear whether the report is a court record or
‘whether it belongs to and remains in the handsof the body that requested the investigation as the
Supervising Judge has held. Id; see also Ex. 7. Ifthe report is to be made public, the statutes fail
to specify who shall make that determination or how such publishing may occur, especially since
the statutes are further silent as to whetherthereport is considered a general presentment such
that O.C.G.A § 15-12-80 applies. Id. Finally, the statutes fal to describe how or whether those.
2
individuals named in the report may be offered an opportunity to review the report or otherwise
challenge is release given the necessary implicationoftheir due process rights. 1d.
Given this lack of specificity, courts fail 0 interpret and apply the statutes in a uniform
‘manner across jurisdictions. As such, the statutes violate the principles of fundamental faimess
and are unconstitutionally vague
B. The Statutes are Unconstitutional As Appliedto This SPG,
‘The Georgia special purpose grand jury statutes have been applied to this matter through
an unconstitutional framework with little regard to the illegal consequences that resulted in
prejudicing and violating the rights ofall partes impacted by the investigation. As stated above,
the Supervising Judge, along with the FCDA’s Office, has operated under the assumption that,
although baseless and contrary to established precedent, the SPGJis a criminal investigative
body. As the SPGY is a civil investigative body pursuant to Georgia case law, this
mischaracterizationofits fundamental character resulted in a cascade ofunconstitutional
consequences. For example, the SPG) was permitted to compel the attendance and testimony of
Out-of-state witnesses as well as the testimonyofwitnesses asserting valid claimsof sovereign
immunity. Even if, as the Supervising Judge declared, this SPGJ was somehow criminal, it was.
still unconstitutionally administered because the FCDA improperly and arbitrarily assigned
“target” labels, compelled those “targets” to appear, and the grand jurors drew adverse inferences
from witnesses’ Fifth Amendment assertions. In both civil and criminal interpretations, the:
substantive due process rights of all parties impacted by the investigation have been violated.
‘The unconstitutional administrationofthis SPGJ violated all notions of fundamental faimess;
witnesses could not depend on the proper applicationofthe law by the Supervising Judge, nor
could they rely on statements from the FCDA in assessing how to adequately protect their rights.
2
i. The Supervising Judge Improperly Designated the SPGas a Criminal Investigative
Body When Case Law Mandates its Civil.
“The only two cases in Georgia jurisprudence that touch upon the nature ofa special
purpose grand jury clarify that it is acivil, not a criminal, body. See State v. Bartel, 223 Ga. App.
696 (1996); see also Kenerly v. State, 311 Ga. App. 190 (2011). This issue was first raised before
the Supervising Judge when counsel for Governor Kemp argued the sovereign immunity
prevented the SPGJ from compelling his testimony. See Ex. 11; see also August 17, 2022 Motion
to Quash Subpoena Issued to Governor Brian P. Kemp. The Supervising Judge agreed that a civil
SPGJ could not compel such testimony from the Governor. Ex. 11 at 31 (“And that's your
argument that, look, thisspecial purpose grand jury is actually a civil thing. Andif you're right,
civil I agree, sovereign immunity. T don't see any waiver anywhere.”). In denying Governor
Kemp's Motion, the Supervising Judge ruled (for the first time in this investigation) that the
SPGJ was a criminal investigative grand jury —a ruling contrary to established Georgia
precedent. Ex. 10. This ruling created a ripple effectofconstitutional violations which implicated
the due process rightsofthe Movant and other parties subpoenacd by this body.
In coming to this decision, the Supervising Judge drew misplaced conclusions as to the
relevant case law. Specifically, he reasoned that the special purpose grand juryin State v. Bartel,
223 Ga. App. 696 (1996), was deemed a civil investigative body because it was “convened to
conducta civil investigation.” Ex. 10 at 4. In other words, that the stated purpose for impaneling
an investigative body determines whether it is a criminal or civil matter —not its inherent powers.
2
Id. The reasoning employed by the Supervising Judge was not derived from anything the Bartel
Court held nor can it be traced to any other case.'S
Georgia precedent applies a different standard. The Georgia Court of Appeals in Kenerly
v. State, 311 Ga. App. 190 (2011), interpreted Bartel as “concluding that special purpose grand
juries conduct only civil investigations.” Kenerly at 194 (citing Bartel, 223 Ga. App. at 699)
(emphasis added). Moreover, the Kenerly court relied on the stated powersofthe body, rather
than the bodyspurpose, as the Court did here, to interpret the boundariesofthe SPGI under the:
relevant statutes. Kenerdy, 311 Ga. App. at 194 (finding that a special purpose grand jury does
not have the power to indict: “[BJecause the powers and duties ofa special grandjury are
specifically provided for, the powers granted to regular grand juries, including the power to
indict, do not apply.”).
Counsel for Governor Kemp correctly argued that, “Bartel eld that special purpose
‘grandjuries conduct only civil investigations.” See Ex. 11; see also August 17, 2022 Motion to
Qush Subpoena Issued to Governor Brian P. Kemp. In his Order denying their Motion, the
Supervising Judge never addressed the fact that counsels argument was a direct quote from
binding Georgia precedent but, instead, stated counsels “claim” was “unfounded.” Ex. 10 FN 4.
‘The Supervising Judge did not just ail to distinguish the Kenerly case - he completely refused to
In Bartel, the Georgia CourtofAppeals held that the oath required for witnesses testifying
before a criminal grand jury was “irrelevant” in acivil grand jury proceeding, It was unclear
whether the grand jury was impaneled pursuant to the special purpose grand jury statute, the
grand jury statutes relating to civil investigations, or both, but the Court held that the result
would be the same because they are all civil investigations. The Court noted that it defies logic to
require the oath applicable for criminal grand juries to be administered in civil investigations
where “there obviously is not and cannot be ‘any indictment or special presentment’ or any
individual charged witha particular criminal offense.”
16 See also In re Gwinnett CountyGrandJury, 284 Ga. 510, 512 (2008) (distinguishing between
the “criminal accusatory and civil investigative roles” ofgrand juries).
2
‘acknowledge or address it. Ex. 10. While utterly ignoring binding precedent, the Supervising
Judge then denied appellate review despite the fact that his ruling affected the constitutional
integrity of the investigation moving forward. Ex. 10 FN 8 (“The Court also declines to issue a
certificate of immediate review ofthis decision because it is clear that sovereign immunity does
not apply to criminal matters. See Rivera v. Washington, 298 Ga. 770, 777 (2016)
(recommending issuanceofcertificate of immediate review when resolution of immunity issue is
not clear).”).
As stated previously, the Supervising Judge concluded the SPGJ was criminal because it
was impaneled to investigate whether certain activity constituted a crime under Georgia law. Ex.
10. In so doing, he ignored the fact that most special purpose grand juries are impaneled to do
just that — investigate certain questionable activity, oftentimes public malfeasance, where it is
unclear on its face whether the activity is criminal. Ifthere was such a thing as a criminal
special purpose grand jury, the CourtofAppeals would have said so in Kenerly. Kenerly, 311
Ga. App. 190. Instead, it affirmed that special purpose grandjury investigations into possible
criminal activity are still civil in nature. Jd. at 194. The Kenerly special purpose grand jury was
impaneled for the purposeof investigating suspected criminal activity surrounding the
acquisitionof real property at fraudulently inflated prices, and Gwinnett County Commissioner,
Kevin Kenerly, was subsequently criminally indicted for his role in those deals.” In affirming
V7 See infra FN 6.
8 Specialgrand jury 10 look at Gwinnett landpurchases, ATLANTA JOURNAL-CONSTITUTION,
(Sep. 25, 2009), hitps://vwww.aic.com/news/local/special-grand-jury-look-gwinnett-land-
purchases/Yf5VPyqK TWSSFBMOUVsdWM/ (District Attorney Danny Porter stated: “I think
the grand jury, as a groupofcitizens, needs to look at these expendituresof county money and
try to determineifthere’s anything criminal... there is, it needs to be prosecuted.");
Grandjury on Gwinnett land to wrap up work, ASSOCIATED PRESS, (Oct. 4,
2010), hitps://aceesswdun.comy/print/2010/10/23274S (investigating allegation that county
2%
the civil natureof that grand jury proceeding, the Kenerly Court implicitly rejected the notion
thata special purpose grand jury is criminalif investigating potential criminal activity.” Yet, this
was the sole basis cited by the Supervising Judge in declaring this SPGJ to be criminal. Ex. 10.
In fact, Kenerly is the only SPGJ case which provides substantive guidance on statutory
interpretation, and the Court of Appeals in that case thoughtfully delineated its useof“the
venerable principleof the maxim expressinfucit cessare tacitum” to “assume deliberate
omissionofactions not listed in a statute and not otherwise addressed elsewhere.” (Emphasis
included) Kenerly, 311 Ga. App. at 193. See also Hinton v. State, 224 Ga. App. 49, 50 (1996).
‘The Supreme Court of Georgia and other Georgia courts have also applied this method of
statutory interpretation. See Hinton v. State, 224 Ga. App. 49, 50 (1996); Chase v. State, 285 Ga.
693,695.96 (2009); Battallia v. Cityof Columbus, 199 Ga. App. 897, 898 (1991). Thus, the
Supervising Judge's decision that the SPGY is a criminal body is affirmatively refuted by binding
Georgia precedent, This erroneous decision had vast constitutional and procedural implications,
and the resulting taint invalidates the constitutionality and validityofthe entire proceeding
‘commissioner pushed the Commission to purchase property for $7m more than it was valued at
two years earlier due to his friendship with landowner).
19 Additionally, other SPGI’s investigating potential criminal activity were filed as civil actions.
See Dekalb County Civil Case No. 13CV1024 (PGI investigated allegations ofpublic
corruption within the Watershed Management Department); Cobb County Civil Case No. 05-1-
8242 (SPGJ investigated alleged bias and deception in the bidding ofa computer laptop.
program). .
2
ofGeorgia. Duc to the substantial numberofwitnesses compelled to testify under the Uniform
Act, their testimony is inexorably intertwined with the conclusionsof the SPGJ, and there is no
way to extricate the taint that this improperly compelled testimony caused.
In addition to improperly compelling testimony from out-of-state witnesses, the SPGJ
improperly compelled testimony from Governor Kemp despite his valid assertionof sovereign
immunity. Sovereign immunity is a constitutional doctrine. Ga. Const. art. 1 § 2, Para. IX(e). As
explained, see supra Section III(A)(1), the doctrine of sovereign immunity was overcome by the
Judge's decision to classify the SPGJ as a criminal investigative body in contradiction to binding
Georgia precedent.
In declaring this was a criminal SPGI, the Supervising Judge improperly and
unconstitutionally imbued the SPGY with powers it did not, in fact, have. The testimony illegally
obtained by the SPGI violates notions of fundamental faimess and the due process rights of
Movant as well as other parties investigated by the SPGJ. This pervasive taint which
impermissibly corrupted the investigation can only be remedied by quashing the report and
precluding the use of all illegally obtained evidence.
C. The Statutes Were Unconstitutionally Applied to this SPGJ if Classified as
Criminal,
Even if, as the Supervising Judge concluded, the SPGY was somehow criminal, it was still
unconstitutionally interpreted and applied. All notions of fundamental fairess were violated by
the FCDA’s arbitrary assignmentof “target” statuses and the adverse inferences the SPGJ drew
from witnesses’ Fifth Amendment assertions.
2%
i. The FCDA's Arbitrary Use and Subsequent Abandonment of “Target”
‘Statuses Violated PrinciplesofFundamental Faimness.
Early on in the investigation, the FCDA sent target letters to a groupofwitnesses
affirmatively assigning them “target” status. Generally, a “target” is a definition given by the
Departmentof Justice to an individual contemplated for prosecution: “[a] ‘target’ is a person as
to whom the prosecutor or the grand jury has substantial evidence linking him or her to the
‘commission ofa crime and who, in the judgmentofthe prosecutor, is a putative defendant.” See
United States Attorneys Manual (“USAM”) 9-11.151. The labelof a target within the federal
criminal justice system carries with it both weight as wel as presumptive rights. USAM 9-
11.150 (subpoenaing targetsofgrand jury investigation "may carry the appearance of
unfairness"); and USAM 9-11.154 (when targetofgrand recount jury investigation informs
government that they plan to invoke their fifth amendment privilege in grand jury, they should
ordinarily be excused from appearing). There is no identifiable Georgia law or any other
authority that defines a targetofan investigation and what that might mean or entail within State
proceedings.
As evidenced in the public motions and subsequent hearings held before the Supervising
Judge, while the FCDA’ Office might have assigned “target” status to a number of individuals
whom they sought to subpoena, they offered no parallel rights or protectionsto those same
individuals as would be expected in a constitutionally-sound investigative process (as is done at
the federal level). See Ex. 12. In fact, neither the Courtnorthe FCDA’s Office appeared to treat
those deemed targets any differently than any other witness who was subpoenaed to testify. /d.
“This raises the questionofwhat constitutional protections a target should have in a
criminal special purpose grand jury (which has never before been addressed under Georgia law)
27
Georgia law and the Georgia Constitution prohibit the appearance before a regular grandjury of
a witness named in a proposed charging instrument. See State v. Lamp, 296 Ga. 892 (2015)
(grand juries are prohibited from compelling the appearance of a witness who has been accused
inaretumed or proposed charging document at the time they are called to testify); State v.
Butler, 177 Ga. App. 594 (1986) (holding that while it violates the Fifth Amendment to call a
witness to testify to the grand jury which is considering an indictment against the witness, such
wasnotthecase here where defendant was called to testify to an alleged crime committed by her
husband); Jenkins v. State, 65 Ga. App. 16 (1941) (grandjury had no lawful right to call the
accused before it while considering a billofindictment against him); 0.C.G.A § 24-5-506.
A criminal SPGJ (as created here by the Supervising Judge) tasked with investigating
criminal conduct and drafting a report recommending criminal indictment creates unique
problems in this context relative to the Fifth Amendment, Ga. Con. Art. 1, § 1, para. xvi and
O.C.G.A § 24-5-506. The SPGJ cannot return an indictment or even consider a proposed
charging instrument, so a strict readingofthe case law would allow the SPGJ to compel any
witness to appear and provide testimony that could then be used ina subsequent grand jury
proceeding considering a charging instrument naming that witness (even though that same
testimony could not be compelled live before the regular grand jury). This circumvents the Fifth
Amendment, Ga. Con. Art. I, § I, para. xvi, and 0.C.G.A § 24-5-506 and wouldpermitthe use of
a special purpose grand jury to obtain and present testimony which would otherwise be
unavailable to and unable to be brought before a regular criminal grand jury.
Not only were purported “targets” not given any protections, but they also appear to have
been assigned their “target” status on an arbitrary basis. The target notifications were publicly
released in July of 2022, and the practiceof labeling individuals as targets appearedtobe
2
abandoned by the FCDA's Office soon thereafter. This shift coincided with the Supervising
Judge expressing his own concerns about the use of this terminology. See Ex. 12. During the
disqualification hearing, the Supervising Judge pointed out the lackof meaning given to “target”
status within State proceedings. Jd. at 12 (“I don’t think the word target is as magical in State
proceedings as it is in Federal proceedings. ..”). Notably, he also warmed the FCDA, “you may
want to think through in the future labeling someone that and then hailing them in because of
how this has played out.” fd at 13. Following those comments from the Supervising Judge, no
other “targets” were publicly named.
‘This inconsistency is more than an inconvenience for those who had to make important
decisions (both personally and upon adviceofcounsel) about how to conduct themselves in the
‘public sphere as well as what key constitutional decisions needed to be made regarding the
ability to answer questions while under oath. Whether an individual is labeled a target s often
the ultimate question for both counsel and the client in deciding how best to defend themselves.
‘The fact that the FDA's Office chose to label some potential witnesses “targets” (which they
certainly could have chosen not to do) but then chose not to label others as such, begs the
question: are those “others” by this purposeful omission, “not targets™? If that answer is no: the
only logical conclusion is that the target labels were arbitrarily given, and no witnesses called
thereafter could rely on the legitimacy of their “witness” status.
2 In his Order disqualifying the FCDA, the Supervising Judge stated: “The designation,
borrowed from federal criminal practice, is a bit confusing in the contextofthis grand jury,
which has no power to bring criminal charges against anyone. It is nonetheless A potent
investigative signal that the District Attomey views Senator Jones (and the other alternate
electors) as persons more closely connected10the alleged electoral improprieties than other
witnesses who have come before the grand jury or who may yet do so.” Ex. 4 at FN 6.
2
‘When witnesses appeared before the SPGJ pursuant to 2 subpoena and had not been
givena target notification (while knowing such labels were already given to others), they made
conscious decisions regarding their ability to testify based on that reliance. Either the FCDA’s
Office must admit that they unconstitutionally assigned target labels to some witnesses while
failing to notify othersorthey must admit their useoftarget labels was misapplied and arbitrary.
To either end,this substantial failure violates all notions of fundamental faimess and due process
becauseno witness calledto testify could depend on the designation given by FCDA’s Office
and were forcedto make blind decisions in asserting constitutional privileges. Since the practice
of naming “targets” began and ended in the early stagesofthe investigation (with the first round
of Material Witness Certificates), the majorityof the testimony heard by this SPGJ suffered from
the cancerous and arbitrary applicationofthis otherwise meaningful title with attendant rights.
i. Jurors Improperly Drew Adverse Inferences from Witnesses’ Invocation of
the Fifth Amendment,
Ina criminal matter, jurors cannot draw negative inferences when a witness asserls his
rights under the Fifth Amendment. Barnes v. State, 335 Ga. App. 709 (2016). But here, as
V, the special purpose grand jurors plainly did so." See Ex. 8.
discussed further in Section
Further, the grand jurors formed opinions about certain witnesses” credibility based on whether
or not 2 witness took a few moments to consider the question versus quickly asserting privilege.
See infra Section V. From the foreperson’s comments, it appears the grand jurors were not
properly instructed on this important constitutional safeguard. As recently revealed, the unnamed
jurors shared a completely inaccurate and impermissible understandingofFifth Amendment
21The scratching of pens on paper could be heard as jurors tallied how many times the person
invoked the Fifth Amendment” Ex. 8 at No. 1.
30
rights. Ex. 8 at No. 10. The jurors atributed this failed understanding to the explanation provided
to them by the FCDA’s office. Jd Moreover,ifone or moreofthe special purpose grand jurors
‘watched the hearing online, they would have heard the Supervising Judge say, “butifthey did
nothing wrong, why aren't they talking to the grandjury?” Ex. 12 at 27.
Thus, even ifthe SPGJ was somehow criminal, the SPGI proceeding was
unconstitutionally administered. It violated the rightsof impacted parties by arbitrarily assigning
“target” status while not providing adequate protections for those individuals. Furthermore,
‘grand jurors improperly drew adverse inferences from witnesses’ invocationofthe Fifth
Amendment and relied upon those inferences in forming their conclusions. Given the pervasive
and inextricable taint which ensued from this unconstitutional application, the report must be
quashed and all evidence compelled by this SPG must be suppressed.
Iv. THEFULTONCOUNTYDISTRICTATTORNEY'SOFFICEMUSTBE
DISQUALIFIED.
‘The FCDA’s Office must be recused, disqualified, and prevented from any further
investigation or prosecution of this matter. The Supervising Judge has already held that the
FCDA’s Office has an actual, disqualifying conflict in this investigation. Ex. 4. Inexplicably,
however, the Supervising Judge refused to disqualify the FCDA from the investigation. Instead,
without any supporting authority, the Supervising Judge removed the now Lieutenant Governor
ofGeorgia, Burt Jones, from the investigation and prohibited any future action against him by
the FCDA. Id
‘The FCDA’s Office has maintained significant power and control over the SPGJ. It was
the FCDA’s Office who made the request to impanel the SPGJ and determined the scopeof the
investigation, it decided who to subpoena to testify, and what evidence to compel. Ex. 7. As the
31
Supervising Judge noted in his order regarding publication, the structureofthis investigation has
been “imbalanced, incomplete, and one-sided.” Id. at 5.
Given the national attention, gravity and positionsofmanyofthe individuals involved, it
is even more imperative that the FCDA’s Office remain unattached and impartial, as is required
ofall prosecutors. See Berger v.UnitedStates, 295 U.S. 78 (1935) (the prosecutor is “a
sovereignty whose obligation to govern impartially is as compelling as ts obligation to govern at
all; and whose interest, therefore in a criminal prosecution is not that it shall win a case, but that
justice shall be done.”); see also Young v. U.S. ex rel. Vuitton et Fils S.A, 481 U.S. 787, 803
(1987); Lux v. Commonwealth, 24 Va. App. 561, 568 (1997). After all, “[tJhe prosecutor has
‘more control over life, liberty, and reputation than any other person in America.” Robert H.
Jackson, At’y Gen.of the U.S., The Federal Prosecutor, Address to the Second Annual
ConferenceofUnited States Attorneys (Apr. 1, 1940)
Georgia law delineates two distinct grounds for disqualification of a prosecuting attorney.
First, a prosecutor must be disqualified when a conflictof interest exists - when the prosecutor
has apersonal interest or stake in thedefendant's conviction. See Williams v. State, 258 Ga. 305,
315 (1988). Such a conflict may be either actual or perceived. See Young, 481 U.S. at 787.
Second, a prosecutor can be removed on groundsof “forensic misconduct,” which commonly
arises from “improper expression by the prosecuting attomeyofhis [or her] personalbeliefin the
defendant's guilt.” Williams, 258 Ga. at 315 (citing Vermont v. Holman, 420 A2d 852 (Vt.
1980)
In this matter, the FCDA’ Office has both an actual and perceived conflictof interest.
‘The Supervising Judge previously foundthatan actual conflict exists prohibiting the FCDA's
Office from investigating Lieutenant Governor Burt Jones but erred in failing to disqualify the
32
FCDA’s Office from the entirety of the investigation as the law demands. Additionally, the scope
of the FCDA’s disqualifying conduct extends beyond the actual conflict already found by the
Supervising Judge. The FCDA’s Office, by and through the elected FCDA, exacerbated the
already existing conflict by making extrajudicial statements throughout the entiretyofthis
investigation which violate prosecutorial standards, constitute forensic misconduct and create an
untenable appearance of impropriety. For allofthe reasons below, the FCDA and the entirety of
the FCDA’s Office must be disqualified from any further investigation or potential prosecution
of this matter. .
A. The Supervising Judge Should Have Disqualified the FCDA from the Entire
Investigation Rather than Just a Witness.
On July 25, 2022, the Supervising Judge ordered the disqualificationof the FCDA’s
Office from any further investigation and/or prosecutionofLieutenant Governor Burt Jones due
to an “actual and untenable” conflict. Ex. 4 at 4. By entering an orderofdisqualification of the
FCDA’s Office as to Lt. Governor Jones, the Supervising Judge recognized what Georgia law
clearly prescribes - that a prosecutor can be removed from a matter for which a legal conflict
exists at any stage in the proceedings, including the investigative stage. The Supreme Court of
Georgia recognizes that *“a Georgia district attomey isof counsel in all criminal cases or matters
‘pending in his circuit. This includes the investigatory stagesofmatters preparatory to seeking an
indictment as well as the pendencyof the case.” McLaughlin v. Payne, 295 Ga. 609 (2014)
quoting King v. State, 246 Ga. 386, 389 (1980). The Supervising Judge was correct in
determining that disqualification was appropriateforthe FCDA's Office as it related to both the
SPG as well as any potential future proceedings such as seeking an indictment or going to ral.
3
‘The Supervising Judge was incorrect, however, because the FCDA’s conflict extends to the
entire investigation - notjust one witness.
‘The SPGI was impaneledforthe purposeof investigating “the facts and circumstances
relating directly or indirectly to possible attempts to disrupt the lawful administrationof the 2020
elections in the State of Georgia.” Ex. 1. Thus, the FCDA and her office were tasked with a
singular purpose. However, pursuant to the Supervising Judge's reasoning in his Disqualification
Order, the investigation itselfmay continue only with Lt. Governor Jones removed.
Accordingly,ifcharges are lodged against a groupofpeople, particularly in a multi-defendant
prosecution, Lt. Gov. Jones will have effectively been preemptively severed outofthat
prosecution. Prosecutorial disqualification does not apply in such a haphazard or disjointed
‘manner. Rather, when a district attorney is disqualified from
a prosecution, as she was here, she
must be disqualified from the entire prosecution. In those instances, the case remains a singular
unitand the conflicted district attorney is excised; it is improper fora court to fragment an
investigation or prosecution by carving outa target or defendant while permitting the conflicted
district attorney to remain, and for good reason. The parade of unforeseen consequences to the
parties remaining in the investigation, as well as the need for the public to have confidence in the
judicial process, requires the removalofthe conflicted district attorney from the investigation
and all other proceedings. To do otherwise would, among other things, permit the district
attorney to weaponize these conflicts against the other parties remaining in the proceeding.
‘The United States Supreme Court in Youngv. United Statesex rel. Vuitton Et Fils S.A. et.
1, 481 U.S. 787 (1987), recognized that the existenceofan actual conflict cannot be limited to
the investigation or prosecutionof one individual but is a conflict that permeates the entire
proceeding.
34
‘Once we have drawn that conclusion [that a conflict exists], however, we have deemed
the prosecutor subject to influences that undermine confidence thata prosecution can be
conducted in a disinterested fashion.Ifthis is the case, we cannot have confidence in a
proceeding in which this officer plays the critical roleofpreparing and presenting the
case...”
Id. at 811. (Emphasis added).
‘The United States Supreme Court made clear in Young that the remedy for an actual conflict
could not be made piecemeal, as the Supervising Judge improperly chose to do here:
Appointmentofan interested prosecutor is also an error whose effects are pervasive.
Such an appointment calls into question, and therefore requires scrutiny of, the conduct
ofan entire prosecution, rather than simply a discrete prosecutorial decision. Determining
the effectofthis appointment thus would be extremely difficult. A prosecution contains a
‘myriad of occasions for the exerciseofdiscretion, each of which goes to shape the record
in a case, but fewofwhich are part ofthe record.
d.at81l.
Lastly, the Court in Young emphasized that allowing a matter to continue where a conflicted
prosecutor remained constitutes clear error.
Furthermore, appointmentofan interested prosecutor creates an appearance of
impropriety that diminishes faith in the faimessofthe criminal justice system in general.
“The narrow focus of harmless-error analysis is not sensitive to this underlying concern. If
a prosecutor uses the expansive prosecutorial powers to gather information for private.
purposes, the prosecution function has been seriously abused even if, in the process,
sufficient evidence is obtained to convicta defendant, Prosecutors "have available a
terrible array of coercive methods to obtain information,” such as "police investigation
and interrogation, warrants, informers and agents whose activities are immunized,
‘authorized wiretapping, civil investigatory demands, [and] enhanced subpoena power."
‘The misuseof those methods "would unfairly harass citizens, give unfair advantage to
[the prosecutor's personal interests], and impair public willingness to accept the
legitimate useofthose powers."
1d. at 811 (quoting C. Wolfram, Modern Legal Ethics 460 (1986)(emphasis added). The
Supreme Court added that:
Public confidence in the disinterested conductof that official is essential. Harmless-error
analysis is not equa to the task of assuring that confidence. It is best suited for the review
35
ofdiscrete exercisesofjudgment by lower courts, where information is available that
makes it possible to gauge the effect of a decision on the trial as a whole. In this case,
however, we establish a categorical rule against the appointmentofan interested
prosecutor, adherence to which requires no subtle calculationsof judgment. Given the
fundamental and pervasive effectsof such an appointment, we therefore hold that
harmless-error analysis is inappropriate in reviewing the appointment ofan interested
prosecutor in a case such as this.
Id. at 814 (citing United States v. Sells Engincering, Inc., 463 U.S. 418, 432 (1983)
(prosecutorial use of grandjury to elicit evidence for use in civil case "improper per se")
(emphasis added).
In applying the clear standard set forth by the United States Supreme Court to the actual conflict
which exists in this proceeding, itcannotbe understated how important this issue is, especially in
an investigationof this magnitude. The rightsof President Trump, as well as all others impacted
by this investigation, are now subject to the prosecutorial discretion and decision-making ofa
prosecuting body that even the Supervising Judge acknowledged has an actual, disqualifying
conflict, This is simply untenable. For this reason alone, the FCDA’s Office must be removed
from any further investigation or prosecutionofthis mater.
36
A prosecutor is the administrator ofjustice who should exercise sound discretion and
independentjudgment in serving the public interest and must act with integrity while avoiding
the appearance of impropriety. See ABA Standard 3-1.2. Prosecutors must be circumspect and
not make comments that have a substantial likelihoodof materially prejudicing a criminal
proceeding or that heighten the public condemnationofthe accused, and they should limit
comments to what is necessary to inform the public ofthe prosecutor's action and that serve a
legitimate law enforcement purpose. See ABA Standard 3-1.4; ABA Standard 3-1.10(c); see also
Georgia Rule 3.8(g) (emphasis added). Furthermore, prosecutors should not allow improper
considerations, such es partisan, political or personal considerations, to effect prosecutorial
discretion,nor can theirjudgment be influenced by a personal interest in potential media
attention. ABA Standard 3-1.6(2); ABA Standard 3-1.10(h).
Courts have previously looked at violationsofthe rules of professional conduct in
evaluating whether a prosecutorial conflict exists, and these considerations form the foundation
of much ofthe law on disqualification.” When comments go so far as to address the guilt ofthe
accused, they constitute forensic misconduct thereby requiring disqualification under Georgia
law. See Williams v. State, 258 Ga. 305 (1988) (“improper expression by the prosecuting
attorneyofhis [or her] personalbeliefin the defendant's guilt”) (citing Vermont v. Hohman and
Inre JS. 140 Vt. 230 (1981),
i. The FCDA’s Statements to the Press Violate Prosecutorial Standards and
Constitute Forensic Misconduct.
Since the inceptionofthis investigation, the FCDA has spoken nearly forty times with at
Least fourteen different media outlets about this matter. Ex. S. Even the Supervising Judge noted.
‘The statements served no legitimate law enforcement purpose and heightened the public
condemnationofthe witnesses and those contemplated by the scope of this investigation. See Ex.
s.
Inre JS., 140 Vt. 230 (1981) (“it is unconscionable for a prosecutor representing the people.
to undermine the rights specifically guaranteed in the Constitution he has taken an oath to
uphold”)
24 “When any prosecutor throughout this country is interviewing people trying to determine ifa
crime was committed, andif they understood what they were doing, the mens rea is always
important. So you look at facts to see, ‘did they really have intent?” [or] ‘did they really
understand what they were doing? Detailed facts become important like, askingfor a specific
number and then going back to investigate and understand that that number is just one more than
the number that is needed. It lets you know that someone had aclear mind. They understood
what they were doing, and so when you are pursuing the investigation, facts like that that may
not seem so important, become very important.” Ex. $ at No. 4.
38
Only days before the grand jurors would be charged with investigating whether the
activity under investigation rose to thatof acrime, the FCDA publicly and explicitly stated the
conduct under investigation was in fact criminal * Even after the grandjury was impaneled, the
FCDA continued making public statements that the activities to be reviewed by the newly
constituted SPGJ were illegal26 Most concerning, in September of 2022, while the SPGI was in
the middleoftheir investigation and (we now know, see infra Section V) were permitted to
consume media coverage, the FCDA commented that “credible allegationsofserious crimes”
existed and “people are facing prison sentences.” Id. at No. 37. In each such statement, the
FCDA commented on the ultimate issue the grand jury was impaneled to decide. Given the
SPGP's daily consumptionofthe news media, the FCDA’s comments created a substantial
likelihood of materially prejudicing the SPGI's decision. The FCDA’ expressionof her personal
opinionsofthe criminality of the conduct and the guilt ofthose being investigated rose to the
level of forensic misconduct which creates an actual conflict requiring disqualification. See
Williams v. State, 258 Ga. 305 (1988),
ii. The FCDA’s Online Activity Violates Prosecutorial Standards and Creates the
Appearance
ofImpropriety.
In ts order disqualifying the FCDA, the Supervising Judge noted: “[a]n investigation of
this significance, gamering the public attention it necessarily does and touching so many political
2 4So in this case, you have an allegation ofa human being,of 2person, ofan American citizen,
possibly doing something that would've infringed upon the rights oflots of Georgians.
Specifically from my county—Fulton County—right to vote being infringed upon. And the
allegations, quite frankly, were not a civil wrongdoing, buta crime.” Ex. 5 at No. 22.
2-__.and two, that if we live in a free land ina democracy, we have to have free and fair
elections. And so, I am very concerned that ifbehavior that is illegal goes unchecked, that it
could lead to a very bad start and a very, very bad path... [While discussing the electors] There
are so many issues that could have come aboutifsomebody participates in submitting a
document that they know is false. You can’t do that” Ex. 5 No. 24.
39
nerves in our society, cannot be burdened by legitimate doubts about the District Attomey’s
Motives.” Ex. 4 at 5. He concluded, “[t]he District Attorney does not have to be apolitical - but
her investigations do.” Jd. Further, the Supervising Judge held, “the fact that concer about the
District Attorney's partiality naturally, immediately, and reasonably arises in the minds ofthe
public, the pundits, and ~ most critically ~ the subjectsofthe investigation” is what necessitates
disqualification. Jd. Courts have an interest in ensuring that “legal proceedings appear fair to all
who observe them.” Wheat v. United States, 486 U.S. 153, 160 (1988). A concern for actual
prejudice misses the point, for what is at stake is the public perceptionofthe integrity ofour
v. United States ex rel. Vuitton Et Fils SA. et. AL, 481 U.S. 787,
criminal justice system. Young
812.(1987).
“Justice must satisfy the appearanceof justice," and a prosecutor with conflicting
Ioyalties presents the appearance ofprecisely the opposite. Society's interest in
disinterested prosecution therefore would not be adequately protected by harmless-error
analysis, for such analysis would not be sensitive to the fundamental natureofthe error
committed.
Id. at 812 (quoting Offutt v. UnitedStates, 346 U.S. 11, 14 (1954).
Between the private life of the citizen and the public glare of criminal accusation stands
the prosecutor. That state official has the power to employ the full machinery ofthe state
in scrutinizing any given individual. Even ifa defendant is ultimately acquitted, forced
immersion in criminal investigation and adjudication is a wrenching disruption of
everyday life. For this reason, we must have assurance that those who would wield this
‘power will be guided solely by their sense ofpublic responsibility for the attainment of
Justice
1d. at 814.
A court must consider how the facts would appear to a well-informed, thoughtful and objective
obscrver, US. v. Jordan, 49 F.3d 152, 156 (5 Cir. 1995), and courts should “resolve all doubts
in favorof disqualification.” UnitedStates v. Clarkson, 567 F.2d 270, 273 (4% Cir. 1977),
40
‘The FCDA’s social media activity during the investigation creates the appearance of
impropriety. In July 2022, after subpoenaing a slew ofhigh-profile witnesses, she used her
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Furthermore, the FCDA promoted her own campaign on the shouldersofpartisan support
for this SPGJ investigation? Within a couple
ofdays, the FCDA’s Twitter account increased by
#1 0n July 18, 2022, the FCDA posted the cartoon depicting her fishing Lyndsey Graham out of
a swamp and President Trumpstating, “I know you'll do the right thing for the swamp,
Lyndsey.” The timingofthis post is particularly relevant because, less than two weeks prior, the
SPGJ subpoenaed Lyndsey Graham to testify, and based on the foreperson’s statements, see
supra Section V, the grand jurors were aware of Senator Graham's challenges to that subpoena.
2 On July 11, 2022, political strategist Adam Parkhomenko tweeted multiple times asking for 1)
users to follow the FCDA's twitter account, 2) donations to the FCDA’s campaign, and 3) one-
thousand retweetsofhis requests stating, “I can’tthink of a better way to celebrate after Lyndsey
Graham lost in court today then support the person who is holding them all accountable.” The
FCDA personally replied thanking him for his support on July 14, 2022 and her tweetwas liked
by close to twenty-two thousand followers and retweeted over eight-thousand times, On July 15,
2022,whilecontinuing to solicit followers, Adam again tied his request to this investigation by
postinga Yahoo! News ariel elated fo th target lees sent out that day. The next day, ina
serics of tweets, while noting the FCDA now had fifty-thousand new followers, he again tweeted
a
approximately one-hundred thousand followers, and requests for campaign donations were
retweeted thousandsoftimes. On at least three occasions, the FCDA personally inserted herself
into this Twitter campaign for “followers, tweets and donations” which specifically referenced
this investigation; it is that personal involvement and interest which creates the disqualifying
conflict. The FCDA’s posts do not further a legitimate law enforcement purpose but instead
portray a biased prosecutor with a personal interest.
‘While these posts, if standing alone, might not be sufficient for disqualification, they
‘must be considered in combination with the facts giving rise to the disqualifying conflict
previously found to exist. The Supervising Judge called the FCDA’s behavior in campaigning for
the political opponent ofa named target a “what were you thinking moment” resulting in
“horrible optics” and “problematic” from a disqualification perspective. Ex. 12 at 46. Those
sentiments apply equally to the FCDA’s social media posts which cannot be considered in a
vacuum. The cumulative impact ofthe FCDA’s public behavior casts a shadowofbias over her
office and the entire investigation as it touches upon the same concerns referenced by the
Supervising Judge. /d. (noting the need for the public to believe a “fair and balanced approach”
‘was taken in this “non-partisan” investigation driven only by the facts and following the
evidence wherever it leads.”). The FCDA’s behavior does not paint the picture ofan open-
‘minded, uninterested prosecutor fairly seekingjustice onbehalfof the public. Therefore, in
asking for campaign donations, retweets and followers, this time stating, “her account has
increased by SOk followers this week. She subpoenaed Lindsey Graham. Let's help build her
platform...” On July 17, 2022, as her followers climbed to eighty-six thousand, he tweeted two
additional times asking for more followers. The FCDA again retweeted publicly thanking Adam
for his support, and her tweet was retweeted over twenty-five hundred times and liked by over
fourteen-thousand followers. She then retweeted his original July 11, 2022 post thereby
personally soliciting followers, retweets and campaign donations on the back ofhis requests
which specifically referenced this investigation. Ex. 5 at 8-10.
a2
addition to the actual conflict previously found to exist and the conflict created through forensic
misconduct, this appearanceof impropriety likewise creates a conflict The totalityofthe
circumstances demands disqualification.
On February 13, 2023, the Supervising Judge ordered the release ofa redacted version of
the final report as a means ofprotecting the due process rightsofindividuals who may be named
in such report. Ex. 7. The Court referred to the SPGY process as a “one-sided exploration,” where
lawyers were not allowed to be present, potential future defendants were not allowed to present
evidence in their defense, and, in the wordsofthe court “there was very limited due process in
this process for those who might now be namedas indictment-worthy in the final report.” Id. at
5. The process was “imbalanced, incomplete, and one-sided.” Id. at 5. Accordingly, the
Supervising Judge felt that fundamental faimess required the severe redactionofthe report upon
its release to the public.
On February 21,2023, five days after the Supervising Judge consciously decided to
release only a limited, redacted versionof the SPGJ's report, the forepersonofthe SPGJ decided
to speak with the media — fist, in an interview with the Associated Press, then with the New.
York Times, and then the Atlanta Journal Constitution. Ex. 8. The foreperson then sat for a 42-
minute interview with NBC's Blayne Alexander and was subsequently interviewed live on-air by
CNN's Kate Bouldan that evening. Jd. The foreperson’s now widespread statements have
provided a first-hand glimpse inside the SPGY process ~ an otherwise historically secretive affair.
Additionally, on March 15, 2023, five special purpose grandjurors spoke anonymously to the
3
Atlanta Journal Constitution. Jd. at No. 11. Collectively, the six jurors’ statements reveal a
tainted process incapableof producing valuable evidentiary material and a District Attomey’s
Office who provided constitutionally flawed instructions.
In Georgia, the rules directed to grandjurors as they relate to grand jury secrecy are
relatively permissive compared to otherjurisdictions. 0.C.G.A. § 15-12-67(b). The only
limitation placed on grand jurors is thatjuror deliberations must remain confidential. See Jnre
Gwinnett CountyGrand Jury, 284 Ga. $10, 512 (2008). Membersofthe grand jury are sworn to
“keep the deliberations of the grand jury secret unless called upon to give evidence thereof in
some sortofcourtof lawofthis state.” Id; 0.C.G.A. § 15-12-67(b). Its difficult to takea
scalpel to the work of grand juries and parse out what does or does not constitute deliberations,
but the foreperson seemingly breached that obligation in her public appearances. The foreperson
disclosed grand jurors’ opinions as to the credibilityofwitnesses,” their strategic decisions in
drafting the report,® and general discussions between the jurors.*! She ultimately revealed that
the SPGJ recommended at least twelve people for indictment, Ex. 8 at No. 4. That
recommendation is,ofcourse, the product of deliberations. In fact, the FCDA's Office would
agree, as stated by Assistant District Attorney Wakeford: “The report is the necessary result of
the deliberations of the grandjury.” Ex. 3 at 38
“The collective grand juror interviews also revealed the many outside influences on the
SPGJ during the eight months of their investigation. Specifically, the foreperson revealed that the
Witnesses were “honest,” “forthcoming,” “not very willing to speak,” and “genuine.” Ex. 3.
0 The foreperson stated the perjury section “ended up included there because it was less pointed
ofa suggestion” than the recommendations made elsewhere in the report. Ex. 8 at No. 4.
31We definitely talked about the altemate electors a fair amount, they were absolutely part of the
discussion... We talked a lot about December and things that happened in the Georgia
legislature.” Ex. 8 at No. 2.
7)
FCDA’ Office explicitly told the grandjurors that they were allowed to consume news coverage
related to the investigation during the time period they conducted it. Id. at No. 1. Not only was
the SPGJ permitted to review news coverage, but a grand juror broughta newspaper into the
room every day and pointed out stories about the events under investigation. Jd. The SPGI’s
review of outside material must be analyzed in combination with the improper public statements
contemporancously made by both the FCDA's Office as well as the Supervising Judge. The
foreperson made statements indicating that the grand jurors considered the viability of litigating
legal issues outsideof their purview, indicated knowledgeof how witnesses responded to
questioning in other matters outsideoftheir purview, and that they considered the resources of
the FCDA’s Office in making their decisions which, again, was outside of their purview. The
foreperson disclosed that the grand jury reviewed footage and testimony from the Jan. 6 hearings
and other pending litigation, as well as media interviews by certain witnesses. Based upon that
extraneous information, the grandjurors decided which witnesses to call (or not to call) and drew
assumptions regarding what witnesses might testify (or not testify) to. For example, the grand
jurors assumed, “Trump, had he been summoned would likely have invoked the Fifth
3 The foreperson described prosecutors, in response to witnesses invoking the Fifth, engaging in
what she came to thinkofas a “show and tell” process where they would show videos of that
witness, periodically asking him or her to confirm certain things, and “the scratchingof pens on
paper could be heard as jurors tallied how many times the person invoked the Fifth
Amendment.” Ex. 8 at No. 1. “When people would take the Fifthoverand over, we could kind
of go, ugh” onejuror said. “Not because we're like, oh my gosh you're guilty, whatever. It was
like we're going to be here all day.” Ex. 8 at No. 11.
a
‘The grand jurors’ comments reveal a grand jury that relied upon improper outside sources
and illegally drawn inferences in directing the courseoftheir investigation and rendering their
ultimate decision. Throughout the foreperson’s media tour, and the subsequent statements of
additional grand jurors, it became apparent that this grandjury was improperly supervised or,
worse, improperly instructed from the outset. The public cannot have faith in the impartiality of
this constitutionally unsound investigation. The resultsofthis tainted investigation included in
the final report will negatively impact the due process rightsofthe named individuals, and the
report must be suppressed as it violates the principlesoffundamental faimess.
Additionally, during the courseof the SPGJ investigation, the Supervising Judge indicated bias
on more than one occasion by making prejudicial comments.*® More specifically, he made
improper remarks impacting the Fifth Amendment rightsof the accused. As argued above, this
behavior affected the substantive rightsofwitnesses and non-witnesses alike, including President
Trump.
The supervisingjudge provided interviews to the Atlanta Journal Constitution, the Associated
Press, 11 Alive, CNN, Yahoo! News, and ABC News. See Ex. 9.
3 In speaking about the electors, the Supervising Judge stated, “we're not going to get into
whether they should be surprised or not that they have become the subjectofnegative attention
based on the decisions they made.” Ex. 12 at 20.
48
A. The Supervising Judge Made Prejudicial Statements Regarding Witnesses’
Invocation of the Fifth Amendment.
On July 21, 2022, the Supervising Judge heard argument from counsel for the Georgia
electors who sought to quash their subpoenas. In doing so, counsel argued the electors should not
be required to appear before the SPG in order to assert their Fifth Amendment rights. In
response, the Supervising Judge replied, “butif they did nothing wrong, why aren’t they talking
to the grand jury?” Ex. 12 at 27. Counsel for the electors further argued that, because the
allegations against them related to signing certificates, questions about their name could
conceivably warrant a Fifth Amendment assertion. In response, the Supervising Judge stated,
“That may be something that the Grand Jury may want to know, that this person won't even give
her name under oath. That could be instructive to what the Grand Jury is doing but they wouldn't
knowifthey never met the person.” Jd. at 28. His statements were made in open-court and
streamed live on YouTube to the public. As the Supreme Court held in Ohio v. Reiner, 532
‘The court may not suggest that a witness invoking their Fifth Amendment right is evidence of
guilt. Griffin v. California, 380 U.S. 609 (1965); see also Carter v. Ky., 450 U.S. 288 (1981)
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52
IN THE SUPERIOR COURT OF FULTON COUNTY
STATE OF GEORGIA
IN RE: SPECIAL PURPOSE ) CaseNo.:2022-EX-000024
GRAND JURY )
)
) Hearing Requested
)
CERTIFICATE OF SERVICE
Undersigned counsel hereby confirms that it served the above and foregoing Motion to
Quash the Special Purpose Grand Jury Report, to Preclude the Use ofAny Evidence Derived
Therefrom, and To Recuse the Fulton County District Attorney's Office via email and U.S.
Postage to:
District Attomey Fani Willis
Fulton County Justice Center
Officeofthe District Attomey
136 Pryor St. SW, Third Floor
Atlanta, Ga 30303
Email: [email protected].
SHE]
Findlig Law R
3575 Piedmont R-NE/ Suite 1010
Atlanta, GA 30305
Tel: (404)460 - 4500
drew@thefindlingfirm com
Georgia Bar 260425
Counselfor President Donald
J.Trump
Exhibit 1
January 24, 2021 Order Approving Request
for Special Purpose Grand Jury, In re 2 May
2022 Special Purpose Grand Jury, Case NO.
2022-EX-000024 (Fulton Co. Sup. Court).
4
IN THE SUPERIOR COURT OF FULTON COUNTY
ATLANTA JUDICIAL CIRCUIT )
STATE OF GEORGIA LOEX ODI
Atm
IN RE: REQUEST FOR
SPECIAL PURPOSE A fn Ad
GRAND JURY (otetesrmaton
ORDER APPROVING REQUEST FOR SPECIAL PURPOSE 0
‘GRAND JURY PURSUANT TO 0.C.G.A. §15-12-100, et seq.
The District Attorney for the Atlanta Judicial Circuit submitted tothe judges ofthe
SuperiorCourtof Fulton County a request to impanelaspecial purposejury for the purposes set
forth in that request. This request was considered and approved by a majorityofthe total
‘umberof the judgesofthis Court, as required by O.C.G.A. §15-12-100(b).
IT IS THEREFORE ORDERED thataspecial purpose grandjury be drawn and
impaneled to serve as provided in O.C.G.A. § 15-12-62.1, 15-12-67, and 15-12-100, to
commence on May 2, 2022, and continuing for a period not to exceed 12 months. Such period
shall not include any time periods when the supervisingjudge determines that the special
‘purpose grandjury cannot meet for safety or other reasons, or any time periods when normal
court operations are suspended by orderofthe Supreme CourtofGeorgia or theChiefJudge of
the Superior Court. The special purpose grand jury shall be authorized to investigate any and all
facts and circumstancesrelatingdirectly or indirectly to alleged violationsofthe lawsofthe
State of Georgia, as set forth in the request ofthe District Attorney referenced herein above.
assigned to supervise and assist the special purposegrand jury, and shall charge said special
“This authorization shall include the investigationofany overt acts or predicate acts
relating tothe subjectof the special purpose grandjury's investigative purpose. The special
purpose grand jury, when making its resentments and reports, pursuant to O.C.G.A. §§ 15-12-
71 and 15-12-101, maymake recommendations conceming criminal prosecution as it shal see
fit. Furthermore,theprovisions ofO.C.G.A. § 15-12-83 shall apply.
This Court also note tha the appointment of special purpose grand fury vill permit the
time, efforts, and atention ofthe regulargrand juries) impaneled in ths Circuit to continue to
be devoted to the consideration ofthe backlogof criminal maters that has accumulated as a
result ofthe COVID-19 Pandemic.
ITIS FURTHER ORDERED the thisOrdershllbefiledintheOffice oftheClerkof
the Superior CourtofFlich County
$0 ORDERED, TH] n D iN 2022.
3
CHRISTOPHER i EF JUDGE
Superior Courtof Fulton County
Atlanta Judicial Circuit
Exhibit 2
January 20, 2021 Letter Requesting Special
Purpose Grand Jury
OFFICE OF THE FULTON COUNTY DISTRICT ATTORNEY
ATLANTA JUDICIAL CIRCUIT
136 PRYORSTREET SW, 3RD FLOOR
Tow TH ATLANTA, GEORGIA 30303 THON IE
Diswrict Avorney EE
tiie
‘The Honorable Christopher S. Brasher L022-EX- 000DIT
Chief Judge, Fulton County Superior Court FILED IN OFFICE
Fulton County Courthouse or
185 Central Avenue SW, Suite T-8905
Atlanta, Georgia 30303 wba
Sco ar
January 20,2022
DearChief Judge Brasher
hope this letter finds you well and in good spirits. Please be advised that the District Atomey’s
Office has received information indicating a reasonable probability tha the StateofGeorgia's
administrationofelections in 2020, including the State's election ofthe President ofthe United
States,was subject to possible criminal disruptions. Our offce has also learned that individuals
associated with these disruptions have contacted other agencies empowered to investigate this
matter, including the Georgia Secretaryof State, the Georgia Attomey General, and the Urited
States Attomey’s Office for the Northern Distict ofGeorgia, leaving this office asthesole
agency withjurisdiction tha s not a potential witness to conduct related to the mater. As a
result, our office has opened an investigation into any coordinated tempts to unlawfully alter
the outcomeofthe 2020 elections in ths state.
We have made efforts to interview multiple witnesses and gather evidence, and asignificant
number of witnesses and prospective witnesses have refused to cooperate with the investigation
absenta subpoena requiring their testimony. By wayof example, Georgia SecretaryofState
Brad Raffensperger, an essential witness to the investigation, has indicated that he will not
participate in an interview or otherwise offer evidence until he i presented witha subpoena by
my office. Please see Exhibit A, attached to this letter.
Therefore, Iam hereby requesting, a th elected District Attomey for Fulton County, pursuant
100.C.G.A. § 15-12-10 et. seq., that a special purpose grandjury be impaneled for the purpose
ofinvestigating the fact and circumstances relating directly or indirectly to possible temps to
disrupt the lawl administration of the 2020 elections in the Stateof Georgia. Specifically, a
special purpose grandjury, which vill not have the authority t0 return an indictment but may
make recommendations concerning criminal prosecution as it shall sce fi, is needed for three
reasons: first, a special purpose grandjury can be impaneled by the Court for any time period
required in order to accomplish its investigation, which vil likely exceed a normal grand jury
term; second, the special purpose grandjury would be empowered to review this matter and this
‘matter only, with an investigatory focus appropriate to the complexityofthe facts and
circumstances involved; and third, the sittinggrand jury would not be required to attempt to
‘address this matter in addition totheirnormal duties.
Additionally, I am requesting that, pursuant to O.C.G.A. § 15-12-101, & Fulton County Superior
Court Jud beassign
ge edtoassist and supervisethespecial purposegrand juryin carryingoutits
investigation and duties.
Thave attached a proposed order impaneling the special purpose grand jury for the consideration
of the Court.
gore
coo\ WIA,
Jah vw
District Attomey, Atlanta Judicial Circuit
‘Exhibit A: TranscriptofOctober 31, 2021 episode ofMeet the Press on NBC News at 26:04
(video archived at https:/www,‘youtube.com/watch?v=B71cBRPgt9k)
‘Exhibit B: Proposed Order
‘Well, there's nothing to recalculate becauseifyou look at the numbers, the numbers are the
numbers. And so you can slice that, dicethat anyway you want. But at the endofthe day,
President Trump came up 11,300 votes short. AndI had the numbers. Here are the real facts,
though, 28,000 Georgians did not vote for anyone for president ofthe United StatesofAmerica
in Georgia. They skipped. They didn't vote for Biden. They didn't vote for President Trump. They
didn'tvote for the libertarian Jo Jorgesen. Theyust leftitblank. And Senator David Perdue got
20,000 more votes in the metropolitan areas ofthe met--ofmetropolitan Atlanta and Athens.
And that really tells thebig storyofwhy President Trump did not carry the stateofGeorgia.
CHUCK TODD:
‘The Fulton County district attorney has beeninvestigating whether the president did break any
laws in that phone cal to you. Have you ~ I know youve turned over documents and various
things. Haveyoubeen interviewed by investigators? You hadn't the last time we talked. Have you
since?
BRAD RAFFENSPERGER:
No, Ihaven't been.Ithink she's busy with other matters. She has an awful lotof other cases that
she inherited. But we fully complied, sent al the documents that we had, and she actually talked
tosomeofourstaffmembers. So ifshe wantstointerview me,there'sa process forthatand I
willgladly participateinthat because Iwantto make sure that Ifollowthelaw,follow the
Constitution. And when yougeta grandjury summons, you respond to i.
CHUCKTODD:
INRE:
SPECIAL PURPOSE GRAND JURY
ORDERIMPANELINGSPECIALPURPOSEGRANDJURY
PURSUANT TO O.C.G.A. § 15-12-10, ET SEQ.
Pursuantto the requestofthe District Attorneyfor the Atlanta JudicialCircuitto the Judges
of the Superior Court of Fulton County to impanel a Special Purpose Grand Jury under the
provisions of O.C.G.A. § 15-12-10 et seq., for the purpose of investigating the facts and
circumstances surrounding potential disruptions to the lawful administrationofthe 2020 elections
in the Stateof Georgia, including the election ofthe Presidentofthe United States; and
‘Honorable NAME, to commence serving on May 2, 2022, not to exceed 12 months under this
Order,exclanytimeperiodsw
uding henthesupervising judgedeterminesthattheSpecial Purpose
Grand Jury cannot meet for safety or other reasons, or any time periods when normal court
and circumstances relating directly or indirectly to alleged violationsof the lawsof the State of
Georgia intended to change, disrupt, or influence the administration or outcome of the 2020
General Electionin Georgia and its subsequent runoff, during the period from January 20, 2017,
othe present day. This authorization shall include the investigation ofany overt acs or predicate
acts relating to the subjectofthe Special Purpose Grand Jury's investigativepurpose. The Special
Purpose Grand Jury, when making its presentments and reports, pursuant to O.C.G.A. §§ 15-12-
71 and 15-12-101, may make recommendationsconcerningcriminal prosecution as it shall sce ft.
Furthermore, the provisions of 0.C.G.A. § 15-12-83 shall apply.
IT IS FURTHER ORDERED that this Order be filed in the Officeofthe Clerk of the
Superior CourtofFulton County, Georgia, and published in the newspaper ofrecord.
SO ORDERED, this DATE,
f ) 2022-EX-000024
| aeesanices:
| N BEHALF OF THE STATE:
TT KARENRIVERS,RWR, RPR,CCR-Z575
OFFICIAL COURT REPORTER
i FULTON COUNTY JUSTICE CENTER TOWER
| 185 CENTRAL AVENUE, S.W.
i ATLANTA, GEORGIA 30303
1
I
| |
to
THE COURT: So, Mr. Ney, if I could have |
the appearance for the State. |
2
anticipate it will be Donald Wakeford. |
THE COURT: Great. Well, welcome all of |
you.
| |.
know later on what I think. |
MS. WILLIS: Fair enough. |
; THE COURT: Excellent.
MS. WILLIS: Back in May of last year,
the Honorable Chief Brasher swore in 26 members of
the public to create a special purpose grand jury.
Their entire function was to be an imvestigative
tool. And we are very very thankful to those |
citizens. As you and I both know, they gave up a
J great deal of their time. Hopefully, you and I can
1 agree on that.
| 6
| everyone in the courtroom's rights. Having been
|
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|
| make a decision as to whether we would ask for a |
Ep
2 that deliberations are kept secret. You, had you |
24 been present for anything that happened in front of|
| .
| |
| .
| |
| it's secret statutorily the final report. And then
| »
24 purpose grand jury's in someways point to how
| |
|
fine example. The ambit of the authority for the |
| epeciai purpose sxand Jury in erat case vas to Look]
into a civil investigation. That is not what this |
J I
| out by the intervenors' in their submission to the |
|
| court. Which is that 15-12-80 is specifically |
3 conflict. |
; MR. WAKEFORD: And the other term --Well,|
it's specifically in conflict, I would say the term
they use is report, it is not general presentment. |
Now, understand the position of the inervenors'.|
2 We'xe not closing our eyes to their position that |
1 come on, there's no distinction between a report
1 and a general presentment. I would refer you,
1 though, to where I began, which is that in this |
Ei situation the law has created a situation where |
1 special purpose grand jury can return something |
18 that is either special presentment, a general |
1 presentment or has elements of both. And so it
1 just cannot be considered to not be in conflict
1 with 15-12-80, which says general only.
p THE CURT: If it has elements of both |
2 then are the general presentment elements
| I 2s
| |
prosentaenc. I think you ould still be arguing |
what you're arguing. Even though they called it
| Ir
|
| |
|
witnesses who came to the grand jury and spoke the |
truth to the grand jury. |
THE COURT: So, how do = how does one
, reconcile this prospective with the parallel highly|
public proceedings with the January 6th sommissiont|
i Many of the same witnesses hopefully saying similar|
things if they were asked the same question, but
that's not my business, and the commission actually
1 referring to the Department of Justice, you need to|
1 look at these people for these things. Dangerous. |
1 Pressure on the Department of Justice. They seem
15 to withstand that, and they're doing what they're
1H doing. Maybe they'll bring charges, maybe they
i won't. Those were recommendations. I think they
1 were called referrals. But clearly congress, one
1 branch, doesn't tell the executive DOJ, another
1 branch, what to do. But there was nothing
1 clandestine, secret, tucked into a report that the |
2 public didn't get to see about that process. And
2 that's different. That was not a special purpose
2 grand jury. But that is another situation that has
2 been ongoing that I think I need to assess and
2 reconcile with how it's happening here. Our
| LI 11
y that, and so the way the District Attorney explored]
4 vas aroun the one means sho had, 0 spociai |
purpose grand jury. Parts of it secret. Some of
it, maybe not. But this danger and impact balance
it against the fact that the January 6th commission
seem to do what it did and DOJ didn't have to shut
down after those referrals came.
MR. WAKEFORD: Well, first of all they
, were looking at issues in a different light than
1 the special purpose grand jury was asked to look at
1 them. Obviously, Congress addresses the entire
1] nation. Special purpose grand jury is focusing on |
1 Georgia and possible criminal activity within the |
1 state of Georgia or the touches upon the state of
1 Georgia. Additionally, Congress doesn't have to
1 contend with 15-12-101 and 102. I'm not making
1 fun. We are traveling under the law here. So
I
1 MR. WAKEFORD: I would also add, your |
1 Honor, that while by the necessity of the laws |
1 governing serving subpoenas in different states |
1 some of the witnesses have been made public. But |
1 the public does not know who the witnesses were for|
|e me ee
1] There is no presumption of public access to those.
] mmm
1} MR. WAKEFORD: I mean, Rule 21. In re:
dm
Al the grand 3ury in open court at the conclusions of
Iss
|
|
2 be presented in open court, including special |
prasentnents and indictuents. Here, the ropore |
under 13-12-71 had to be presented in open court |
> and actually already had been. That is not a
; requirement under 15-12-100 or 101. The only
requirement for the final report is that it go to
you as the supervising judge, and them in this case
gy go to the jury District Attorney as recipient of
| me |
1 court requirement for special purpose grand jury |
1 reports. It's just not there. And the Gwinnett
pi to be a part of. |
i 39
|
| appeal of an order that I would enter forbidding
: them from talking about the contents of the final |
report? It gets appealed. Restrain of speech,
| |
i I a4
| |
a
issued a report and the jurors themselves have
asked for it to be published. There's enormous
public interest in what they have said, and that
exist in this state. It exist the across nation.
i I as
| |
| |
in 2020. That was something that the District
; Attorney asked for. Had to pull some levers to do |
that, judicial levers. But it was executive branch
|
probably will be published by putting it in the !
| Iss
|
|
roe.|
So I'm not necessarily seizing upon the same one. |
|
i 56
| pressure, 12 you will. The grand jury Leselt said
you need to publish it. And if one travels to
2 approach? |
| | ow
| THE COURT: You may. |
|
MR. CLYDE: Where I put the blue tab is |
hore sudge Clark has ordered this special purpose |
grand jury report to be published in the legal
orbit. It is an example -- and I would say that
just as == in a sense I would think that the two
special purpose grand Jury reports that ae before |
: the Court are in a sense examples of the two ends
of the spectrum. Obviously, in the Dekalb special
19 purpose grand jury they recommended prosecutions of
1 2 named individual. And that was disclosed and
1 published by Judge Adams in the Dekalb situation.
1 In the Gwinnett situation, this is a grand jury |
1 that found a great deal of discomfort and
1 criticized various aspects of the land purchasing
1 decisions made by Guinnett, but generally is not
1 recommend prosecution, is moving in the other
18 direction. But in both cases they were published
1 in their entirety at the direction of the
2 supervising court judges in both cases. These are |
24 special purpose grand jury's.
2 THE COURT: So these would be then |
2 examples that it is possible to do it, and I
24 assumed it had been legally challenged, and -- and
2 a higher court had said the trial judge was in
| |
i
|
A error to do that, then Mr. Wakeford would have |
| cooun ne those optntons. 0 those ase out these.
8 But what about his argument that if —- and I know
I seu come now the comant of tne sion supose sor
[cots ot geet rensons. sue enat about the sxgumens
: at the contents shania drive the decision makin |
i process? |
i MR. CLYDE: So, your Fomor, I'm going to |
Ise
TT en|
| interested in whether it was made public. I was |
interested in getting Judge Scott out of my |
courtroom.
MR. CLYDE: And the only thing I want to
; point out is Burrell Ellis is ultimately prosecuted|
: for perjury in the aftermath of that special |
purpose grand jury based on his testimony that was |
presented at that special purpose grand jury. He's
; prosecuted. He is --there's a verdict. He was |
1 convicted at trial. And he ultimately on appeal --
1 parts of his conviction are affirmed. Parts of it
4 are reversed. But there's nowhere in that opinion,
1 and that opinion does recount the history of !
1 special purpose grand jury, that it is anyway i
1 critical of the release of the report nor did
4 Burrell Ellis and his counsel ever make any
1 argument that the release of the report somehow put,
1 him in an impossible position at his trial. It was
1 “= it obviously as the Court has pointed out there |
2 hasn't been a decision directly on point with the |
2 issue that we're taking on today. But it is an
2 example of somebody who is prosecuted in the
a.
a supports. We believe the Court is within its
rights to read the report. If this grand jury and
to be made public.
1 The second part is does the Court have
1h the authority to seal under Rule 217 Absolutely, it]
dome mun it has to meer the fale 71 sundszes. |
3 And there is the -- there is -- the argument that
3 expression of discomfort or ==
4 THE COURT: I fully understand it. I
to be made public. |
; MR. CLYDE: And your Honor, I guess we
would say it's not just a lighter presumption; it
doesn't meet the standard. In other words, the
discomfort of the prosecuting authority in
disclosing court records isn't enough to make them |
sealed. It has to be significant identifiable !
evidence that's going to cause a problem. And your
Honor, I don't think that submission has been made.
1 THE COURT: I have a question about that
1 standard. In your brief, page 18, you use the {
1 phrase "clear and convincing proof." And clear and|
4 convincing evidence, that is a standard out there |
1 which is different from a preponderance. Much more
1 than that. It's not well-defined. It's less than
1 a reasonable doubt. It's actually what the JQC has)
1 to use for judges. "Clear and convincing," and
5 thats the phrase you used. It's a whole lot more
pt than a preponderance. And I'm wondering if you |
2 have case law for that or it was just a colorful |
2 phrase trying to show that there is a burden that
2p the parties seeking to seal something has to meet. |
2 #3 thor ia. But I'm nes Samilise wish it aeing |
2 clear and convincing evidence. That is a higher |
2 burden than I weigh it and find in which way do ™
63
I |
|
| scales lean. Where is the preponderance? Sealing |
and not sealing. And that's why I was saying the |
District Attorney's concern about timing and not 1
process, I'd let the weight that you can put on the|
| | @
|
1 deliberations, but I also can't talk about what any|
3 witness testified abouc. In particular, I want to
pS deliberations.
2 that question. i
2 MR. CLYDE: It's a step too far. In |
2 other words, as the Court has indicated the outcone|
| [I
| of grand jury process, the outcome of those |
deliberations is a public document and |
historically. And so that process of the
deliberations and an outcome gets rendered to the
: court system is a significant and important step in
the process, but I don't think you could seal the |
final report as being part of their deliberations. |
and candidly, T think the statement by the special |
, purpose grand Jurors that they wanted their report |
1 published speaks to that. I don't think they see
1 it as an exposure of their deliberations. They see
1 it as this is the judgment -- I read it as they see
1 it. This is the judgment that we've reached, and
1 that's what the court system historically said that|
2 pursuant to 15-12-80. |
2 THE COURT: All right. Ms. Gaither, |
2 anything you want to add? Did he cover it?
| =:
| |
1% with the Forsyth case, 166 Ga. App. 340. I'll read)
| -
| thie cose to the District Mvtormey. That would — |
significant, but mainly that we are not in the
cealm of a general presentment and certainly my
comments about the content guiding the analysis
[I
| 78
|
1 concluded.) |
; |
j} |
. i
:
2
| | |
{
2| |
i
25 |
:; |
|
Exhibit 4
July 25, 2022 Order Disqualifying District
Attorney’s Office as to Senator Jones Only,
In re 2 May 2022 Special Purpose Grand
Jury, Case No. 2022-EX-000024 (Fulton Co.
Sup. Court).
FILED IN OFFICE
On 20 January 2022, the District Attorney of Fulton County petitioned the Chief
Judgeofthe Superior Court of Fulton County to convene the Superior Court bench to
consider approving the District Attorney's requestfor impaneling a special purpose grand
jury to investigate possible criminal interference in the November 2020 general election
in Georgia. On 24 January 2022, theChiefJude, having receivedamajority
ofthe tweaty
judges” assent, issued an Order authorizing the special purpose grand jury. Among the {
various instances of possible electoral interference this body would be investigating was i
the decision by State Republican party officials to draft an alternate slate of Presidential |
One of the more prominent persons who chose to participate in this scheme was State
On 2 May 2022, the special purpose grand jury was selected and sworn in; in June
2022 it began receiving evidence.' The District Attorney serves as the ‘legal advisor” to
the grand jury; she and her team of prosecutors also largely shape the grand jury's
investigation by subpoenaing witnesses and leading their questioning. As forecast, the
District Attorney and thus the grandjury ~ began to investigate the alternate electors
Nota
theDistric
bltAttorne
y,y plained her pause in initiating the special purpose grand jury's
onean Sa Fa rooor otc EBB
1
stratagem. The District Attorney has issued subpoenas to at least twelveofthe alternate
electors, including one to Senator Burt Jones, who is the Republican candidate for
Lieutenant Governor in the upcoming 2022 general election.
Senator Jones has fled a motion to disqualify the District Attorney and her office :
from further investigation into his connection to the apparent efforts to interfere with or
otherwise undermine the outcome of the 2020 general election. Eleven other alternate
electors have jointly filed a motion to quash their grand jury subpoenas, asserting their
Fifth Amendment privilege against compulsory incrimination. Senator Jones
‘subsequentlyjoined in his fellow electors’ motion and they adopted his. On 21 July 2022,
the Court held a hearing on these motions. Based on the arguments and evidence
% presented, and a review of relevant legal authorities, the Court GRANTS Senator Jones's
‘motion to disqualify the District Attorney and her office ~ as to Senator Jones only. The
Court DENIES the motion to disqualify as to the other eleven alternate electors and also
"DENIES the motion to quash as to those eleven.* i
| DISQUALIFICATION |
On 24 May 2022, Senator Jones won outright the Republican primary for |
Lieutenant Governor, earning over 50% of the vote.2 On the Democratic side,a runoff
was necessary, as Kwanza Hall, thetop vote getter, secured only 30%ofthe vote. Trailing
i him with 18%of the vote was the second-place finisher, Charlie Bailey. Hall and Bailey
| On 14 June 2022, well after the grand jury had begun receiving evidence from
| witnesses called and examinedbytheDistrictAttorney's teamofprosecutors, the District |
Attorney hosted and headlined a fundraiser for Bailey. By this time, media coverage of
the grand jury proceedings was national and non-stop and the District Attorney was the
! very public face of those proceedings. She also was one of the faces on the Bailey
fundraiser announcement: it prominently featured the District Attorney's name, photo,
and title and was widely shared on Bailey's campaign's social media outlets. The
fundraiser appears to have been a success, earning Bailey's campaign thousands of
| dollars. It is important to note that, as counsel for the District Attorney rightly pointed
out at the hearing on the motion to disqualify, the fundraiser was entitled a “Runoff
| Fundraiser” and occurred when Bailey was battling Kwanza Hall for the Democratic
nomination. But more relevant -- and harmful ~ to the integrity of the grand jury
| investigation is that the die was already cast on the other side of the political divide:
‘whoever won the Bailey-Hall runoffwouldface Senator Jones. Thus, the DistrictAttorney 1
The District Attorney als, a private ciisen and in her persons capacity only, donated to Bailey's
campaign,SenatorJones points 0 this private donation a anotherbasi or disqualification. Alone that
San msuificent basisfo dsqualfction. Se, e.. Capértonv.47. MasseyCoalCo Inc, 556US.868,
364 campaign
(Not everyGude
(3009) cuss) contibtion by5 gant o aiomey crates a probabiy ofbias tha
requires.
Where rls sre more stringent). However, it docs50ad(2013)
b. State, 289 Ga. 46, to the(same)
weigh(bothcases involvecreated
of the conflict Judicialby the
recusals,
more
tensive, diset, publi, and job-related campaign work the District Attorney performed on behalf of
Candi Bay
3
“Thischoice whichtheDistrictAttorney waswithin her rights asan elected official
to make -- has consequences. She has bestowed her office's imprimatur upon Senator
Jones's opponent. And since then, she has publicly (in her pleadings) labeled Senator
Jones a “target” of the grand jury's investigation.s This scenario creates a plain - and
actual and untenable conflict ¢ Any decision the District Attorney makes about Senator
Jones inconnection with thegrandjury investigation isnecessarily infected by it. To label
Jones a target or merely a subject, to subpoena him or instead allow him to proffer, to
| question him aggressively or mildly, to challenge or accept invocations of legislative
privilege or assertions of Fifth Amendment privilege, to immunize or not - eachofthese
critical investigative decisions is different for him because of the District Attorney's
actions taken on behalfofthe Senator's electoral challenger. Perhaps the evidence shows
that there should be a tighter, stricter focus on Senator Jones than on some of the other
alternate electors? Yetanyeffort to treat himdifferently — even ifjustified will prompt
|
5The designation, borrowed from federal criminal practice, sa bit confusing in the context of this grand
Jury,
Signalwhich has Distict
that the nG power tobringcriminal
Atomney chargesagainst
viows Senator anyone.Its
Jones (andth nonetheless
other alternate a potent
clecors) investigative
3s persons more
closdly connected to the alleged electoral impropricties than other itnescs who have come before the
grandjury o whomay yetdoo. |
© The Court appreciates the affidavit provided by Robert Smith, General Counsel for the Prosecuting
Attorneys” Counll ofGeorgia, on bell ofthe District Attorney. His reliance on Whincorth v. State, 75
(Ga. App, 79 (2005) and Ba. of Edi. Nyquist, 590 F.2d 1241, 1247 22 Cir. 1979) is intrucive but not
persuasive. Ho i cores that 3 mere appearance of impropriety s generally not enough to support
Gisqulifcation, except,a note in Nyquist, in the “rarest ofcases Thisison ofthosecass. But its
lio case where the conflict is actual and palpable, not speculativeand remote.
2 This is an entirely plausible scenario given the Senator's politcal experience and public responsibilty.
“Thats, theDistrictAttorney(or th grandjury) decides that participation nthe karate lector scheme
constituted impermissible interference in the 2020 general election, someon of the Senators public
Stature influence, and presumed sophistication ought obetrated differently from an alernate lector
Who hadnorepresentaiv responsibility andwhoparicipated i thesche merely outofpartisan loyalty.
4
entirely reasonable concerns of politically motivated prosecution: is Senator Jones being
singled out becauseof a desiretofurther assist the Bailey campaign?®
Of course, the actual answer does not matter. Its the fact that concern about the
District Attorney's partiality naturally, immediately, and reasonably arises in the minds
of the public, the pundits, and -- most eritically -- the subjects of the investigation that
necessitates the disqualification. An investigation of this significance, gamering the
public attention it necessarily does and touching so many political nerves in our society,
cannot be burdened by legitimate doubts about the District Attorney's motives. The
District Attorney does not have to be apolitical, but her investigations do. The Bailey
fundraiser
shesponsored - in her official capacity
--makes that impossible when it comes
to investigating Bailey's direct political opponent.’®
| ‘The Court GRANTS Senator Jones's motion to disqualify the DistrictAttorney and
her office. This District Attorney and her special prosecution team may no longer
| investigate Senator Jones in the following sense: they may not subpoena him (or seek to
- i
Candidate Bailey has wielded the District Atorney's investigation ss 2 cudgel in bis campaign against
Jones. define:
See, eg. hitps//sowwajc.com/politics/contrasis-on-voting-lavs-and-ballo-aesess
‘seorgia-candidates/7QT7XHSAGNGVXBNQPZ64AX560U in which Bailey is quoted as saying “The only
an secur sections people ie urs Jones, who corse i and subsite the will or the
lof thesufvoters and ty to overs the election.”
Sine
» Nori it knowable, which s another reason to separate the District Attomey and hee off from any
nestgition itoSenatorJones.An”actual conflictdoesnot mea tha Senator Jones hsdene root
haaninvestigative decision wis made explcy to benef candidate Bailey. This carey if ver, occurs,
Sheenwiretaps or leaked e-mail. The confit s “actual because any pubic civinal investigation into
Senator Jones aly bent candidate Bfley'scampaign,of which the District Attorney ian open, avid,
ond official supporter.
1 Senator Jones also sought to disqualify Special Prosecutor Nathan Wade for a campaign donation he
madeto Charlie Baileys eanir aborted campaign fo Attorney Genera. As discussed ove, a routine
Campaign ontsbutin is Ro enough and dhs one was to » different crpagn logethe, with no
Connection oSenator Jones
1When the lectedDistrict Attomeyidisqualified, s, to, ser entre offic. MeLaughlnv. Payne, 295
Ga. 609,613 (010).
5
|
obtain any records from him via subpoena), they may not publicly categorize him as a
subject or target (or anything else)ofthe grandjury's investigation, and they may not ask
the grandjury to include any recommendations about him i theirfinal report. This does |
not mean that the District Attorney cannot gather evidence about Senator Jones's |
involvement in efforts to interfere vith or undermine the 2020 general election results.
| Her office may ask witnesses about the Senators role in the various efforts the State
Republican party undertook to call into question the legitimacy of the results of the
election. What her office may not do is make useof any such evidence to develop a case
against the Senator. That decision, as to whether any charges should be brought, and
what they should be, will be left toa different prosecutor's office, as determined by the
Attorney General.
“The Court DENIES the motion to disqualify as adopted by the other eleven
dlectors. There has been no showing that the District Attorney or any member of her
prosecution tea is impaired by a conflict of interest vis-d-vis any of these individuals.
One of those eleven, Shawn Still, is running for the State Senate but he has offered no
evidence that the District Attorney or anyone else from her office has materially supported
cither his campaign or the campaign of his opponent
= Counselfo the ceven als aed the specter oftheDistrictAttorneyireleasing the spel prosegrand
Sus Fol report on th cvofthe November 2022 general secon a efor 0 savaniage bemocrate
Liniidates over Republican ones. Apa from afin no bassfo this claim bevond unsubstantiated
ears, counsels concern displaysa misunderstanding ofth ivesigativ grandjury proses.The rand
Su wil propre ina Tal That Teport 1s eased
action (or inaction).majority
report recommendingJus, to the
nein who toten pate it oth Chiewil he fort Only fe3 theofthe Superior Court bench
Sie the gHrybein this dissolution
ebscqent vote undersigned b released to DistricttheAormey, O.C.GA
§1512101(0). The wil not proces ator near ime ofthe 2022
Somerton, should th sandoy compet s workbythen.
6
| QUASHAL
The eleven other alternate electors have moved to quash their subpoenas on the
basisof their collective, blanket assertionoftheir Fifth Amendment privilege. This group.
assertion came after the District Attorney upgraded their status from witness to target in
late June 2022 (followingseveral alternateelectors’ voluntary interviews with the District
Attorney's team (and the Bailey fundraiser)). These eleven now characterize the |
subpoenas for their testimony as “unreasonable and oppressive.” The Court disagrees.
Counsel for the eleven presented several creative legal arguments concerning the possible
(im)validity of future charges that might conceivably be brought against these alternate
electors. While intriguing, such argumentation is premature. This grand jury has no
authority to bring charges. Kenerly v. State, 311 Ga. App. 190 (2010). It is merely
| investigating who did what after the 2020 general election and developing a perspective i
| about whether anyone's post-election actions merit criminal prosecution in Fulton |
| County. |
“The eleven electors’ conduct falls well within the reach of this broad charter. Its |
1 not unreasonable toseek their testimony anditis not oppressive to require an appearance i
by way of subpoena. Nothing about that process deprives the electors of theirFifth |
Amendment privilege, which they may freely assert as applicable when they appear
‘before the grand jury.» Their subpoenas will not be quashed. See BankofNova Scotia
v. United States, 487 U.S. 250, 258-59 (1988); State v. Lampl, 296 Ga. 892, 898-99
=Gamoetfothecoven revealedatth a1 uly 2033 hein that hee advice o her cent willbetoasert
DE of the dectos
ca be Tod at th time ry appestances. See State b. Pad, 309 Ga. 10, 135 (2020)
inre ok en Bn sods, ne fh ion of Hn
7
(2015) (targetofgrand jury investigation may be compelled to appear before grand jury);
0.C.G.A. § 24-5-506(a) (only persons charged with the commissionof a criminal offense
are not compellable to testify).
SO ORDERED this 25% dayof July 2022.
Pil
HT oA
JidgeNobert C.1. McBurney
1 Superior Court of Fulton County
Atlanta Judicial Circuit
| |
| i
eo |
|
Exhibit 5
List of Media Appearances and Social
Media Posts by FCDA and/or FCDA’s
Office
List of Media Appearances and Social Media Posts by FCDA and/or FCDA’s Office
1. January 4, 2021 - Jerry Lambe, This is the Democratic DAfor Atlanta Looking to Investigate
Trump's Phone Call with Georgia's SecretaryofState, LAW AND CRIME (Jan. 4, 2021),
hitps:/lawanderime,com/2020-election/this-is-the-democratic-da-for-atlanta-lookingto-
investigate-trumps-phone-call-with-georgias-secretary-of-state/; see also Justin Gray
(@lustinGrayWSB), Twitter (Jan. 4, 2021, 11:10 AM),
hitps://twitter.com/JustinGrayWSB/status/134612690314140877225=20. (FCDA called “the
President's telephone call with Georgia SecretaryofState disturbing... anyone who commits
a felony violationofGeorgia law in myjurisdiction will be held accountable.”)
2. February 10, 2021 - Christian Boone, Greg Bluestein, Fulton's DA opens criminal
investigation into Trump attempt to overturn Georgia's election, ATLANTA JOURNAL-
CONSTITUTION (Feb. 10, 2021), htps://ww.ajc.comypolitics/fultons-da-opens-criminal-
investigation-into-trump-demand-to-
overtumelection/YWJPS4B4BREHDLHQCZYDDWBVIA/2d. (FCDA would not say
‘whether anyone else besides the president was under investigation but stated she had no
reason to believe that any Georgia official is a targetofthe investigation.)
3. February 12,2021 - Fox 5 Atlanta, Exclusive: Filton County district attorney on decision to
‘open investigation into Trump call, YOUTUBE, (Feb. 12, 2021),
hitps//www.youtube.com/watch?v=mK cczSoStKS.
4. February 12, 2021 - Rachel Maddow, MSNBC, Gd Probe Of Trump Likely ToLook Beyond
Raffensperger Call: Fulton's D.A. Willis, YOUTUBE, (Feb, 12, 2021),
hitps://www. youtube,com/watch?v=1Qz_v2hmtHQ. (FCDA discussed the investigation and
stated, “When any prosecutor throughout this country is interviewing people trying to
determineif a crime was committed, and ifthey understood what they were doing, the mens
reais always important. So you look at facts to see, ‘did they really have intent?” [or] ‘did
they really understand what they were doing?” Detailed facts become important like, asking
foraspecific number and then going back to investigate and understand that that number is
just one more than the number that is needed. It ets you know that someone had a clear
‘mind. They understood whet they were doing, and so when youare pursuing the.
investigation, facts like that that may not seem so important, become very important.”)
5. February 13, 2021 - Danny Hakim, Richard Fausset, In Georgia, a NewDistrict Attorney
Starts Circling Trump and His Allies, NEW YORK TIMES (Feb. 13, 2021),
hitps://www.nytimes.com/2021/02/13/us/politics/fani-wills-trump.html. (FCDA was “open
to considering notjust conspiracy but racketeering charges” and even “criminal solicitation
to commit election fraud.” She explained that RICO charges apply to otherwise lawful
organizations that are used to break the law,
ifyou have various overt actsforan illegal
purpose,I think you can — you may — get there.”)
6. February 10, 2021 - Danny Hakim, Richard Fausset, Georgia Prosecutors Open Criminal
Inquiry Into Trump's Efforts to Subvert Election, NEW YORKTIMES (Feb. 10, 2021),
hitps//www.nytimes.com/2021/02/10/us/politics/trump-georgia-investigation html.
1
7. February 19, 2021 - Christian Boone, Tamar Hallerman, New Fulton DA balances Trump
probe, massive local workload, ATLANTA JOURNAL CONSTITUTION, (Feb. 19, 2021),
hitps://www.ajc.com/news/crime/new-fulton-da-balances-trump-probe-massive-
Tocalworkload/AHWEA3OAIFESSCTWBGLQBMSSR4. (FCDA suggested she had no
timetable for the investigation or her decision about whether to bring charges against
President Trump. She insisted politics played no role in her probe stating that she took “no
pleasure in this,” and commented, “who else is going to do it. Nobody is above the law.”)
8. February 25, 2021 - Kate Brumback, Georgiaprosecutor investigating Trump call urges
patience, FOX5 ATLANTA (AP), (Feb. 26, 2021), htps://sww.foxSatlanta.com/news/georgia-
‘prosecutor-investigating-trump-call-urges-patience (FCDA discussed various aspectsof the
investigation and called the resignationofByung J. ‘Bjay’ Pak “particularly peculiar.”)
9. February 25, 2021 - Associated Press, Georgiaprosecutor discusses election inguiry,
‘YOUTUBE (Feb. 25, 2021), http://www. youtube.com/watch?v=2KfEQXsSWZE.
10. February 25, 2021 - Associated Press, Georgiaprosecutor discusses election inquiry,
YOUTUBE (Feb. 25, 2021), hitps://www. youtubecom/watch?v=2K FEdxsSw2E.
11. March 8, 2021 - Dale Russell, Fulton County DA talks to the Fox 5 I-Team about Trump
‘grandjury investigation, FOX 5 ATLANTA (Mar. 8, 2021),
hitps://vwwvw.foxSatlanta.com/news/grand-jury-investigation-of-former-president-trump-set-
to-begin.
12. September 8, 2021 - Closer Look With Rose Scott, District Attorney Willis Discusses COVID
Crime Across Fulton County, NPR-WABE, (Sep., 8, 2021),
https://www.npr.org/podcasts/832218152/closer-look-with-rose-scott.
“13. September 17, 2021 - Sara Murray, Jason Morris, Georgia criminalprobe into Trump's
attempts to overturn 2020 election quietly movesforward, CNN (Sep. 17, 2021),
htps:/www.can.com/2021/09/17/politics/georgiz-probe-trump-election/index html (FCDA
states, ”I do not have the right to look the other way on any crime that may have happened in
‘my jurisdiction.” She further comments that she hopesto strike a formal cooperation
agreement with congressional committees investigating the insurrection stating, “itis
certainly information my office needs to see.”)
14. September 28, 2021 - Janell Ross, Atlanta’s First Black FemaleDistrictAttorney Is at the
CenterofAmerica’s Converging Crises, TIME, (Sep. 28, 2021),
hitps//ime.com/6099301/fani-willis-atlanta/ (She explained the moment when she heard the
call and had oneofthose, Wait. What in the hell moments.)
15. September 29, 2021 - 11 Alive, Fulton County DA to discuss backlog, possibiltyofviolent
criminals being released, YOUTUBE, (Sep. 29, 2021),
hitps://www. youtube.com/watch?v=sjGaiFOWt9g (She told the crowd: “certainly, if
someone did Something as serious as interfere with people’s right to vote—which you know
as a woman, and a personofcolor, is a sacred right where people lost a lot of lives, we are
going to invest in that”)
2
16. January 4, 2022 - Kate Brumback, Associated Press, Fulton County DA investigating Trump
closer to decision on charges, FOX 5 ATLANTA, (Jan. 11,2022),
hitps://www.foxSatlanta.com/news/fulton-county-da-investigating-trump-closer-to-decision-
on-charges.
17. January 24, 2022 - Janell Ross, As Atlanta DA's Trump Election Probe Advances, She
Explains Her Approach, TIME, (Jan. 25, 2021), htps//time.con/6141873/georgia-clection-
probe-trump-fani-willis.
18. February 3, 2022 - Atlanta Journal Constitution, Filton DA details next stageofTrump
probe, YOUTUBE (Feb. 3, 2022), https://www.youtube.com/watch?v=LHbIZK8v0-k.
19. February 3, 2022 - Dale Russell, Former President Trump's comments prompt new security
measuresfor Fulton DA, FOX 5 ATLANTA, (Feb. 3, 2022),
https//swww. foxSatlanta.com/news/former-president-trumps-comments-prompt-new-
security-measures-for-fulton-da.
20. February 7, 2022 - Sara Murray, Devan Cole, Atlanta DA investigating Trump's election
interference: "We're not hereplaying a game’ CNN, (Feb. 7, 2022),
hitps://www.cnn.com/2022/02/07/politics/fani-wills-donald-trump-¢lection-
investigation/index html. (FCDA stated, “this is a criminal investigation, we're not here.
playing games. I plan to usethepower ofthe law. Weare al citizens. Mr. Trump, justas any
other American citizen, is entitled to dignity. He is entitled to being treated fairly. He will be
treated fairly in thisjurisdiction, but plan to do myjob, and my job is to make sure that we
get the evidence that gives us the truth. P'm not concerned at all about games to delay this.”
‘The FCDA disclosed the previously unknown fact that President Trump had retained counsel
inthe Georgia investigation. She stated, “Last calendar year, I met with them and I assured
them what I knew — we would not bring forth an indictment in the 2021 year. I met with
them at the end of2021 to tell them that I would be moving forward, not necessarily with an
indictment, but with the next stepsofthe investigation.”(video embedded within article)
21. February 14,2022 - USA Today, Georgia DA Fani Wills talks about Trump election,
YOUTUBE, (Feb. 14, 2022), https://www.youtube.com/watch?v=SuxGeL f3Mkd.FCDA said
ofthe phone call, “almost immediately knew that there was something to be investigated.”)
22. April 19, 2022 - Tamar Hallerman, Fulton DA clarifies timelinefor witness testimony in
Trumpprobe, ATLANTA JOURNAL CONSTITUTION, (April 19, 2022), ,
hitps://www.ajc.com/news/georgia-newsfulton-da-clarifies-timeline-for-witness-testimony-
in-trump-probe/QPKS7EJWYZHDRDXYHSNORSKXGE/. (FCDA states, I think it is also
equally and fundamentally important that the government makes sure that in a free society
that people canvoteand that is not infringed upon by anyone. So in this case, you have an
allegation ofa human being, ofa person,ofan American citizen, possibly doing something
that wouldve infringed upon the rights of lotsof Georgians. Specifically from my county—
Fulton County—right to vote being infringed upon. And the allegations, quite frankly, were
nota civil wrongdoing, buta crime. And so everybody is equal before the law no matter what
position they hold, no matter how much wealth, no matter how poor they are, no matter how
educated, no matter how uneducated... People have many, many days of legal arguments. A.
3
judge, and my guess is even the Supreme Courtof Georgia will weigh in on that issue. Ido
not think that executive immunity would protect against prosecution in this case.”)
23. April 29, 2022 - Ben Brasch, Tamar Hallerman, Fulton DAfaces biggest decisionofcareer
as Trump grandjury looms, ATLANTA JOURNAL-CONSTITUTION, (April 29, 2022),
https://www.aje.con/politics/fulton-da-faces-biggest-decision-of-career-as-trump-grand-jury-
looms/60KYH6PMRZB3TPBSQZISHLSCCU (FCDA said she has yet to make up her mind
about whether the former president or his advocates broke the law and reiterates that she will
treat President Trump like anyone else who crosses her desk.)
24. May 2,202 - Anderson Cooper, CNN, Georgia district attorney: Trump grandjury
subpoenas will be enforced, YOUTUBE, (May 2, 2022),
hitps://www.youtube.com/watch?v=vHcuOex8e7Q. (FCDA discusses upcoming subpoenas
to uncooperative witnesses, communications with President Trump's legal counsel and, in
reference to the slateofelectors, states, “...and two, thatifwe live in a free land in a
democracy, we have to have free and fair elections. And so, 1 am very concemed that if
behavior that i illegal, goes unchecked, that it could lead to a very bad start and a very, very
bad path”)
25. May 26,2022 - Danny Hakim, Richard Fausset, Up to 50 Subpoenas Expected as Grand
Jury Begins Trump Inquiry, NEW YORK TiMes, (May 27, 2022),
hitps://swwnytimes.com/2022/05/27us/trump-grand-jury-georgia htm. (FCDA referenced
President Trump stating, “it’s not of much consequence what title they wore,” and, “l'm not
taking on a former president. We're not adversaries. I don’t know him personally. He does
not know me personally. We should have no personal feelings about him.” She discussed the
slate of electors and compared it to her 2014 RICO case stating, “There are so many issues
that could have come aboutifsomebody participates in submitting a document that they
Know is false. You can’t do that. Ifyou go back and look at Atlanta Public Schools, that's
oneofthe things that happened, is they certified these test results that they knew were false.
‘You cannot do that.” She again disclosed the number ofpeople who had declined to speak
with her and plans for subpoenas. She discussed challenges to subpoenas stating, "I don’t
know how many games folks are going to play. I don’t know how many times we're going
to haveto fight someonejust to get them to come speak to a grand jury and tellthetruth. And
there could be delays for those reasons.” FCDA said that there had been “no formal
coordination” between her office and the Jan. 6 committee and further stated, “but, I mean,
obviously, we're looking at everything thatrelatesto Georgia that that committee is
overtuming”)
26. June 6, 2022 - Michael Isikoff, Daniel Klaidman, Georgia DA Fani Wills is confident as her
Trumpprobe takes shape, YA00! NEWS, (June 6, 2022), https://news yahoocomv/georgic-
da-fani-willis-is-confident-as-her-trump-probe-takes-shape-145820588html. (The outlet
reported, “Willis spoke freely in her office for over an hour”just after Raffensperger spent 5
hours testifying. The FCDA commented directly on pending and future challenges to the
investigation stating, "that’s nothing for prosecutors.” She further stated, “I did not choose
this. 1 did not choose for Donald Trump to be on my plate,” but noted that she had no choice.
‘She again discussed RICO and whata great tool it is o use so thejury canseethe "whole
story." She commented that “since I was a very litle bitty girl, you get dragged to the polls
So you understand very, very early on, voting is such an intrinsic right. And so I understand
4
how important the infraction on someones right to vote is. So I do get the significance.” In
discussing the upcoming hearing on & motion to quash subpoenas by membersofthe Georgia
legislature, she commented that, should they choose to challenge their subpoena further, they
would need to do so from ajail cell: She will get a ‘material witness’ warrant commanding
them to comply or face arrest. I's “just what you do," she said. "I've had a witness arrested
before becausethey ignore my subpoena. And you do not expect to have to do it. But I will.”
She stated she would notbringan indictment once early voting begins but noted that she has
plentyoftime before that — "and after. )
27. June 27,2022 - Breakdown, 4forceofnature, ATLANTA JOURNAL-CONSTITUTION (June 27,
2022), https//podcasts.apple.com/us/podcast/a-force-of-
nature/id992983540%i=1000567810613 (In response to the questionofwhether she would
subpoena President Trump, she responded, “it is foreseeable thatI would subpoena the target
of this investigation, A target”)
28. June 30, 2022 - Tamar Hallerman, Fulton DA pushes back against legislatorsfighting
subpoenas, ATLANTA JOURNAL-CONSTITUTION, (June 30, 2022),
hitps://www.ajc.comipolitics/fulton-da-pushes-back-against-legislators-fighting-
subpoenas’COOXST6FYND3VNL7EZQLWSI4FA/.
29. July 6, 2022 - MSNBC, Fulton County DA on Issuing Subpoenas: “This Is Not A Game, At
AI", Youtuse, (July 6, 2022), https://www.youtube com/watch?v=gThpijITxO4. (FCDA
said she expects to subpoena additional membersofTrump's inner circle and further stated,
“1 think that people thought that we came into this as some kindof game. This is not a game.
atall. What I am doing is very serious. It’s very important work. And we're goingto do our
due diligence and make sure that we look at ali aspectsofthe case”);
hitps:/www.youtube.comiwatch?v=HHWp82iyWgE (When asked about Senator Graham's
‘comment that the investigation was a fishing expedition, FCDA replied “whatdo I have to
gain from these politics? It's an inaccurate estimation. It's someone that doesn’t understand
the seriousnessofwhat we're doing. I hope they don’t come and testify truthfully before the
grandjury.” FCDA stated, “election interference is a very important subject... I think it’s
important that they hear from people that may have had something to do with an election
interference.” When asked abouta subpoena for President Trump, she replied, “anything’s
possible.” When asked how she would respond to resistance, FCDA stated, “we'll take you
before thejudge and the judge will make a ruling ifwe have a legal right to bring them
before the court... that's why you havethepower of the state, and the power ofthe
subpoena to bring them here. Myjob is not to bring you here because you want to come, my
jobisto make sure the grandjurors get allofthe evidence they want.”)
30. July 13, 2022 - Tamar Hallerman, Graham moves (o quash Fulton subpoena in Trump
probe, ATLANTA JOURNAL-CONSTITUTION, (July 13, 2022),
hitps://www.ajc.com/politics/graham-moves-to-quash-fulton-subpoena-in-
trumpprobe/CQX4KUFVABHMNBVPAAGI4FAS3Q. (FCDA confirmed that her team
informed multiple people that they were “targets”ofthe investigation.)
31. July 14, 2022 - Tamar Hallerman, AJC subpoena showsgrand jury's interest in USS. attorney
tumult, ATLANTA JOURNAL-CONSTITUTION, (July 14, 2022),
5
hitps://swww ajc.com/politis/ajc-subpoena-shows-grand-jurys-interest-in-us-
attomeytumult/yVPTGTQF3SFGBNTW2VSMSEZ3HU. (FCDA indicated she was open to
subpoenaing others who worked in the White House, including President Trump and his
formerChiefof Staff, Mark Meadows: "I think it would be safe to say thatifpeople have
information in particular about Georgia and interference in the Georgia elections, and they
‘were in the White House, that will not bar us from wanting to talk to them.” She again
confirmed that multiple targetsofher investigation have been identified.)
32. July 15, 2022 - Tamar Hallerman, Greg Bluestein, Top Georgia Republicans informed
they're targetsofFulton DA probe, ATLANTA JOURNAL-CONSTITUTION, (July 15, 2022),
hitps://sww.aje.com/politics/top-ga-republicans-informed- theyretargets-of-fulton-
daprobe/3CZJHEYODSADFDCVP3372HROFQ.
33. August 2,2022 - 11 Alive, Fulton DA Fani Willi talks gangs, Donald Trump grandjury
probe, YOUTUBE (Aug. 2, 202), hitps://www.youtube.com/watch?v=sUZVs6ZDSME.
(FCDA discussed whether to subpoena President Trump and stated, “the grand jury needs to
hear as much information from as many people that are willing to come and testify
truthfully.)
34. August 3, 2022 - Michael Isikoff, Exclusive: Trump allies launch effort to recall Fulton
County DA Fani Wills, YAHOO! NEWS, (Aug. 3, 2022), htps://ca.news.yahoo.com/exclusive-
trump-allies-launch-cffort-to-recall-fulton-county-da-fani-willis-22431 5547 html.
35. August 29, 2022 - 11 Alive, Fulion County DA to announce ‘major’ gang arrests,
indictments, YOUTUBE, (Aug. 29, 2022), hitps://www.youtube.com/watch?v=Qzeyw-OnpGO.
(“I think we're about 60% through of ll of the people we need to be brought up....You
know, there can’t be any predictions. As you know, many people are unsuccessfully fighting
our subpoenas. We will continue to fight to make sure that the grand jury and the public gets
the truth.")
36. September 12, 2022 - Richard Fausset, In Atlanta, a Local Prosecutor Takes on Murder,
Street Gangs anda President, NEW YORKTIMES, (Sep. 12, 2022),
hitps:/isrwwntimes.com/2022/09/12/us/fani-t-wills-trump-atlanta. html (FCDA stated, “I
‘mean,ifcrime happens in myjurisdiction, who's going to investigate it? Ido not have the
right to look the other way on a crime that could have impacted a major rightofpeople in
this community and throughout the nation.” The authorsofthe article noted, her comfort in
the public eye stands in marked contrast to the low-key approachofanother Trump legal
pursuer, Attormey General Merrick B. Garland”). :
37. September 15, 2022 - Matthew Brown, Tom Hamburger, Georgia 2020 election inguiry may
lead to prison sentences, prosecutor says, THE WASHINGTON POST, (Sep. 15, 2022),
(FCDA suggested that serious crimes have been committed and “people are facing prison
sentences.” FCDA declined to comment on recent filings related to pressure on [Ruby]
Freeman except to say: "I hate a bully. Obviously, I think we would find it offensive to bully
an election official to influence an election.” The author notes, "Willis’s open and frank
assessment is unusual for a prosecutor, as such high-profile investigations are often shrouded
6
in secrecy. Her approach in this inquiry has drawn criticism from some in the legal
community, and it contrasts with the general reticenceof Attomey General Merrick Garland.
‘Willis said she believes transparency is a requirementofher job.”)
38. November 2022 - Mark Binelli, She Took On Atlanta's Gangs. Now She May Be Comingfor
Trump., NEW YORK TIMES MAGAZINE, (Feb. 2, 2023),
hitps:/Avww.nytimes.com/2023/02/02/magazine/ani-willis-
trump htmI?foclid=IwAROYii9UK3ySFRc20lgkUVvSm2NXkjc-AbpWSzIwnTWSJel-
DOuQKDMmec.
39. February 13, 2023 - Tamar Hallerman, Bill Rankin, Fultonjudge: Portions ofTrump grand
Jjury report 10 be released this week, THE ATLANTA JOURNAL-CONSTITUTION, (Feb. 13, 2023),
hitps://www. Lalive. convarticle/news/politics/trump-investigations-georgia-prosecutor/85-
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Exhibit 6
January 9, 2023 Order Dissolving Special
Purpose Grand Jury and Setting Hearing on
Publication, In re 2 May 2022 Special
Purpose Grand Jury, Case No. 2022-EX-
000024 (Fulton Co. Sup. Court).
FILED IN OFFI
1
ofitsfinal report theundersigned’s
thespecial purposegrandjury's delivery
Given
recommendation,andthe Superior Court bench’s vote, it is the ORDER
ofthis Court that
the special purposegrandjury now stands DISSOLVED. The Court thanks the grand
Jurors for their dedication, professionalism, and significant commitment of time and
attention
tothis important matter. It was no small sacrifice
to serve.
Remaining is the question of publicationofthe final report. The special purpose
purpose grandjury's finel report constitutes a presentment. The Court invites argument
on this issue and sets the matter
downforahearing on 24 January 2023 atnoonin
Courtroom 8-D. The District Attorney's Office shall be given an opportunity at that
tine to provide its perspective as will any consolidated media intervenors. Argument
shouldfocus ontheapplicability 0f0.C.G.A.§ 15-12-80 tothespecial purposegrandjury's
work as well as the precedential impactof In re July-August, 2003 DeKalb Cnty. Grand
for
Jury, 265 Ga. App. 870, 872-73 (2004); In re Floyd Cnty. GrandJury Presentments
‘May Term 1996, 225 Ga. App. 705, 707 (1997); and Kelley v. Tanksley, 105 Ga. App. 65,
2
Exhibit 7
February 13, 2023 Order Re: Special
Purpose Grand Jury’s Final Report, In re 2
May 2022 Special Purpose Grand Jury, Case
No. 2022-EX-000024 (Fulton Co. Sup.
Court).
FILED IN OFFICE
Pages5of 8
Thompson v. Macon-Bibb Cnty. Hosp. Auth., 246 Ge. 777, 779 (1980), quoting In re
Grand JuryofHennepin County, 271 N.W.2d 817, 819 (1978) (punctuation omitted)
This is particularly true if the grand jury's final report includes recommendations
involving individuals who never appeared before the grand jury and so bad no
‘opportunity, limited or not,tobeheard.Theconstitutionallyprotected dueprocess rights
ofanyone
whomaybenamed in the final report also require thisoutcome: when
“identifiable individuals referred to in such [reports] are afforded no statutory
‘mechanism
bywhichthey may respond
tothe charges against them, ‘serious questions of
due process and fairness’ are raised.” In re Presentment of Lowndes Cnty. Grand Jury,
March Term 1982, 166 Ga. App. 258, 258 (1983), quoting Thompson,
246Ga.at778; see
also Kelleyv. Tanksley, 105 Ga. App. 65 (1961) (restriction onpublication necessary when
isreturned).
is criticalofidentifiable individuals but no indictment
grandjury report
DeKalb County grand jury, following its investigation into Jones's alleged misuse of
Em en
LR
Page6 of
sealedeverythingandsent the issue to the Courtof Appeals, which ruled that the report
could bepublished pursuant to0.C.G.A. § 15-12-80 because
Joneshadan opportunity totestifybefore the grandjury under oath [and]
those individuals thathewould havecalledaswitnesses alsotestified under
subpoena; therefore, anyofhis due process rights under Thompson v.
Macon-Bibb County Hosp. Auth. 246 Ga. 777, 273 S.E.2d 19 (1980), were
satisfied.
In re July-August, 2003 DeKalb Cnty. Grand Jury, 265 Ga. App. 870, 871 (2004). In
otherwords,the CourtofAppeals determined,inthat unique scenario,thatJones--who
testified andwhohadallwitnesses hewouldhavecalled if presentinghissideof the
securitydetail storytestify aswell- enjoyedsufficientdue process forthereporttobe
published. Here, however, for anyone named in the special purpose grand jury's final
report who was not afforded the opportunity to appear before the grand jury, none of
those due process rights has been satisfied.Andforthosewho did appear - willingly or
not — only the right to be heard (although without counsel or rebuttal) was protected.
Giventhat,theCourtfindsthatfulldisclosureofthefinal report atthistime is notproper
under Thompson, Kelley, andtheirprogeny.
‘There are, however, three parts of the final report that are ripe for publication.
Theydonotimplicate theconcerns raised in Thompson andKelley, and, while publication
may ot be convenient for the pacing of the District Attorney's investigation, the
compelling public interest in these proceedings and the unquestionable value and
importance of transparency require their release. These three portions include the
introduction and conclusion to the final report, as well as Section VIII, in which the
‘specialpurposegrand jurydiscusses its concern that some witnesses mayhavelied under
oath during their testimony to the grand jury. Because the grandjury does not identify
those witnesses, that conclusionmaybe publicly disclosedatthistime.
Page7of8
‘Therefore, consistent with the special purpose grand jury's recommendation made
pursuant to 0.C.G.A. § 15-12-80 that its final report be published, those three portions of
the report will be placed in the docket for this matter (making those excerpts -- but only
those excerpts -- a “court record”) on 16 February 2023. The several-day delay will allow
the District Attorney's team to meet with the undersigned,ifnecessary, to discuss logistics
of publication and to determine if any portion of those three parts of the final report
should be redacted for other reasons (noticeof which will be provided in the 16 February
Page8of8
EXHIBIT 8:
List of Foreperson and Grand Jurors’ Media
Appearances / Public Comments
List of Foreperson and Grand Jurors’ Media Appearances/ Public Statements
1. February 21, 2023 - Kate Brumback, Inside the Trump grandjury thatprobed election
‘meddling, ASSOCIATED PRESS (Feb. 21, 2023), https://apnews.comvarticle/politics-new-
‘york-city-only-on-ap-donald-trump-georgia-266e28c4e47e5473 15233¢0£77015729.
(Prosecutors played the then-president’s phone call with Raffensperger on the first day
thejurors met to consider evidence. Prosecutors told jurors they could consume news
coverage related to the case but urged them to keep an open mind. As the proceedings
‘moved forward, oneofher fellowjurors brought the newspaper every day and pointed
out stories about the investigation. When witnesses refused to answer almost every
question, the lawyers would engage in what Kohrs came to thinkofas “show and tell.”
‘The lawyers would show videoofthe person appearing on television or testifying before
the U.S. House committee that investigated the Jan. 6, 2021, riot at the U.S. Capitol,
periodically asking the witness to confirm certain statements. Then the scratchingofpens
on paper could be heard as jurors tallied how many times the person invoked the Fifth
Amendment)
2. February 21,2023 - Danny Hakim, Jury in Georgia Trump Inquiry Recommended
Multiple Indictments, Forewoman Says, NEW YORK TIMES, (Feb. 21,2023),
ttps://sww.nytimes.com/2023/02/21/us/trump- georgia-grand-jury-indietments html
(“We definitely started with the first phone call, the call to Secretary Raffensperger that
was so publicized”)
3. February 21, 2023 - Tamar Hallerman, Bill Rankin, Fulton grandjuror: Multiple
indictments recommended, ATLANTA JOURNAL-CONSTITUTION, (Feb. 21, 2023),
hitps://www.aje.com/polities/fulton-grand:uror-multiple-indictments-
recommended/KGAJO32SPSCIXO4EYGCONSPSOE/ (“We heard alotofrecordings of
President Trump on the phone... It is amazing how many hoursof footage you can find
ofthat man on the phone... We kindofknew what to expect, and so especially with our
time being limited and with our resources being limited, when it came to that it was like
eh, we'd rather get this person, which is a battle that we can win, than this other one.”
With regard to the investigation, she stated: “It shouldn't have needed to happen and it
shouldn't have been so complicated and it just was complicated. It just had all these extra
alleys and all these extra twists and tums that it didn’t need. I realized there was way too
‘much going on and this should not have been this insane.”)
4. February 21, 2023 - Kate Bouldan, CNN, Foreperson reacts to Trump's claim that hegets
total exoneration in GA probe, YOUTUBE, (Feb, 21, 2023),
hitps://www.youtube,com/watch?v=_qyEGTWI7tY (“1 will tell you that it was a process
where we heard his name a lot. We definitely hearda lot about former President Trump,
and we definitely discussed him a lot in the room... and I will sey that when this list
‘comes out. there are no major plot twists waiting for you.”) (On the sectionofthe report
containing perjury recommendations: “1 would say that it ended up included there
because it was less pointed ofa suggestion than some ofthe other things we may have
written in the partsofthe report thejudge chose to keep confidential... we thought it
‘was important to keep it separate as well”) (On whether charges should be brought:
“This was too much. Too much information. Too muchofmy time. Too much of
everyone's time. Too muchoftheir time. Too much argument in court about getting
‘people to appear before us. There was just too much for this to just be, oh okay, we're
00d. Bye. I will be fine as long as something happens. Personally, I hope to see her take
almost any kindofdecisive action, to actually do Something. Thereare too many times
in recent history that seem to me like someone has gotten called out for something that
‘people had a problem with, and nothing ever happens.”)(On how many people were
recommended for indictment, when asked if it was more than a dozen she responded, “I
believe so. That's probablya good assumption.”)
5. February 21, 2023 - Lawrence O*Donnell, MSNBC, Lawrence: Ga grandjurorgives
‘most revealing Trump investigation interview ever, YOUTUBE (Feb. 21, 2023),
hitps://wwwyoutube.com/watch?v=c-MGSfSQY Va (“could see how getting the former
president to talk to us would have been a year in negotiation by itsel...I’d be fascinated
by what he [Trump] said, but do you think he would come in and say anything
‘groundbreaking orjust the same kinda thing we've heard?”) (“At some point through this
investigation, especially as we began to speak to higher profile witnesses, I think some of
the combativeness that we experienced meant that the DA's team, as well as us, started to
‘pick our battles. And when someone, like for example, goes before the January 6%
Committee and says they plead the fifth 200 times, do you really expect them to come.
before you and say something different?”) (“We kindofknew what to expect, and so
especially with our time being limited and with our resources being limited, when it came
to that it was like eh, we'd rather get this person, which is a battle that we can win, than
this other one.”)
6. February 21,2023 ~ Blayne Alexander, Dareh Gregorian, Georgia grandjury
recommended indictmentsfor more than a dozenpeople in Trumpprobe,foreperson says,
NBC News (Feb. 21, 2023), htps://www.nbenews.com/politics/donald-trumplgeorgia-
grand-jury-recommended-indictments-dozen-people-trump-probe-fo-rena7 1675.(Kohrs
said Graham was "fantastic," adding: "He was personable. He was forthcoming. He was
very willing to just have a conversation." A witness who did strike her as “honest” was
Sen. Lindsey Graham, R-5.C., who'd fought his subpoena for testimony in the courts).
7. February 21, 2023 - The Reidout, Did Georgia grandjury recommend charging Trump?
“I'd betyes,” legal experts say, MSNBC, (Feb. 21,2023),htps://www.msnbe.com/the-
reidoutAwatch/special-grand-jury-forewoman-in-trump-georgia-election-interference-
probe-on-recommended-indictments-163784261685.
8. February 22, 2023 - Marshall Cohen, Katie Carver, Devan Cole, Foreperson on Georgia
‘grandjury investigating Trump and 2020 election saysjurors ‘definitely discussed him a
lot," CNN (Feb. 22, 2023), hitps://www.cnn.com/2023/02/21fpoitics/fulton-county-
trump-grand-jury-foreperson-eboffindex. html. (“Can you imagine doing this for eight
‘months and not coming out with a whole lst [ofrecommended indictments]. It’s nota
short list. Its not.”) (“1 would love to see something actually happen. Don’t make me
take back my faith in the system. The only thing I would be disappointed in, at this point,
isifthis whole thingjust diseppears. Thats the only thing that would make me sad.”)
(The foreperson was “pleasantly surprised by the friendlinessofsome witnesses, like
Michael Flynn: “Flynn was honestly a very nice in person. He was a very nice man. He.
was definitely interesting. But I don’t recall him saying anything carth-shattering.” But
revealed disdain for other witnesses who similarly invoked the fifth amendment: “Mark
Meadows did not share very much,” she said. “I askedifhe had Twitter, and he pled the
Fifth.”)
9. February 22, 2023 - Moming Joe, Fulton Countygrand jury foreperson speaks out,
MSNBC (Feb. 22, 2023), htps://wwwmstibe.com/morning joe/watch/fulton-county-
grand-jury-foreperson-speaks-out-163802693545.
10. February 22, 2023 - Alex Wagner, MSNBC,Specialgrand juryforeperson shares details,
drops heavy hints in Georgia Trump case, YOUTUBE (Feb. 22, 2023),
hitps://www youtube. com/watch?y=vI0bIWxIkk.
11. March 15, 2023 — Tamar Hallerman, Bill Rankin, Exclusive: Behind the scenesof the
Trump grand jury, ATLANTAJOURNAL-CONSTITUTION, (March 15, 2023),
hitps:/www.ajc.com/politics/exclusive-behind-the-scenes-of-the-trump-grand-
Jury/6CXLKTFMKNDU7OGTER4BTUTZPE/.
Exhibit 9
List of Supervising Judge’s Media
Appearances
List ofAppearances — Supervising Judge
1. February 22, 2023 ~Tamar Hallerman, Bill Rankin, Trump attorneys: Special grandjury
probe ‘a clown show’, ATLANTAJOURNAL-CONSTITUTION (Feb. 23, 2023),
hitps:/www.ajc.com/politics/trump-attomeys-special-grand-jury-probe-a-clown-
show/ZTR6VUWXGFC2BMOCXGFHGDAPCY.
2. February 23, 2023 - Kate Brumback, Trump investigation: Couldgrandjuror words
tank charges?, ASSOCIATED PRESS, (Feb. 23, 2023), https://apnews.com/article/politics-
‘georgia-donald-trump-9938¢36b008aacb7a7b1502b09762bbd.
3. February 24, 2023 - Jonathan Raymond, Judge takes question on Georgia Trumpjury
Jforeperson giving interviews, 11 ALIVE (Feb. 24, 2023),
hitps://www. alive.com/article/news/politics/judge-obert-meburmey-question-on-
‘georgia-trump-jury-foreperson-giving-interviews/$5-5117a736-09db-4da2-8631-
0376949¢700.
4. February 24, 2023 - Sara Murray, Fulton Countyjudge who oversawspecialgrand jury
in Trumpprobe saysjurors arefree to discussfinal report, CNN, (Feb. 24, 2023),
hitps://swww.cnn.com/2023/02/24/politics/georgia-grand-jury-trump- final-report-
jurors/index.html.
5. February 24, 2023 - Michael Isikoff, Daniel Klaidman, Georgiajudge gave grand jurors
lenient guidance on talking to media about Trump case, YAHOO! NEWS, (Feb. 24, 2023).
6. February 27, 2023 - Olivia Rubin, Judge oversecing Trump Georgia grandjury speaks
afterforeperson’s controversial interviews, ABCNEWS, (Feb. 27, 2023),
hitps:/abenews.go.com/Politics/judge-overseeing-trump-georgia-grand-jury-speaks-
after/story?id=97503245.
Exhibit 10
August 29, 2022 Order Denying Motion to
Quash (Governor Kemp), In re 2 May 2022
Special Purpose Grand Jury, Case No. 2022-
EX-000024 (Fulton Co. Sup. Court).
|
| FILED IN OFFICE
Te SRe(oy cous
IN THE SUPERIOR COURT OF FULTON COUNTY | C77
@
Epa A)
STATE OF GEORGIA 1
i
rrr———res
IN RE 2 MAY 2022 SPECIAL PURPOSE | !
GRAND JURY—-SUBPOENA FOR 2022-EX-000024
GOVERNOR KEMP .
+ Nothingintheconveningrequest(orthesubsequentconveningOrder)indicated thattheDistrict
Atorne orthe specialpurpose randfry wouldbeconsidering vlviolations
theSuperiorCuttbeach clacton.Thefocus
ERE TET
orthe possibiltyofbringingany andpirposewereandhavebeeneversiace fo
1
|
i|.
and the Secretary of State, directed the Governor to appear — special purpose
grand jury so that that investigative body could learn moreabot whether eriminal
conducthadoccurred inconnectionwith alleged effortstointerfere iththe2020 general
election in Georgia. According to both the pleadings from and the lawyers for the
Governor and theDistrictAttorney, this subpoena cme oly after weeksoftortured and
tortuous negotiations over obtaining an interview with the Governor — the details of
Which do mot bear repeating here, the than to note that both sides share responsiblity
for the torture and the tortuousness.
‘The date of the Governor's subpoenaed appearance before the special purpose
grand jury was changed at least once, at his lawyer's request. On the eve of the most
toquash
toappear;bis lawyers fileda motion
recently agreed-upon date forthe Governor
the subpoena. The motion invoked sovereign immunity and assbrted that this Court
lacked jurisdiction to issue, enforce, or even consider the stern “The State promptly
In Georgia, one cannot sue “the State” unless the State his enacted a specific
‘waiver, legislative or constitutional, that permits
aparticular speciesofcivil claim -- tort,
contract, declaratoryjudgment, etc. tobe brought against it. Thats, theStateand its
agencies and agents (of which the Governor is one) enjoy sovereign immunity,
constitutional doctrine that “forbids our courts to entertain a lawsuit against the State
|| 2
i
i
|
|
withoutts consent.” Lathrop v. Deal, 301 Ga. 408, 408 (2017); seI Ga. Const. art. I,
52, YIX(e). Absent that consent, Georgia's courts lackjurisdiction to consider the claim
brought against the State. McConnell v. Dept.of Labor, 302 Ga.18, 18-19 (2017) (if
sovereign immunity applies, a court “lacks authority to decide the hers of a claim that
isbarred"); see also City ofCol. Park. Clayton Cnty. 306 Ga. 301} 314-15 (2019).
Both sides agree with the foregoing — as they should, as it is well-settled law.
‘Where they diverge is whether sovereign immunity applies in the contextof this special
purpose grand jury's criminal investigation. The Governor insists he is immune to the
subpoena because there is no waiver, legislative or constitutional, that would allow the
grandjury to require him (or, presumably, any other sate agent, including the Secretary
of Stateand Attorney Generale) to appear in whet he characterizes as a civil proceeding.
The District Attorney argues that sovereign immunity does notaoly in this context
because, fist, there is no lawsuit being brought against the State (or the Governor), and
i
second,sovereign immunity simply has no application in criminal matters.
i
‘The Governor relies primarily on State v. Bartel, 223 Ga. App.
y 696 (1996), in
Supportofhisclaim that whatthisspecial purpose grandjuryi doing is conducting civ
investigations Bartel does not provide the support his claim needs because Bartel does
“Who interestingly, i theleadsgnstory onthe Govemors motionseskingquasha spitehaviog ise.
appearedbeforethespecialpurposegrandjury withoutincident, objection, or invocationofthe doctrine of
Soveign immunity),
+310 additonal rele on to cases that establish that agrand jury ano conductcilinvestigations of
anit, sihough
mappote hesosase
bacave bowo
this reachhtdoenfoavestiguionsofcounty
‘stateoffices andofficials;rather,agrandjury'scivilauthority
Gis ar special PUpove: rnd Mu Is gage in evecain.
Comal Tost
islimited bystatute --andlikelybysovereign
IvesSgaion.
353 (93),
Moreover,
suze, hl 1 ci tht had he and Jory 1 tat ise bok engaged ns cial
oneofthe two cases,FloydCaty. GrandJuryv. Dep'tof Family &ChildrenServs., 218Ga. App.
investigation, it would have been authorized to subpoena state agents. The Governor's legal team also
BitesAtoey bas In noaramid:
indictments. Kenérysways
‘points the Court to Kenerly v. State, 311 Ga. App. 190 (2011), but that casemerelyreaffirmedwhat the
way prosepealpurpose
spec purposeEesadJres
grand isdonothav the author
for engaging ss
in inal
investigationsandindeedthespecial purposegrand jury impanelmentstatuteexplicitly allows it. 0.C.G.A.
i 3
not say what he says it does. In Bartel, a witness who had — before a special
purpose grand fry in Floyd County was ater prosecutedfo allegedly having perfured
‘himselfwhile testifying. The Bartel special purpose grand jury was convened to conduct
a civil investigation nto “alleged irregularities in the operations of the Floyd County
to theGovernor's presentationatthe
Hospital Authority.” 223 Ga. App. at 696. Contrary
hearing on his motion to quash, the court in Bartel did not “conclude(] that special
purposegrand juries conduct only civil investigations.” (Movant's PowerPointatSlide3).
No such language can be found in Bartel, which dealt with the natureofthe oath the
witnesses took before testiying.4 It is correct to saythatthe special purpose grandjury
in Bartel had, as its purpose, a civil investigation. Itis incorreet to say that the Court of
‘Appeals in Bartel in any way concluded that the only purpose a special purpose grand
jurycanhaveis civil. '
investigation: its convening was sought by the elected official who'investigates, lodges,
and prosecutes criminal charges in this Circuit; its convening Order specifies its purpose
as the investigation of possible criminal activities; and its final output is a report
thespecial purpose
recommending whether criminal charges should be brought. Unlik}
grand jury in Bartel, it is not investigating “irregularities” in hospital administration. It
§15-12-100(a) (“Thechief judgeofthe superior court of any county ... on his or her own mation [or] on
oonor petitionofthe ISH requesttheuesofthesuperiofor hecoutofthecounty
attorney «mayvestgatingnyallegedviolation to
panei Specialgrandjury fortheporpossof lawsfis ate. .)
"Tha aspecialprpos grand zy engaged in criminal vestigation cannot see an indictment does ot
diminiahtheciminal nateofHswork o Somehow transmogefy iat criminal investigation info a Givi
ore. Palos oh ri ne ies ny
Indeed, hopeful dueonlyto inadvectne, the Governor's legal eam nsvisul presentation making
tisunfounded claimsbowttheholding of Bartel dicected theCourtvi ctatior :
oapageofthe pinion
(699) that doesnotexist.
4
|
||
will not be recommending whether anyone should be sued or should be referred for civil
administrative proceedings; it will be recommending whether anyone should be
prosested for cimes. Put imply ther is nothingabout his spc puspose grandfry
that involves or implicates civil practice.s |
Because neither the special purpose grand jury nor the District Attorney has
brought (or is even contemplating) a lawsuit (ie., a civil proceeding) against the
to invoke. Again,
Governor, his office, or anyof hisagents, thereis no sovereign immunity
alawsuitagainstthe State.
toquoteLathrop, that doctrine “forbids our courts to entertain
without its consent.” 301 Ga. at 408. It is clear that the Governor.is not consenting to
this subpoena. Itisalso clear that his lack of consent isofno jurisdictional momentto
this Court because there is before it no civil proceeding, suit, or action. The Governor
‘must honorthesubpoena —as have the SecretaryofState and the. omer General and
inthese criminal proceedings. Sover ign
‘manyother agentsofthe State immunity wards
off civil actions, not criminal ones.¢
Given that decision, the Court turns next to the process cocerns raised by the
‘Governor: about what must hetestifyand when?Aswithseveral other witnesses who, in
response to their lawful subpoenas, raised concerns about various privileges, the
Governor's questioning will have limits. Neither the District Attbrney nor the grand
of
to datehasbeenthelackof city manth attorneysinvolved.Asthe streams
Theone exception
publiclyrevealed e-mails demonstrate,thatall-too-common andalwaysunwelcome aspect ofcivil litigation
‘hasintruded uponthesecriminal proceedings.
©Thatthisissowas made al themore plain atthehearing
by (1) thefac that eperysovereign immunity
cas the Governors welsesourced leg team cited in cout and in its motion quash involved civ
Proceedings 3) he Courts observationthat isthe ultimate nsigator
theSate’styledTheStat ofanylegal proceedings
hat illonfromtis investigation (Leanindictment of Georia versus Defendant
X
‘ichwould expan why ths are ho criminal sovereign immunityappellt cases asserting that the
Statoimmune from itself nd(3theDistrictAtorniy’ap exampleofhatwuld happen i &wordin
which sovereign immunity sppiedtocriminal actions: police officescould lotsubpoenas, GBI forensic
expertscouldresist summansasonthe basitha theyworkattheState velan ottheloca”lev,ec.
| 5
|
Jurors may ask the Governor about the contents of any attonfy-lent prvieged
communications. The Court is aware of severalcomsatins of interest to the
investigation in which the Governor participated and to which the attorney-client
peveg apps. As with hose ater witness, questioning mist cease abou the
contentsofthe communications if the privilege is validly raised. Undoubtedly, other
sssues wil arise that do not fall neatly into this category of privilege. If heycannotbe
resolved by the flet of lawyers on each side, they should be brought to the Court for
resolution (oratleast helpful direction).”
¢
J bert C.T, McBurney
Superior CourtofFulton County
Atlanta Judicial Circuit
TheCourt declinesthe
Governor'sinvitation toimpartwholesale ntoGeorgiala theconceptofexecutive
privilege. Itstimemaycome, but thisisnotit. |
+TheCotaloo
over manitydeclinesto
locs noseacrifat
pps cmaoftiers.
immediate reveofWashington
SeeRor. his docs398
besase itis lethat
Gn70,777Goi)
scommending sono ofeee ofmediate oie wh eslaion GfVou suet sk IAD.
6
|
Exhibit 11
Transcript of August 25, 2022 Special
Purpose Grand Jury Hearing before the
Honorable Robert C.I. McBurney, Atlanta,
Georgia, In re 2 May 2022 Special Purpose
Grand Jury, Case No. 2022-EX-000024
(Fulton Co. Sup. Court).
[ 1
' IN THE SUPERIOR COURT OF FULTON COUNTY
: state oF GEORGIA [r=
4 Re: ) [sega |
5 | seeciar eureose GRaND sURY ) a| |
6 ) CASE NUMBER: 2022-EX-00024
;|
|
8 2022-EX-00024 |
ol
10! SPECIAL PURPOSE. GRAND JURY NOTIONS TRANSCRIPT !
nl Before the HONORABLE JUDGE ROBERT C.1 HCBURNEY |
|14 | neseasances:
12 | on July 25, 2022, Atlanta, GA 30303
||
i
20 here.
2 THE COURT: Great. Okay. Clapp as in applause or
22 Platt as in . . .
2 ATTORNEY CLAPP: Clapp as in applause, two B's.
2 THE COURT: Got it. Excellent, and then on behalf of
25 the 11 alternate electors, Ms. Pearson and Ms. Deborroughs
HADASSAH J. DAVID, OFFICIAL COURT REPORTER i
'
1
1 T see Ms. Deborroughs virtually. She is appearing in
2 Newnan or even further away, but we greenlighted that J
3 virtual appearance. It's fine, and we've got Ms. Pearson
4 here.
5 ATTORNEY PEARSON: You do, Your Honor.
5 THE COURT: Okay. Anyone else on behalf of your
7 clients or just the two of you?
8 ATTORNEY PEARSON: No, Your Honor, just us.
s THE CORT: MI right. Iowans to stazt with a |
10 question for either Ur. Dillon or Ms. Clapp, and that is i
u whether you are joining in the motion that Ms. Pearson |
12 filed in which Fifth Amendment concerns are raised as i
13 opposed to conflict issues?
u ATTORNEY DILLON: Yes, Your Honor. Insofar as Ms.
15 Pearson's motion, I believe at page 7. It raises the fact
16 that these witnesses who have received both subpoenas and
17 target letters should have their appearances waived. We
18 join in that portion of her motion.
19 THE COURT: What is the status of your client? I
20 know he's received the subpoena, that is the only part
2 that's been disclosed to me. |
22 ATTORNEY DILLON: Well, in the government's response
23 to our motion, they actually point out that Senator Jones
2 received a target letter in this case.
25 THE COURT: Okay. Do you disagree with that or . . . | |
ons 3. wv, arco, coe ewes | |
1 ATTORNEY DILLON: No, I do not. It is an irrefutable
2 fact at this point. We publicly acknowledge that it is an
3 irrefutable fact.
4 THE COURT: Okay, so my thought is that we talk about
5 some of the Fifth Amendment concerns first because it may
6 make moot for practical purposes the conflict concerns
7 that you raise in your motion. Let me simplify my thought
8 process for you. If in the end I determine that Senator
9 Jones need not appear because of Fifth Amendment reasons,
10 I don't know we need to reach the question of
1 disqualification if that would be his only connection to
12 this grand jury.
13 This Grand Jury is not a Grand Jury that would be
14 voting on a bill of indictment. It is a Grand Jury that
15 has been tasked with generating a report that would
16 contain in it, ideally, a recommendation to the District
17 Attorney as to whether she should pursue charges or not
18 and what those charges might look like, and any other
19 things that that Grand Jury wants to put in there other
20 than a true bill.
21 So the way the Fifth Amendment analysis plays out is
22 that I conclude that Senator Jones doesn't need to appear,
23 if they state his name or something, and we can work
24 through those logistics probably in a smaller group
25 setting. Do you agree that we don't need to reach the
HADASSAH J. DAVID, OFFICIAL COURT REPORTER A
: |,
1 question of disqualification? !
2 ATTORNEY DIZON: No, Your Honor. I do disagree. |
3 HE CouRE: Okay.
4 ATTORNEY DILLON: I think that the disqualification
5 issue is right, and I think that it has been exacerbated
i|
1 ADA WADE: Not a barrage of like 50 questions where
2 they decide to assert, but just to be able to hit the
3 different buckets though and to answer the Court's
4 question directly, that, yes, sir, there are other areas
5 that we plan to attack.
6 THE COURT: There's more than one bucket for each of
7 the 12 = =
8 ADA WADE: Yes,sir.
9 THE COURT: =~ Is what I'm hearing you say - - well,
10 then we would need to work through that. That helps, I
1 appreciate that, and I think there is ample case law,
12 state and federal, that authorizes witnesses who say up
13 £ront that I'm going to assert the Fifth Amendment to
u still be called before the Grand Jury to then assert it.
15 Bank of Nova Scotia from the US Supreme Court is the
16 earliest one I found where you sometimes need to have
17 those people get in front of the Grand Jury to actually
18 invoke, because they might not when put in that situation,
19 and then the investigators are not forced to rely on a
20 claim that they will, or to your point, Mr. Wakeford and
21 Mr. Wade, there may be areas that come up that aren't
22 | properly covered by that protection.
23 I know we've been bouncing around a lot, but I think
24 it makes sense for me to hear now from Ms. Pearson or Ms.
2 Deborrough about the approach you've taken, which is my
HADASSAH J. DAVID, OFFICIAL COURT REPORTER 16 -
1
9 I've had this job for 10 years, and then they move on
10 to what did you have to do with the electors scheme Fifth
1 Anendnent, and then they stop. They don’t go any further| |
12 with that topic, but to the District Attorney's offices
13 point it’s a broad waterfront, and you have seized upon
14 maybe the big bright lighthouse, vis-a-vis your client's,
15 but there could be some (unintelligible) buildings at that
16 that lighthouse that it’s appropriate for questions to be |
17 asked and more importantly answered.
i
|
1 a legal perspective. They were all witnesses, they were
2 all converted to targets, and there has been no
3 differentiation from the DA's office between that.
“ THE COURT: Let me interrupt you for a second. So,
5 you are saying all 11 of them have received target letters
6 or some communication from the District Attorney's Office
7 that uses the “I” word?
8 ATTORNEY PEARSON: Yes.
9 THE COURT: Whatever that may mean in the State
10 context, but just because two of your clients have, you
1 are saying they are similarly situated, it's just a matter
12 of time for the postman to get there.
13 ATTORNEY PEARSON: I have 11 target letters.
1 THE COURT: Okay. So in that way they are similarly
15 situated, but it sounds like they are, and you note it in
16 your own motion, they are also very differently situated.
17 You have, and T apologize if I have the title wrong, Mr.
18 Schaffer as the chair of the Republican Party in Georgia,
19 A very, very, different role in connection with the
20 affairs of election then. I don't remember who the
2 elderly individual difficulty with mobility and whatnot.
22 T've never heard of the person.
23 Tt is a differently situated individual once you get
24 outside of that lighthouse of, I was an alternate elector.
25 ATTORNEY PEARSON: That's true, Your Honor, but I
HADASSAH J. DAVID, OFFICIAL COURT REPORTER 0
|
|
1 talk to me a little bit about the last, second to last
2 point I heard from ks. Pearson about an inability to
3 immunize because, of course, one ticket you can punch that
4 you may not want to punch for anyone, but you may for some
5 of the alternate electors whose sole connection or primary
6 connection to what you're investigating may be the
7 alternate elector situation, would be to lot them know
8 that nothing you say during a Grand Jury can be used
s against you.
10 If you put that in writing then you magically have
un some compulsory powers, I do, that did not exist before,
12 but if thers is not a way to provide sufficient protection
13 you may not have that, and I hadn't processed it the way
1 Ms. Pearson did. Anything you want to add on that? hr.
15 Wade is shaking his head. As in you disagree or I don’t
16 want to add to 1t?
bY ADA WADE: I vehemently disagree, and there was no
18 effort or attempt or even any indication that our position
19 would be to offer any type of immunity, if that is what
20 she’s looking for.
2 THE COURT: I didn’t hear Ms. Pearson looking for
22 anything. Wnat I heard her say was that even if you
23 wanted to, and you're saying I don’t want to, the scope of
2 the District Attorney's offices offer of immunity wouldn't
25 be sufficient in Ms. Pearson's mind to protect her clients
HADASSAH J. DAVID, OFFICIAL COURT REPORTER ”
;
12 the buckets. 1
13 In no way would I be requiring that here are the 112
14 questions, here is a script, but it would be that these !
15 are the categories that we want to explore, and then there
|| TELS
TEE TUT
TII IUL
OTI
6 books, blah, blah, blah , and it specifically excludes
| ESImimoI
7 subpoena targets, Your Honor, and these are the rules --
jE
1 constructing statutes. If there is a list and it’s not
(|A IE E
15 THE COURT: It didn’t say subpoena tall people or
ER I
16 short people, it says witnesses.
[|[| SETI
Emm
[|[|SI
[| EI mn TTIE IIT
T
21 says that because targets are discussed differently in the
RI
EEE.
|
|
i
1 sentence, Mr. Dillon.
2 ATTORNEY DILLON: A very powerful sentence, and with
3 regard to regular grand juries, I have no doubt that the
4 District Attorney might, but the statute under which the
5 subpoena is issued in this case properly is not that the
6 ordinary Grand Jury, mor the special grand jury, and it’s
7 under this chapter in the Georgia code, and the rules are
8 different.
9 THE COURT: So your argument is that a regular Grand
10 Jury that could indict and would target -- Lampl says you
11 can call that person in front of a that Grand Jury who has
12 the ability to indict Lample, and they can invoke his
13 Fifth from which they need to draw no adverse inference,
1 but a special purpose Grand Jury which can indict no one
15 or anything, they can’t subpoena a target because they use
16 the word witness instead of ‘target?
17 ATTORNEY DILLON: Yes, Your Honor.
18 THE COURT: Is the word target used in the
13 non-special purpose Grand Jury statute, or is the word
20 witness used?
21 ATTORNEY DILLON: Interesting question, Your Honor,
22 but I do note that the subpoena is - -
23 THE COURT: What's the answer?
2 ATTORNEY DILLON: I don’t know, but I do note that
25 the statute under which the subpoenas were supposed to be
HADASSAH J. DAVID, OFFICIAL COURT REPORTER 32
|i
1 issued in this case is under Title 15, but the subpoena is|
2 actually rolled out under the provision of the Georgia .
3 code that is not under Title 15, and they were, in fact, :
1 technically, improper subpoenas because they were issued i
5 under the normal statute and not under this chapter.
5 THE COURT: So T guess we could republish them and
, resign them if that is the = = |
8 ATTORNEY DILLON: Exactly, and then recognize that
s this rule applies, but not the Lampl rule that we're
10 citing here.
un ATTORNEY PEARSON: Your Honor, we would take a
12 slightly different differentiation of Lample = - !
13 THE COURT: A third reading. :
14 ATTORNEY PEARSON: It’s actually the same read, and i
15 that is the sentence that he read is (unintelligible) What| |
16 the the Supreme Court is saying in Lampl, we have an
17 individual who didn’t take his Fifth in the Grand Jury,
18 the special purpose grand jury, the special purpose Grand |
19 Jury used its authority to have a conveyer who was later |
2 indicted in an improper Grand Jury.
21 I'm not suggesting they were improper, but a i
22 different regular Grand jury, and then he tried to get i
|
1] i 15 vicasssen evecciee thot rire smnment sight 50 |
2 disclose after the fact or before the fact they wers
3 called, then they are allowed to do that. That is the i
4 source of publicity around this. It is, I think here we
2 come out the same day or are they spread out, Ws. Pearson?|
3 ATTORNEY PEARSON: Your Honor, we have - - they are :
|
1 don't think it's appropriate under the case law Lampl and
2 others to quash the subpoenas, but it may be that these
3 witnesses have very, very, brief appearances in front of
4 the Grand Jury.
5 ATTORNEY PEARSON: Your Honor, just so that I
6 understand. We aren't going to elaborate on it ahead of
7 time. We will collaborate when the first witnesses come
8 here or in between each witness? I mean, we've got 11
3 people to get through, so I guess I need some clarity on
10 how that's going to work for each witness.
u THE COURT: So I invite early collaboration, but I
12 also understand that if the District Attorney's Office is
3 reluctant to get too specific too far in advance, so they
u may buckle under the pressure of how long that would take
15 as well, and there may be some basic frameworks that they
16 want to share with you in advance, but if you're now
7 getting into the nuts and bolts that I get to stay out of.
18 Iwill get in the mix should an impasse be reached.
19 If that impasse is reached tomorrow, because you're
20 talking about a witness who is coming on an undisclosed
21 date next week, at an undisclosed location, then I could
22 talk with you all tomorrow, but it may well be that the
23 default is let's talk when you're witness is here.
2 That may mean you won't get to everything next week.
25 That was - - the reason why I was asking is that if they
HADASSAH J. DAVID, OFFICIAL COURT REPORTER “
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1 are spread out you four weeks you - - they're all coming |
2 in next week. I could see it being that what had been |
3 scheduled for Thursday ends up being what was scheduled
‘ fox Tuesday, because you only got through two people on | |
5 Tuesday because of the confirming that doesn't occur until
6 Tuesday, so I'm not forcing an answer to your question,
7 what you develop with the District Attorney's Office.
8 ATTORNEY PEARSON: In Light of that, Your Honor,
9 would the Court at all be amenable to to moving our grand
10 Jurors, not quashing them but moving them to later so that
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1 support. Using the title of your office and having a
2 social media that you as this political office holder are
3 holding a fundraiser for the opponent of someone that this
4 political office is investigating. I don’t know that it’s
5 an actual conflict, but I use that phrase, “what were you
6 thinking,” where the prosecutor thought I could prosecute
7 the codefendant of someone I defended.
8 It's a what are you thinking moment? The optics are
9 horrific. If you are trying to have the public believe
10 that this is a non-partition driven by the facts, and I'm
u not here to critique decisions. The decision was made,
12 but If we are trying to maintain confidence that this
13 investigation is pursuing facts in a non-partisan sense,
14 no matter who the District Attorney is, we follow the
15 evidence where it goes and ignore that fact that I hosted
16 a fundraiser for the political opponent of someone I just
n named a target.
18 That strikes me as problematic. Maybe not from an
: 19 actual conflict level, but if we are at a cocktail party
20 and people are asking do you think that this is a fair and
2 balanced approach to things, I do. Well, how do you
22 explain this?
23 I mean, how does one explain? I mean, that is the
2 concern I'm working through is that it is not a lowercase
25 A appearance, it is a capital A with flashy lights
HADASSAH J. DAVID, OFFICIAL COURT REPORTER 16
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2 office.
2 The District Attomey is the legal adviser of the |
special purpose Grand Jury, amd may vel Fave an |
2 investigation of their oun, but Senator Jones is trying to
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1 fight a subpoena to the special purpose Grand Jury, and it
2 was brought under their authority.
3 THE COURT: It was, and I think technically you are
4 correct. I wouldn't want anyone to be misled, that the
5 special purpose Grand Jury is the only -- meaning those
6 grand jurors are the only source of subpoenas that they
7 say to their legal adviser, where is what we'd like to see
8 next. That can happen, but what can also happen, and it
9 doesn’t matter who it happened here because your point is
10 a good one, but I don’t want people leaving here thinking
1n oh, it’s only the special purpose Grand Jury that decides
12 to come in and. Equally so and perhaps most of the time
13 it's the District Attorney's team that says, here's who we
1 would like to have come before the special purpose Grand
15 Jury next. .
16 That subpoena comes through the Grand Jury maybe the
n wrong statute under the subpoena, but it comes through the
18 Grand Jury, but the idea, motivation, and the decision is
19 £rom the District Attorney's office. I don't know how
20 Senator Jones’ subpoena which channel from which it
2 flowed, I've got an inkling, but it doesn’t matter. Your
22 point is a good one.
23 I don’t know that it cures the concern about
2 political support for an opponent not having any bearing
25 on how focused or not the special purpose Grand Jury would
HADASSAH J. DAVID, OFFICIAL COURT REPORTER ”
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1 went out at the same time.
2 THE COURT: Okay.
3 ATTORNEY GREEN-CROSS: So it was not pegged to any
4 event that had any relevance of Lieutenant Governor's race
5 or any other political option was dictated by the terms
6 and the pace of that investigation.
7 THE COURT: So the 11 that Ms. Pearce and Ms.
8 Deborrough received were issued on the same day, and
s effectively the same time as Senator Jones?
10 ATTORNEY GREEN-CROSS: Yes.
1 THE COURT: Tt is not Senator Jones got his on a
12 special day, and it was a broadcasted event, and then the
13 other 11 went out?
1 ATTORNEY GREEN-CROSS: It was a routine issuance of
15 the change of status as Mr. Wade explained in an effort to
16 be transparent to everyone who had been working and
7 talking with the State.
18 The final point I think I kind of want to make is
1 that, as noted in the brief, we have partisan District
20 Attorneys and partisan elections for those offices, so it
2 should surprise exactly nobody elected District Attorney's
22 should have political affiliations with other individual
23 within the same political party, and I think the post case
2 == I've got a copy for the Court if you are not familiar
25 with it and a copy for Mr. Dillon.
HADASSAH J. DAVID, OFFICIAL COURT REPORTER 30
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I
1 attention because it does draw a focus on these are the
2 things that happen when you have political affiliations
3 for elected offices. It's expected, it's normal, and
4 until or it shows some actual conflict then that is just
5 maybe the upside, maybe the downside, but that's a
6 consequence of the system that we have.
7 THE COURT: Okay.
8 ATTORNEY GREEN-CROSS: One more final thing, and I
3 think this could streamline some of our other
10 conversations about remedy. The State is not interested
1 in any sumer surprises. I couldn't source that October
12 deadline to anything. I'm unable to determine when that
13 is. I don't believe we have that here. It's especially
u unlikely.
15 THE COURT: My understanding from speaking with the
16 Grand Jury directly. My supervisory role is that the
7 timeline is whatever the timeline is. There is no
18 deadline, they like to be done with this soon, but that is
19 only because they are giving much of their life to this
20 process, but they'll follow this process as it unfolds,
21 and as I intimated to Mr. Dillon and I'll make it clearer
22 when I wrap up the disqualification session that if the
23 work is completed such that it lands on or near the
2 election, it will state in the pleading and be in my
25 office until it gets disclosed after the election.
HADASSAH J. DAVID, OFFICIAL COURT REPORTER 52
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1 If that's not enough, legally, then we'll all agree
2 that there was an appearance of conflict, hopefully
3 something like that doesn't happen again between now and
1 the conclusion of this electoral cycle, but that is what I
5 need you to start with appearance verses actual and
6 anything else we need to cover that you already didn't.
7 ATTORNEY DILLON: Your Honor, if I may. My associate
8 has a power point, and we'd like to plug into the screen
9 if that is possible to the Court.
10 THE COURT: It is, Ms. Clapp is a part of this zoom
un session, and you're able to share your screen. Is what
12 you're going to share something you shared with Ms. Cross
13 or is this brand new?
14 ATTORNEY DILLON: We have not shared this with Ms.
15 Cross.
16 THE COURT: It's not evidence?
bY ATTORNEY DILLON: It's not evidence, but we do have
18 some exhibits, Your Honor, we do have some evidence here
19 today.
20 THE COURT: Okay, if there is going to be evidence,
21 let's just make sure Ms. Cross gets a chance to see it
22 before we blast it on the screen.
23 ATTORNEY DILLON: Absolutely. oh, no. It won't be
2 blasted on the screen. It won't be published before —-
2 THE COURT: Okay.
HADASSAH J. DAVID, OFFICIAL COURT REPORTER 5
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1 ATTORNEY DILLON: It's also in my brief.
2 THE COURT: Lampl.
3 ATTORNEY DILLON: Okay. The DA cites it for the
4 proposition that, "The standard of neutrality for
5 prosecutors is not necessarily astringent as those
6 applicable to judicial or quasi -- judicial offices," and
7 she is correct, direct quote from Young.
8 It is not astringent, and the Court goes on to say
9 that the different in treatment is relevant whether a
10 conflict is found, however, not to it's gravity once
1 identified. We may require a stronger showing for a
12 prosecutor that a judge in order to conclude that a
13 conflict of interest exists, but once we have drawn that
u conclusion we have deemed the prosecutor subject to
5 influences that undermine confidence that a prosecution
16 can be conducted in a disinterested fashion.
17 If this is the case we can not have confidence that a
18 proceeding in which the officer plays the critical role of
19 preparing and presenting the case for the defendant's
20 guilt or hear the defendant's recommendation for a charge.
21 And so here is the Supreme Court saying that if the
22 confidence is undermined, if the Court is saying, what
23 were you thinking, then the decision is already made,
24 because if we have a what were you thinking factor that
25 even if they recommend discharge, and even if they died,
HADASSAH J. DAVID, OFFICIAL COURT REPORTER 6
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1 career as opposed to revelations about someones connection
2 to a series of events that are particularly controversial
3 in our society right now might prove problematic for that
4 political candidate. I can't help that part. Those were
5 choices that were made. That might elevate that candidate
6 in the eyes of some. They might not elevate that
7 candidate in the eyes of many.
8 ATTORNEY DILLON: It may, Your Honor, and with regard
9 to those facts, Senator Jones was willing to come in and
10 meet with the prosecutor and sit down and say these are
1 the facts of the case, under oath and maybe not under
12 cath, but then they received this carpet bombing of target
13 letters for everyone who signed the document, it is
1 suddenly 16 witnesses had the door slammed in their face
15 because they were told that they less friends of the
16 investigation or targets.
7 Can we go to the next slide? Mr. Jones received his
18 target letter on July 6th as the DA indicated. Contrary
19 to their motion where they indicated he was a potential
20 target, he was told he was What? Next slide. "You are
21 advised that you are "A target" of the Grand Jury.” This
22 was on July 6th.
23 Next slide, please. On July the 12th, six days
2 after, I received this target letter, and I will say that
25 we consider this to be highly confidential, and the only
HADASSAH J. DAVID, OFFICIAL COURT REPORTER 5
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1 two people in the world that knew about the target letter |
2 were me and the district Attorney's office. I get this |
3 unsolicited e-mail from a reporter with -- |
1 ATTORNEY GREEN-CROSS: I'm sorzy —-
5 THE COURT: Stop.
6 ATTORNEY GREEN-CROSS: I'm sorry. This isn't a
7 document. that T've seen before, so before we publish it,
8 Mr. Dillon can you —- '
s THE COURT: Can you take that down, Ms. Clapp back to |
10 the preceding page? And so, Mr. Dillon, you had assured
u me that —- !
12 ATTORNEY DILLON: Yes, I did, Your Honor, and tnmy | |
1 THE COURT: Well, be less zealous. Represent your
15 Client, but let's not slap e-mails for which no foundation
16 has not been laid upon the screen. I thought you said, in
1 fact, T know you said don't worzy, the actusl exhibits I
1 won't put on the screen, they'll just be in my hands and
1 they won't be published. |
20 ATTORNEY DILLON: I had a carefully drafted script,
2 argument. May I approach and enter before the Court with | |
2 a copy.
2 THE COURT: You may.
25 ATTORNEY GREEN-CROSS: If it's a copy of Defense
PN ——————
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1 Exhibit 2 then again, there's no foundation. I haven't
2 seen it before.
3 THE COURT: I'll take it. I won't necessarily make
4 it a part of the record --
5 ATTORNEY GREEN-CROSS: That was a part of my request.
6 THE COURT: If we're going to have a discussion about
7 it, I need to be able to see it. Thank you.
8 ATTORNEY DILLON: It's an original and one.
9 THE COURT: ALL right. Any way. Your representation
bY is that you previously shared with me what happened in
1 your life, and in your life a reporter out of the blue
12 reached out to you and said hey, I heard that your client
13 is targed in the District Attorney's investigation?
u ATTORNEY DILLON: Yes, Your Honor.
15 THE COURT: Well, the special Grand Jury's
16 investigation. Okay.
17 ATTORNEY DILLON: Three days later this same reporter
18 broke the story, and we won't publish that either. It's
13 not an exhibit, and it's on the internet, and we believe
20 the Court -- we'd love to publish the story.
2 THE COURT: You're free to do that, not through the
22 Court's zoom.
23 ATTORNEY DILLON: Okay. We'll hold off on that slide
2 for now, but I will represent to the Court three days
25 later this same reporter broke that everyone who signed on
HADASSAH J. DAVID, OFFICIAL COURT REPORTER 5
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1 Bailey who leaked it, and then now we have ==
2 ATTORNEY DILLON: Yes, Your Honor.
3 THE COURT: But we don't have that here.
4 ATTORNEY DILLON: I do not have that. No indication
5 that Mr. Bailey was involved. ALL I know is that this
6 organization knew and I knew, and of course my client
7 knew, and then six days later this internet reporter
8 knows, and then shortly after that there's an AJC story
5 about it. If we could I'd like to publish Exhibit 3,
10 which is a flyer for it.
1u THE COURT: That's in your pleading.
12 ATTORNEY DILLON: It is.
13 THE COURT: You may -- it's already public record.
1 Let me make sure the State can look at it, but if it's in
15 the pleading =
16 ATTORNEY GREEN-CROSS: If it is what's in the
” pleading then we don’t have an objection to the
18 authenticity of it.
19 THE COURT: Okay.
20 ATTORNEY DILLON: May I approach, Your Honor.
21 THE COURT: I've got it on my screen. So we have
22 this fundraiser, and it's a blockbuster headlining Fani
23 Willis the District Attorney. In fine print you can see
2 where Mr. Bailey is, in fact, a candidate there, the font
25 is so small that I have to squint to see what it says.
HADASSAH J. DAVID, OFFICIAL COURT REPORTER o
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3 This occurs about three esks befors the decision is made | |
2 to make my client target in this case.
3 The District Attorney, according to publicly
4 available records, which I have marked as Exhibit 4. This
5 particular document, Your Honor is from the public
6 campaign finance website here in Georgia, so this is
7 publicly available data. It shows during the day of and
8 during the day after this fundraiser $32,000 made to the
5 office of Wr. Bailey. fle submit is a direct result of
10 this fundraiser. I'm told that the custom is, often
1 people show up with a check or they give their regrets and | |
12 sent a check the next day. During this particular |
13 month,Mr. Bailey raised over $270,000 dollars. |
14 THE COURT: So this was a particularly small i
1 fundraiser for hin?
16 ATTORNEY DILLON: This might have been a particularly| |
pe) big one. This might have been the one that caused the |
18 avalanche of checks to come in. |
1 THE COURT: Could be for all those people who are
20 checking the ethics website to see what the cash flow |
2 Looking Like for the first couple of weeks were, so I'll
22 put my money behind it. |
2 ATTORNEY DILLON: This is the sort of headline
2 fundraiser that gets people to say, oh, we have a big
2 uhesl. We have somebody who is on the nightly news, as
HADASSAH J. DAVID, OFFICIAL COURT REPORTER “
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1 this Court knows, who is pulling for Charlie Bailey.
2 THE COURT: Okay.
3 ATTORNEY DILLON: One candidate in the Lieutenant
4 Governor's office or the Lieutenant Governor's race gets a
5 headliner, the other one, three weeks later gets a target
6 letter -- quistly get's a target letter. Now, there were
7 numerous news stories speculating about the existence of
8 target letters on or about the time of the Yahoo news
9 article, and there was a lot of buzz about that.
10 In fact, there was even an AJC story where DA Wilis
un was quoted as saying that numerous attorneys had received
12 target letters on their behalf. It didn't name Senator
13 Jones, fortunately. In fact, it wasn't publicly known
1 that Senator Jones received a target letter until the DA
15 filed their brief two days ago.
16 They were the first people to acknowledge he was a
17 target for this Grand Jury. We had never acknowledged
18 that. It was a mere speculation in the press, but it's
19 that sort of thing that gives the DA the the ability to
20 benefit their friends and harm somebody who is under
21 investigation, and that is really what we're talking
a about.
23 The cases that the DA's point to in their motion from
24 1916 and 1936 are talking about transactions where the
25 financial transactions were $150, and was that materially,
HADASSAH J. DAVID, OFFICIAL COURT REPORTER o
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1
1 and while those are interesting cases, but once that $150
2 was material in the depression, we were talking about
3 $30,000 and we're talking about swaying an election, a
4 statewide election in Georgia, and that's a significant
5 thing.
6 This is not something that is being done by accident.
7 This is being done by design. This fundraiser was pointed
8 at benefiting Senator Jones --
9 ' THE COURT: Isn't that the purpose of the fundraiser.
10 I agree =~ the point of -- the question is does the
1 District Attorney decision to support someone with whom
12 she is politically aligned, it surprises no one that they
13 are politically aligned. Does that rise to the level of
1 creating -- an appearance of -- , and I've opined on that
15 a little bit an actual conflict, and I understand because
16 you can't climb into someone's mind.
17 You have to do a little of this through the
18 shadowboxing of, okay -- there is a fundraiser and all of
19 this money came in, and then there was a target letter.
20 Do you have more of a connection of one who proceeded the
21 other?
22 ATTORNEY DILLON: As far as a direct connection?
23 THE COURT: Any connection.
24 ATTORNEY DILLON: What is out there in the press,
25 what is out there in the ether. A part of Senator Jones’
HADASSAH J. DAVID, OFFICIAL COURT REPORTER os
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1 concern is that this report is going to come out in
2 October. I'm glad to hear there's no October surprise,
3 but there's been this whole series of drips, this whole
1 series of leaks out of the Fulton County DA's office that
5 have tilted benefit towards Mr. Bailey. It pointed to my
6 client as being a presumptive violator of the law, and
7 it's only because the DA has the authority to do that.
8 So if this Court were to determine that she has a
° conflict, and this appearance is sufficient, and we go to
10 the Attorney General's office to appoint a new prosecutor
1 with regard to Senator Jones who could sit down with hin
12 and say, Well, Senator Jones, we're interested in what
13 happened in December 2020, would you like to talk to us,
u and just like we did on day one, with the DA's office?
15 Certainly, we would be glad to. Do we have a target
16 letter from your office? No, you do not, Senator Jones,
bt) because we have useful information that would age your
18 investigation, because this is an investigation when it
15 was impaneled that was supposed to gather evidence to see
20 whether or not there was an effort to undermine democracy
21 in this country, and when Senator Jones said, I have a
22 subpoena here, I'm going to talk to these people we said
23 fine. We prepared our rates, but then we've got this
2 target letter and then everything changed, just like it
25 did for these 11 clients.
HADASSAH J. DAVID, OFFICIAL COURT REPORTER ”
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1 ATTORNEY DILLON: This was pulled off of the
2 internet.
3 ATTORNEY GREEN-CROSS: Did you pull it from off of
4 the internet?
s ATTORNEY DILLON: Yes, I did.
6 ATTORNEY GREEN-CROSS: Okay. Was it from the PAC
7 website?
8 ATTORNEY DILLON: You have to have access to the PAC
9 website to get it.
10 ATTORNEY GREEN-CROSS: And I'm wondering how you got
1 it.
12 ATTORNEY DILLON: It's out there in the ethers.
13 THE COURT: He got it from Yahoo.
1 ATTORNEY DILLON: I got it from Yahoo.
15 ATTORNEY GREEN-CROSS: I want to kind of thank you
16 for your candor.
17 ATTORNEY DILLON: HWould you like to present it to
18 your client? She would have attended this training, and
19 see if it's complete?
20 ATTORNEY GREEN-CROSS: I would like to preserve
21 publication of the document until I can ascertain whether
22 it is true, accurate, and complete, because I understand
23 that it has been sourced to the internet, and that is not
24 something that I can accept, this authentication.
25 THE COURT: Okay, so it's admitted. I'll take it,
HADASSAH J. DAVID, OFFICIAL COURT REPORTER 2
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10 relevant.
11 THE COURT: Okay. So are you going to be reminding
12 her now by reading it? :
» NORORITY DILION: © would Love o Just Tend a fow
1| entepets, 56 © nay, vous nonor.
15 THE COURT: If they are truly snippets. !
2 ATTORIEE DILLON: "The 0A and Assistant DA's should
11 | retrain from aking exers Sudtoial coments that nave s | |
18 substantial likelihood of heightening public condemnation |
19 of the accused.” That is rule 3.8.
I
1 preferable outcome?
2 ATTORNEY DILLON: Well, as the Court is aware, there
3 are not numerous special Grand Juries of this magnitude to
4 point to for precedent, so what we suggest in our brief is
5 that the statutory provision that requires, once there's
6 a conflict made apparent, that it be referred to Attorney
7 General Carr's office and he find someone to conduct that
8 portion of that here independent of this special Grand
2 Jury, and it can be as simple as finding a District
10 Attorney that doesn't have to find a good solid democratic
1 District Attorney somewhere who doesn't have a conflict
12 and give him the authority to pursue Senator Jones' issue
13 in this, and we would be glad to sit down with him.
1 fle would be glad to sit down with you. We would be
15 glad to approach this with the same willingness to say
16 let's get to the bottom of this issue and whether or not
17 there was a conspiracy to undermine democracy in this
18 country because that is an important issue, and let's put
19 the media circus behind us. So let's answer the questions
20 and forget it affecting this election for Lieutenant
21 Governor, because there's no way she can keep a hand in
22 it.
23 THE COURT: She being the District Attorney?
24 ATTORNEY DILLON: She being the District Attorney.
25 Forgive me, Your Honor, and not affect the outcome of this
HADASSAH J. DAVID, OFFICIAL COURT REPORTER 7
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1 election for Lieutenant Governor.
2 THE COURT: So if Attorney General Carr selected
3 fictional istrict Attorney X who had also given $2,000 to| |
4 Charlie Bailey's campaign for Lieutenant Governor --
5 ATTORNEY DILLON: It would not be a problem at all.
6 It's an ordinary contribution, and it's exactly what
7 counsel points to. Now, if they had hosted a fundraiser
8 during the time period that they were investigating
9 Senator Jones, I might have to go to that judge and talk
10 about that fundraiser.
1 THE COURT: What if that District Attorney had
12 already hosted -- the District Attorney is not involved in| |
un that investigation. She hosted a fundraiser tuo weeks |
1 ago, $50 grand or even more money than DA Willis, but it's| |
15 done. Tt's over and done with, and I'm not going to do « |
16 anymore fundraisers fxom here on out, because now I've |
n been tasked with seeing what connection, if ahy, Senator |
18 Jones had to what was going on in November and December. |
jt) ATTORNEY DILLON: If every District Attorney in the
20 whole state had hosted a fundraiser for Mr. Bailey then
2 that issue might be apparent, but I suspect, giving the
2 List of good democratic District Attorneys in this state
23 that we can find somebody who doesn't have a conflict and
2 hasn't hosted a fundraiser for either one, because
25 certainly, if somebody that hosted a fundraiser for
HADASSAH J. DAVID, OFFICIAL COURT REPORTER "
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1 Senator Jones, the Attorney General shouldn't nominate
2 that person either. Find somebody who doesn't have a dog
3 in the hunt. Fani Willis has a dog in this hunt.
4 THE COURT: Got it. Thank you, sir.
5 ATTORNEY DILLON: Thank you, Your Honor. Oh, can we
6 offer into evidence Exhibits now.
7 ATTORNEY GREEN-CROSS: Actually, I was going to ask
8 to leave it up.
9 THE COURT: Leave it up? Okay, don't take it down?
10 Too late. Thank you, Ms. Clapp.
un ATTORNEY DILLON: Can we offer into evidence 1-5?
12 THE COURT: If there's no objection, 1-5. Was § the
13 one where the province was the internet?
u ATTORNEY GREEN-CROSS: Yes. I was going to object to
15 the authenticity. I believe the foundation has been shoiin
16 for Exhibit NO. 5, we entered it into evidence so I didn't
7 object to the Court reviewing it, but I do object to it
18 being tendered and admitted.
19 THE COURT: Why don't we do this? I will take 1-5,
20 and then I will give Mr. Dillon to maybe shore up his
21 sourcing of it, and if, in fact, it is pretty clear that
22 Smith was the name of -- Mr. Smith's presentation then
23 I'11 add to 5 the other 4. I'll hold on to it, but it
24 won't become part of the record until either Ms. Cross you
25 agree to talk to Mr. Dillon a little bit more and we see
HADASSAH J. DAVID, OFFICIAL COURT REPORTER 76
1 the source, or we're substituting to you -- someone can )
2 get it off the PACK site. i
3 ATTORNEY GREEN-CROSS: I do want to raise objections :
4 to some of the others, but if they're being tendered now i
5 into evidence, Exihibit 1, the letter, I don't have any
6 objection to that.
7 THE COURT: Okay, 1 is admitted.
8 ATTORNEY GREEN-CROSS: Exhibit No. 2 is the e-mail
9 that I do have an objection to that being tendered and :
10 accepted into evidence without any providence of it. I do
1n also object to the relevance of it. There's nothing in |
12 this e-mail that sources any information to the District :
13 | Attomests office tnsofer as this being offered to shan | |
1 that the leaks are coming from this side of the table. I | |
15 object to the relevance of that, and I don't think it !
16 shows that, and T object to the admission of it into |
17 evidence. !
18 THE COURT: Okay.
19 ATTORNEY GREEN-CROSS:. No. 3 is the fundraiser flyer
20 that is up on the screen now, and we don't have any i
21 objection to that being tendered and admitted into i
22 evidence. Exhibit No. 4. Again, T have an objection to i
23 the relevance of this. I don't think it shows what, at
2 least what's been argued. It's been identified and
25 offered for the purpose of establishing how much money was
HADASSAH J. DAVID, OFFICIAL COURT REPORTER 7
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1 raised at the fundraiser, but what the actual document is
2 or appears to be, based on Mr. Dillon's representation,
3 and I don't have any reason to doubt it.
1 This is publicly available about how much money was
5 donated to mr. Bailey campaign during a 2-day period in
6 this document to the fundraiser, and while w I don't
7 think that is going, and because of that I don't think
8 that we have an objection to the ruling.
9 THE COURT: Okay, and then 5 is being conditionally
10 adnitted, provisionally admitted. I'm assuming you can
un clear up the source.
12 ATTORNEY GREEN-CROSS: Yes, sir.
13 THE COURT: ALL right. Anything you want to add, Mr.
u Dillon?
15 ATTORNEY DILLON: No, Your Honor.
16 THE COURT: ALL right. I will admit Exhibits 1 and
7 3, and then 5 will be provisionally admitted. We'll see
18 if the loose ends can be tied up there. Last question,
13 Mr. Dillon, and I'll let you sit down. Beyond the Young
20 case, is there a case or are there cases you want me to
2 look at that stand for the proposition that the appearance
22 of a conflict could be sufficient for a Judge to take any
2 of the forms of remedial action that you are seeking?
2 ATTORNEY DILLON: Your Honor, I rely on the Davenport
25 case, and that is a Georgia case.
HADASSAH J. DAVID, OFFICIAL COURT REPORTER Fe
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I
1 THE COURT: © don't see it in here. You're free to | |
2 rely on it. It didn't manage to make it's vay into your
3 motion.
a ATTORNEY GREEN-CROSS: It was in mine. It's on page
s a
5 THE COURT: You guys share very well when it comes to
2 cases.
® ATTORNEY GREEN-CROSS: The Cite is 170 —= I'm’ sorry,
9 it's 157 Georgia Appeals 704, if that's the case you're
10 seferring to.
n THE COURT: Okay. Do you agree, Ms. Cross, that that
12 discusses the Davenport actusl vs. apparent conflicts. !
13 ATTORNEY GRESN-CROSS: I didn't cite it for that 1
14 proposition, and that's not my recollection of discussion
15 in the case.
16 THE COURT: Okay. I'LL look at it anyway.
bY ATTORNEY GREEN-CROSS: Yes, but don't == yes.
18 ATTORNEY DILLON: Your Honor, I never did get clarity
1 on the basis for the objection to Exhibit 2, other than
20 she objected to it.
2 THE COURT: Relevance was one, and I think it was
2 foundation, although, the recipient, Nr. Dillon, I think
2 he could authenticate it as recelving it, but I'm not sure
2 the relevance you suppose that Mr. Isokoff (sp.) theorized
2 what he did because the District Attorney's office lot him
HADASSAH J. DAVID, OFFICIAL COURT REPORTER 1
1
1 know about it, as opposed to the witness from the Grand
2 Jury or the grand juror.
3 I don't know who's in the circle of discussing who is
4 going to be a target or not, but you've made your point.
5 I'm just not going to make it part of the record.
6 ATTORNEY DILLON: Okay, and with regard to Exhibit 4,
7 the financial fundraising report. We offer that as to Mr.
8 Bailey's take over the two days, the day of the fundraiser
9 and the day after, and we submit that it is relevant.
10 THE COURT: Okay. I thought it showed his take for
un the whole month.
12 ATTORNEY DILLON: No, no, no, mo. It's just a 2-day
13 period.
1 THE COURT: It is before and after the 14th?
15 ATTORNEY DILLON: It is the day of the 14th and the
16 day after.
17 THE COURT: And it is publicly available?
18 ATTORNEY DILLON: Yes, it is, Your Honor.
19 THE COURT: ALL right. I'll admit it.
20 ATTORNEY DILLON: That was Exhibit 4.
21 THE COURT: Yes.
22 ATTORNEY DILLON: May I offer a copy to the Court;
23 I'm not sure I did that, Your Honor.
2 THE COURT: What you want to make sure is that the
25 court reporter, ultimately, has them. I've got number 2
HADASSAH J. DAVID, OFFICIAL COURT REPORTER 0
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'
1 actual Lieutenant Governor nominee for his party, so I
2 want to make that as clear as it can be.
3 THE COURT: When was the runoff election?
4 ATTORNEY GREEN-CROSS: Sometime after June.
5 THE COURT: Good.
6 ATTORNEY GREEN-CROSS: Someone with easier access to
7 google might be able to ~~ the last week of June.
8 THE COURT: Late June?
9 ATTORNEY GREEN-CROSS: late June.
10 THE COURT: ALL right. Got it.
un ATTORNEY GREEN-CROSS: Mr. Smith is going to be so
12 pleased, because he gets another mention. I shared with
13 Mr. Dillon an affidavit from Mr. Smith, who is actually
1 general counsel of the prosecuting of Georgia. May I
15 approach, Your Honor?
16 THE COURT: Yes.
EY ATTORNEY GREEN-CROSS: I've got an original for the
18 court reporter, but I'll hold onto that until it's been
19 tendered and amended. This is an affidavit, thank you,
20 that I shred with tr. Dillon not long before the hearing
2 identifying that Mr. Smith is someone who deals with
22 conflict. He routinely advises District Attorney's as far
2 as general and other entities to the inquiry about the
2 legal requirements and that's the legal conflict for
25 individuals, prosecuting attorneys.
HADASSAH J. DAVID, OFFICIAL COURT REEORTER a
1 He's reviewed the motion, he's reviewed the response, |
2 the motion of Senator Jones, including the runoff }
3 fundraiser flyer that we're still looking at, and he ;
“ determined, in fact, inhis opinion that it does not a |
5 legal requirement.
6 I'm not suggesting that Mr. Smith's opinion
7 (undecipherable) the Court's, but insofar as the
8 individual who routinely advises district attorneys about
9 these matters, this is the individual who is saying that
10 there is not an actual conflict. There is also language !
1 in their indicating, of course, that he does advise that
12 an actual conflict is required, as opposed to the ,
3 appearance of one, so we ask that State's Exhibit No. 1be|
1 adnitted. i
» TE ove: any objection to state's 1 being i
16 adnitted, assuming Jones 5 ultimately get's admitted? |
bl ATTORNEY DILLON: Yes, Your Honor. I'm going to
18 object, subject to Jones 5 being admitted along with this. |
19 THE COURT: Okay.
2 ATTORNEY DILLON: T have no resson to doubt the !
2 authenticity of this, but Mr. Smith also trains them on an i
22 ethical (unintelligible) and so we could be back here next| |
2 week with a motion for prosecutorial misconduct, which I
i|
|
1 provided the Court, he lays out exactly the rules that DA
2 Willis' office has violated.
3 THE COURT: Okay. Sort out Exhibit 5 soon, so I can
4 put that alarm on it. I'm going to admit DA 1 or State's
5 1, but I'd love to see 5. It seems like it ought to come
6 in. I understand the State's concern.
7 ATTORNEY GREEN-CROSS: I think we can work that out.
8 There comes a time when the Court considers Senator Jones'
9 offer of Exhibit No. 5, Mr. Smith's presentation. I
10 believe at least the excerpt that Mr. Dillon read this
un afternoon was a concern or admonishment, or flagging the
12 extra judicial statements of the District Attorney or
13 prosecuting entity.
1 You've heard no evidence this afternoon or to my
15 knowledge in the record anywhere that there has been any
16 extra judicial statement from the District Attorney's
jy office about Mr. Jones officer that has played a part in
18 this.
19 Insofer as the objection this afternoon came to the
20 identification, apparently, for the first time officially,
21 that Senator Jones has received a target letter, of course
22 that was in direct response in the motion to disqualify
23 that was file by Senator Jones on Friday. They raised in
24 that motion equal protection and due process claims. They
25 reference constitutional protections of the Federal and
HADASSAH J. DAVID, OFFICIAL COURT REPORTER 0
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1 make sure a copy gets to our court reporter, but I'd like
2 a copy of 5 as well.
3 ATTORNEY GREEN-CROSS: I'm handing up the original of
4 the affidavit of Mr. Smith.
5 THE COURT: Thanks. Mr. Dillon?
6 ATTORNEY DILLON: Very briefly, Judge. Regarding to
1 the last point raised by the State.
8 THE COURT: Which was?
9 ATTORNEY DILLON: That it is perfectly okay to out
10 the target letter status of Senator Jones in their
1 pleading.
12 THE COURT: I didn't hear that it was perfectly
13 okay. It was an explanation for -- the hand was forced,
14 and because an argument was made or treated differently.
15 I didn't hear that it was perfectly okay. I heard that it
16 was a justification. You don't think it's justified
17 because?
18 ATTORNEY DILLON: I think they could have made that
19 argunent under (unintelligible) and not further the
20 appearance that they're favoring Mr. Bailey in trying to
21 do what? Hold my client up to public ridicule and
22 increase his shame, and do the things that Mr. Smith's
23 presentation says they should never do.
24 THE COURT: Ms. Pearson, was there anything you
25 wanted to add. Your motion with Ms. Deborrough, the
HADASSAH J. DAVID, OFFICIAL COURT REBORTER a
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25
phi
Your Honor. We're not talking about -- although we're
sil
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i
1 talking about political things, we're talking about
2 political motivation by one party against another party,
3 and to actions taken in one uniform direction against
4 republican candidates, prominent republican actors —-
5 THE COURT: fas there a third group of alternate
6 democrat electors in case the democrat electors -- I'm not
7 aware that another group that the special purpose Grand
8 Jury should be investigating in connection with Republican
9 efforts to create republican alternate electors and to
10 challenge the outcome that, at that time, and continues to
1 show that a democrat won. I was going to press Ms. Cross,
12 but she didn't go there about partisan, because partisan
13 has lots of meanings.
14 I don't think that partisan, the case that she cited
15 was democrat and republican, it was I'm partisan because
16 I'm trying to get this guy prosecuted. I have a stake in
17 the outcome of this prosecution. That is not where her
18 argument went today, but everything about this is
19 inherently political, because two political parties
20 collided, someone appears who have won, and folks who
21 appear to have lost didn't like that outcome and said
22 appearances can be deceiving and took some steps, and the
23 question is where those steps legal, and that's, the
24 purpose of this special purpose Grand Jury is
2 investigating, so it seems to me utterly unremarkable that
HADASSAH J. DAVID, OFFICIAL COURT REPORTER oe
{
!
1 your clients are all republicans. fhat would be ,
2 remarkable is Lf they weren't. What's the politicization | |
3 because don't want to miss it if there's a reason to be | |
4 concerned, but you're not asking, I'd hope for, we have to
1 for what I'm trying to say, but you are correct that our | |
15 focus was quashal, and that we are joining in that motion i
16 as an add on.
17 I would also say, Your Honor, that just on behalf of
1
1 separate entity to do that, that's not supervised by this
2 District Attorney?
3 ATTORNEY DILLON: That's correct, Your Honor.
4 THE COURT: Okay, thank you. All right. I think
5 we've covered everything, but let me find out from Ms.
6 Cross, Mr. Wade, Wr. Wakeford. Anything else from the
7 District Attorney's office?
8 ADA WADE: Nothing, Judge. Thank you.
9 THE COURT: Okay. Mr. Dillen or Ms. Clapp, anything
10 further from Senator Jone's legal team?
1 ATTORNEY DILLON: No, Your Honor.
12 THE COURT: Ms. Pearson, Ms. Deborrough, anything
13 else from your clients?
4 ATTORNEY PEARSON: No, Your Honor. Thank You.
15 THE COURT: ALL right. So we're clear, some things
16 I'11 need to memorialize in writing. I am not quashing
17 the subpoenas. I'm repeating myself, but I will be
18 issuing an order, a written order on the question of
19 disqualification, and it will address, not just Mr.
20 Dillon's client, bur Ms. Pearson and Ms. Deboroughs'
21 clients as well.
22 1'11 probably put in there a little bit about the
23 timing of the issuance of the report, but I want to make
2 it clear now in front of everyone what I've heard from the
25 District Attorney's office as well, there is no plan for a
HADASSAH J. DAVID, OFFICIAL COURT REPORTER 0
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1
6 accepting [1] 47/6 [admitted [12] 7025 76/18
i666 3)537958/18 58/22 |ecess [2] 70/882/6 77/1 77121 78/10 78/10
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7 |accommodate[2] 367 |83/168318
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§ [accommodations [1] 36/6 [adopted [1] 872
____ __|according [1] 633 adoption [1] 2/10
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9 7022 94/11 24/3 39/12 40/13 40/16
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A lacknowledge [2] 6/2 64/16 adverse [1] 32/13
am] aud [acknowledged [1] 64/17 |advise [1] 83/11
ability [7] 12/15 14/2 14/10/action [S] 47/17 49/7 53/22] advised [3] 5812190120
26/1532/12 64/19 94/12 | 612178123 90721
able [12] 2/182/25 13/1 [actions [1] 88/3 adviser [4]8/2 47/3 47/23
14/8 16/2 17/2 28/18 45/8 [active [1] 87/7 48/7
54/11 60/7 81/4 82/7 actively [1] 20/19 advises [2] 82/22 83/8
[about [85] 2/4 4/5 6/4 8/24 activity [1] 87/20 advocated [1] 47/11
9111/1111/1413/13 [actors [1] 88/4 affairs [1] 18/20
15/14 15/16 15/20 16/25 [actual [30] 8/343/1 4372 affect [3] 53/16 57/25
173 19/16 2072 22/1 2272 |43/8 4319 44/15 45/4 45/7 | 74125
231124142525 26/5 |45/17 46/5 46/195124 [affected [3] 7/14 20/6 34/6
26/1129/18 3324 34/18 | S24 53225323 54/5 affecting [1] 74120
3433453633723 | SSN4SIR2 5917615 [affidavit [5] 51/21 68125
38/16 38/21 39/4 40/20 | 61/19 61721 65/15 73/19 | 82/13 82/19 86/4
4117 4212 42/5 4217 dann| TARO TS T9N2 8211 affiliated [1] 3/25
43/1543/16 47/4 48/23 | 83/10 83/12 affiliations [2] 50/22 52/2
52105325321 5716 [actually [11] 52316/17 [after [15] 9/25 10/1835/2
57/16 58/1 59/1 60/6 61/8 | 19/1825/728122332 | 35/11 37/8 52/25 58/24
61/17 62/9 63/1 64/7 64/8 |3314 35/7 68/1576/7 | 62/8 63/8 80/9 80/14 80/16
64/9 64/22 64124 6512 65/3| 82/13 82/4 85/17 93/6
671167122 6724 72/9 |ADA [2] 1151/16 afternoon [8] 2122/5 412
7210 72/19 73/19 75/10 [adaptation [1] 8/3 4/7 4/16 84/11 84/14 84/19
78/4 80/1 81/7 81/22 82/23 [34d [9] 211212123 22/14 [afterwards [1] 68/2
$3/884/17 87028702 |22/16 36/13 76/23 78/13 [again [6] 20/20 36/8 54/3
$77588/188/1 88/12 | 86/2589/16 60/1 7722 87/17
88/18 89/24 92122 addition [1] 20/23 against [6] 12/14 21/12
absence [1] 19/21 address [8] 2/1829/16 | 22/9 31/19 88/2 88/3
labsolute [1] 4717 34/13 38122 61/21 85/14 |age [1] 66/17
labsolutely [2] 54/23 68/4 | 87/14 92/19 agencies [1] 8/17
abuses [1] 26/10 adjourned [1] 93/24 lago [4] 10/1 64/15 72/4
accept [1] 70/24 admission [1] 77/16 75/14
accepted [1] 77/10 admit [3] 78/16 80/19 84/4 agree [14] 6/25 13/14
|
A [altered [1] 69715 anticipated [1] 68/8
agree... [12] 19/2223/21 |flternate [15] 2/124125 |any [53] 2122 6/18 7125
24/1 43/14 43/18 4412 44/3| 1W22 13/13 13/15 14/18 | 11/20 13/6 13/17 14/15
54/1650 765 701 | 15/14 18724 22/52207 | 14/17 15/23 17/11 19/18
87/10 39/17 61/1 88/5 88/9 91/24|20/19 22/18 22/19 2512
agreed [2] 13121777 [Although [3] 51/2079/22 |28/182821 29/3 29/5 30/3|
agreeing [1] 91/19 8725 34/6 35/14 35/16 36/24
lagreement [2] 21/19 37/18 |AVays [21 351736/6 |43n2 4717 47174804 |
ahead [5] 10/19 1474 29/23" [5] 3/11 20/19 28/11 | 49/16 50/3 50/4 50/5 52/11|
40/6 59/13 31/3 39/25 44/9 49/14 85/3| 53/1 53/3 53/21 60/9 61/21| ©
air [1] 93/17 92/16 65/23 68/1 69/14 69/15 :
AJC [3] 62/8 64/10 67/17 |*mbiguous [8] 20/11 27/11) 73/14 75/17 77/5 77/10 1
alarm [1] 84/4 27123 27125 28/1 28/4 28/4| T7112 77120 78/3 78/22 |
aligned [3] 65/12 6513 | 28/10 83/15 84/15 85/14
ns amenable [1] 41/9 [anybody [1] 73/4
all [60] 3/12 3/13 4/13 5/9 [Amended [1] 82/19 janybody's [1] 81/14
13/21 14/25 17/1 17725 |amendment [30] 4/64/10 [anymore [1] 75/16
18/1 18/2 18/5 20/5 20/21|S12 6/56/19 6/219/29/3 anyone [7] 3/22 4/18 4/18
2012521520715 215 | 13 11/12 13/2 14/7 14/12| 5/6 22/4 25/14 48/4
3003183116347 | 1523 16/13 17/8 17/11 [anything [24] 9/11 19/13
34/17 3711 3711 37/4 30016| 195231 25M1 2515 [191722142222 26113 |
3011730119 3070 402 | 27222919 35113619 (32/15 34/25 36/8 36/15 i
A149 42/5439 7s | 3173620383389 (36193719 43194710 | |
471949025 53/11 S41 | 437 52/12 54/6 67/21 69/15 :
57/6 60/9 61/11 62/5 63/19 [3mount [1] 47/14 73/19 78/13 86/24 92/6 i
65/18 67/4 67/6 69/17 75/5 [Ample [1] 16/11 9219 92/12 i
78/13 78/16 80/19 82/10 [analysis [4] 6219/2913 (anyway [2] 79/16 93/1 |
87/6 89/1 89/7 920492115 |9/5 janywhere [1] 84/15 I
93/21 93/23 anchored [1] 49/16 apologize [1] 18/17 |
allegation [2] 49/8 51/21 [ANNA [4] 1/17 1184/3 apparatus [1] 73/13
allocated [1] 37/5 419 apparent [8] 53/16 53/19
allowed [2] 353809 [snnounced [1] 67/5 61/5 73/18 73123 74/6
allowing [1] 26/23 another [9] 11/9 41/12 [7521 79/12
allows [1] 45/3 73/20 82/12 87/7 88/2 88/7 [apparently [4] 3/17 7/11
ally [1] 45/22 89/18 90/8 84/20 85121 i
almost [2] 47/4 49/20 answer [12] 11/1 11/2 Appeals [1] 79/9 '
alone [2] 611190717 |11201420 16/324/14 [appear [9] 69 622906 | ;
along [2] 24/3 83/18 27/3 32/23 38/1 41/6 74119| 12/15 1413 24/8 31/17 |
already [8] 11/10 20/525/7 8923 37/11 88721 |
53113 54/6 56123 62/13 [answered [1] 1717 appearance [26] 5/3 10/6 |
7512 answering [5] 12/25 13/17|31/19 42/16 42/19 42721
lalso [11] 4/19 18/16 40/12| 28/21 42/8 55/13 420214044410 44n7 | |
48/8 56/1 75/3 77/11 83/10 [answers [2] 323 17/18 | 45/6 46/25 53/24 5472 54/5
83/21 83/24 89/17 antennas [1] 12/22 55/13 57/21 57/23 61/19 |
|
[A Taround[7 15m016n3 [22242333204 38/4 4013
appearance. [7] GUzz | 20/18 35/4 35/7 38/8 42/12| 43/1 43/10 43/21 44/1
65/14 66/9 78/21 83/13 [arrived [1] 43/16 44/10 44/11 4509 45/12
86/20 89/11 jarticle [1] 64/9 45/18 46/14 47/1 47121
appearances [6] 1/14 5/17 2 113] 47/23 48/13 48/19 51/9
277 403 8122 8822 [ascertain [1] 7021 51/16 53/18 57/17 61/8
appeared [1] 3423 ask [17] 13/13 14/3 15/20| 61/11 62/23 63/3 65/11
appearing [1] 5/1 15/22 26/1 26/5 26/23 27/6| 66/10 68/16 68/24 69/17
appears [3] 72787 |29/12291338/5393 | 69/22 7117 71/22 7306
om 69247317 76/783/13 | 7313 74/6 74/10 74/11
appellate [1] 31/8 87/12 74/23 T4I24 T5/2 75/3
applause [2] 421423 [ked [10] 70 15/11 | 75/11 75/12 75/19 76/1
applicable [1] 56/6 171719/4 19/13 23022 | 81/17 81/23 84/12 89/5
applies [1] 339 35/21 41/25 87/13 89/18 | 89/9 90/6 90/7 9077 90/8
apply [3] 28153005 [sking [10] 1S/12 15/16 |90/20 90/22 91/5 91/13
$324 241526/18349 36124 |91179212
appoiat [1] 66/10 402546120 67/21 89/4 |Attorney's [35] 2/143023
appointed [1] 10/12 aspect [3] 91/11 91/11 | 7/24 8/59/14 10/11 11/6
appreciate [8] 8/1111 | *V16 11/9 18/6 35/6 36/8 38/12
N01 20/15 35/13 87/5 [Aspects [3] 1511536720 |39/10 40/12 41/7 41/22
90/1 93/22 91120 50/21 57/25 59/2 60/13
approach [8] 871625 |SSert [8] 1312 15/21 15722 67/11 67/14 67125 68120
N01 5155002 6220 | 1672 16/13 1611425123 | 71/6 72/8 77/13 79125
74/15 82115 28/12 81/20 82122 83/25 84/16
approaching [1] 15/5 [1Ssertion [2] 4/6 11/11 | 921792125 9373
appropriate [4] 1716 |1ssessment 2] 14/1 14/14 [attorneys [8] 1/19 50220
27/13 40/1 73/12 assist [1] 39725 64/11 69/17 7522 82125
approval [1] 3/5 (Assistant [1] 71/16 83/8858
approves [1] 27/5 associate [2] 4/1954/7 attributing [1] 43/19
are [116] [assume [3] 20/5 25/6 39/18| August [1] 94/16
area [6] 14/11 15/1 26/22 [Suming [3] 61378/10 [authenticate [1] 79123
38/7 53/20 55/17 83/16 authentication [1] 70/24
areas [7] 14/6 14/13 16/4 [155ured [2] 55/6 59/10 authenticity [4] 62/18 69/8
16/21 17/6 1777 3001 [astringent [2] S6/556/8 | 76/15 83/21
aren [2] 1612127115 astrological [1] 3720 [authorities [1] 89/20
aren't 1] 40/6 Atlanta [1] 112 authority [10] 26/14 33/19)
arguably [2] 19710341 [tack [1] 16/5 3415 3416 34/7 4812 61123
largue [1] 89/19 attempt [2] 22/1825/14 | 66/7 73/11 74/12
argued [1] 7724 attended [1] 70/18 authorized [2] 8/22 303
argument [7] 32/9 42/3 Attention [8] 8/1320/16 authorizes [1] 16/12
5028614860878 |292531338174222 (AVA [2] 21/6 29/10
83/18 47116 52/1 available [5] 63/4 63/7
arise [1] 49/13 attorney [72] 1/17 4/4 4/8 | 78/4 80/17 93/1
arm [2] 2018 21/1 6/178/1922 10/12 17/12 [avalanche [1] 6318
!
A 73/4 73/19 74/18 7421 believe [18] 5/15 12/10
avoid[1] 555 |75167524 78/779025 | 13/14 14/8 14/14 34/4
avoided [1] 35/15 81/15 82/12 85/3 86/14 | 34/14 34/20 38/10 39/16
avoiding [1] 55/12 86/17 88/12 88/15 88/19 | 4514 4619 49/25 52/13 .
aware [4] 1277 20/19 7412 |89/3 89/6 BO/L18921 | GO/19 76/15 84/10 90122
pe 90/19 93/7 bend [1] 61/20
away [2] 5226125 become [4] 20/1537/7 [benefit [2] 64120 66/5
4527624 benefiting [1] 65/3
B becoming [1] 81/25 best [2] 8/15 94/12 i
back [5] 3/951/2559/9 [been [45] 2/6 5/21 6/15 7/5 better [3] 8/1011/726/10|
61120 83/22 7067114 7/21 11/25 12/17 |between [10] 9/11 13/23
bad [1] 67/6 16/23 17/2 18/2 20/5 25/7 | 14/4 18/3 23/16 40/8 54/3
badgering [1] 14/9 271252919 31/10 34/21 | 90/11 91/8 93/12
Bailey [22] 9/21 9/23 43/20| 35/21 41/2 41/23 47/18 [beyond [6] 15/13 38/6
43214304 43125 49/22 |S16 51/S51/1051/16 | 51/18 51/19 51/19 78/19
53/8 62/1 62/5 62124 63/9 | 59/16 63/16 63/17 66/3 [big [7] 3/4 3/12 3/18 8125
63/13 64/1 66/5 75/20 78/5| 67/23 69/15 70123 7125 | 17/14 63/17 63/24
81/1581/16 81/18 81/25 |72/175/1776/1577/24 [bigger [1] 57/4
86/20 7724 81/1082/18 84/15 [bill [3] 1/18 6/14 6/20
Bailey's [3] 75/480/8 | 85/12 85/16 93124 bit [8] 22/1 36/4 41/16
81/12 before [38] 1/112/22.9/6 | 57/11 65/15 76/25 81/23
balanced [1] 46/21 123 1211516142211 |92122 |
Bank [2] 161525722 | 27/527/729/1431/17 (blah [3] 30/6 30/6 30/6 |
bares [1] 90/9 34/24 35/2 35/9 36/7 38/17|blanket [1] 11/19
barrage [1] 16/1 39/6 42/4 42/17 45/19 blast [1] 54122 |
[barred [1] 28/19 45/20 48/14 49/15422 [blasted [1] 54124
based [3] 20/16 55/16 78/2| 54124 59/7 59/7 59122 60/2 |blockbuster [1] 62/22 |
basic [2] 11/10 40/15 63/1 68/1 80/14 81/2 82/20 [blue [1] 60/11 |
basically [2] 35/1638/5 |85/25 93/15 93/18 93/19 [board [1] 94/14 |
basis [3] 13/14 71/8 79/19 [began [2] 12/117221 [body [1] 28/20
be [188] begin [1] 12/5 bolts [1] 40/17
bearing [1] 48/24 beginning [1] 25/10 bombing [1] 58/12
because [73] 2/16 3/2 3/14 [behalf [11] 2/62/11 4/24 [books [1] 30/6
6/56/9 10/14 1021 11/5 | 5/6 13/4 34/9 36/15 43/10 [both [3] 5/16 21/19 89/24
1613/8 16/18 18/10 | 47/11 64/12 89/17 bottle [1] 55/6
21/1122/327/1729/6 [behind [4] 63/2271/25 [bottom [1] 74/16 i
29/1030/930/2132/15 | 72/1 74/19 (bouncing [1] 16/23 :
33/4 35/21 37/7 37/20 38/5 [being [28] 7/87/16 9/10 (bound [1] 27/23
38/730/6 39/8 40/19 41/4 |12/1420/420/2027/12 brand [1] 54/13 i
415 41/1541/16 4323 | 35/10 41/2 41/3 41/16 49/6 brief [12] 10/1 40/3 42/23
44/6 48/9 52/1 52/19 53/13| 65/6 65/7 66/6 67123 74123| 50/19 55/21 56/1 64/15
53/19 55/556124 58/15 |TARAT6NIBTIATIO |T5414 8119913938 |
50216124 65/15 66/7 |77/13 772178198315 briefly [3] 26/4 85/18 86/6|
66/17 66/1870/22 71/23 | 83/18 90/20 93/9 bright [1] 17/14
|
B 6675/4 78/5 717 9122 1013 12/6 12/8
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ringing G6] 3/16 3/16 3/17 1519 2VI2 21421114 | 4313 43/6 45719 45720
123 21/1522/3 22/8 23/21 47/17 50/23 51/8 51/11
brings [1] 72/20 23/22 24/16 26/8 26/11 51/15 51/18 55/7 55/20
broad [2] 17/13 45/5 26/1727/127/8 27/8219 | 55/21 56/17 56/19 57/1
rondoned (1) Sutz |27232005 3201 2012 | 573 706 SLL 632 7302
broke [2] 60/18 60/25 32/14 32/15 33/24 33/25 73/4 78/20 78/20 78/25
brought [7] 8/13 11/3 34/1 34/24 35/20 35/22 78/25 79/9 79/15 88/6
14/23 29/14 35/10 42/1 35/24 36/6 36/7 37/11 88/14 91/4 91/6
482 oy me 37/1537/19 |cases [6] 27/24 64/23 65/1
2.37/23 37/24 38/7 78/20 79/787/15
ey 6 [38213824393 411 [cash [1] 6320
buckets [8] 15/20 16/3 47/12 48/8 48/8 56/16 categories [2] 15/18 23/15
17/3 21/15 23/12 23/21 56/17 57/4 57/7 58/17 59/8|category [2] 30/19 87/9
renin 59/9 62/14 62/23 6715 caught [1] 20/11
buckle [1] 40/14 69/2470/21 70/24 73/19 cause [2] 49/14 49/20
buffer [1] 93/12 74/9 74/21 75/23 76/5 caused [2] 12/21 63/17
build [1] 11/13 76/11 77/1 78/10 78/18 CCR [2] 1/2194/21
building [6] 3/4 35/22 81/3 82/2 84/3 84/7 85/19 center [1] 43/7
35/23 37/16 38/21 38/22 85/21 88/22 91/16 certain [4] 8/18 11/12 28/9
buildings [1] 17/15 can't [8] 3/1321/1158/4 | 39/18
bur [1] 92/20 65/16 69/7 69/11 73/18 certainly [10] 12/21 21/23
burden [3] 21/13 51/14 85/11 25/13 28/6 49/5 61/10
ds candidate [5] 20/23 45725| 66/15 67/13 68/10 75025
business [1] 735 58/4 58/5 58/7 62124 64/3 [Certificate [1] 94/1
buzz [1] 64/9 87/5 (CERTIFIED [1] 1/23
pum 68 ] candidates [1] 88/4 certify [2] 94/9 94/13
c lcandor [1] 70/16 cetera [1] 9/4
CIM TT cannons [1] 30/10 chain [2] 19/6 19/16
cabin [1] 90/17 cannot [3] 19/326/21 |chair [1] 18/18
cable [1] 47/13 90/16 chairman [1] 20/24
call [8] 2/11 12123 12/23 capital [1] 46/25 challenge [4] 9/17 37/25
13/3 21/14 29/24 32/11 care [1] 69/11 88/10 89/22
91/8 career [1] 58/1 chance [3] 42/10 49/11
called [4] 16/14 27/17 35/3 [careful [1] 41/16 54/21
a carefully [1] 59720 change [5] 12/142512
came [5] 36/3 65/19 72/8 |carpet [1] 58/12 36/25 50/15 93/10
84/19 89125 Carr [1] 7512 changed [1] 66/24
cameras [8] 3/43/123/18 |Carr’s [2] 74/791/12 |channel [1] 48/20
19/25 34/1034/1635/15 |earry [1] 43/8 chapter [2] 32/733/5
38/25 carved [1] 91/12 characterization [1] 47/7
campaign [5] 51/16 51/17 [case [0] 1/62/8 2/8524 [charge [2] 12/14 56/20
|
Cc [clearer [1] 52/21 7714
(charged [2]3720301 |clearly [3] 310.3477 81/17 comment [1] 85/15
charges [4] 6/17 6/18 1977 [clears [1] 37/11 comments [1] 71/17
Fo; client [31] 5/197/89/21 commonalities [1] 39/18
charging [1] 31/11 9/25 11/21 17/1 17/7 20/18 commonality [1] 13/22
Chariie 8] 5/21 9/23 43/24] 2422. 24123 2512 25/11 [communicated [1] 36122
432549721 61/25 641 | 37/15 571155915 60/12. |communication [1] 18/6
754 61/6 61/19 62/6 63/2 66/6 (compel [2] 30/4 33/24 '
check [5] 20/18 4525 |S720 672270187201 (compelled [2] 23/1 3117 |
i] waits vars 72/4 72/4 86/21 87/9 90/5 (complaining [1] 38/16
checking [2] 41/18 6320 |92/20 complete [7] 8/14 10/10
checks 3] Wid 6y1g [clients [7] 1714193 |3mz4conononsronz | |
cholcos [2] S8/s8720 |73ISSTTRISSUG | 94mt |
choose [1] 90/10 87/19 (completed [1] 52/23 I
choosiag [1] 47714 clients [23] 5/7 13/5 17/25 [compulsory [1] 22/11
chronological (1] 9/16 | 18/10 19/1119/1920/5 ~~ |concern [14] 8/6 24/10
circle [1] 80/3 2020 22/25 24120 26/23 | 25/9 36/3 38/20 39/2 46124
circumstances [5] 20/11 | 34/9 36/1 36/5 36/5 36/15 | 48723 53/20 66/1 71/23
N24 2712 2723 2725 |38/14 66S BIL BINS | 84/6 84/11 8/14
circumvent [1] 2514 |9/13 92/13 9221 concerned [4] 24/12 24/13
circus 4] 7/6356 3553 |Climb [1] 65116 69/14 89/4 :
on clones [1] 39/21 concerning [1] 15/23 !
cite [7] 21725203022 [Closing [1] 817 concerns [13] 323512 -| |
SU15524 1908 70113 [clothes [1] 38/24 615 6/6 11/3 14/22 20/1
cited [2] 42238804 [00 2] 451145713 23/736/9 36/17 41/17
cites [2] 55/21 56/3 (cocktail [2] 46/19 47/12 | 42/14 93/16 |
citing [1] 33110 lcode [3] 29/25 32/7333 [conclude [4]6/2224/7 |
city [1] 315 lcodefendant [1] 46/7 | 56/12 73/10 !
civic [1] 5578 collaborate [1] 40/7 concluded [1] 51/20 :
claim [1] 16/20 collaboration [1] 40/11 [conclusion [2] 54/4 56/14
claims [1] 84724 colleagues [1] 15/12 condemnation [1] 71/18
CLAPP [11] 118410 [collide [1] 813 conditionally [1] 78/9
‘41 4123 5/10 23/11 53/12 [collided [1] 88720 conduct [2] 10/8 74/7
547105909 76/10 93/5 [come [21] 7/25 16/21 17/1 [conducted [1] 56/16 1
Clapp's [1] 8773 21/1325212502327/4 conducting [3] 13/10 30/2
clarification [1] 13720 |28/20 3424 35/9 3712 4077| 6718
Clarity [3] 177243511 |41/23 44/12 48/12.48/14 conference [3] 39/6 3919
os 5819 63/18 66/1 84/5 91/17| 39/12
clarity [2] 409 79/18 [Somes [7] 25/16 48/16 confidence [4] 46/12 56115
Clayton (2) 1209314 |48/17 67/8 6B/179/6 84/8 | 56/17 56/22
clear [12] 26/19 27/21 [comfortable [3] 12/25 26/t{confidential [1] 58725
37194118 4216537
7621 78/11 832 8213 |[coming
2623 [8] 27/1 37/1 37/4 confirmation
|confirmed [1] [1]72/10
72/15
9211592024 38/1538/18402041/1 [confirming [1] 41/5
I
Cc continues [1] 88/10 court [57] 1/1123 1724
con [54]
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42/16 Contrary [2] S¥4 S818 | 163 16/1520/12 24/18
4114224 4313 43/8 |contribution [1] 75/6 | 26/13 26/15 2720 28/19
$4115 44718 45/4 45/6 4577 |cOntrols [1] 55/17 29124 33/16 419 44123
45/1846/5 46/10 47/0 [controversial [1] 5872 | 44724 45/3 45/5 4777 47/10
47/15 52/4 5320 5322 |conversation [7] 23721 | 47/16 47/19 49/24 50124
S323 83554 ssng |23UTIRIIS | SUSSULA SULT SINT
S514 35/18 56/10 2613 | 20/9 93/8 51/20 51123 54/9 55/19
$721 572 61/5 61/5 |conversations [1] 52/10 | 55/21 56/8 56/21 56/22
61/19 61/19 41/22 61/22 [converted [1] 1872 59022, 60/20 60/24 64/1
65/15 66/9 73/7 7318 [conveyer [1] 3319 66/8 68/21 69/8 7472 76/17
TAR173023 74/6 74/11 |convince [1] 53125 80/22 80125 81/2 82/18
75123 78/22 82/2 82/24 |°00Perate [2] 10/14 10/16| 84/1 84/8 85/15 86/1 94/8
83/10 83/12 85/17 87/11 |coples [1] SU 94/14 94/23 9425
Havin copy [10] 50/24 50/25 51/3|Court's [5] 15/19 49/8
conflicts [3] 53177320 | 59/23 59/25 67/15 69125 | 51125 60122 83/7
Torts 80122 86/1 86/2 courthouse [3] 3672 38725
conformity [1] 9413 |cOrTect O] 722172 | 3971
conjecture Lj 432 17/23 48/4 49/17 56/7 68/4 [courtroom [1] 34/11
conte [1] 15/8 89/14 92/3 cover [3] 8/6 44/6 54/6
connection [17] 6/11 11/15] cOrTespondence [1] 30/5 [coverage [1] 35/19
0/21 13/10 15/1 18/19 [could [33] 39 8/13 17/15 covered [3] 16/22 21/24
20/5 22/6 36/16 53/1 65/20|19/4 190 19/13 19715 | 92/5
65022, 65123 73/1575 |19/16 19/17 19/18 19/19 [covering [1] 2/13
37121 88/8 23/1 26/18 28724 32/10 crazy [1] 45/11
consequence [1] 52/6 |33/6.40/21 412 46/6 5219 |create [8] 10/6 35/6 35/8
consequences [1] 25/5 |62/9 6319 66/11 7822 | 55/6 57120 57/21 88/9
consider [1] S825 79123 8322 86/18 91/12 |9125
considered [1] 6812 |SVL7OU2293/1093/1T |ereating [1] 65/14
considers [1] 84/3 93/17 creative [1] 9121
conspiracy [1] 7417 [couldn't [2] SY1173/8 [criminal [3] 13/1 13116
Constitution [1] $51 [counsel [12] 414239 [asitz
constitutional [2] 1920 | 23/16 3US £215 6819 eritcal [1] 56/18
pire 68/20 68/20 75/7 82/14 critique [1] 46/11
constructing [1] 3011 |913 94/14 CROSS [13] 1/17 4/3 4/11
consult [2] 85/18 8519 (country [2] 66/21 74/18 | 3177 54112 54/15 5421
contain [1] 616 COUNTY [11] 1/1124 | 7624 79/11 81/3 81/7
contend [1] 106 9/14 10/10 12/9 31/4 66/4 | 88/11 92/6
contestea 1] 20119 GB/12 73/13 94/5 9425 |Cross's [3] 53/14 53/17
context
Too [3] 11/12 13/17 couple [County's [1] 7/7 T2116
[4] 2/57/22.47/8 crowded [1] 3/13,
contingent [3] 89/21 89/24| course
prow 63/21 [5] 22/3 47/18 62/6 |cures
cure [1][1] 90/23
48/23
continue [2] 822319 | 83118421 custom [1] 63/10
|
Cc [December [2] 66/13 75/18[22/11 22/14 25/3 27/15
leat [1] 1020 [decide [3] 15/13 16/2907 | 27/20 31/25 38/14 38118
CVR 1] 121 decides [1] 48/11 38/19 59/12 61/13 66/14
yee [1] 54/4 decision [8] 13/14 46/11 | 66/25 68/12 70/3 70/5
ST [48/1851/356123 57/17 |79/18 79/25 80/23 9012
D 63/1 65/11 94/9
DA [14] 42/6 42/9 45/13 decisions [2] 20/16 46/11 didn [5] 22/21 30/15 33/17
55/21 56/3 58/18 64/10 (deemed [1] 56/14 34122 493
64/14 64/19 66/7 71/16 |default [1] 40/23 didn't [12] 2/17 54/6 61/11]
75/14 84/1 84/4 defendant [3] 45/11 45/13 | 61/12 64/12 76/16 79/2 |
[DA's [13] 2/73/24 3/25 7/7] 1/10 79/13 86/12 86/15 88/12
117 18/3 55/6 64/23 66/4 defendant's [2] S6/19 [88/21
66/14 67/9 68/18 71/16 |56/20 died [1] 56125
daily [1] 67/17 defended [1] 46/7 difference [1] 90/11
(damage [1] 20/4 defense [3] 45/9 45/12 [different [18] 2/22 11/1
data [1] 63/7 505 16/3 17/5 18/19 27/9 28/6
date [4] 40/2155/593/1 |define [1] 83/24 28/8 28/17 28/17 28118
93/16 i definiteness [1] 15/6 30/19 30/23 32/8 33/12
dates [1] 38/14 |democracy [2] 66/20 74/17) 33/22 53/15 56/9
Davenport [2] 78/24 79/12 democrat [4] 88/6 88/6 differentiation [2] 18/3
DAVID [4] 1/21 94/8 83/11 88/15 33/12 |
9412194123 democratic [2] 74/10 differently [4] 18/16 18/23| |
day 19] 23/20 37/2 38/19|7522 30/21 86/14 |
43/8 50/8 50/12 63/7 63/8 (democrats [1] 89/21 difficulty [1] 18/21 |
63/12 66/14 67/16 78/5 |denied [1] 85/17 DILLON [38] 1184115 | |
80/880/980/1280/15 |depression [1] 63/2 5/1020/1 20/18 23/11
80/16 94/10 94/16 description [1] 49/15 | 29/17 31/23 32/1 36/19 |
|days [10] 10/1 10/18 38/19 |design [1] 65/7 42/7 42/20 43/14 4318 |
58023 60/17 60/24 62/7 designate [2] 3/10 89/9 | 47/11 49/11 49/19 5025
64115 72/4 8018 designation [1] 12/13 | 51/4 52/21 53/12 59/8
deadline [2] 52/1252/18 [desk [1] 67/8 5/10 69/8 76/20 76/25
dealing [1] 19/13 detail [1] 24/2 78/14 78/19 79122 82/13
deals [1] 82/21 determination [1] 13/24 | 82/20 84/10 85/25 86/5
dealt [1] 19/1 determine [5] 6/852/12 | 87/2 90/3 90/5 92/9 |
Deboroughs' [1] 92/20 | 57/5 66/8 91/21 Dillon's [4] 78/287/989/8| |
DEBORROUGH [14] [determined [3] 1124 | 92/20 |
119 13/4 14723 16/25 |51238304 direct [9] 7/20 42/22 47/16
2172323/102420 36/10 [develop [3] 39/1339/23 | 56/7 6319 65/22 67121
36/1539/19 43115 50/8 | 41/7 84122 87/11
86/25 92/12 developed [1] 42/16 direction [1] 88/3
Deborroughs [3] 4/25 5/1 [development [1] 61/18 (directly [4] 16/4 31/1
37/10 device [1] 3/6 52/16 7218
Debrrovogh [1] 21/19 [dictated [1] 50/5 disadvantage [1] 23/25
deceiving [1] 88/22 did [24] 3/115/13 17/10 (disagree [5] 5/257/2 22/15
D_ |6nSI28I69/109/19 9120| 28/10 29/8 29/9 32124 44l6
Gisagree. [2] 22/17 53724|10/22 1023 11/4 11/7 | 44/23 45/2 45/4 46/4 48/10
disagreement 1] 3718 | L/10195820182119 | 4323
disagreements [1] 23/16 | 2211 23/5 2571 26/11 don't [51] 322 6/10 6125
discharge [1] 5625 26/12 26/13 29/7 29/8 30/8 | 919 11/19 11/19 12/19
disclose [3] 253352 |322232124347 34118 | 18/20 191 20/4 27/19
5710 35/3 35/24 36/7 38/12 42/9 | 28/15 35/25 38/8 39/16
disclosed [4] 52124122 |43/14 43/17 44/2.46/20 | 40/1 41721 48119 52/13
52257224 46121 46121 54/17 54/18 | 53/4 53/13 53/23 53/25
discreetly [2] 38/21 3822 |SSBSS/14 S/S 6021 | 55/5 55123 59/17 623
discretion [6] 28/14 44/18 | 62/4 65/17 65/20 66/7 | 62/17 67/13 69/6 TUL
‘44124 44125 45/5 710 | SIS 66/16 673 6810 | 71/21 T3/1176/9 76/19
discretionary [1] 4416 |SYBIL | TIS TINS TI0 TIR3
discuss [1] 1415 TANT TH 322 T3124 |TBI3 7816 78/7 79/1 T9117
d
discusse [2) 11/18 3021 | 75/18 76/17 T6119 77/3 | 8073 86/16 88/14 89/3
discusses [1] 79/12 TIO TINO TONSIL | 90/22 93/9 93/21
discussing [1] 80/3 8612186228623 90/11 [DONALD [2] 1/16 49
discussion [6] 14/4 23/18 | SV1291/1491/1492/1 |donated [1] 78/5
25/1025/13 60/6 79/14 | 9321941 donations [4] 43/18 43/22
discussions [3] 11/10 23/3 |document [9] STISS8/13 | 43/23 43124
24119 59/7 63/5 67/4 69/170/21 [done [19] 13/4 20/4 20/5
disease [1] 90/16 78/178/6 271735020 36/7 52/18 53/5
disgorges [1] 93/4 documents [2] 30/5 57/6 | 53/5 65/6 65/7 69/21 73/5
disinterested [1] S16 [40s [13] 9/6 44/17 46/23 |73/11 75/15 75/15 81/1
dismissed [1] 25/8 52/1 5720 61/4 65/10 |89/10 93/11
display [2] 27/10 3/4 |S13 67/10 6920 71/4 |door [2] 58/14 67/4
disputing [1] 33/25 83/483/11 doubt [3] 32/3 78/3 83/20
disquali fication [24] 4/11 [doesn [13] 9/4912 13/5 _|down [17] 1512021/16
GILL 711704 8775/8 29/18 | 26/13 29/7 30/9 30123 43/7 | 24/15 26/25 27/6 27/10
292 42/5 4213 423s | A523 ASIII 4T/14 4819 | 37/14 57/7 58110 59/9
43/15 44/16 5222 5712 | 4821 66/11 74/13 74114 76/9
73/9 81/8 87/8 90/12 90/15 |A0esn't [13] 622 12/14 | 78/19 85/20 94/10
0/15 90123 91/22 92119 | 17/7 41/5 42/13 51/9 54/3 |downgrade [1] 25/6
disqualified [4] 9/10 10/11| 67° T4/10 74/11 7523 downgraded [1] 25/7
51/10 91/6 7612 91/13 downside [1] 52/5
disqualify [9] 2/7209 2/9 [408 13] 7612 76/3 91/13 |arafted [1] 59720
2/15 4/4 7217 73/25 84/22 |40ing [8] 20/1025/1626/1 |drag [2] 26/20 57/7
$1 27/1028/2585/285/3 |dragged [4] 21/16 26/25
distinct ion [1] 87124 87119 27162710
district [95] dollars [2] 57/9 63/13 [draw [4] 29/3 32/13 38/17
diverse [1] 1422 don [26] 4188023 12/1 |s521
divided [1] 38/19 17/11 19/11 19/1720221 [drawn [1] 56/13
divorce [1] 45120 2215223231233 |drips [1] 663
do [82] 3/75/5556 |2324261192724283 (driven [1] 46/10
|
D 14/18 15/14 18/24 22/7 [ethers [1] 70/12 .
river [1] 426 [electoral [2] 2/1544 ethical [3] 27/13 83/22
drone [2] 3163/17 electors [13] 2/124125 | 83/24
dropped [1] 12/18 112317/1022/539/18 [ethics [5] 10/7 63/20 68/16 *
drug [1] 78 61/1886 88/6 88/9 89/21 | 68/18 69/1
due [1] 84724 8924 9124 leven [25] 572 8/20 17/7
during [10] 22/8318 [elevate [3] 4535855816 | 17202201822222719 | |
"47118 49/8 6317 63/8 63/12 [elevation [1] 25/6 28122 28124 29/5 31/21 |
69121 75/8 7815 Eleven [1] 19/24 34/136/13719 39/1 5111| |
duty [2] 4721 5558 else [9] 4/18 5/636/13 | 51/20 5323 56125 56125 | |
36/15 54/6 85/9 8510 92/6| 57/1 64/10 73/22.75/14 1
E 92/13 81/19 |
email [3] 59/3 77/8 77/12 |emphasized [1] 49/12 [evening [1] 23/20 |
e-mails [3] 19/1620/9 [encourages [1] 44/12 [event [3] 50/4 50/12 53/7
59115 end [5] 6/8 9/5 28/11 53/4 [events [3] 47/8 49/155872 | |
each [8] 13/24 1472 14/13 | 93/10 ever [1] 34125 |
15/12 15/16 16/6 40/8 [ended [1] 90/4 every [4] 3/15 14/21 31/13
40710 lends [2] 41/3 78/18 75/19
earlier [3] 34/2036/22 [enemies [1] 85/6 everybody [5] 33/25 47/12
68125 enhanced [1] 25/9 85/9 85/10 91/6
earliest [1] 16/16 lenough [5] 24/16 42/24 [everyone [8] 3/14 3/17 8/9
early [2] 10/15 40/11 45/5 54/1 5723 35/18 50/16 58/13 60/25
easier [1] 82/6 ensure [1] 35/22 92/24
echo [1] 20/1 enter [2] 352259722 [everyone's [1] 93/22
effect [3] 8/17 49/14 49/20 [entered [1] 76/16 everything [6] 3/15 40/24
effectively [1] 50/9 entire [4] 73/1389/12 | 41/15 66/24 88/18 92/5
effort [5] 7/15 22/18 50/15| 90/16 90/24 everywhere [1] 12/22
| 66120 72125 entirely [3] 28/828/17 [evidence [26] 26/12 29/4
efforts [1] 88/9 28/17 30/4 33/23 46115 47117
egress [1] 36/6 entirety [2] 47/789/12 |54/16 54/17 54/18 5420
either [9] 5/1019/526/14 [entities [1] 82/23 66/19 67/2 67/12 69/4 1212
27/1 60/18 73120 75/24 [entity [3] 43/1 84/13 92/1 |72/3 76/6 76/11 76/16 77/5
761276124 environment [1] 35/8 |77/10 77/17 77/22 84/14
elaborate [1] 40/6 envision [2] 15/11 15/12 | 87/15 91/18
elderly [1] 18/21 equal [1] 84124 EX [3] 1/61/82/3
elected [4] 50/21 52/3 91/5 Equally [1] 48/12 exacerbated [3] 7/520/7 i
93/16 equipment [3] 2253/11 |87/14 :
election [20] 7208/18 [3/15 exact [1] 38/15
15/15 18/20 20/19 49/2 [especially [1] 52/13 exactly [9] 13/22 25/16
52/24 52125 65/3 65/4 73/1|essence [1] 67/6 33/8 37/5 50121 61/3 75/6
73/16 74/20 75/1 81/16 [essentially [2] 19/24 85/1| 84/1 85/9
82/3 93/5 93/6 93/12 93/15 | establishing [1] 77/25 exaggerated [1] 36/4 .
elections [1] 50/20 et [1] 9/4 example [1] 45/17 i
elector [6] 13/13 13/15 [ether [1] 65/25 examples [1] 45/7 :
|
E facing [1] 13/1 [ite 13] 2/1784123 93/17
Exce llent [fact [22] 5/15 6/2 6/3 10/1 |filed [8] 2/6 2/6 2/10 2/14
[1]4724
exception a 9/19 10720 19/11 33/3 35/2 35/2|2/15 5/12 10/1 64/15
exceptions [1] 8/19 4419 46/15 59/17 61/11 (final [3] 50/18 52/8 93/4
excorpt [1] 84/10 61/12 62/24 64/10 64/13 |finance [1] 63/6
excluded [1] 30/12 7/6 72/10 76/21 83/4 85/7 (financial [3] 51/19 64/25
excludes [1] 30/6 factor [2] 28/11 56/24 8077
exercise [3] 28/12 28/14 [T2615 [9] 26/1928/728/9 find [10] 27/24 28/18 29/5
38/1 wedono 461349118" |74/7 74/10 75123 7612 90/8
exhibit [18] 60/1 60/1: 58/11 91/13 92/5
6219 pip 5 fair [5] 12/1723/2529/15 [finding [2] 74/9 91/10
76016 71/8 71227919 | 46/20 89/6 fine [S] 2/18 4/16 5/3 62/23)
80/6. 8020 81/11 83/13 [faith [1] 13/14 66/23
84/3 84/9 85122, fall [1] 7/17 [finish [1] 61/16
exhibits [4] 54/18 59/17 [falls [1] 58/15 [finished [1] 9/15
76/6 78/16 false [1] 57/5 first [14]6/5 10/2 17/23
[Exhibit [1] 775 falsity [1] 57/6 31/23 35/1 3718 37/15 4017
lexist [1] 22/11 familiar [3] 49/14 50/24 | 42/22 43/17 47/9 63/21
existence [2] 64/7 68/14 | S15 64/16 84720
exists [1] 56/13 fan [1] 8/25 fit [1) 42/13
expanded [1] 36/10 Fani [3] 441162227613 |flagging [1] 84/11
expect [1] 5119 far [7) 24/32612531/14 |flashy [1] 46/25
expected [2] 4/1 5273 40/13 45/23 65/22 82/22 (flexible [1] 41/23
expecting [1] 11/1 fashion [2] 44/18 56/16 [flip [1] 15/10
expert [2] 31/8 69/1 fashioned [1] 872 flow [1] 6320
explain [4] 46/22 46/23 [favorably [1] 21/7 flowed [1] 48/21
47188717 favoring [2] 9/20 86/20 [flows [2] 61/18 93/2
explained [1] 50/15 federal [10] 12/20 16/12 [flyer [3] 62/10 77/19 83/3
explains [1] 25/4 192020321/1121/12 [focus [12] 7/15 11/23 52/1
explanation [1] 86/13 |28/1629/629/88425 | 53/14 57/12 5724 71123
explorable [2] 39/22 39/22 feed [1] 3/12 72/14 81723 87/1 89/15
exploration [1] 73/15 (few [6] 8/19 17/23 17/24 | 91/8
explore [2] 23/15 4113 | 24203787113 [focused [3] 44/9 48/25
lexplored [1] 38/8 fictional [1] 75/3 67/20
exposes [1] 1315 fifth [32] 4/6 4/10 5/12 6/5 focuses [1] 91/7
extent [1] 89720 6196/21 9/2 9/3 11/2 11/11 [folks [6] 11/8 12/3 28/14
extra [3] 71/17 84/12 84/16 13/2 1477 14/12 1522 | 38/7 38723 88720
extreme [2] 1719 45/17 | 16/13 17/8 17/10 19/5 23/6 [follow [3] 46/14 52/20 91/1
eve [2] 38/13 49723 25/1125/1527/22.28/13 [following [1] 87/23
eyes [2] 58/6 58/7 20/1932/1333/1736/9 [font [2] 62/24 81/19
| 36/1736/19 38/2 38/8 footnote [1] 12/17
F__________ ane force [2] 209 dsis
face [3] 28/21 45/21 58/14 (fight [1] 48/1 forced [4] 16/19 19/25
[Faced [1] 9/16 figure [1] 26/21 27/12 86/13
F 10/9 66/4 68/12 73/13 94/5| 38/22 40/9 40/13 40/17
RTa— Anan suas
ran agov[l] |5972 61/5701
forecast [1] 39/11 [eneestygeger 79/18 8516 85/6 87/2 88/16
foreclosed [1] 1412 |;4 1) 125 get's [4] 57/9 57/9 64/6
foregoing [1] 94/10 fundraiser [25] 10/5 44/12| 83/16
forget [1] 74120 46/3 46/16 47/1 62/22 6318 |gets [13] 3/13 10/17 10/18
Forgive [1] 74/25 63/10 63/15 6324'65/7 | 41/21 42/12 52125 54/21
form [1] 44/1 65/9 6S/I8TS/TTS/10 | 63/24 64/4 64/5 71/8 82/12
formal [2) ISS | 767137520 75124 75025 | 86/1 3
formally [1] 31/11 77/19 78/1 78/6 80/8 S1/18 [getting [7] 3/4 1019208| |
formsFr oy |s 201920710 31/3 40/17 |
fortunately rs[1] 75/16 [give [10] 10/16 15/6 17/20
forward 8) 38 213 236 Le Bl TOS ae
TIASGIINATIR | ther [9) 223 5213/6 | 63/11 74112 76720
ssa 17/11 85/15 86/19 91/25 [given [3] 2972 75/3 87/18
fought [1] 38/12 92/10 94/13 gives [S] 20/12 25/18 25/19]
found [1 16465118 |pure 11) 1377 64/19 68/18
seo
[foundation [4] 59/15 60/1 GC
|G [eiving
ons Ml S219 675751
Jens 79022 GA [1] 1/12 ghd [7] 1013557662 | |
[founded [1] 68/9 gather [3] 66/19 67/2 67/3 ‘66/15 74/13 74/14 74/15 |
four [2] 3/12 41/1 gave [4] 38/14 38/16 43/20 [glued [1] 38/25 |
framework [1] 39/24 69/12 go [23] 2212221222 |}
framewor ks [1)
fraught [1] 28/1 40/15 \general [18] 3/2 8/24 15/15 13/6 17/11 1719 26/6
15/20 43/21 4412 68/19 | 29123 38/1 39/24 41/15
free [61 3/1 60/21 68/2 689 68/19 73/16 74/7 7512 76/1 | 45/23 55/5 57/1 58/17 66/9
70/1 83/35[1] 31/24
freshest 82/14 82/23 89/9 90/6 90/7| bhp
907 68/9 73/22 75/9 81/2 85/24
Friday [1] 84/23 General's [1] 66/10 goes [3] 46/15 56/8 93/22
friend [1] 1224 [generated [1] 7/6 going [71] 2/5 3/8 7/16
friends [4] S81S6420 generating [1] 6/15 7/19 8120 10120 11/23
73/5 85/6 gentleman [1] 6722 13/13 1323 14/12 14/16
frog [1] 34/15 genuinely [2] 19/3 26121 | 1/13 19/8 20/6 20/14
[frogmarc hed [2] 1924 |georgia [26] 1/2 10/8 12/13 24/14 25/11 2612 26/12
3410 18/18 21/1 21/6 27/14 26/12 27/3 27124 28/22
frogmarching [1] 35/9 | 20/11 20253020327 |20/17 34/13 34114 36/12
front [16] 1636/47 | 387242028 47/15 5112 63/6 | 37/6 37/17 38/5 3973 39/4
1OPSUNG LUB2AILS E || aria
Gia 68120 71/5 78/25 7919||sme
39/5 30/9
2523 MLA 044 0459418 ae39/12
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362 38/1 40/3 43/7574 | 0414 ie a :
ond
frustrated [1] 61/6
[get [34] 272.2121 21242125| 54120 57/11 60/6 661
812410125 16/17 18/12 | 66/22 67/6 69/10 T1/11
full [1] 35/19 18/2320/1423/22 24112 | 731 73121 73124 7515
FULTON [9] 11724717| 33/33 3412 3124 38/6
|
idelines [1] 39/13 69/1570123 1124 T1125
CT File 1] Si 7312.73/5 73/13 76/3 76/15
going. [1S] SUS TET | [3] 795708816 | 80/25 81/2.8110 8412
TGATST
sunse 804 SUS
tsBUS| vs 12] 21/19
BRE OB 7906 84/15 84/17ot93a
84/21 87/11
sunsyassdost JH | SCRE
gonna [1] 14/15 ha [2] 31243124 85/16
good [13] 2/2472 4/7 4/15 |paq [24] 11/10 14123 17/9 hate [2] 20/8 20/9
4613143022 4112 | 23/8 2472 34123 3910 4172 mv 50]
48/10 48/22 74/10 75/22 | 41135 50/4 50/16 51/16 haven't [2] 49/9 60/1
82/5 581459110 5920 61/1 having [8] 3/12 23/23
good-faith [1] 13/14 4/11 64/17 68/11 7513 | 2421 25/24 41/23 46/1
google [1] 82/7 75/7 75/11 75/18 75120 | 4824 90/9
GOP [1] 2024 HADASSAH [4] 1/21 94/8 he [36] 10/14 10/15 10/17
osh [1] 61/7 94/21 94123 1071820724 31/18 31/23
0t [32] 2/20 3/6 413 4124| dassah.david [1] 125 | 31725 33/15 33/22 37/16
$/321/23
4274S36/21 482140/8SUL41/4 |pqiing
had [1] 22113 45/25 49/12 55/3 55/6 55/7
1) 1377 55/7 58/19 58120 58/20
S024 5135121536 [gan [1] 81/15 oy San
S93 GUILT GZS 6221 and [5] 7/18 514 TAIL | Gop 69/20 70/13 7417
S623 GB TOMO
0/14 21S TONS | |andheld
T64 8025 86113 oats[1] 3/6 79123 ego
79125 81/16 82/12
81/14 82/10 82/17 banding [1] 863 |nes [3] 5/20 7/8 57/8831
gotten [1] 49/16 [handle [1] 73/19 83/1
government
(Governor [7][1]8215224/1 Inandling
|uangs [1] [2]59/18
2/7321 |yead [3] [1]
headline 11/363/23
22/15 317
J3/L T4121 7511 75/4 82/1. | happen [8] 37/7SUBST
37/9 37/22| pendliner
(Governor's [8] 717504 488 48/8522 arg vans[4] 9/23 10/5
644 64/4 S113 happened [4] 13/1248) headlining [1] 62/22
jgrand [104] 60/10 6/13 health [1] 93/9
gravity [1] 56/10 happens [2] 49/214922 |hear [13] 4/1 11/17 16/124
great [3] 4/2123/21 85123 happy [4] 3/18 29/19 53/12) 23/21 28/9 28/10 29/19
idiicd 85/14 38/18 53/12 56/20 6612
greater [2] 39/2 90/3 harassment [1] 35/23 |g6/12 86/15
greatly [1] 39/8 hard [2] 3/19 38/12 heard [15] 18/22 22/2
jgreen [8] V1722445 arm [2] 718 64120 2222 34/15 3512 53/3
m317
GREEN-CROSS M] 117|las [60] 2/14 2/14 919
6/15 7/5|| eyrad
53/4 53/13
7147/17 812 8119 ania 60/12
$4124 67/22
S05
413 4/11 3177 9/20 9/22 10/14 12/21 1872| gpg
greenlighted [1] 5/2 20/4 27121 29/11 31/10 |earing [4] 16/9 35/5 53/1
group [7] 6/24 14117 14122) 33/11 3515 35/19.38/4 | gag
23/17 73/3 88/5 88/7 38/12.41/22.42/6 42/15 |heightened [1] 24/10
grown [1] 61/14 42/19 44123 47111 4718 heightening [1] 71/18
guess [6] 23/523/933/6 | 51/9 54/8 55/19 57/2 59/16 |nelp [3] 3/5 11/7 12/4 25/4
405 4114721 61/14 6617 66/8 67/23
\
Hm hit [1] 162 1 :
etn. (5974 lhold [7] 811829117 6023 [iy a7 3714 5372 628
helpful [1] 8/12 76123 BUS 821886121 | 681 545 86/1 89/4 93/19
helping [1] 57/22 older [1] 4612 TI [18] 51/4 51/22 52/21
helps [2] 16/10 38/4 holding [2] 46/3 67115 | 5525 0/3 3/21 70125
her [13] 5/18 22/22 2225 (MLonor 180] 42 SISSI8 | 7119 76123 76123 78119
25/11282431/736/4 |SLATRINSA0L3 125 17/16 0/19 82/15 87/17
38145718 71/12 72019 | L627 INO ISI ISIS | 93)93137 0377
88/17 90/8 1722 18125 201102022. {py 145) 3/18 3122 4/3
here [62] 21202021225 |M3 2U6UNT2U22 [40130 12124 16/13 39/3
3/6 3/13 4/3 4120 5/4 819 afod il 261192715| 3923 43/19 49/1 49/16
817 11/8.11120 20/4 20110| ISIETINAING {5133 53112 53/12 53715
20102112 201623713 | 397SULSUGSAILT32121 | 53115 5014 5916 63110 6672
231425122620 2625 |SLIGIGA8362 | 66133 67120 6720 7010
6211027193310 | $73 WIS AUS SUAS | 73101 73721 73724 75135
348342353 | S210 44 SAT SANSSSI | 75/1070733 0s 803
3853043005408 | S71 neoi | 3/6 83/17 84/4 85/14 3613
40/23 44/14 45/16 46/11 san 31: 87/23 88/6 88/15 88/16
asm aiodyisdon |TULTASTAIBTARS | gor1q 002 92117 93/19
52/13 54/18 56/21 57/4 Tm’ (1) 79/8
577757112 6213 63/6 66122|SYS U2 SUGBLS Ip 111) 35721 4gr21 S024]
m2 76731 131748 |SESSIONS su73 50m Gara 65/14 !
sen sytssnz |S STD 75/16 80/25 82/17 92/24
85/17 91/7 dea [2] 48/18 91721
hereby [2] 94/994715 [Homor's [1] 14/5 lideally [1] 6/16
herein [1] 94/12 HONORABLE [1] 1/11 gengically [1] 17/25
herself
prt= [5] 8/2 25/25 61/12 [hope [1] 89/4
hopefully [4] 2/1828/14 |identification
g4/p0 [2] 14/6
hey [3] 60/12 68/1 85/1 san i” identified [4] 13/21 56/11
higher [2] 51115114 [BOFif 1 oS 77124 8117
highlighted [2] 51/4 51/5 pa 5 ii ion identify [1] 38/20
highly [1] 58/25 xkK KK identifying [1] 82/21
him [14] 9724 1223 1213 ignore [2] 4/18 46/15
2512443/19 57/5 63015 [hours [31 32383011 Lippy nies 12) 22/19 2224
66/11 68/12 69/1 74/tz (low 125] 4SBTSN0 ipynynize 3] 2112223 | |
74/13 79/25$70
mest(1) 89/13 UNL1383422362
3612539/12.40/10 40/14 immunized
[Jit] [3] 1232110| |
hindrance [1] 34/19 42/14 46/21 46123 48/19 iynae (3) 7716 7120 53/16
his [26] 6/11 6/23 17/2 17) pid ae So eel impanecled [2] 30/14 66/19
17/4 21/3 21/4 22/15 25/11 impasse [4] 3724 39725
31/1831/1932/1233/17 | 93219322 40/18 40719
42/8 49/12 50/11 55/2 55/8 [however [S] L3/122712 {oie 14) 4074 .
58/17 69/20 76/20 80/10 |37/12 37/12 56/10 important [1] 74/18 |
82/1 83/4 86/22 90/5 hunt [3] 76/3 76/3 91/14 {iyortantly [1] 17/17
|
1 inquiry [4] 14614011 [303
28/19 3 /4 | 19/19 82/23 investigators [2] 1017
on 1 ]ss
improper[4 as inside[1 6718 16119
impropriety [4] 10/7 42/20/insofar [10] 5/14 11221 [invite [1] 40/11
an 11 10772020 30115 4311 4322 7713 hove 44/11
inability [1] 22/2 81/21 83/784/19932 (invocation [1] 29/4
inadvertent [1] 72/7 inspect [1] 30/5 invoke [10] 16/18 19/19
include [1] 14/16 instead [4] 17/1832/16 | 20/1 20/13 21/15 21/15 :
included [2] 301030112 | 43/25 44/1 25/1126/2 27/12 32112
including [4] 15/12 26/23 [Instructed [1] S113 invoking [2] 31/19 57/13
612833 instruction [1] 15/19 [involved [10] 20/24 20125
inconvenience [1] 28/11 |strustive [1] 28725 21/3 21/4 21/5 23/23 35/18
increase [1] 86/22 {instrument [1] 31/11 35/21 62/5 75/12
incriminating [4] 19/11 [terest [6] 14/17 15/1 43/3jinvolvement [2] 13/25 141
19/14 19/23 31721 43/10 56/13 68/11 irrefutable [2] 6/1 6/3
incrimination [1] 31/20 [interested [2] 52/10 66/12 [Irrefutably [1] 72/13
independent [1] 74/8 interesting [2] 32/21 65/1 irrelevant [1] 37/21
indicated [5] 1015 1015 |terference [1] 73/16 lis [382]
58/18 58/19 67/1 interim [1] 93/20 ism [2] 9/10 13/5
indicates [1] 91/4 intermediate [1] 73/17 [isn't [4] 39/14 59/6 65/9
indicating [1] 83/11 internet [6] 60/19 62/7 | 81/23
indication [3] 22/18 34724|792 TVA TOR3 T6113 |Tsokoff [2] 61/4 79024
62/4 interpret [1] 45/24 issuance [2] 50/14 92/23
indict [5] 32/1032/12 [Interrupt [1] 18/4 issue [16] 7/57/18 9/19
3214 57/5 7313 interview [1] 55/9 9120 12/12 15/23 33/25
indicted [2] 25/8 33/20 [{nterviews [1] 24121 34/2 51/9 55/18 57/4 57/6
indictment [2] 6/14 7/19 |ntimated [1] 5221 T4112 T4116 74/18 75/21
individual [11] 12/14 [Introductory [1] 49/12 issued [5] 9/24 32/5 33/1
13241325 14/1 14/14 [[nvestigate [1] 89/5 33/4508
18/21 18/23 33/17 50/22 [Investigated [1] 91/25 [issues [2] 5/13 19/17
8388319 investigating (11] 9/13 issuing [1] 92/18
ed
individualiz [1] 23/8 |22/6 28/20 46/4 7518 85/2 it [349]
lindividuals [3] 13/21 82/25| S8/8 88/25 89/19 90/10 i's [62] 2/19 3/8 814 8/20
91723 ou2l 35/14 40/1 44/16 45/21
inference [2] 20/33/13 |[nvestigation [34] 10/3 | 49/25 51/2 51/3 51/11
influences [1] 56/15 1009 10/14 112213/10 | 51/13 51/18 51/19 52/3
information [3] 66/17 oro] 15/1 15/2 30/3 31/22 42/17| 52/3 52113 54/16 54/17
772 43/4 44/13 46/13 4712 47/4| 56/1 56/10 59/25 60/8
ingress [1] 36/6 47/18 47725 49/8 50/6 | 60/18 60/19 61/10 61/13
inherently [2] $7/23 83/19|S816 60/13 60/16 64121 | 61/14 63/13 62114 62122
initial [1] 55/1 GG/18 66/18 67/18 73/14 | 64/18 66/7 69/7 69/9 69/13
initially [1] 67/1 75/13 89/13 90/16 90124 | 70/12 70/19 70/25 73/5
inkling [1] 48/21 91/14 91/15 9312 73/12 73020 73122 73124
innocent [1] 27/22 investigative [3] 8/16 15/4| 75/6 75/6 75/14 75/15
1 [juncture [1] 72/21 [justification [1] 86/16
7747979/4
is...[13] 7 (June [6] 924 53/8 82/4 justified [1] 86/16
7919 80/12 81/19 82/18 |82/7 82/8829 K
8/16 87249019931 |furies 8] SWAS2 TA Tian|
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[join 1] 5/18 7114 813 8/14 8/17 8/22 9/7| 62/7
[joining [2] 5/11 89/15 9/15 10/3 12/4 12/16 13/11 [know [52] 2/163/16520 | |
joint [1] 89/22 13/18 14/11 15/4 16/14 | 6/10 8/23 9/9 10121 11/19
[Jone's [1] 92/10 16/1719/19 192520/3 | 16/23 17/3 19/1202 21/10
JONES [68] 1/182/72/8 | 21/10 21/17 22/8 24/8 21/22 221725025 27/1
417523 6/9 6/22. 7/8 7119| 24/1525/23 26/9 26/10 | 27/20 28/2 28/3 28/10
9/4 9/6 9/10 10/3 10/9 27/16 28/23 28/2529/7 | 28/23 29/1 30/10 3118
1013 14/16 15/1320/6 |30/1302230/133118 | 32/24 34/22 34125 35121
21/323/11292038/18 |31/22 32/6 32/6 32/10 35/25 38/5 39/5 41/22 46/4
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47125 4917 49/23 50/9 33/1833/19332033/22 | 59/17 61/8 61/10 62/5
S0/1153/9 55/2 57/7 56/9 |33/23 34/8 34/20 34125 | 67/13 67/15 68/5 68/13
58/17 61/2 61/24 64/13 | 35/10 38/1 40/4 41/19 43/4| 69/12 71/21 80/1 80/3 89/8
64/14 65/8 66/11 66/12 | 47/3 47/21 47/24 48/1 48/5| 9321
66/16 66/21 67/25 68/11 |48/11 48/15 48/16 48/18 [knowing [1] 68/11
72/11 73/3 75/9 75/18 76/1 | 48/25 52/16 55/3 58/21 [knowledge [1] 84/15
SUIL8U/118124832 | 64/1767/1067/19 68/2 [known [2] 1012 64/13
83/16 83/18 84/17 84/21 | 68/572/1174/9 80/2 88/8 [knows [3] 61/17 62/8641 | |
8423 86/10 87/1189/12 |8812490720 91/791/20 (Kwanzaa [1] 81/15 1
90/6 90/9 90/17 90125 33 4 ss cons L
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S616 56/6 71178412 | 61/14 66/14 6624 6710 \prunica) “Sain 331
84/16 89/22 8925 94/14 | 69/11 69/14 71 1/13 [FH
July [9] 1/12 2/4 53/9 53/9|8U/S 0/12 81/1 85/9 89/13 |i. 111 53123
S5/4S81858225823 |SINTRA lunonaee [3] 83 51725
94/10 93/8 93120 Santo
IL [let[18] 2/156/7 15/21 18/4 links [1] 19/15
larger [2] 49/58120 |22/728/539023.40023 list [6] 27/5 30/10 30/11
largest [1] 81/19 41224215 44120 61/16 |30/12 30/12 75/22
last [7] 221 221 2319 |S214 T219 78197905 listed [1] 51/16
44120 78/18 82/7 86/7 90/6 92/5 literally [1] 57/8
ate [5] 55/3 55/4 76/10 |19€' [9] 2123/20 13/9 Sa21llttle [11] 3/13 2271 35/14
82/8829 59/15 74/16 74/18 74/19 | 41/16 57/11 59/13 65/15
later [9] 10/17 26/11 33/19| 91/13 65/17 76/25 81/23 92/22
4110 53/11 60/17 Gos [letter [26] 524 9/4925 [II [8] 7/22 25/2 28/4 31/1
6217 64/5 10/18 10/19 2417 49/13 | 37/14 41022 4212 43/11
law [16] 12/13 14/3 16/11|SYBS/1058/1858124 [location [1) 40/21
271193877 3020407 | 59/1 61/2 64/6 64/6 64/14 [logistics [1] 624
0123425 44nd 4s | 65/19 66/16 66124 67/16 [long [6] 37/16 38/23 39/10
45174715 S54 5517 | SYA T23TIS8ARY | 40/14 69/13 82720
6616 86/10 90/10 longer [2] 37/6 41/16
lawyer [6] 11/9 175 1777 letters [10] §/17 18/5 18/13/look [10] 6/18 35/16 55/19
25/24 39/11 39/11 4925 S8/13 61/12 61/13 | 62/14 69/11 78/21 79/16
lawyer-to-lawyer [1] 64/8 64/12 67/5 81/10 85/2 91/17
30111 letting [1] 38/21 looking [6] 3/22 22/20
lawyers [4] 22035118 [level B] 13125 46/19 65/13| 22/21 23/3 63/21 83/3
37143722 leveled [1] 12/14 looks [1] 43/19
layed [1] 55/20 liability [2] 13/113/16 [loose [1] 78/18
lays [1] 84/1 Lieutenant [12] 7/16 9/21 [lost [2] 59/21 88/21
lead [4] 14/6 19/15 19/16|44/1 504 64/3 64/4 73/1 [lot [11] 2/19 220 16723
1917 74120 75/1 75/4 81/12 82/1|2/4 24/2 31/3 42/3 42/12
leak [6] 61/25 68/14 71/21 |11fe 13] 52/19 6U/L1 GULL | 49/13 61/10 649
71/22 71/25 72/1 light [S] 2/259/311/25 lots [1] 88/13
leaked [1] 62/1 41/8 93/9 love [3] 60/20 71/13 84/5
leaking [2] 67/12 67712 [lighthouse [3] 17/14 17/16 [lower [2] 5113 51/13
leaks [3] 66/4 72/25 77/14|1824 lowercase [1] 46/24
learned [2] 67717913 |Lghts [1] 46125 Lowndes [1] 9/14 |
least [5] 249 27/4274 |e B61 3086181116 [ny
77124 84/10 14211517 16/1 1815 |e— |
leave [5] 8/9 3523 76/8 | 23/8 23/8 23/19 43/19 45/9 |machine [1] 73/5
76/9 85/25 45/10 48/748/14 49/13 |made [18] 14/2 20/17
leaving [1] 48/10 52/18 53/14 54/3 54/8 S572 | 27121 37/18 41/17 4313
logal [17] 92 18/1 2818 | 55/10 62/9 6321 66/13 | 46/11 47/19 56723 57117
45/3 4773 4719 47/12 47/15| 66/14 66124 68/21 70/17 |S8/5 63/1 63/8 74/6 80/4
471234877 8224 8224 | 70/20 84/5 85/485/9 85/9 | 86/14 86/18 89/22
83/5 85/12 85/16 83/23 | 36/1 88/21 magical [1] 12/20
92110 likelihood [1] 71/18 magically [1] 22/10
legally [1] 54/1 limb [1] 73/22 Magloclin [2] 91/4 91/4
less [4] 12/23 42/3 ss [lines [1] 243 magnitude [1] 74/3
59/14 link [1] 19/5 mal14] 203 3973 778
|
M_ [somsi40y13 11/11 15/6 16/18 23/17
malls 3] 19/16 20/9 59/15 |maybe [L1] 17/14 37/5 |24/15 32/4 S813 58/5 58/6
main [2] 27721 27121 46/18 47/20 48/16 52/5 | 63/16 63/17 75/9 75/21
maintain [1] 46/12 52557145722 58/11 |82/1
major [1] 35/16 76/20 mind [2] 22/25 65/16
make (24] 2/20 6/6 14/16 [MCBURNEY [1] 111 |mindful [1] 28/11 i
34/1437/12 3713374 |e [39] S2L6/T8I19/7 mine [1] 79/4 |
397144503 50085201 |L/712413/131315 minimum [2] 29/2425| |
54121 60/3 62114 63/2 7072| 15/14 1624 17/18 18/4 minor [1] 17/6
30/5 80/24 81/1 8212 86/1 |22/1 25/4 26/1 29/24 44/20|minute [2] 24/13 613
92/23 93/11 93/15 45/19 45/20 46/18 53/21 [misconduct [1] 83/23 .
makes [4] 16/24 28/3 28/10] SY25 S24 57/22 5972 [misled [1] 48/4 |
45015 50/11 60/10 61/16 62/14 [miss [1] 89/3
making [1] 71/17 67/21 68/25 73/18 74/25 _|misunderstood [1] 7/23
manage [2] 42147072 | 78/20 85/2 87/4 88/25 92/5 |mix [1] 40/18
managed [1] 8/11 uy mobility [2] 14/24 1821
[mandatory [2] 44/16 44/t7meat [16] 11S 13/5 moment [1] 46/8 |
many [7] 80162025 21/1 |17119 18/920/8 27/18 30/8 money [7] 63/22 65119 i
27357253615 5877 |AUB4024 441174509 [75/14 77/25 78/4 81/18
map [1] 2412 462346023 4948711 | 8124
marched [1] 34/15 8718 month [1] 80/11 :
marching [1] 55/10 meaning [2] 31/1148/5 month,Mr [1] 63/13 :
mark [1] 68/21 meaningful [1] 93/12 moot [4] 6/6 9/8 10/22 42/9)
marked [1] 63/4 meanings [1] 88/13 more [28] 3/10 3/21 15/14
material [1] 65/2 means [1] 28/16 16/6 17/17 24/3 24/6 24/12
materially [1] 64125 meant [1] 43/17 24/13 28/1 28/16 29/18
matter [10] 18/112671 media [11] 2237/6721 | 36/8 36/19 3777 38/17 39/4
A614 4712 47714 48/9 | IST ISI9ISII6N | 43/7 49/11 52/8 61/10
48218579103 034 | 462 6TDAG82 TAN | 65120 73/8 75/14 76125
matters [2] 3121830 medial [1] 47/4 81/4 87/12. 9012
may [62] 6/5723823 [meet 2] 10165810 [morning [1] 415
Osi ar alts. |members [1] 7/7 most [5] 36/4 3823 43112| |
12/25 13/6 1322 14/ |memorialize [1) 92/16 | 73/25 87/11 i
15/17 16/21 17/1 17/6 18/0 |mention [1] 82/12 motion [40] 2/62/82/10 |
2214 2214 22/6 22/13 25/10 |Mentioned [3] 38/20 49/15 2/15 2/16 2/17 4/45/11
26/4 282228023 29/16 | 67/11 SI15 5/18 523 6/7 11/4
30/4 30/5 30/8 31/17 34/21 [ere [1] 64/18 11/18 13/21 18/16 27/18
36253714 37243058 [merely [2] 2/10 72/9 36/10 36/22 41/17 43/11
39/9 39/13 39/21 40/2 met [2] 29/1 85/12 57/16 57/16 58/19 64/23
10/14 4015 4022 d0rz4 [method [1] 36712 72/16 79/3 83/1 83/2 83/23
4113 41/14 43/6 47724 |micromanage [1] 41/21 | 84122 84/24 85/15 85/17
49/15 51/5 53/20 5477 55/3 middle [1] 59/21 86/25 87/1 87/3 89/8 89/15
56/11 5720 58/8 59/23, |midst [1] 42117 89/20
5924 62113 6220 71/14 |might [17] 6/18 8/14 8/15 motions [3] 1/10 2/52/13
M my [66] 4/19 6/467 7/8 |7311091725
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motivation [3] 4818 4599| 113 16125 1777 17/8 17124 [neutrality [1] S614
on 1725192 19/11 19/19 [never [9] 18/2227/25 29/1
one ha 1am1710 205242 251102623 |Ss STR GanT TONS ||
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moving [3] 21192316 41/9 | 5513 5513 58/16 5611 [Newnan [1] 572
sag 50/12.59/18 59/21 60/5 [news [7] 11/25 38/16 47/13
mr [103] 62/6 62121 63/2 63/22 66/5 | 63/25 6417 64/8 67/14
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or Yoade [2] 12 714 | gaj14 35/18 86121 89/18 |4024 41/2 41/15 48/8
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SSIL192/5 9209 92/12 near [2] 52123 93/5 84/14 85/8
92/12 52/20 92/20 [necessarily [4] 9/12 13/25| 95/31 92/1485/24
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37/10 neck [1] 55/6 nominate [1] 76/1
(Ms. Clapp [1] 5/10 need [44] 2/17 3/3 3/18 6/9| nominated [1] 13/12
Mis. Pearson [6] 428 S11 G10 622 6125 86 319 94 nominee 1) 3213
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27/6 35/13 35/23 44/10 | 44/14 49/5 53/25 54/5 54/6 non-special [1] 32/19
MRSSUIDTIRSTSIA | 5123 60/7 61/1961/20 [norman 13] 33/5 38/24 5213
sul 85/24 92/16 93/13 normally [1] 51/19
mud [1] 7/9 needs [S] 10/1137/22 3912
N occur [1] 41/5 47/6 501252/754/20 54125
not [181] een 56/3 60/16 60/23 62/19
occurs 64/2 65/18 69/2 69/23 70/6
asait2 24|October [6] 8/14 8125 9716| 7025 733 71/11 7206
noted [1] 50/19 52/11 66/2 66/2 72/12 72/19 73/9 76/9 77/7
noteworthy [1] 38/11 of Charlie [1] 43/24 77/18 78/9 79/11 79/16
nothing [12] 201022/8 [Off [9] 8/18 10721 S7/11 | 80/6 80/10 83/19 84738619|
23/2 26/11 27/11 27115 60/23 70/1 70/3 77/2 81/16| 86/13 86/15 90/1 90/18 ,
34/4 36/13 43/9 312 77/11| OV12 92/4 9219 :
9218 offer [8] 22/19 22/24 69/3 [old [2] 55/22 55/23
notice [1] 81/11 7616 76/11 80/7 80/22 84/9 [omit [1] 3/22
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[November [3] 720 4972 |77125 51/23 56/10 56/13 65/1
75/18 offering [1] 7/24 3/4 7415
now [33] 8/8 9/11 12/24 office [66] 2/72/143/23 one [55] 3/18 3/21 7/23
15/3 15/7 16/24 20/17 23/3 3/253125 4/4 4/87/7717 | 10/4 13/11 14/21 14/22.
25/8 31/7 34/16 39/1 40716| 724 84919 9/14 10/11 | 15/8 15/8 16/6 16/16 22/3
US/194520 543583 | LU/6 11/9 18/3 18/6 2023 | 24/6 24/6 27/21 29/16
6024 61/13 61/18 621 |23/3 35/6 36/8 38/4 38/12 |31/10 32/14 34/25 35/15
64/6 67/2 71/12 75/7 75/16 39/10 40/12 41/7 41/13 38/5 38/10 39/14 39/22
7616 77/4 T7120 81/10 41/22 42/10 46/1 46/2 46/4 | 45/11 45/18 46/23 48/10 |
85/20 92/24 93/1 47122 48/19 52/25 55/7 48/22 49/17 49/18 51/17 i
number [4] 1/6 38/2 38/6 57/25 59/2 63/9 64/4 66/4 | 52/8 60/8 63/17 63/17 64/3 |
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oppased... 14] SSLGS/L |come [8] 39/9 73/1 741 partition [1] 4610
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opposition [1] 2/15 8925 party [9] 18/18 21/1 46/19
optics [3] 43/6 43/7
option 2] 318 sus 4658 |et 1) 35716
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organization [1] 62/6 100116] 4114 37/538/19 [Pause [1] 4313
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originally [1] 43/14 overlap [1] 39/17 PEARSON [27] 1/19 4125
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ad page 7 [1] 5/15 21/423/24 26/9 26/20
otherwise [4] 26/1549/4 pages [1] 94/10 27123 29/14 30/15 30/16
85/11 85/14 [pains [1] 35/7 33124 36/3 38120 40/9 41/4
ought [4] 81953120 84/5 |painting [1] 49/20 46120 48/10 59/1 61/7
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our [27] 8123 20/10
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74/4 8172 85/5 85/22 86/1 |‘49/1 5410 58/4 60/4 60/5 perception [1] 55/18
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person's [1] 192 57/1857/25 58/471/23 [presumptive [1] 66/6
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Peterson's [1] 11/4 politicization [5] 87/15 [print [1] 62123 |
phrase [3] 34153512 |S71887/198721892 prior [2] 2420 8125
"219 42/20 46/5 politicized [2] 28/128/3 |privilege [4] 11/12 1372
piece [2]879/8 politicizing [1] 87/20 15/23 31/19
Divot [2] 4114 391 pool [2] 3/123/19 privileges [1] 20/13
Place [8] 13/22 15/3 17/23 [POFtion [2] 187418 |proactive [1] 24125
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places [1] 26/25 possible [2] 54/957/21 | 11/13 68/10 69/10 9222
Dian [4] 15/22 16/5 92/25 [Post [2] 50235113 problem [2] 75/5 81/14
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planet [1] 6177 posture [1] 49/6 583
planned [1] 15/18 potential [4] 4/14 13/15 [procedure [2] 1493071 | |
Pratt 11] 4/22 14125 58/19 proceeded [1] 65/20 |
played [3] 13/8 61/4 84/17 [Potentially [1] 43/5 [proceeding [2] 45/12 56/18 |
blays [3] 6218/4 Sq/18 [Power [21 261105458 proceedings [4] 211 12/20 |
Pleading [6] 45/8 5224 [Powerful [2] 31253212 | 12121 94/11
"62011 63/15 62/17 85/11 [Powers [1] 22/11 process [10] 6/823/19 37/6]
please [4] 12/4 51/6 58/23 [Practieal [2] 6/6 73/12 |41/11 42/6 52/20 52120 |
85/19 precedence [1] 29/6 57122 84124 89/8 |
pleased [1] 82/12 precedent [3] 20/13 28/18 [processed [1] 22/13
Plug [1] 548 Tals [processes [2]69/18 87/16
Doiguantly [1] 12711 [Preceding [2] 45120 59/10 |product 2] 8/15 28/12
Doin [34] 523 612 10/10 [Preferable [1] 7411 professional [4] 21/6 27/14)
ona 122127171522 [prepared [1] 66123 29/11 71/4
16/20 17/13 21/2 21/5 23/2|Preparing [1] 56/19 proffer [3] 19/21 24/15
24122 2423 25/2 20/16. Present [1] 70/17 29/13
34/13 34/14 34/19 4/9 [Presentation [6] 69/12 |prohibited [1] 10/8
48/22 49/6 S0/18 54/8 5571|69/20 76/22 8325 84/9 |prominent [2] 87/6 88/4 |
55/2 64/23
$112 85/3 74/4
81/1665/10 36/23 [1] 69/16
86/7 80/4|[Presented proper[1][2]61/25
proof 34/8 91/14 ::
pointed [4] 26/8 65/7 66/5 [Presenting [1] 56719 properly [3] 162226116 | |
os preserve [1] 70/20 32/5
pointing [1] 12/6 president [1] 91/8 proposed [1] 36/12 i
points [3] 757 91/3 press [9] 9/19 57/8 57/13 [proposition [3] 56/4 78/21
|
P [published [3] 54/24 59/19| 55/13 65/10 78/18 88/23
proposition... [1] 79/14 | 9/5 89/23 91124 92/18
prosecute [2] 45/13 46/6 Pull [1] 703 questioning [2] 26/22
prosecuted [1] 88/16 pulled [1] 70/1 7314
[prosecuting [7] 43/1 45/18| Pulling [1] 64/1 questions [16]4/5 11/20
'S1/9 68/20 82/14 82125 |Punch [2] 22/3 22/4 1124 12/25 13/17 15/11
84/13 punished [1] 85/7 15/13 16/1 17/16 23/14
prosecution [3] 43/5 56/15|Purported [1] 43/18 2411424121 27/3 28/21
po purpose [29] 1/5 1/102/3 | 36/12 74/19
prosecutor [9] 4821/8 |1216 14/710 24/11 24/12 |quiet [2] 2912129721
112 45/8 dele S612 |272132/14320193318 [quietly [1] 64/6
56/14 58/10 66/10 33/1834/20 34125 35/10 (quite [1] 57/12
prosecutorial [1] 8323 |43/4 47124 48/1 48/5 48/11 quote [3] 56/7 67/17 71/4
prosecutors [4] 44203 | 8144825659775 |quoted [1] 64/11
56/5719 wn ssassasu0 fp
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nefont IB 16022|rsuing [1] 46/13 raise [3] 6/7519 7713
protections [1] 4ns [Purview [1] 812 raised [11] 3/24 5/12 9/22
protects [1] 27/20 push [1] 90/5 36/9 41/17 42/15 63/13
prove [1] 58/3 put [16] 6/19 16/18 20/18 | 72/22 78/1 84/23 86/7
provide [1] 22/12 21/922/1027/1059/18 |Faiser [1] 81125
provided [2] 12/1884/1 |63/22 TW17U3 74/18 81/4 raises [1] S/1S
[providence [1] 77/10 84/489/2092/2293/7 [raising [3] 10/581/18
province [1] 76/13 puts[1] 23125 8123
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read [2] 71/13 840 | 58/8 66/11 68/17 69/1 806 [reporter [12] 1/23 59/3
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7112 regarding [2] 31/20 86/6 | 80/25 81/2 82/18 86/1 94/8
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real [1] 737 regrets [1] 63/11 reporting [2] 61/17 94/15
really [10] 3/3 3/921/13 |Tegular [3] 32/3 32/9 33/22 reports [1] 9/1
37/23 41/12 45/21 64/21 regularized [1] 37/8 represent [4] 45/11 49/24
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reason [9] 2477 24/9 20/5 "elated [1] 91/10 representation [3] 60/9
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28903 release [4]8/8 9/11 93/12 |representatives [1] 11/8
reasons [1] 6/9 93/18 represented [2] 45/19 85/8
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5/20 5124 18/5 50/8552 |93/15.
58/12 58/17 58/24 61/1 releasing [1] 57/8
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receiving BI 29723 relevant [5] 19/1856/9 | 88/15 89/5
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reference [3] 47/20 51/3 |Feplacement [1] 89/10 [responses [1] 3/23
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revelations [1] 58/1 25/129/1135/1435/20 (Sean [1] 2022
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ridicule [1] 86/21 50/9 50/23 51/4 60/17 [Secretary [1] 91/9
ridiculous [1] 19/10 602574158511 87/9 [eC [22] 5/18/19 19/17
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10124 15/3 15/7 17/8 20/12 [saw [1] 45/8 5421 60/7 62/23 62125
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92/4 92/15 93/1 64612732 TINS [Som [2] 3825 87/8
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role [5] 8/4 18/19 1922 | 30/18 312433/16 56/21 [*elf-incrimination [1]
52/16 56/18 56122 64/11 6724839 |3120 20/23
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7119 Schafer [1] 20/24 49/7 49123 50/9 50/11 53/9
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28/15 29/11 30/7 32/7 71/4 [scheduled [2] 41/3 41/3 | $412 64/14 65/8 65/25
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025435412 6506 [Stake [1] 88/16 39/17 44/18 47/9 47/9
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27120 33/16 55/20 56121 | 711593925 10/3 10/4 | 92892114
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theory [3] 57247120 |SUP3SVI252955/14 | 69/21 75/8 81/15 84/8
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trials [1] 61/24 spstmasaseons (V___|
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4512 45/10 49/10 50/10
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55123 56/7 57/3 78/19
[your [161]
z_____
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[zoom [2] 54110 60/22
Exhibit12
Transcript of July 25, 2022 Special Purpose
Grand Jury Hearing before the Honorable
Robert C.I. McBurney, Atlanta, Georgia, In
re 2 May 2022 Special Purpose Grand Jury,
Case No. 2022-EX-000024 (Fulton Co. Sup.
Court).
oo TT
: tt
39
ores , AUG 25 2871
)
8 2022-EX-00024 |
9 i
0| SPECIAL PURPOSE. GRAND JURY HOTIONS TRANSCRIPT |
11 Before the HONORABLE JUDGE ROBERT C.I MCBURNEY |
i
I
14 | appearances: i
25 | hadassah. davidefultoncountyga.gov |
1 PROCEEDINGS
2 THE COURT: Good afternoon. Let's get on the record
3 in 2022-Ex-000024. This is a special purpose Grand Jury.
4 It is about 2:00 o'clock on the 21st of July, and we are
5 going to work through, this afternoon, a couple of motions
6 that have been filed. A motion filed on behalf of Senator
7 Jones seeking to disqualify the DA's office from handling
8 the case, the case that is Senator Jones and then a motion
9 to quash and disqualify, but to disqualify, I think, is
10 merely an adoption of Senator Jones’ motion that was filed
n on behalf of 11 of the == for today we'll call them
12 alternate electors.
13 Those are the two motions I think we are covering.
1 The State has filed, the District Attorney's Office has
15 filed, an opposition to the motion to disqualify. I let
16 then know, because when I received the motion to quash
bY that they didn't need to file a written response motion
18 which is fine, and hopefully you will be able to address
19 it today. It's a lot of moving parts.
20 We've got a lot of lawyers here, so I want to make
21 sure we get on the record who is here and who will be
22 speaking for the different parties. Before we go any
23 further, though, Rule 22 wise. There were some media
2 outlets that only reached out today to get the green
25 light. If you were able to get equipment in here you are
HADASSAH J. DAVID, OFFICIAL COURT REPORTER 2
1 free to use it, but I did not sign your Rule 22 today, !
2 because the general Rule 22 Ls to be signed 24 hours in .
3 advance, but you really only need the Rule 22 for purposes| |
4 of getting in the building with the big cameras, so if you
5 sought Rule 22 approval to record things while you're in
6 here and you've got a handheld device, you are welcome to
7 do that.
8 Going forward it's 24 hours in advance, and it would
s really help if you could report back to your Rule 22
10 people, if you would designate more clearly on the Rule 22
u forms what kind of equipment you want to bring in. I am
12 all for having a pool feed rather than four big cameras in
13 here. It gets a little crowded for you all, but I can't
u tell because everyone who submits a Rule 22 checks
15 everything -- I want to bring in every kind of equipment
16 in. I'm bringing in a drone. I know you're not bringing
bY in a drone, but apparently for everyone bringing in the
18 big cameras we only need one, and like I said, I'm happy
13 to have a pool, but it’s hard to tell.
20 With that, let's start with the State. Who will be
21 handling -- it can be more than one person, but I just
22 don't want to omit anyone if I'm looking to the District
23 Attorney's Office for answers or responses to concerns
2 raised by some of these witnesses. Who from the DA's
25
me
office or affiliated from the DA's office should I be
|
i
1 expected to hear from?
2 ATTORNEY GREEN-CROSS: Good afternoon, Your Honor,
3 I'm Anna Green-Cross. I'm here representing the District
4 Attorney's office on the motion to disqualify prosecutors.
5 THE COURT: So if I have questions about quashal or
6 assertion of Fifth Amendment rights?
7 ADA WADE: Good afternoon, Judge. I'm Nathan Wade,
8 special prosecutor from the District Attorney's office as
9 well as Donald fiakeford.
10 THE COURT: So Wade and Wakeford for Fifth Amendment
1n quashal and Green-Cross for the disqualification.
12 ATTORNEY GREEN-CROSS: Yes.
13 THE COURT: Okay, got it. Thank you. All right. If
u we pivot over to potential witnesses and counsel, Mr.
15 Dillon, good morning. How are you?
16 ATTORNEY DILLON: Good afternoon. I'm fine, Judge.
17 THE COURT: You are representing Senator Jones. Is
18 there anyone else? I don’t want to ignore anyone.
19 ATTORNEY DILLON: My associate Anna Clapp is also
20 here.
21 THE COURT: Great. Okay. Clapp as in applause or
22 Platt as in . . .
23 ATTORNEY CLAPP: Clapp as in applause, two P's.
2 THE COURT: Got it. Excellent, and then on behalf of
25 the 11 alternate electors, Ms. Pearson and Ms. Deborroughs
HADASSAH J. DAVID, OFFICIAL COURT REPORTER 4
|
:
1 I see Ms. Deborroughs virtually. She is appearing in |
2 Newnan or even further away, but we greenlighted that
3 virtual appearance. It's fine, and we've got Ns. Pearson
4 here.
5 ATTORNEY PEARSON: You do, Your Honor.
5 THE COURT: Okay. Anyone else on behalf of your
7 clients or just the two of you?
s ATTORNEY PEARSON: No, Your Honor, just us.
5 THE COURT: AIL right. I want to start with a |
10 question for either Mr. Dillon or Ms. Clapp, and that is i
1u whether you are joining in the motion that Ms. Pearson |
12 filed in which Fifth Amendment concerns are raised as i
13 opposed to conflict issues?
1 ATTORNEY DILLON: Yes, Your Honor. Insofar as Ms.
15 Pearsons motion, I believe at page 7. It raises the fact
16 that these witnesses who have received both subpoenas and
bY target letters should have their appearances waived. fie
18 Join in that portion of her motion.
13 THE COURT: What is the status of your client? I
20 know he's received the subpoena, that is the only part
2 that's been disclosed to me. :
2 ATTORNEY DILLON: Well, in the government's response
2 to our motion, they actually point out that Senator Jones
2 received a target letter in this case.
2 THE COURT: Okay. Do you disagree with that or . . . | |
HADASSAH J. DAVID, OFFICIAL COURT REPORTER S
cd
1 ATTORNEY DILLON: No, I do not. It is an irrefutable
2 fact at this point. We publicly acknowledge that it is an
3 irrefutable fact.
4 THE COURT: Okay, so my thought is that we talk about
5 some of the Fifth Amendment concerns first because it may
6 make moot for practical purposes the conflict concerns
7 that you raise in your motion. Let me simplify my thought
8 process for you. If in the end I determine that Senator
9 Jones need not appear because of Fifth Amendment reasons,
10 I don't know we need to reach the question of
1 disqualification if that would be his only connection to
12 this grand jury.
13 This Grand Jury is not a Grand Jury that would be
u voting on a bill of indictment. It is a Grand Jury that
15 has been tasked with generating a report that would
16 contain in it, ideally, a recommendation to the District
17 Attorney as to whether she should pursue charges or not
18 and what those charges might look like, and any other
19 things that that Grand Jury wants to put in there other
20 than a true bill.
21 So the way the Fifth Amendment analysis plays out is
2 that I conclude that Senator Jones doesn't need to appear,
23 if they state his name or something, and we can work
2 through those logistics probably in a smaller group
25 setting. Do you agree that we don't need to reach the
HADASSAH J. DAVID, OFFICIAL COURT REPORTER s
|
'
1 question of disqualification? y
2 ATTORNEY DILLON: No, Your Honor. I do disagree.
3 THE COURT: Okay.
4 ATTORNEY DILLON: I think that the disqualification
5 issue is right, and I think that it has been exacerbated
6 by the media circus that's been generated out of the
7 Fulton County's DA's office in this case, and that the
8 harm to my client, Senator Jones, is that he's being drug
9 through the mud publicly as a subject of this special
10 Grand Jury.
1 THE COURT: Well, apparently as a target, not a
12 subject.
13 ATTORNEY DILLON: Well, I say a subject as someone
1 who has been affected by this special Grand Jury,
15 particularly as a target, but with the effort and focus
16 being that it’s going to have an impact on the Lieutenant
17 Governor's race this fall. And so if the DA's office has
18 a hand in it and they issue a report that says, Well,
19 we're going to recommend an indictment of Senator Jones,
20 it will have a direct impact on the election in November,
21 and that's been reported in the media numerous times.
22 THE COURT: Okay. So I'll correct a couple of things
23 for you. One, and I may have misunderstood what you were
21 saying, but the District Attorney's Office is not offering
25 any report. That would come from the grand jurors as :
HADASSAH J. DAVID, OFFICIAL COURT REPORTER 5 '
1 supervised by me. I appreciate that the District Attorney
2 has fashioned herself as the legal adviser to the Grand
3 Jury, and that's an adaptation of the actual language of
4 the role that that office plays, but ultimately it's the
5 Grand Jury's report not the District Attorney's.
6 Second, and a concern we do need to cover today,
7 regardless of how we approach the disqualification piece
8 would be the timing of the release of the report. Now, I
9 think that’s something that everyone ought to leave here
10 today with a better understanding of how that will be
u managed.
12 That is within my purview, and it was helpful to have
13 it brought to my attention that timelines could collide,
14 that the Grand Jury might complete Its work in October,
15 and that might not be the best time for Its work product
16 to be shared publicly in the way that many investigative
17 agencies, that's what the Grand Jury is an effect here,
18 they hold off on taking certain steps until an election
19 has passed with a few exceptions, and we need to see
20 what's going on with that report, if it's even ready by
21 then.
22 The Grand Jury is authorized to continue its work
23 through May 1 of next year, so I don’t know that it’s
24 right yet to worry about that other than to get a general
25 understanding that I wouldn't be a big fan of an October
HADASSAH J. DAVID, OFFICIAL COURT REPORTER "
1
u with this Grand Jury is that I was one of the people who
12 agresd or was nominated, or however it happened to be an
13 alternate elector, you're going to ask me about that, and
14 I have a good-faith basis to believe my decision to agree
1 uy?
1 ADA WAKEFORD: I undezstand, Your Honor. Thank you
20 for the clarification. I would say that the 11
n individuals tdentifid in the motion are not sll situated | |
22 in exactly the same place, so there may be commonality i
23 between them, but there is going to need to be an i
2 individual determination with regard to each of them. The| -
25 level of involvement is necessarily individual, so what I
HADASSAH J. DAVID, OFFICIAL COURT REPORTER 5
1 think would work is for an individual assessment to be
2 made in each case, since we undoubtedly have the ability
3 under the law under Lampl to ask the witnesses to appear,
4 then there would be ahead of time a discussion between the
5 parties with Your Honor's involvement need be, to discuss
6 areas of inquiry that may lead to an identification of
7 Fifth Amendment rights.
8 If that is the case, I believe we would be able to
9 work out a procedure where there is not a badgering of a
10 witness, but simply an ability for the special purpose
n Grand Jury to walk up to an area of inquiry and be told
12 this is going to be foreclosed by the Fifth Amendment and
13 move on if there are other areas to pursue, so each them
1 will require, I believe an individual assessment.
15 THE COURT: Are there any of the 11 = - I'm gonna
16 make it 12. I'm going to include Senator Jones in the
17 group, so any of those 12 where the only topic of interest
18 is that witness's participation in the alternate elector
13 scheme.
20 ADA WAKEFORD: The answer to that is no.
2 THE COURT: Every one of them ~ ~ it sounds like it’s
22 a very diverse group, and one of the concerns Ms.
23 Deborrough and Ms. Pearson had brought up was that some of
2 them are remote, some of them have trouble with mobility,
25 but you are saying all of them have some other potential
HADASSAH J. DAVID, OFFICTAL COURT REPORTER ”
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1 ADR WADE: Not a barrage of like 50 questions where
2 they decide to assert, hut just to be able to hit the
3 different buckets though and to answer the Court's
a question directly, that, yes, sir, there are other areas
s that ve plan to attack.
6 THE COURT: Thers's more than one bucket for each of
7 the 12 - =
. ADR WADS: Yes,sir.
9 THE COURT: ~~ Ts what I'm hearing you say - - well,
10 hen we would need to work through that. That helps, I
u appreciate that, and I think there is ample case law,
12 state and federal, that authorizes witnesses who say up
13 font that I'm going to assert the Fifth Amendment to
1 Still be called before the Grand Jury to then assert it.
1s Bank of Nova Scotia from the US Supreme Court is the
1 earliest one I found where you sometimes need to have
those people get in front of the Grand Jury to actuslly
1 invoke, because they might aot when put in that situation,
1 and then the investigators are not forced to rely on a
2 Clain that they will, or to your point, Mr. Wakeford and
u Mr. Wade, there may be areas that come up that aren't
2 properly covered by that protection.
= I know weve been bouncing around a lot, but T think
2% it makes sense for me to hear now from ls. Pearson or Ns.
2s Deborzough about the approach you've taken, which is my
HADASSAH J. DAVID, OFFICIAL COURT REPORTER 1
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1 2 legal perspective. They were all witnesses, they were
2 all converted to targets, and there has been no
3 differentiation from the DA's office between that.
1 THE COURT: Let me interrupt you for a second. So,
5 you are saying all 11 of them have received target letters
6 or some communication from the District Attorney's Office
7 that uses the “1” word?
8 ATTORNEY PEARSON: Yes.
5 THE COURT: Whatever that may mean in the State
10 context, but just because two of your clients have, you
1 are saying they are similarly situated, it’s just a matter
12 of time for the postman to get there.
13 ATTORNEY PEARSON: I have 11 target letters.
1 THE COURT: Okay. So in that way they are similarly
15 situated, but it sounds like they are, and you note it in
16 your own motion, they are also very differently situated.
17 You have, and I apologize if I have the title wrong, Mr.
18 Schaffer as the chair of the Republican Party in Georgia,
19 A very, very, different role in connection with the
20 affairs of election then. I don't remember who the
2 elderly individual difficulty with mobility and whatnot.
22 I've never heard of the person.
23 It is a differently situated individual once you get
2 outside of that lighthouse of, I was an alternate elector.
25 ATTORNEY PEARSON: That's true, Your Honor, but I
HADASSAH J. DAVID, OFFICIAL COURT REPORTER -
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1 talk to me a little bit about the last, second to last
2 point I heard from Ms. Pearson about an inability to
3 immunize because, of course, one ticket you can punch that
4 you may not want to punch for anyone, but you may for some
5 of the alternate electors whose sole connection or primary
6 connection to what you're investigating may be the
7 alternate elector situation, would be to let them know
8 that nothing you say during a Grand Jury can be used
9 against you.
10 If you put that in writing then you magically have
u some compulsory powers, I do, that did not exist before,
12 but if there is not a way to provide sufficient protection
13 you may not have that, and I hadn't processed it the way
14 Ms. Pearson did. Anything you want to add on that? Mr.
15 Wade is shaking his head. As in you disagree or I don’t
16 want to add to it?
7 ADA WADE: I vehemently disagree, and there was no
18 effort or attempt or even any indication that our position
19 would be to offer any type of immunity, if that is what
20 she's looking for.
2 THE COURT: I didn't hear Ms. Pearson looking for
22 anything. What I heard her say was that even if you
23 wanted to, and you're saying I don’t want to, the scope of
2 the District Attorney's offices offer of immunity wouldn't
25 be sufficient in Ms. Pearson's mind to protect her clients
HADASSAH J. DAVID, OFFICIAL COURT REORTER 2
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1 they can. That is the only thing Lample even arguably
2 says. The only issue then is you get to quash them if you
3 want to.
4 If you believe that you should, and there's nothing
5 that says your authority under the statute, or under
6 supervisory authority is in any way affected by Lampl at
7 all whatsoever, so you clearly have the authority to do
8 what you think is proper with this Grand Jury here, and
s we're asking you, on behalf of our clients, not to have
10 them frogmarched in front of a cameras and in this
u courtroom.
12 THE COURT: Okay.
13 ADA WAKEFORD: At this point I was going to address
4 the original point I was going to make, which is I believe
1s we've heard the phrase “frog marched” in front of the
6 cameras three times now.
17 THE COURT: All right.
18 ADA WAKEFORD: I do not want to talk about this, but
13 I have to at this point. Publicity is a hindrance to the
20 special purpose Grand Jury's work. I believe earlier
21 Ms. Pearson stated that there may have been a witness in
22 here yesterday, but she didn’t know who it was or how they
23 appeared, or what they had talked about, which is an
24 indication that the witnesses can come before the special
25 purpose Grand Jury, and no one ever know anything about
HADASSAH J. DAVID, OFFICIAL COURT REPORTER 2
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1 it. If witnesses exercise their First Amendment right to !
2 disclose after the fact or before the fact they were i
3 called, then they are allowed to do that. That is the !
4 source of publicity around this. It is, I think here we
5 are tired of hearing that there is publicity jammed up by
6 the District Attorney's Office in order to create a circus
7 around this when we have actually taken pains to try to
8 create an environment of circus around this, so there is
s no frogmarching, and there are ways to cone before the
10 special purpose Grand Jury without publicity being brought
u into it. T just wanted to clarify it right after the
12 third tine we heard that phrase. !
13 THE COURT: Okay. Well, I appreciate much of what
u vou said. I think it's a little rich to suggest that any
15 particular side that has avoided the cameras. One need |
16 look only at basically any major news outlet, and you will |
7 see who is talking to the media, and it is not always the
18 lawyers for the witnesses, so I think everyone involved in
19 this has taken full advantage of media coverage.
20 That said, they're are some things that can be done,
21 I know, because I've been asked to be involved with it to
22 ensure that witnesses can enter into the building and !
23 leave the building without much harassment from the media,
2 and we can get to do that. !
25 I don't know that there are many of Ms. Pearson's 1
HADASSAH J. DAVID, OFFICIAL COURT REPORTER 2 |
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1 clients that the media would even recognize when they
2 walked up the front steps of the courthouse if that's how
3 they came in, so I think the concern about putting people
4 on public display is a bit exaggerated for most of her
s clients, but if there are clients who need special
6 accommodations and ingress and egress we can always
7 accommodate them, we've done it before and can do it
8 again. Anything more from the District Attorney's office
s on the fifth Amendment concerns raised in Ms. Pearson and
10 Mr. Deborrough’s motion as expanded by Mr.Dillon?
u ADA WAKEFORD: No, your Honor. We have responded to
12 your questions, and we have proposed a method going
13 forward, and we have nothing else to add.
1 THE COURT: Thank you. Okay. Ms. Pearson or Ms.
15 Deborrough, anything else on behalf of your 11 clients in
16 connection with the quashal of the requests, in other
17 words the Fifth Amendment concerns?
18 ATTORNEY PEARSON: I think that's it, Your Honor.
19 THE COURT: Mr. Dillon, anything more on the Fifth
20 Amendment aspects?
2 ATTORNEY DILLON: No, Your Honor, we've got the
22 motion as communicated earlier.
23 THE COURT: Okay. Thank You. So I will not be
2 quashing any of the subpoenas, but I will be asking —- we
25 may need to change some of the timelines. How many of
HADASSAH J. DAVID, OFFICIAL COURT REPORTER 2
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1 don't think it's appropriate under the case law Lampl and
2 others to quash the subpoenas, but it may be that these
3 witnesses have very, very, brief appearances in front of
4 the Grand Jury.
5 ATTORNEY PEARSON: Your Honor, just so that I
6 understand. We aren't going to elaborate on it ahead of
7 time. We will collaborate when the first witnesses come
8 here or in between each witness? I mean, we've got 11
9 people to get through, so I guess I need some clarity on
10 how that's going to work for each witness.
u THE COURT: So I invite early collaboration, but I
2 also understand that if the District Attorney's Office is
13 reluctant to get too specific too far in advance, so they
0) may buckle under the pressure of how long that would take
15 as well, and there may be some basic frameworks that they
16 want to share with you in advance, but if you're now
17 getting into the nuts and bolts that I get to stay out of.
18 1 will get in the mix should an impasse be reached.
13 If that impasse is reached tomorrow, because you're
20 talking about a witness who is coming on an undisclosed
2 date next week, at an undisclosed location, then I could
22 talk with you all tomorrow, but it may well be that the
23 default is let's talk when you're witness is here.
2 That may mean you won't get to everything next week.
25 That was - - the reason why I was asking is that if they
HADASSAH J. DAVID, OFFICIAL COURT REPORTER w
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1 are spread out you four weeks you - - they're all coming |
2 in next week. I could see it being that what had been |
3 scheduled for Thursday ends up being what was scheduled
4 for Tuesday, because you only got through two people on |
5 Tuesday because of the confirming that doesn't occur until
6 Tuesday, so I'm not forcing an answer to your question,
7 what you develop with the District Attorney's Office.
8 ATTORNEY PEARSON: In light of that, Your Honor,
9 would the Court at all be amenable to to moving our grand
10 Jurors, not quashing them but moving them to later so that
16 is not the situation we’ve got here, but that is the kind
17 of extreme example of what the law recognizes as an actual
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1 support. Using the title of your office and having a
2 social media that you as this political office holder are
3 holding a fundraiser for the opponent of someone that this
4 political office is investigating. I don’t know that it’s
5 an actual conflict, but I use that phrase, “what were you
6 thinking,” where the prosecutor thought I could prosecute
7 the codefendant of someone I defended.
8 It’s a what are you thinking moment? The optics are
9 horrific. If you are trying to have the public believe
10 that this is a non-partition driven by the facts, and I'm
n not here to critique decisions. The decision was made,
12 but If we are trying to maintain confidence that this
13 investigation is pursuing facts in a non-partisan sense,
1 no matter who the District Attorney is, we follow the
15 evidence where it goes and ignore that fact that I hosted
16 a fundraiser for the political opponent of someone I just
7 named a target.
18 That strikes me as problematic. Maybe not from an
19 actual conflict level, but if we are at a cocktail party
20 and people are asking do you think that this is a fair and
2 balanced approach to things, I do. Well, how do you
22 explain this?
23 I mean, how does one explain? I mean, that is the
2 concern I'm working through is that it is not a lowercase
25 A appearance, it is a capital A with flashy lights
HADASSAH J. DAVID, OFFICIAL COURT REPORTER i
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22 office.
2 The District Attorney is the legal adviser of the |
2 special purpose Grand Jury, and may well have an
25 investigation of their oun, but Senator Jones is trying to
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1 fight a subpoena to the special purpose Grand Jury, and it
2 was brought under their authority.
3 THE COURT: It was, and I think technically you are
4 correct. I wouldn't want anyone to be misled, that the
5 special purpose Grand Jury is the only —- meaning those
6 grand jurors are the only source of subpoenas that they
7 say to their legal adviser, where is what we’d like to see
8 next. That can happen, but what can also happen, and it |.
9 doesn’t matter who it happened here because your point is
10 a good one, but I don’t want people leaving here thinking
u oh, it's only the special purpose Grand Jury that decides
12 to come in and. Equally so and perhaps most of the time
13 it's the District Attorney's team that says, here's who we
1 would like to have come before the special purpose Grand
15 Jury next. .
16 That subpoena comes through the Grand Jury maybe the
7 wrong statute under the subpoena, but it comes through the
18 Grand Jury, but the idea, motivation, and the decision is
19 £rom the District Attorney's office. I don't know how
20 Senator Jones’ subpoena which channel from which it
2 flowed, I've got an inkling, but it doesn’t matter. Your
22 point is a good one.
23 I don’t know that it cures the concern about
2 political support for an opponent not having any bearing
25 on how focused or not the special purpose Grand Jury would
HADASSAH J. DAVID, OFFICIAL COURT REPORTER wo
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1 went out at the same time.
2 THE COURT: Okay.
3 ATTORNEY GREEN-CROSS: So it was not pegged to any
4 event that had any relevance of Lieutenant Governor's race
5 or any other political option was dictated by the terms
6 and the pace of that investigation.
7 THE COURT: So the 11 that Ms. Pearce and Ms.
8 Deborrough received were issued on the same day, and
9 effectively the same time as Senator Jones?
10 ATTORNEY GREEN-CROSS: Yes.
1n THE COURT: It is not Senator Jones got his on a
12 special day, and it was a broadcasted event, and then the
13 other 11 went out?
1 ATTORNEY GREEN-CROSS: It was a routine issuance of
15 the change of status as Mr. Wade explained in an effort to
16 be transparent to everyone who had been working and
7 talking with the State.
18 The final point I think I kind of want to make is
19 that, as noted in the brief, we have partisan District
20 Attorneys and partisan elections for those offices, so it
2 should surprise exactly nobody elected District Attorney's
22 should have political affiliations with other individual
23 within the same political party, and I think the post case
24 == I've got a copy for the Court if you are not familiar
25 with it and a copy for Mr. Dillon.
HADASSAH J. DAVID, OFFICIAL COURT REPORTER 5
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1 attention because it does draw a focus on these are the
2 things that happen when you have political affiliations
3 for elected offices. It's expected, it's normal, and
4 until or it shows some actual conflict then that is just
5 maybe the upside, maybe the downside, but that's a
6 consequence of the system that we have.
7 THE COURT: Okay.
8 ATTORNEY GREEN-CROSS: One more final thing, and I
9 think this could streamline some of our other
10 conversations about remedy. The State is not interested
1 in any sumer surprises. I couldn't source that October
12 deadline to anything. I'm unable to determine when that
13 is. I don't believe we have that here. It's especially
1 unlikely.
15 THE COURT: My understanding from speaking with the
16 Grand Jury directly. My supervisory role is that the
17 timeline is whatever the timeline is. There is no |
18 deadline, they like to be done with this soon, but that is
19 only because they are giving much of their life to this
20 process, but they'll follow this process as it unfolds,
21 and as I intimated to Mr. Dillon and I'll make it clearer
22 when I wrap up the disqualification session that if the
23 work is completed such that it lands on or near the
2 election, it will state in the pleading and be in my
25 office until it gets disclosed after the election.
EADASSAK J. DAVID, OFFICIAL COURT REPORTER 2
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1 If that's not enough, legally, then we'll all agree
2 that there was an appearance of conflict, hopefully
3 something like that doesn't happen again between now and
1 the conclusion of this electoral cycle, but that is what I
5 need you to start with appearance verses actual and
6 anything else we need to cover that you already didn't.
7 ATTORNEY DILLON: Your Honor, if I may. My associate
8 has a power point, and we'd like to plug into the screen
9 if that is possible to the Court.
10 THE COURT: It is, Ms. Clapp is a part of this zoom
1 session, and you're able to share your screen. Is what
12 you're going to share something you shared with Ms. Cross
13 _or is this brand new?
1 ATTORNEY DILLON: We have not shared this with Ms.
15 cross.
16 THE COURT: It's not evidence?
bY ATTORNEY DILLON: It's not evidence, but we do have
18 some exhibits, Your Honor, we do have some evidence hers
1 today.
20 THE COURT: Okay, if there is going to be evidence,
2 let's just make sure Ms. Cross gets a chance to see it
2 before we blast it on the screen.
23 ATTORNEY DILLON: Absolutely. oh, mo. It won't be
2 blasted on the screen. It won't be published before —
2s THE COURT: Okay.
HADASSAH J. DAVID, OFFICIAL COURT REPORTER m
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1 ATTORNEY DILLON: It's also in my brief,
2 THE COURT: Lampl.
3 ATTORNEY DILLON: Okay. The DA cites it for the
4 proposition that, "The standard of neutrality for
5 prosecutors is not necessarily astringent as those
5 applicable to judicial or quasi — judicial offices,” and
7 she is correct, direct quote from Young.
8 It is not astringent, and the Court goes on to say
9 that the different in treatment is relevant whether a
10 conflict is found, however, mot to it's gravity once
un identified. We may require a stronger showing for a
12 prosecutor that a judge in order to conclude that a
13 conflict of interest exists, but once we have drawn that
1 conclusion we have deemed the prosecutor subject to
15 influences that undermine confidence that a prosecution
16 can be conducted in a disinterested fashion.
17 If this is the case we can not have confidence that a
18 proceeding in which the officer plays the critical role of
19 preparing and presenting the case for the defendant's
20 guilt or hear the defendant's recommendation for a charge.
2 And so here is the Supreme Court saying that if the
22 confidence is undermined, if the Court is saying, what
23 were you thinking, then the decision is already made,
2 because if we have a what were you thinking factor that
25 even if they recomnend discharge, and even if they died,
HADASSAH J. DAVID, OFFICIAL COURT REPORTER ”
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5 —
4 The bigger issue here is not whether or not they can |
5 indict him for submitting a false document, they determine
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1 career as opposed to revelations about someones connection
2 to a series of events that are particularly controversial
3 in our society right now might prove problematic for that
4 political candidate. I can't help that part. Those were
5 choices that were made. That might elevate that candidate
6 in the eyes of some. They might not elevate that
7 candidate in the eyes of many.
8 ATTORNEY DILLON: It may, Your Honor, and with regard
9 to those facts, Senator Jones was willing to come in and
10 meet with the prosecutor and sit down and say these are
un the facts of the case, under oath and maybe not under
12 oath, but then they received this carpet bombing of target
13 letters for everyone who signed the document, it is
u suddenly 16 witnesses had the door slammed in their face
15 because they were told that they less friends of the
16 investigation or targets.
17 Can we go to the next slide? Mr. Jones received his
18 target letter on July 6th as the DA indicated. Contrary
19 to their motion where they indicated he was a potential
20 target, he was told he was What? Next slide. "You are
21 advised that you are "A target” of the Grand Jury.” This
22 was on July 6th.
23 Next slide, please. On July the 12th, six days
2 after, I received this target letter, and I will say that
25 we consider this to be highly confidential, and the only
HADASSAH J. DAVID, OFFICIAL COURT REPORTER a
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1 two people in the world that knew about the target letter | |
2 were me and the district Attorney's office. I get this I
3 unsolicited email from a reporter with -- :
4 ATTORNEY GREEN-CROSS: I'm sorry -—-
5 THE COURT: Stop.
6 ATTORNEY GREEN-CROSS: I'm sorry. This isn't a
7 document that I've seen before, so before we publish it,
8 Mr. Dillon can you -- !
s THE COURT: Can you take that down, Ms. Clapp back to
10 the preceding page? And so, Mr. Dillon, you had assured
u no that — |
12 ATTORNEY DILLON: Yes, I did, Your Honor, and in my |
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1 This occurs about three weeks before the decision is made | |
2 to make ny client target in this case.
3 The District Attorney, according to publicly
‘ available records, which I have marked as Exhibit 4. This
s particular document, Your Honor is from the public
6 campaign Finance website here in Georgia, so this is
7 publicly available data. It shows during the day of and
8 during the day after this fundraiser $32,000 made to the
5 office of Mr. Bailey. We subait is a direct result of
10 this fundraiser. I'm told that the custom is, often
n people show up with a chock or they give their regrots and| |
12 sent a check the next day. During this particular 1
13 month,Mr. Bailey raised over $270,000 dollars. |
1 THE COURT: So this was a particularly small |
15 fundraiser for him?
16 ATTORNEY DILLON: This might have been a particularly | |
pe) big one. This might have been the one that caused the |
1 avalanche of checks to come in. |
1 THE COURT: Could be for ail those people who are
20 checking the ethics website to see what the cash flow |
2 Looking like for the first couple of weeks were, so I'll
2 put my money behind it. |
2» ATTORNEY DILLON: This is the sort of headline
2 fundraiser that gets people to say, oh, we have a big
25 wheel. We have somebody who is on the nightly news, as
HADASSAH J. DAVID, OFFICIAL COURT REPORTER ©
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1 this Court knows, who is pulling for Charlie Bailey.
2 THE COURT: Okay.
3 ATTORNEY DILLON: One candidate in the Lieutenant
4 Governor's office or the lieutenant Governor's race gets a
5 headliner, the other one, three weeks later gets a target
6 letter -- quistly get's a target letter. Now, there were
7 numerous news stories speculating about the existence of
8 target letters on or about the time of the Yahoo news
9 article, and there was a lot of buzz about that.
10 In fact, there was even an AJC story where DA Wilis
n was quoted as saying that numerous attorneys had received
12 target letters on their behalf. It didn't name Senator
13 Jones, fortunately. In fact, it wasn't publicly known
1 that Senator Jones received a target letter until the DA
15 filed their brief two days ago.
16 They were the first people to acknowledge he was a
17 target for this Grand Jury. We had never acknowledged
0) that. It was a mere speculation in the press, but it's
13 that sort of thing that gives the DA the the ability to
20 benefit their friends and harm somebody who is under
2 investigation, and that is really what we're talking
2 about.
23 The cases that the DA's point to in their motion from
2 1916 and 1936 are talking about transactions where the
25 financial transactions were $150, and was that materially,
HADASSAH J. DAVID, OFFICIAL COURT REPORTER “
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1 and while those are interesting cases, but once that $150
2 was material in the depression, we were talking about
3 $30,000 and we're talking about swaying an election, a
4 statewide election in Georgia, and that's a significant
5 thing.
6 This is not something that is being done by accident.
7 This is being done by design. This fundraiser was pointed
8 at benefiting Senator Jones ==
9 THE COURT: Isn't that the purpose of the fundraiser.
10 I agree -- the point of -- the question is does the
u District Attorney decision to support someone with whom
12 she is politically aligned, it surprises no one that they
13 are politically aligned. Does that rise to the level of
u creating —- an appearance of —- , and I've opined on that
15 a little bit an actual conflict, and I understand because
16 you can't climb into someone's mind.
7 You have to do a little of this through the
18 shadowboxing of, okay -- there is a fundraiser and all of
19 this money came in, and then there was a target letter.
20 Do you have more of a connection of one who proceeded the
21 other?
22 ATTORNEY DILLON: As far as a direct connection?
23 THE COURT: Any connection.
2 ATTORNEY DILLON: What is out there in the press,
25 what is out there in the ether. A part of Semator Jones’
HADASSAH J. DAVID, OFFICIAL COURT REPORTER pa
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1 concern is that this report is going to come out in
2 October. I'm glad to hear thers's no October surprise,
3 but there's been this whole series of drips, this whole
1 series of leaks out of the Fulton County DA's office that
5 have tilted benefit towards Mr. Bailey. It pointed to my
6 client as being a presumptive violator of the law, and
7 it's only because the DA has the authority to do that.
8 So if this Court were to determine that she has a
9 conflict, and this appearance is sufficient, and we go to
10 the Attorney General's office to appoint a new prosecutor.
1 with regard to Senator Jones who could sit down with him
12 and say, Well, Senator Jones, we're interested in what
13 happened in December 2020, would you like to talk to us,
1 and just like we did on day one, with the DA's office?
15 Certainly, we would be glad to. Do we have a target
16 letter from your office? No, you do not, Senator Jones,
17 because we have useful information that would age your
18 investigation, because this is an investigation when it
19 was impaneled that was supposed to gather evidence to see
20 whether or not there was an effort to undermine democracy
2 in this country, and when Senator Jones said, I have a
22 subpoena here, I'm going to talk to these people we said,
23 fine. We prepared our rates, but then we've got this
2 target letter and then everything changed, just like it
25 did for these 11 clients.
HADASSAH J. DAVID, OFFICIAL COURT REPORTER ”
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1 ATTORNEY DILLON: This was pulled off of the
2 internet.
3 ATTORNEY GREEN-CROSS: Did you pull it from off of
4 the internet?
5 ATTORNEY DILLON: Yes, I did.
s ATTORNEY GREEN-CROSS: Okay. Was it from the PAC
7 website?
8 ATTORNEY DILLON: You have to have access to the PAC
EE website to get it.
10 ATTORNEY GREEN-CROSS: And I'm wondering how you got
1 it.
12 ATTORNEY DILLON: It's out there in the ethers.
13 THE COURT: He got it from Yahoo.
14 ATTORNEY DILLON: I got it from Yahoo.
15 ATTORNEY GREEN-CROSS: I want to kind of thank you
16 for your candor.
17 ATTORNEY DILLON: Would you like to present it to
18 your client? She would have attended this training, and
19 see if it's complete?
20 ATTORNEY GREEN-CROSS: I would like to preserve
21 publication of the document until I can ascertain whether
22 it is true, accurate, and complete, because I understand
23 that it has been sourced to the internet, and that is not
2 something that I can accept, this authentication.
25 THE COURT: Okay, so it's admitted. I'll take it,
HADASSAH J. DAVID, OFFICIAL COURT REPORTER 70
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1 preferable outcome?
2 ATTORNEY DILLON: Well, as the Court is aware, there
3 are not numerous special Grand Juries of this magnitude to
4 point to for precedent, so what we suggest in our brief is
5 that the statutory provision that requires, once there's
6 a conflict made apparent, that it be referred to Attorney
7 General Carr's office and he find someone to conduct that
8 portion of that here independent of this special Grand
° Jury, and it can be as simple as finding a District
10 Attorney that doesn't have to find a good solid democratic
11 District Attorney somewhere who doesn't have a conflict
12 and give him the authority to pursue Senator Jones' issue
13 in this, and we would be glad to sit down with him.
14 We would be glad to sit down with you. We would be
15 glad to approach this with the same willingness to say
16 let's get to the bottom of this issue and whether or not
17 there was a conspiracy to undermine democracy in this
18 country because that is an important issue, and let's put
19 the media circus behind us. So let's answer the questions
20 and forget it affecting this election for Lieutenant
21 Governor, because there's no way she can keep a hand in
22 it.
23 THE COURT: She being the District Attorney?
24 ATTORNEY DILLON: She being the District Attorney.
25 Forgive me, Your Honor, and not affect the outcome of this
HADASSAH J. DAVID, OFFICIAL COURT REPORTER 2
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2] clacton for entenant cover. |
2 THE COURT: So Lf Attorney General Carr selected
3 fictional District Attorney X who had also given $2,000 to|
4 Charlie Bailey's campaign for Lieutenant Governor ——
s ATTORNEY DILLON: It would not be a problem at all.
5 It's an ordinary contribution, and it's exactly what
? counsel points to. Now, if they had hosted a fundraiser
8 during the tine period that they were investigating
5 Senator Jones, I might have to go to that judge and talk
10 about that fundraiser.
un THE COURT: What if that District Attorney had
12 already hosted — the District Attornsy is not involved in | |
3 that investigation. She hosted a fundraiser two weeks |
14 ago, $50 grand or even more money than DA Willis, but it's | |
1s dons. It's over and dons with, and I'm not going to do
16 anymore fundraisers from here on out, because now I've
17 been tasked with seeing what connection, if any, Senator |
18 Jones had to uhat was going on in November and December.
19 ATTORNEY DILLON: If every District Attomey in the
0 whole state had hosted a fundraiser for Mr. Bailey then
21 that issue might be appasent, but I suspect, giving the
2 List of good democratic District Attorneys in this state
2 that we can find somebody who doesn't have a conflict and
24 hasn't hosted a fundraiser for either one, because
25 certainly, if somebody that hosted a fundraiser for
HADASSAH J. DAVID, OFFICIAL COURT REEORTER ns |
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1 Senator Jones, the Attorney General shouldn't nominate
2 that person either. Find somebody who doesn't have a dog
3 in the hunt. Fani Willis has a dog in this hunt.
4 THE COURT: Got it. Thank you, sir.
5 ATTORNEY DILLON: Thank you, Your Honor. Oh, can we
6 offer into evidence Exhibits now.
7 ATTORNEY GREEN-CROSS: Actually, I was going to ask
8 to leave it up.
9 THE COURT: Leave it up? Okay, don't take it down?
10 Too late. Thank you, Ms. Clapp.
nu ATTORNEY DILLON: Can we offer into evidence 1-52
2 THE COURT: If there's no objection, 1-5. Was 5 the
13 one where the province was the internet?
1 ATTORNEY GREEN-CROSS: Yes. I was going to object to
15 the authenticity. I believe the foundation has been shown
16 for Exhibit NO. 5, we entered it into evidence so I didn't
n object to the Court reviewing it, but I do object to it
18 being tendered and admitted.
13 THE COURT: hy don't we do this? I will take 1-5,
20 and then I will give Mr. Dillon to maybe shore up his
2 sourcing of it, and if, in fact, it is pretty clear that
22 Snith was the name of —- Mr. Smith's presentation then
23 I'11 add to § the other 4. I'll hold on to it, but it
2 won't become part of the record until either Ms. Cross you
25 agree to talk to Mr. Dillon a little bit more and we see
HADASSAH J. DAVID, OFFICIAL COURT REPORTER -”
1 the source, or we're substituting to you -- someone can ’
2 get it off the PACK site. i
3 ATTORNEY GREEN-CROSS: I do want to raise objections :
4 to some of the others, but if they're being tendered now i
5 into evidence, Exihibit 1, the letter, I don't have any
6 objection to that.
7 THE COURT: Okay, 1 is admitted.
8 ATTORNEY GREEN-CROSS: Exhibit No. 2 is the e-mail
3 that I do have an objection to that being tendered and
10 accepted into evidence without any providence of it. I do
1 also object to the relevance of it. There's nothing in IP
12 this e-mail that sources any information to the District i
13 Attorney's office insofar as this being offered to show |
14 that the leaks are coming from this side of the table. I i
15 object to the relevance of that, and I don't think it !
16 shows that, and I object to the admission of it into |
17 evidence. . |
18 THE COURT: Okay.
19 ATTORNEY GREEN-CROSS:. No. 3 is the fundraiser flyer
20 that is up on the screen now, and we don’t have any '
21 objection to that being tendered and admitted into i
2 evidence. Exhibit No. 4. Again, T have an objection to | |
23 the relevance of this. I don't think it shows what, at
2 least what's been argued. It's been identified and
25 offered for the purpose of establishing how much money was
HADASSAH J. DAVID, OFFICIAL COURT REPORTER 9
1
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1 raised at the fundraiser, but what the actual document is
2 or appears to be, based on Mr. Dillon's representation,
3 and I don't have any reason to doubt it.
4 This is publicly available about how much money was
5 donated to mr. Bailey campaign during a 2-day period in
6 this document to the fundraiser, and while w I don't
7 think that is going, and because of that I don't think
8 that we have an objection to the ruling.
9 THE COURT: Okay, and then 5 is being conditionally
10 adnitted, provisionally admitted. I'm assuming you can
u clear up the source.
12 ATTORNEY GREEN-CROSS: Yes, sir.
13 THE COURT: ALL right. Anything you want to add, Mr.
1 Dillon?
15 ATTORNEY DILLON: No, Your Honor.
16 THE COURT: ALL right. I will adnit Exhibits 1 and
7 3, and then 5 will be provisionally admitted. We'll see
18 if the loose ends can be tied up there. Last question,
19 Mr. Dillon, and I'll let you sit down. Beyond the Young
20 case, is there a case or are there cases you want me to
2 look at that stand for the proposition that the appearance
22 of a conflict could be sufficient for a Judge to take any
2 of the forms of remedial action that you are seeking?
2 ATTORNEY DILLON: Your Honor, I rely on the Davenport
25 case, and that is a Georgia case.
HADASSAH J. DAVID, OFFICIAL COURT REORTER "
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1 THE COURT: I don't see it in here. You're fre to |
2 rely on it. It didn't manage to make it's way into your
3 motion.
4 ATTORNEY GREGN-CROSS: It was in mine. It's on page
s .
5 THE COURT: You guys share very well when it comes to
7 cases.
. ATTORNEY GREEN-CROSS: The Cite is 170 —= I'm’ sorry,
5 it's 157 Georgia Appeals 704, if that's the case you're
10 referring to. -
n THE COURT: Okay. Do you agree, Ms. Cross, that that
12 discusses the Davenport actual vs. apparent conflicts. !
13 ATTORNEY GREEN-CROSS: I didn't cite it for that i
14 proposition, and that's not my recollection of discussion
15 in the cass.
1 THE COURT: Okay. I'LL look at it anyway.
iY ATTORNEY GREEN-CROSS: Yes, but don't —— yes.
1 ATTORNEY DILLON: Your Honor, I never did get clarity
1 on the basis for the objection to Exhibit 2, other than
2 she objected to it.
2 THE COURT: Relevance was one, and I think it was
2 foundation, although, the recipient, Nr. Dillon, I think
2 he could authenticate it as receiving it, but I'm not sure
2 the relevance you suppose that Wr. Isokoff(sp.) theorized
2 what he did because the District Attomey's office let him
HADASSA J. DAVID, OFFICIAL COURT REPORTER 1
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1 know about it, as opposed to the witness from the Grand
2 Jury ox the grand juror.
3 I don't know who's in the circle of discussing who is
4 going to be a target or not, but you've made your point.
5 I'm just not going to make it part of the record.
6 ATTORNEY DILLON: Okay, and with regard to Exhibit 4,
7 the financial fundraising report. We offer that as to Mr.
8 Bailey's take over the two days, the day of the fundraiser
9 and the day after, and we submit that it is relevant.
10 THE COURT: Okay. I thought it showed his take for
1 the whole month.
12 ATTORNEY DILLON: No, no, no, mo. It's just a 2-day
13 period.
1 THE COURT: It is before and after the 14th?
1s ATTORNEY DILLON: It is the day of the 14th and the
16 day after.
17 THE COURT: And it is publicly available?
18 ATTORNEY DILLON: Yes, it is, Your Honor.
19 THE COURT: ALL right. I'll admit it.
20 ATTORNEY DILLON: That was Exhibit 4.
21 THE COURT: Yes.
22 ATTORNEY DILLON: May I offer a copy to the Court;
23 I'm not sure I did that, Your Honor.
20 THE COURT: What you want to make sure is that the
25 court reporter, ultimately, has them. I've got number 2
HADASSAH J. DAVID, OFFICIAL COURT REPORTER 0
\
. JU ——
, 142 OWE: ts. Cross, yous closing thoughts about
o| wsmerssicacion,
9° ATTORNEY GREEN-CROSS: Very brief ones. Your Honor,
10 we're taking a look now at what has been admitted as Mr. |
|
1 actual Lieutenant Governor nominee for his party, so I
2 want to make that as clear as it can be.
3 THE COURT: When was the runoff election?
4 ATTORNEY GREEN-CROSS: Sometime after June.
5 THE COURT: Good.
6 ATTORNEY GREEN-CROSS: Someone with easier access to
7 google might be able to -- the last week of June.
8 THE COURT: Late June?
9 ATTORNEY GREEN-CROSS: Late June.
10 THE COURT: ALL right. Got it.
1 ATTORNEY GREEN-CROSS: Mr. Smith is going to be so
12 Pleased, because he gets another mention. I shared with
13 Mr. Dillon an affidavit from Mr. Smith, who is actually
14 general counsel of the prosecuting of Georgia. May I
15 approach, Your Honor?
16 THE COURT: Yes.
IY ATTORNEY GREEN-CROSS: I've got an original for the
18 court reporter, but I'll hold onto that until it's been
19 tendered and amended. This is an affidavit, thank you,
20 that I shred with Mr. Dillon not long before the hearing
21 identifying that Mr. Smith is someone who deals with
22 conflict. He routinely advises District Attorney's as far
23 2s general and other entities to the inquiry about the
24 legal requirements and that's the legal conflict for
25 individuals, prosecuting attorneys.
HADASSAH J. DAVID, OFFICIAL COURT REPORTER 0
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1 provided the Court, he lays out exactly the rules that DA
2 Willis' office has violated.
3 THE COURT: Okay. Sort out Exhibit 5 soon, so I can
4 put that alarm on it. I'm going to admit DA 1 or State's
5 1, but I'd love to see 5. It seems like it ought to come
6 in. I understand the State's concern.
7 ATTORNEY GREEN-CROSS: I think we can work that out.
8 There comes a time when the Court considers Senator Jones’
9 offer of Exhibit No. 5, Mr. Smith's presentation. I
10 believe at least the excerpt that Mr. Dillon read this
u afternoon was a concern or admonishment, or flagging the
12 extra judicial statements of the District Attorney or
13 prosecuting entity.
u You've heard no evidence this afternoon or to my
15 knowledge in the record anywhere that there has been any
16 extra judicial statement from the District Attorney's
bY office about Mr. Jones officer that has played a part in
18 this.
13 Insofar as the objection this afternoon came to the
20 identification, apparently, for the first time officially,
2 that Senator Jones has received a target letter, of course
22 that was in direct response in the motion to disqualify
23 that was file by Senator Jones on Friday. They raised in
2 that motion equal protection and due process claims. They
25 reference constitutional protections of the Federal and
HADASSAH J. DAVID, OFFICIAL COURT REPORTER a
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i
1 make sure a copy gets to our court reporter, but I'd like
2 a copy of 5 as well.
3 ATTORNEY GREEN-CROSS: I'm handing up the original of
4 the affidavit of Mr. Smith.
5 THE COURT: Thanks. Mr. Dillon?
6 ATTORNEY DILLON: Very briefly, Judge. Regarding to
7 the last point raised by the State.
8 THE COURT: Which was?
9 ATTORNEY DILLON: That it is perfectly okay to out
10 the target letter status of Senator Jones in their
un pleading.
12 THE COURT: I didn't hear that it was perfectly
13 okay. It was an explanation for -- the hand was forced,
14 and because an argument was made or treated differently.
15 I didn't hear that it was perfectly okay. I heard that it
16 was a justification. You don't think it's justified
17 because?
18 ATTORNEY DILLON: I think they could have made that
19 argunent under (unintelligible) and not further the
20 appearance that they're favoring Mr. Bailey in trying to
21 do what? Hold my client up to public ridicule and
22 increase his shame, and do the things that Mr. Smith's
23 presentation says they should never do.
24 THE COURT: Ms. Pearson, was there anything you
25 wanted to add. Your motion with Ms. Deborrough, the
HADASSAH J. DAVID, OFFICTAL COURT REPORTER 6
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i
i
1 talking about political things, we'ze talking about
2 political motivation by one party against another party,
3 and to actions taken in one uniform direction against
4 republican candidates, prominent republican actors —-
5 THE COURT: Was there a third group of alternate
6 democrat electors in case the democrat electors == I'm not
7 aware that another group that the special purpose Grand
8 Jury should be investigating in connection with Republican
° efforts to create republican alternate electors and to
10 challenge the outcome that, at that time, and continues to
un show that a democrat won. I was going to press Ms. Cross,
12 but she didn't go thers about partisan, because partisan
13 has lots of meanings.
14 I don't think that partisan, the case that she cited
15 was democrat and republican, it was I'm partisan because
16 I'm trying to get this guy prosecuted. I have a stake in
17 the outcome of this prosecution. That is not where her
1 argument went today, but everything about this is
19 inherently political, because two political parties :
20 collided, someone appears who have won, and folks who
2 appear to have lost didn't Like that outcome and said
22 appearances can be deceiving and took some steps, and the
2 question is where those steps legal, and that's the
2a purpose of this special purpose Grand Jury is
25 investigating, so it seems to me utterly unremarkable that
HADASSAH J. DAVID, OFFICIAL COURT REPORTER J
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1
1 your clients are all republicans. fat would be ,
2 remarkable is if they weren't. What's the politicization !
3 because T don't want to miss it if there's a reason tobe | |
a concerned, but you'ze not asking, I'd hope for, we have to
s have a Republican District Attorney investigate this |
5 because that's the only way it will be fair.
7 ATTORNEY PEARSON: No, not at all, Your Honor. I |
8 think the process, vell, I know Mr. Dillon's motion is
| that the Avtomey General would be atioved to designate | |
10 the replacement, and so we think that should be done, |
u because I think the appearance of impropriety with Senator|
12 Jones taints the entirety as office of the entire
1 investigation, not just with regard to him as the remedy |
u for what I'm trying to say, but you are correct that our | |
15 focus was quashal, and that we are joining in that motion | |
16 as an add on. i
7 I would also say, Your Honor, that just on behalf of
10 ny clients, you asked if there is another slate that they
10 should be investigating, and I would argue under the
20 authorities that I put in our motion to the extent we were
2 contingent electors, and so were the democrats, because i
2 there was a pending judicial challenge that made it joint.| |
2 And so, yes. The answer to your question is that
2 both electors were contingent about time contingent on the
25 Judicial outcome which never came.
HADASSAH J. DAVID, OFFICIAL COURT REPORTER wo | |
1 THE COURT: Okay. I appreciate that perspective, but
2 you did say you are seeking -- I'm paraphrasing you, more
3 relief or greater relief than Mr. Dillon was seeking, but
4 then I thought you ended it by saying ve want what Mr.
5 Dillon recommended, which is push for his client, Senator
6 Jones situation to the Attorney General, and let the
7 Attorney General decide should I, the Attorney General,
8 find another District Attorney in her office to see if it
9 bares having a conversation with Senator Jones, or
10 investigating, or sending a letter, whatever they choose
1 to do. What's the difference between that and what you
12 think I ought to do in tems of disqualification and your
13 clients?
1 ATTORNEY PEARSON: Your Honor, I think the
15 disqualification, if there is one, it is disqualification
16 to the entire investigation, and the disease cannot be
17 cabin to Senator Jones alone ~-
18 THE COURT: Okay.
19 ATTORNEY PEARSON: -- because it's still the special
20 Grand Jury being advised by this District Attorney, and
21 the report would still be advised by this District
22 Attorney, and so we don't believe that's a sufficient
23 cure, and that if there's a disqualification, it should be
2 fron the entire investigation and not just from Senator
25 Jones.
HADASSAH J. DAVID, OFFICIAL COURT REPORTER 0
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1 separate entity to do that, that's not supervised by this
2 District Attorney?
3 ATTORNEY DILLON: That's correct, Your Homor.
4 THE COURT: Okay, thank you. All right. I think
5 we've covered everything, but let me find out from Ms.
6 Cross, Mr. Wade, Mr. Wakeford. Anything else from the
7 District Attorney's office?
8 ADA WADE: Nothing, Judge. Thank you.
9 THE COURT: Okay. Mr. Dillon or Ms. Clapp, anything
10 further from Senator Jone's legal team?
un ATTORNEY DILLON: No, Your Honor.
12 THE COURT: Ms. Pearson, ks. Deborrough, anything
13 else from your clients?
1 ATTORNEY PEARSON: No, Your Homor. Thank You.
15 THE COURT: ALL right. So we're clear, some things
16 I'11 need to memorialize in writing. I am not quashing
7 the subpoenas. I'm repeating myself, but I will be
18 issuing an order, a written order on the question of
19 disqualification, and it will address, not just Mr.
20 Dillon's client, bur Ms. Pearson and Ms. Deboroughs’
2a clients as well.
22 I'11 probably put in there a little bit about the
23 tining of the issuance of the report, but I want to make
2 it clear now in front of everyone what I've heard from the
25 District Attorney's office as well, there is no plan for a
HADASSAH J. DAVID, OFFICIAL COURT REPORTER 0
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appeared [1] 34123 ask [17] 13/13 14/3 15720 | 61/11 62/23 63/3 65/11
appearing [1] SL 15/22 26/1 2615 26/23 27/6| 66/10 68/16 68/24 69/17
appears ] G72 78n | 2922913385393 | 69122. 71 T1122 73/6
pm 69473761833 | 73/13 7416 74/0 74/11
appellate [1] 31/8 87/12 74/23 74124 75127513
applause [2] 421423 [sked [10] 9/01/11 | 78/11 75/12 75/19 76/1
applicable [1] 56/6 17/1719/4 19/3232 | 8/17 81/23 84/12 89/5
apples [1] 335 35021 4125 87/13 89/18 | 89/9 90/6 90/7 90/7 90/8
pply [3] 28/15 30/15 [king [10] 1/12 15/16 (90120 90122 91/5 91/13
iA 242526183419 3624 | OU179212
appoint [1] 66/10 4012546220 67721 89/4 |Attorney's [35] 2/14 3123
ppointed [1] 10/12 [1Spect [8] OVAL OVIL [7248/5 9/14 10/11 11/6
appreciate [8] $1111 | 16 11/9 18/6 35/6 36/8 38/12
Toi1 20/15 35/13 gs [Aspects [3] 151536120 | 39/10 40/12 4177 41/22
burton 91120 50121 57/25 5972 60/13
approach [8] 8/7 1625 [2SSert [8] 1372 15121 15/22 67/11 67/14 67125 68/20
Nai sus S902 Gamo |1621613 16114253 | 71/6 72/8 77/13 7925
os 2812 81/20 82/22 83/25 84/16
approaching [1] 15/5 [1sertion 2] 4/6 11/11 | 9277921259373
pbropriate [4] 1716 [assessment 2] 14/1 14/14 |attorneys [8] 1/19 50/20
TIIA0 TH12 assist [1] 39/25 64/11 69/17 75/22 82125
approval [1] 35 Assistant [1] 71/16 83/8 85/8
eoproves [1] 27/5 associate [2] 4/19.54/7 attributing [1] 43/19
are [116] assume [3] 20/5 25/6 39/18| August [1] 94/16
area 6] 14/11 15/1 26/22 [Assuming [3] 61378/10 [authenticate [1] 79723
38/7 53/20 55/17 83/16 authentication [1] 70/24
areas [7] 14/6 14/13 16/4 [ured [2] S5/659/10 authenticity [4] 62/18 69/8
16211706 1777 39021 [astringent [2] S6/556/8 | 76/15 83/21
aren [2] 16212715 [astrological [1] 37720 authorities [1] 89/20
aren't [1] 406 Atlanta [1] 1/12 authority [10] 26/14 33/19
arguably [2] 1910341 [Attack 1] 1615 34/5 3416 3477 4872 61123
argue [1] 8919 attempt [2] 22/1825/14 | 66/7 73/11 74/12
argued [1] 7724 attended [1] 7018 authorized [2] 822 30/3
argument [7] 32/9 4y/g [attention [8] 81320116 authorizes [1] 16/12
|AVA [2] 21/6 2910
ford senaseosys |2953133817422
Son 47/16 5211 available [5] 63/4 63/7
arise [1] 49/13 attorney [72] 1/17 4/4 4/8| 78/4 80/17 93/1
arm [2] 20118 21/1 6/178/19722 10/12 17/12 [avalanche [1] 6318
|
A 73/4 73/19 74/1874721 believe [18] 5/15 12/10
vod[[] S55 |5167524787790 | 13/14 1418 14/14 3414
avoided [1] 35/15 81/15 82/1285/3 86/14 |34/14 34/20 38/10 39/16
avoiding [1] 55/12 86/17 88/12 88/15 88/19 | 45/4 46/9 49/25 52/13 s
aware [4] 1277 20/19 7472| 893 89/6 89118921 | 60/19 76/15 84/10 90/22
3877 90/19 93/7 bend [1] 61/20
away [2] 57226125 become [4] 20/1537/7 (benefit [2] 64/20 66/5
ye |4sim2 7624 benefiting [1] 65/8
B becoming [1] 81/25 best [2] 8/15 94/12 i
back [5] 3/951/2559/9 [been [45] 2/6 5/21 6/15 7/5 better [3] 8/1011/726/10 |
6112083122 76 7114 7/21 11/25 12/17 [between [10] 9/11 13/23
bad [1] 67/6 16123 17/2 18/2 20/5 25/7 | 14/4 18/3 23/16 40/8 54/3
badgering [1] 14/9 2725 29/19 31/10 34/21 |90/11 91/8 93/12
Bailey [22) 9/21 9/23 43/20| 35/21 41/2 41/23 47/18 [beyond [6] 15/13 38/6
4312143024 4302549722 |SU1651/551/1051/16 | 51/18 51/19 51/19 78/19
53/8 62/1 62/5 62/24 63/9 | 59/16 63/16 63/17 66/3 |big [7] 3/4 3/12 3/18 8125
63/13 64/1 66/5 75/20 78/5| 67/23 69/15 70/23 71/25 | 17/14 63/17 63124
$1/1581/1681/1881/25 |72/175/1776/1577124 [bigger [1] 57/4
86/20 77/24 81/10 82/18 84/15 [bill [3] 1/18 6/14 6/20
Bailey's [3] 75/480/8 | 85/12 85/16 93124 bit [8] 22/1 36/4 41/16
81/12 before [38] 1/112/229/6 |57/11 65/15 76125 81/23
balanced [1] 46/21 12/3 12/1516/1422/11 |92/22 !
Bank [2] 161525022 | 27/527/729/1431/17 [blah [3] 30/6 30/6 30/6 |
bares [1] 90/9 34124 35/2 35/9 36/7 38/17 [blanket [1] 11/19
barrage [1] 16/1 39/6 42/4 421745119 [blast [1] 5422 |
barred [1] 28/19 45/20 48/14 49/1 54722 [blasted [1] 54/24
based [3] 20/16 55/16 78/2| 54/24 59/7 59/7 59/22 60/2 [blockbuster [1] 62/22
basic [2] 11/10 40/15 63/1 68/1 80/14 81/2 82/20 |blue [1] 60/11
basically [2] 35/1638/5 | 85/25 93/15 93/18 93/19 [board [1] 94/14
basis [3] 13/14 71/879/19 |began [2] 12/11 72/21 body [1] 28/20
be [188] begin [1] 12/5 bolts [1] 40/17
bearing [1] 48/24 beginning [1] 25/10 bombing [1] 58/12
because [73] 2/16 3/2 3/14 [behalf [11] 2/6 2/11 4/24 [books [1] 30/6
6/56/9 10/14 10/21 11/5 | 5/6 13/434/9 36/15 43/10 [both [3] 5/16 21/19 89/24
11/6 13/8 16/18 18/10 |47/11 64/12 89/17 bottle [1] 55/6
2111221327/172906 [behind [4] 63227125 [bottom [1] 74/16 i
29/1030/9302132115 |7217419 bouncing [1] 16/23 '
33/435/21 37/7 37/20 38/5|being [28] 7/87/16 9/10 bound [1] 27723
38/739/6 39/8 40/19 41/4 | 12/1420/420/2027/12 |brand [1] 54/13 i
S1/541/15 41/16 4323 |35/10 4172 41/3 41/16 49/6 [brief [12] 10/1 40/3 42/23
44/6 48/9 52/1 52/19 53/13| 65/6 65/7 66/6 67/23 74/23| 50/19 55/21 56/1 64/15
53/1955/556/24 58/15 |TARA TSN TA TIS |T2ST4I48L99L3 938 |
592161124 65/15 66/7 |711377121 78/983/15 [briefly [3] 26/4 85/18 86/6|
66/17 66/18 70/22 71/23 | 83/18 90/20 93/9 bright [1] 17/14
i
B 63/6 75/4 7815 19/22 10/13 12/6 12/8
(brine 7513/113/152/10 can [86] 3/21 623 10/12 | 14/2 14/8 16/11 3020
ssVILSIS26M0 [6 18/6 1517 18/7 15/8 |3022 30122 30/5 330 40/1.
bringing [4] 3/16 3/16 3/17) 1519 21/12 211421714 | 433 43/6 45119 45120
oo 2115223228231 | 47/17 50/23 518 5111
brings [1] 72/20 2302224/16 26/8 26/11 | 51/15 51/18 55/7 55/120
broad [2] 1713 45/5 26/1727/127/8 27/8 27/9 | 55/21 56/17 5619 57/1
broadeasted [1] S012 |27232905 3201132012 | S773 57/6 58/11 6327312
broke (2) GUIS 602s | 3214 32/15 3324335 | 73/4 7820 78/20 78125
brought [7] S13113 |3¥1342435203500 | 78/25 7909 79/15 88/6
i TI mie.
423201435710 420 |352436163617 3711 | 88/14 91/4 91/6
38/7 ns
Jag, ot 166 | 3801382439411 [cash [1] 6320
buckets [8] 1520163 |$712 488 48/56/16 categories 2] 1511823715
1321152312 2301 | SLT 57/4 5777 8/17 5918|category [2] 30/19 87/9
267212913 59/9 62/14 62/23 6725 [caught [1] 20/11
buckle [1] 40/14 6924 70/21 70/24 73/19 [cause [2] 49/14 49/20
butter [1] 93/12 7419741217523 76/5 [caused [2] 12/21 63/17
bulld [1] 11/13 76/11 77/1 78/10 78/18 CCR [2] 1219421
building [6] 343522 | V3 822843 84/7 85/19 leenter [1] 4377
3523 37/15 38/21 38/22 |85/21 88/22 91/16 certain [4] 8/18 11/12 28/9
buildings [1] 17/15 can't [8] 3/13 21/11 58/4 | 39/18
bur [1] 92120 65/16 69/7 69/1173/18 [certainly [10] 12/21 21/23
burden
5716 [3] 2113 5114 | candidate
8¥1L [8] 20/23 45/25| 2811366/15 2816
67/1349/5
68/10SUL0
75/25
business [1] 73/5 58/4 58/5 58/7 62/24 64/3 Certificate [1] 94/1
buzz [1] 64/9 875 (CERTIFIED [1] 1/23
candidates [1] 88/4 certify [2] 94/9 94/13
C candor [1] 70/16 cetera [1] 9/4
cI vi cannons [1] 30/10 chain [2] 19/6 19/16
cabin [1] 90/17 cannot [3] 19/326/21 [chair [1] 18/18
cable [1] 47/13 90/16 chairman [1] 20/24
call [8] 2/11 12/23 12/23 [capital [1] 46/25 challenge [4] 9/17 37/25
13/321/142972432/11 [care [1] 69/11 88/10 89/22
ous career [1] 58/1 chance [3] 42/10 49/11
called [4] 16/14 27/17 35/3 careful [1] 41/16 5421
4121 carefully [1] 59/20 (change [S] 12/14 25/2
lcame [5] 36/3 65/19 72/8 [carpet [1] 58/12 36/25 50/15 93/10
84/19 89/25 Carr [1] 752 changed [1] 66/24
cameras [8] 3/4 3/12 3/18 |Carr’s [2] 74/791/12 [channel [1] 48/20
19/2534/10 34/16 35/15 [carry [1] 43/8 chapter [2] 32/7 33/5
3825 carved [1] 91/12 characterization [1] 47/7
campaign [5] 51/16 517 [case [50] 1/62/8218 5/24 |charge [2] 12/14 56220
|
Cc clearer [1] 52/21 Tita
Charged 3]3UA03UAL [Cleary [3] 3103477 81/17 comment [1] 85/15
charges [4] 617 6718 1977 clears [1] 3711 comments [1] 71/17
pr client [31] 5/19 7/89/21 commonalities [1] 39/18
|eharging [11 3111 9/25 11/21 17/1 17/7 20/18 [commonality [1] 1322 | -
Chie 18] 9721 9723 43724 24222423 25225011 [communicated (1) 36/22
oe seat | 37/15 57715 59/15 60/12 communication [1] 18/6
a 61/6 61/19 62/6 63/2.66/6 |compel [2] 30/4 33124 :
cick [5] 21184505 |ST20STR2TUIS TAL fcompelled 2] 23013117 |
tl 3/00 0318 73/4 72/4 86/21 87/9 90/5 complaining [1] 38/16 |
ches 9220 [7] 114195 complete
cans ||lents
checkingBl[2]and41186320 $1410010
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horton 0) Sis oma0 |BSSITSTASSILG | 941 |
choose Li 50/10 87119 completed [1] 52/23 |
choosing [1] 47114 clients [23] 5/7 13/5 17/25 [compulsory [1] 22/11 |
chronologionl 1] 9/16 | 18/10 1911 19/192015 concern [14] 8/6 2410
eicle 11 80% 202022252420 26123 | 2519 3613 38120 3912 46124
reuneianccs [5] 20/11 |349 36/1 36/S3G/S36115| 48/23 53120 66/1 71/23
oso rss 2rias |3/14 66S BOILOS | 84/6 84/11 85/14
crcumvent [1] 2514 |V1392/13.92721 concerned [4] 24/12 24/13
69/14 89/4 [1] 15/23 |i
Tis [4] 7/6 35/6355 (Climb
circus clones [1][1] 65/16
39721 concerning
ite [7] 21/72520302 [closing [1] 81/7 concerns [13] 323512 | |
Et Smt 78 Torts [clothes [1] 38724 615616 11/3 14122 20/1
tea] sans [co [2] 4514513 23173619 36/17 41/17
tes ba Som 568 cocktail [2] 46/19 47/12 |42/14 93116 |
iting 1) 33710 code [3] 292532/733/3 [conclude [4] 622247 | |
ey bh 315 codefendant [1] 4677 | 56/12 73/10 |
civicim[1] 55/8 collaborate [1] 407 [concluded [1] 5120 :
soo collaboration [1] 40/11 [conclusion [2] 54/4 56/14
ims [1] 8424 colleagues [1] 15/12 |condemnation [1] 71/18
CLARE [11] 1g que [colide(n] 813 conditionally [1] 78/9
Co aos Sho 23/1 S312 [collided [1] 88/20 conduct [2] 10/8 74/7
ars ro oars| |eome [21] 7/25 16/21 171 [conducted [1] 56/16
Clapp’ [1] 873 20/13 252125723 27/4 _ |conducting [3] 13103072|
an [1 1300 |28203424 359372 4017 67118
Charity [3 vA SeA1 | 41/23 4412 48/12 48/14 conference [3] 39763919
ors 58/9 63/18 66/1 84/5 91/17| 39/12
crit (2) dio 7ontg [comes [7] 25/16 4816 confidence [4] 46/12 56715
Chagos] dao 3ys | 4817 6TB GRIT 848 | S6/L7 S622
th eno a1 [comfortable [3] 12725 2671|confidentil [1] $825
means anes
LAs sa sans | 2723|coming [8] 27/1 3713714 confirmation
|eonfirmed [1] [1]7210
72/15
aan 38/1538/1840720 411 [confirming [1] 41/5
|
C continues [1] 88/10 court [57] 1/11/23 1/24
[conflict
[54] 513 6/6 42716|Sontrary [2] 53458118 | 16/3 16/1520/12 24/18
421 42724 43/2 43/8 [contribution [1] 75/6 |26/13 26/15 27/20 28/19
44/15 44718 45/4 45/6 45/7 |controls [1] 55/17 2924 33/16 41/9 44123
45/18 46/546/19 47/9 (controversial [1] 58/2 |44/244513 45/5 47/7 47/10
4701S 2/4 5320 532 (conversation [7] 23/21 | 47/16 47/19 49/24 50124
5303535 542 55/14 | 2323 3TNT3122.3723 | 51/5 51/14 5117 51/17
55/14 55/18 56/10 56/13 | 9099/8 51/20 51/23 54/9 55/19
5721572265615 [conversations [1] 52/10 |S5/21 56/8 56121 56/22
61/19 61/19 61/22 61/22 |°Onverted [1] 1872 59/22 60/20 60124 64/1
65/15 66/9 73/7 38 [conveyer [1] 33/19 66/8 68/21 69/8 7412 76/17
731217303 74/6 74/11 [convince [1] 53/25 80122 80125 81/2 82/18
75123 78/22 82/22 82/24 [COOPerate [2] 10/14 10/16| 84/1 84/8 85/15 86/1 94/8
83/10 83/12 85/17 87/11 |COPies [1] S14 94/14 94123 94125
87148714 copy [10] 50/24 50/25 51/3|Court's [5]15/19 49/8
conflicts [3] 53/17 73120 | 5923 59125 67115 69125 | 5125 60122 83/7
79012 80122 86/1 86/2 courthouse [3] 36/2 38/25
conformity [1] 94713 |°Orrect[9] 72217122 39/1
conjecture [1] 4372 17123 48/4 49/17 567 68/4 |courtroom [1] 34/11
connect [1] 15/8 89/14 92/3 cover [3] 8/6 44/6 54/6
connection [17] 6/11 11/15|¢Orrespondence [1] 30/5 coverage [1] 35/19
T121 13/10 15/1 18/10 [could [33] 3/9 8/13 17/15 |covered [3] 16/22 21/24
2215 22/6 36/16 58/1 65/20|19/4199 19/13 19/15 (92/5
65022 65723 73/15 75107 |19/16 19/17 19/18 19/19 covering [1] 2/13
$721 88/8 23/126/1828/24 32010 |erazy [1] 45/11
consequence [1] 52/6 |33/6 4021 41/2 4616 52/9. |create [8] 10/6 35/6 35/8
consequences [1] 25/5 | 6219 63/19 66/11 78/22 | 85/6 57/20 57/21 8819
consider [1] 58/25 7923 83/22 86/18 91/12 | 91/25
considered [1] 68/12 91/17 91/22 93/10 93/17 |ereating [1] 65/14
considers [1] $4/8 93/17 creative [1] 91/21
conspiracy 1] 7417 (couldn't [2] 52/11 73/8 criminal [3] 13/1 13/16
(Constitution [1] 85/1 [counsel [12] 4114239 | 45/12
constitutional [2] 1970 | 23/16 31/5 42/18 68/19. oritieal [1] 56/18
34125 68/20 68/20 75/7 82/14 critique [1] 46/11
constructing [1] 30/11 |9139414 (CROSS [13] 1/17 4/3 4/11
consult [2] $5118 85/19 [country [2] 662174118 | 3177 54/12 54/15 5421
contain [1] 6/16 COUNTY [11] 1/11/24 | 76/24 79/11 81/3 81/7
contend [1] 10/6 9/14 10/10 12/9 31/4 66/4 | 88/11 92/6
contested [1] 20/19 68/12 73/13 94/594/25 (Cross's [3] 53/14 53/17
context [3] 11/12 13/17 [County's [1] 777 72/16
1810 couple [4] 2/57/22 47/8 [crowded [1] 3/13
contingent [3] 89/21 89/24| 63/21 cure [1] 90/23
89/24 course [5] 22/3 47/18 62/6 |cures [1] 48/23
continue [2] 8722319 |83/1184221 custom [1] 63/10
1
|
1
c [December [2] 66/13 75/18| 22/11 22/14 25/3 27/15
Tomocut] [decide [3] 18/13 16229077 | 27/20 31/25 38/14 38/18
CVR 1] 121 decides [1] 48/11 38/19 59/12 61/13 66/14
eyele [1] 5414 decision [8] 13/14 46/11 | 66125 68/12 70/3 70/5
| 4818513562357117 | 79/18 79/25 80/23 9012
D 63/1 65/11 9419
DA [14] 42/6 42/9 45/13 |decisions [2] 20/16 46/11 didn [5] 22/21 30/15 33/17
55/21 56/3 58/18 64/10 [deemed [1] 56/14 34122 4973
64/14 64/19 66/7 71/16 [default [1] 40/23 didu't [12] 2/17 54/6 61/11|
75/14 84/1 84/4 defendant [3] 45/11 45/13| 61/12 64/12 76/16 79/2 |
DA's [13] 2/73/24 325 7/7) 51/10 79/13 86/12 86/15 88/12
7/17 18/3 55/6 64/23 66/4 (defendant's [2] 56/19 88/21
66/14 67/9 68/18 71/16 | 56/20 died [1] 56125
daily [1] 67/17 defended [1] 46/7 difference [1] 90/11
(damage [1] 20/4 defense [3] 45/9 45/12 different [18] 2/22 11/1
data [1] 63/7 50125 16/3 17/5 18/19 2719 28/6
date [4] 40/21 55/5 93/1 |define [1] 83/24 28/8 28/17 28/17 28/18
93/16 definiteness [1] 15/6 30/19 30/23 32/8 33/12
dates [1] 38/14 democracy [2] 66/20 74/17| 33/22 53/15 56/9
Davenport [2] 78/24 79/12|democrat [4] 88/6 88/6 differentiation [2] 18/3
DAVID [4] 1/2194/8 | 88/11 88/15 33/12 |
9472194123 democratic [2] 74/10 |differently [4] 18/16 18/23] ,
day [19] 23/20 37/2 38/19| 75/22 30121 86/14 |
43/8 50/8 50/12 63/7 63/8 [democrats [1] 89/21 difficulty [1] 18/21 |
63/12 66/14 67/1678/5 |denied [1] 8517 DILLON [38] 1/18 4/15 |
80/880/980/1280/15 (depression [1] 652 5/10 20/1 20/18 23/11 i
80/16 94/10 94/16 description [1] 49/15 | 29/17 31/23 32/1 36/19 |
days [10] 10/1 10/18 38/19 design [1] 65/7 42/7 42/20 43/14 43/18 !
58/23 60/17 6024 62/7 |designate [2] 3/1089/9 | 47/11 49/11 49/19 50125
64/1572/4 80/8 designation 1] 12/13 | 51/4 52/21 53/12 59/8
deadline [2] 52/12 52/18 desk [1] 67/8 59/10 69/8 76/20 76125
dealing [1] 19/13 detail [1] 2472 78/14 78/19 79/22 82/13
deals [1] 82/21 determination [1] 13/24 | 82/20 84/10 85125 86/5
dealt [1] 19/1 determine [S] G/852/12 | 87/2 90/3 90/5 92/19 |
Deboroughs' [1] 92/20 |57/5 66/8 91/21 (Dillon's [4] 78/2 87/9 89/8| |
DEBORROUGH [14] determined [3] 11/24 92/20 |
1913/4143 16125 |51238314 direct [9] 7/20 42/22 47/16
21/2323/10 24120 36/10 |develop [3] 39/1339/23 | 56/7 63/9 65/22 67/21
36/1539/19 43155058 |41/7 84122 87/11
86/25 92/12 developed [1] 42/16 direction [1] 88/3
Deborroughs [3] 4/25 5/1 |development [1] 61/18 (directly [4] 16/4 31/1
37/10 device [1] 3/6 52116 72/8
Debrrorogh [1] 21/19 [dictated [1] 50/5 disadvantage [1] 23/25
deceiving [1] 88/22 did [24] 3/115/13 17/10 |disagree [5] 5/25 7/2 22/15|
ID |625728/69/109/19 9120|28/10 29/829/9 32124 dds
10723 LUA 107 | 44123 4ST 45/4 46/4 48/10
Gisagree.. [2] 23/77 53724 | 102219/82
disagreoment [1] 3718 |1710 1/182119 | 4823
disagreements [1] 23/16 |22/1123/5252126111 |don't [51] 3/22 6/10 625
discharge [1] 56725 26/12 26/13 29/7 29/8 30/8| 9/9 11/19 11/19 12/19
disclose [3] 25/3352 | 222320243477 34118 | 18120 19/1 20/4 27/19
ji | 3513 35124 36/7 38/12 42/9 | 28/15 35725 38/8 3916
disclosed [4] 57212472 | 43/14 43/47 447246120 | 40/1 41/21 48119 52/13
5205712124 46121 46/21 54/17 54/18 | 53/4 53/13 53/23 53/25
discreetly [2] 38/21 38/22 |SSB S514 55/15 6021 | 5515 55123 59/17 6213
discretion [6] 28/14 44/18| 6214 65/17 65206617 | 62/17 67/13 69/6 TUL
4424 44/25 45/5 47710 |OS/15 66/16 67/3 68/10" | 71/21 73/11 76/9 76/19
discretionary [1] 44/16 |S3TSRTISTIAL | 77S TINS T7120 77123
discuss [1] 14/5 T17 73/19 T3122. 73/24 | 78/3 78/6 78/7 79/1 79/17
discussed [2] 11/18 30/21 | 75/18 76/17 76/19°77/3 | 80/3 86/16 88/14 89/3
discusses [1] 79/12 TIO TIO TINIBLL |90/22 93/9 93121
discussing [1] 80/3 86/21 86/22 86/23 90/11 [DONALD [2] 1/16 419
discussion [6] 14/4 23/18 | S012 911491149211 donated [1] 78/5
25/1025/13 60/6 79/14 | 93219419 donations [4] 43/18 43/22
discussions [3] 11/10 23/8 [document [9] STIS SB/13 | 43123 43124
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information [3] 66/17 Go/o| 15/1 15/2 3013 31/22 42117| 52/3 52/13 54116 54/17
712 43/4 44/13 46/13 4712 47/4| 56/1 56/10 59/25 60/8
ingress [1] 36/6 4711847125 49/8 50/6 | 60/18 60/19 61/10 61/13
inherently [2] $723 83/19| 58/16 60/13 60/16 64721 | 61/14 62/13 62/14 62122
initial [1] 55/1 6/18 G6/18 67/18 73/14 | 64/18 66/7 69/7 69/9 69/13
initially [1] 67/1 75/13 89/13 90/16 90/24 | 70/12 70/19 70/25 73/5
inkling [1] 48/21 91/1491/15 9372 T3/12.73120 73/22 73/24
linnocent [1] 27/22 investigative [3] 8/16 15/4| 75/6 75/6 75/14 75/15
v I
1 [juneture [1] 7221 [justification [1] 86/16
ifs. [13]7Ton
7 4 Tor [June 6) 924 53/8 82/4 justified [1] 86/16
79/9 80/12 81/19 82118 |82/7 8218 8215 IK
S6/168724 90/10 931 [juries [3] 3043237438 |X
93/4 93/13 [jurisdiction [2] 12/11 eep Bl i TUL7421 |
lts[5] 8/1 2719 ping[1] 29/21 i
ty 1481S 822260), vor 1) 802 kind [7] 3113/15 48711 | |
2 ljurors [5] 1/19 7/25 41/10| 45/16 45/21 50/18 70/15 :
J 48/6 93/8 [kinds [1] 23/7
jammed [1] 35/5 ljury [93] 1/5 1/10 2/3 6/12 kmow [1] 15/5
ljob [3] 17/817/919/15 | 6/13 6/13 6/14 6/19 7/10 (knew [4] 59/1 62/6 62/6
[join [1] 518 7/14 813 8/14 8/17 8/22 9/7| 62/7
joining [2] 5/1189/15 9/15 10/3 12/4 12/16 13/11 [know [52] 2/163/16520 | |
joint [1] 89/22 13/1814/11 15/4 16/14 | 6/10 8/23 9/9 1021 11/19
|Jone's [1] 92/10 16/171919 1925203 | 16/23 17/3 19/1202 21/10
JONES [68] 1/182/72/8 | 21/1021/1722/8 24/8 2122221725025 27/1
4/17 5/23 6/9 6/22 7/8 7/19|24/15 2523 26/9 26/10 | 27/20 281228/3 28/10
9/4 9/6 9/10 10/3 10/9 27/16 28/23 28025 29/7 |28/23 29/1 30/10 318
10/13 14/16 15/13 20/6 |30/1302. 30/13 31/18 32124 34/22 34125 35/21
21323/1129203818 |312232/632/632/10 |35/25 381539/5 41122 464
DAs4s a2 aIp1 |321132/14321933/17 |48/19 48/23 51121 53/4
47125 49/7 49123 50/9 33/1833/1933/203322 | 59/17 61/8 61/10 62/5
S0/1153/9 55/2 57/7 58/9 |332334/83412034725 | 67/13 6/15 68/5 68/13
58/17 61/2 61/24 64/13 | 35/1038/1 40/4 41/19 43/4| 69/12 T1121 80/1 80/3 89/8
64/14 65/8 66/11 66/12 |47/3 47/21 47724 48/1 48/5| 93/21
66/16 66/21 67/25 68/11 |48/11 48/15 48/16 48/18 [knowing [1] 68/11
72/11 7313 75/9 75/18 76/1|48125 52/16 55/3 58/21 [knowledge [1] 84/15
SU/1181/118124832 |64/1767/1067/19 68/2 [known [2] 102 64/13
83/16 83/18 84/17 8421 | 68/5 72/1174/9 80/2 88/8 (knows [3] 61/17 62/8 64/1| |
84723 86/10 87/11 89/12 | 88/24 902091179120 (Kwanzaa [1] 81/15 |
90/6 90/9 90/17 90125 | 93/4 93/4 L
Jones’ [5] 2/10 48/20 65/25 Jury's [2] 8/5 60/15 TT
7412 84/8 lust [48] 3121 577 578 1309 [LoAMEL 1277
linge [15] 1/11 417 4116 [15710162 17/4 1723 {110 a 7 |
sir24182503 380 |1725 1810 18/11 2605 [Ie UT SE ST
Ans Sys Se2 sy |271273351 37ne [BATH ’
7822361691298 |38/14 39/5 39/10 d0/s ays TSamp 15] 12/6 1408
ljudge's [1] 51/17 BS AS2AGI6 4909 | ar 2226/7 5022
udicial [10] S112 53/15 | 52/4 S421 SS/10 50/18 | Sar2 3/5 31/24 320 33
S616 56/6 TI17 84712 | GUA S64 sed 6710 | SAG e4G 401 S62
84/16 89/22 89125 94/14 | OL 69/14 TUL TIS [ampl [8] 32/12 33/12
July [9] 1/12 2/4 53/9 53/9| 80/5 80/12 81/1 85/9 89/13|
|89N7 9024 [nds lA] S223
s 9290 asgusge i] 835128
isSH/18 Sez Send
SSA pore
L let [18]2/156/7 15/21 18/4 links [1] 19/15
larger
495581720
[2] |22/728/5392340023 list [6] 27/5 30/10 30/11
largest [1] 81/19 4172 42/5 44120 61/16 | 30/12 30112 7522
last [7] 22/1 227123719 | S24 T9789 T9025 ised [1] 51/16
44207818 82/7867 | 90/692/5 literally [1] 57/8
te [5] 55/3 55/4 76/10 [1e€' [9] 2/2.3/20 13/9 S4/21litle [11] 3/13 22/1 35/14
828820 59/15 74/16 74/18 74/19 | 41/16 57/11 59/13 65/15
later [9] 10/17 26/11 33/19|9113 65/17 76/25 81/23 92/22
41/10 53/11 60/17 60/25 |'etter [26] 524 9/495 [IN [8] 7/22 2572 28/4 311
627 6415 1018 10/19 24/749/13 | 37/14 41/22 42/2 43/11
law [16] 12/13 14/3 16/11 | 53/8 57/10 58/18 58/24 location [1] 40/21
271928773020 40/1 |59/1 61/2 64/6 64/6 64/14 logistics [1] 6/24
234205 4and as |65/19 66/16 66124 67/16 [long [6] 37/16 38/23 39/10
451174715 55/14 55717 |S814 T223 TIS 8421 | 40/1 69/13 82120
66/6 ono Ho. I. longer [2] 37/6 41/16
er[6] 11/9 17 etters 518/13]look [10] 6/1835/1655/19
oe1h 39111 ST | ons sa 6112 6113 ois ait 78121 79/16
lawyer-to-lawyer [1] 64/8 64/12 67/5 81/10 85/2 91/17
39/11 letting [1] 38/21 looking [6] 3/2222/20
lawyers [4] 2203518 [level 13] 13/25 46119 65/13| 22121 23/3 63/21 83/3
371437122, leveled [1] 12/14 looks [1] 43/19
layed [1] 5520 liability [2] 13/1 13/16 [loose [1] 78/18
lays [1] 84/1 [Lieutenant [12] 7/16 9/21 [lost [2] 59/21 88/21
lead [4] 14/6 19/15 19/16 |44/1 S04 64/3 64/4 73/1 lot [11] 2119 2120 16123
19017 74/20 75/1 75/4 81/12 82/1|21/4 24/2 31/3 4213 42/12
leak [6] 61/25 68/14 71/21 [life [3] 52/19 60/11 60/11 | 49/13 61/10 64/9
7122 T15 T light [5] 2259/311/25 [lots [1] 88/13
leaked [1] 62/1 41/8 93/9 love [3] 60/20 71/13 84/5
leaking [2] 67/12 67/12 [lighthouse [3] 17/14 17/16 [lower [2] S113 5113
leaks [3] 66/4 72/25 77/14 | 1824 lowercase [1] 46/24
learned [2] 67/1791/3 [lights [1] 46125 Lowndes [1] 9/14
least [S] 24/9 27/4 27/24like [36] 3/18 6/18 11/16 mM |
77124 84110 14211517161 1805 om |
leave [5] 8/935723 76/8 |23/823/8 23/19 43/19 45/9 [machine [1] 73/5
7619 85125 45/10 48/7 48/14 49713 (made [18] 141220/17
leaving [1] 48/10 52/18 53/14 54/3 54/8 55/2| 27/21 37/18 41/17 43123
legal [17] 8/2 18/1 28/18 | 55/10 62/9 63121 66/13 | 46/11 47/19 56723 57/17
45/3 4713 4719 47112 4715| O6/14 66124 68/21 70/17 | 81S G31 6318 74/6 80/4
47034877 8248324 | 7020 84/5 8514 85/9 85/9 | 86/14 86/18 89/22
83/585/12 85/16 88123 | 86/1 88121 magical [1] 12/20
92110 likelihood [1] 71/18 magically [1] 22/10
legally [1] 5411 limb [1] 7322 Magloclin [2] 91/4 91/4
loss (4] 12/23 42/3 sas [lines [1] 2413 magnitude [1] 7413
59/14 link [1] 19/5 mai14)200 5953778
|
M_ [suxmmasis 11/11 15/6 16/18 23/17
malls 3] 19/16 20/9 59715 |maYbe [L1] 17143715 | 24/15 32/4 58/3 58/5 58l6
main [2] 277212721 46/18 47/20 48/16 52/5 | 63/16 63/17 75/9 75121
maintain [1] 46/12 5255714572 58/11 | 82/7
major [1] 35/16 76120 mind [2] 22/25 65/16
make [24] 2/20 6/6 14/16 [MCBURNEY [1] UI1 mindful [1] 28/11 i
1437/12 37113 3724 |e [39] S21 6/78/1977 {mine [1] 79/4 |
0445235008521 |LW71241313 1315 minimum [2) 291242715|
54721 60/3 62/14 6372 702|15/14 1624 17/18 18/4 minor [1] 17/6
30/5 80/24 81/1 82/2 86/1 |22/1 25/4 26/1 29124 44720 [minute [2] 24113 61/3
92123 93/11 93/15 45/19 45/20 46/18 5321 [misconduct [1] 83/23 .
makes [4] 16/24 28/3 28/10] S325 5524 57122 5912 misled [1] 48/4 |
SS 59/11 60/10 61/16 62/14 |miss [1] 89/3
making [1] 7117 67121 68/25 73/18 74125 [misunderstood [1] 7/23
wanage [2] 414 7on | T8120 85128714 88125 92/5 mix [1] 40118
managed [1] 8/11 9300 mobility [2] 14/24 18/21
|mandatory [2] 44/16 44/17mean [16] 1/15 13/5 moment [1] 46/8 |
many [7] $/1620/25 21/1 | 17/19 18/9 20/8 27/18 30/8 money [7] 63/22 65/19 i
23525 36558 |4084024 44/17 45/9 |7/14 77/25 78/4 81/18
map [1] 2472 4612346023 49/4871 81/24
marched [1] 34/15 3718 month [1] 80/11 i
marching [1] 55/10 meaning [2] 31/1148/5 month,Mr [1] 63/13 2
mark [1] 68/21 meaningful [1] 93/12 |moot [4] 6/6 9/8 10/22 42/9 1
marked [1] 63/4 meanings [1] 88/13 more [28] 3/10 3/21 15/14 |
material [1] 65/2 means [1] 28/16 16/6 17/17 24/3 24/6 24/12
materially [1] 64/25 meant [1] 43/17 24/13 28/1 28/16 29/18 |
matter [10] 18/11 261 |edia [11) 223716 721 |43/7 | 36/8 36/19 37/7 38/17 39/4
UGA 47/2 47a agp |5173593523361 49/11 52/8 61/10
482185779123 034 |4672 6TRAGSL TANG | 65/20 73/8 75/14 76/25
matters [2] 31/21 83/0 |medial [1] 474 81/4 87/12 90/2
may [62] 6/5723803 Meet [2] 10165810 morning [1] 4/15 i
1055 11/7 12/77 1247 |members [1] 71/7 most [5] 36/4 38/23 48/12 |
1225 13/6 1322 14/6 |memorialize [1] 92/16 | 73/25 87/11 :
15/17 16/21 1771 17/6 18/9 [mention [1] 82/12 motion [40] 2/62/82/10 |
2/4 22/4 22/6 22/13 25/10|mentioned [3] 38/20 49/15 2/15 2/16 2/17 4/4 5/11
261428222823 29/16 | 67/11 64/18 5/15 5/18 5123 6/7 11/4
30/4 30/5 30/8 31/17 34/21 [mere [1] 11/18 13/21 18/16 27/18
36125 37/14 3724 39/8 merely [2] 21107219 36/10 36/22 41/17 43/11
39/9 39/13 39/21 40/2 met [2] 29/1 85/12 57/16 57/16 58/19 64/23
40/14 40/15 40722 40a [Method [1] 36/12 72/16 79/3 83/1 83/2 83/23
AUI3 4114 43/6 4704 |micromanage [1] 4121 | 84/22 84124 85/15 85117
49/15 51/5 53/20 54/7 55/3 [idle [1] 59/21 86/25 87/1 87/3 89/8 89/15
56115720 58/85022 [Midst [1] 42/17 89/20
9724 62/13 62/20 71/14 |Might [17] 6/18 8/14 8/15 [motions [3] 1/10 2152/13
my [66] 419 6/4 6/778 |731091725
| Sik aaa ao negative [3] 20/16 293
motivated 1] 471 sop |12119132 135 13/9 13/14 49723
motivation 3] 4818.45%9 | 15/3 16/25 1777 17/8 17/24 [neutrality [1] 56/4
0 1725192 19/11 19/19 [never [9] 18/22 27/25 29/1
avo| 20S 2422571026723 | 53/3 S72 6417 79/18
Tove 1 WIS IS241T0| 201 42/8 43117 | 86123 89725
1s 44/5 44/13 4712 49/4 49/15 [new [4] 54/13 66/10 91/13
moved [1] 42/6 515520165224 5417 | 9117
roving [5] 21923641 | 55113 55713 58/16 5611 [Newnan [1] 572
Fup 59/12 59/18 59/21 60/5 [news [7] 1125 38/16 47/13
mr [103] 62/6 62/21 63/2 63/22 66/5| 63/25 64/7 64/8 67/14
[Mr [2] 172 17/4 G9/LL69/19TABI next [13] 8/23 27/7 4021
or ade [2] RATA | sana 85/18 8621 8918 |d0r2d 4172 41/15 4858
MrDillon [1] 36/10 91/2 91/3 93/7 94/12 94/15| 48/15 58/17 58/20 58/23
Mr-Wade [1] 23/7 myself [3] 10/1959/13 | 63/12 83/22
[MIS [61] 1/19sIyeia
sasteut 119 425 5/1) Boy T Wei nightly [2] 47/4
lens6325
pmumsienatens \N [luo tisn ann 2313 241
2UNBUM DILL name [11] 6/23
202419/73811958 ||spe
26/1 30/9
201205 BOBN0 |1/1428m gegs 32/3
so 32113
as32/14
23124119 241202518 | 38/6 64/12 761228120 | 312 43/23 44121 44/22
SUTSGUASIRIUNG
3YIIIBI ING IS vanes named 3][2] 20012604
46117472 || 45/15 46/14 47114 5207
pps sarne con sors
ANGSVTS
SYSSUTSUTSHI2
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66/2perms
66/16pons
68/23
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26 SALI GL MIL | Niacin
34 11 473 76/16 sorta
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81/3 81/7 86124
SSILLOU 8625 8713 navigate
SSUIUL 2] 11/74/14 | 30/12Tas
83/13 83/20s8479
(nea 3] 5223 93/5
92/12 92/20
Ms. [9] 4/25 92/20
5/10 S/11 114{ necessarily
575 gor [4] 9/12 13/25 |vet
93/11 92/14 92/25
i Ss
SAP13SASIGO 3614 necessary [2] 41/14 7121 [nodding 1] 317
3710 neck [1] 55/6 nominate [1] 76/1
[Ms. Clapp [1] 5/10
Ms: Pearson [6] need [44] 2/17 3/3 3/18 69 nominated [1] 13/12
428 S111 | 6/10 6/22 6/25 8/6 8/19 9/4 [nominee 1] 8211
342136 3GM4STN0 | 9/6 11/2 12/1 1323 1415 [on 5] 121328932119
Ms. Pearson's [1] 3525 | 16/10 16/16 21/182322 | 4110 46/13
(Ms. Peterson's [1] 11/4 |23/1725/22 32/1335/15 |yon-immunized 1 12
[Ms.Deborroughs [1] 11/18 36/5 36/25 37/9 37/12 lnon-partisan [1] 46/13
much [11) 15/1723/19 | 37/14 38/1 39/5 40/9 44/6 Inon-partition [1] 46/10
27/6 35/13 35/23 44/10 | 44/14 49/5 53/25 54/5 Sdl6 non-special [1] 32/19
ASSUISTIASTEA | 57103 60/7 61/19 6120 [normal 13] 33/5 38724 5273
su 85/24 92/16 93/13 normally [1] 51/19
mud [1] 7/9 needs [5] 10/11 37/22 39/2
N occur [1] 41/5 47/6 502 5217 54720 54125
orale 1 2 S03 até 03 als
occurs /18 6972 69123 70/6
eeeyo 24 October [6] 8/14 825 9/16| 7025 713 71/11 72/6
noted 01] 019 S211 6612 6672 72012. 72019 7319 16/9 7717
noteworthy [1] 3g/11 [ofCharlie 0] 4324 | 7187809 79/11 19/16
nothing [13] 2011022/8 Off [9] 8/181021 57/11 | 80/6 80/10 83/19 8438619|
2220/11 27711 2715 | 60/23 TO/170/3 77/2 81/16| 86113 86/15 90/1 90/18 .
San 36/13 4309 32 77/11 |offer
(34/4 934[2]0055/22 55/23
O12[8] 22/19 2224 69/3 [old |
notice [1] 81/11 7616 76/11 80/7 80/22 8419 omit [1] 3122
Nova DI 160182572 [offered [3 G825 77/13 lance [9] 1512418123 37/1
November [3] 720492 |7725 51/23 86/10 S6113 65/1
7518 or o Tt bib one sam mns
warygars|325 328 4/4 4/8777 7117 |10/4 T3/11 14721 1422
2578 31/7 34116 39/1 40/16|7/24 8/4 9/9 9/14 10/11 | 15/8 15/8 16/6 16/16 22/3
Ao saan Sars agra | 11/6 11/9 18/3 18620023 | 241 2416 27121 2916
6024 6113 61/18 62 |2336 36/838/4 38/12 | 31/1032/14 3425 35/15
4/6 6772 71/12 7517 75116|39/10 40/12 41/7 41/13 | 38/5 38/10 39/14 39/22
TTA TIO STL0 |412242110 46/1 4612 46/4| 45/11 45/18 46/23 48110 | |
Tn 472248119 5225 5577 | 4822 49/17 49/18 51/17
number [4] 1163872 38/6 |S725 5902 63/9 64/4 6614 | S218 6UB 63/17 63/17 6473
8025 hii ns ans 64/5 65/12 65/20 66/14
7/11 67/1: 18 68/16 71/2172/22 73117
erLan | 7973S TUTTI (75024 76013 7921 813
nuts [1] 40/17 79/25 83/25 84/2 84/17 87/7 88/2 88/3 90/15 91/8
OAT siz 90/8 91/6 91/9 91/12| 91/10
nus
0 92/7 92/25 93/3 ones [1] 81/9
o'clock [1] 2/4 officer [2] 56/18 84/17 only [30] 2/24 3/33/18
oath [3] 28724 58/11 58/12 offices [5] 171222124 | 5120 6/11 14/17 15/8206
object [8] 69/6 76/14 76/17| 50/20 52/3 56/6 25/8 34/1 34/2 35/16 41/4
76/17 T7111 77/15 77/16 |official [4] 51/16 94/8 45/1 48/5 48/6 48/11 49/18
8318 94/15 94123 52/19 53/2258/2561/7
objected [1] 79/20 officially [1] 84/20 66/7 67/15 67/25 73/19
objection [14] 53/2 62/17 [officals [1] 91/10 73022,85/3 89/6 91/19 .
68/23 69/11 76/12 77/6 often [2] 29/7 63/10 operate [1] 68/7 i
7197721 7278/8 |ob [5] 43/13 48/1154/23 |operates [1] 68/16 :
79/19 83/15 84/19 85/22 | 63/24 76/5 opined [1] 65/14
objections [2] 77/3 93/17 |okay [58] 4/13 4121 5/6 opinion [2] 83/4 83/6
obligation [1] 49/7 5/25 6/47/3722 10225 [opponent [11] 9/2144/13| :
observation [1] 53/17 15/10 18/14 21/18 23/4 46/3 46/16 47/1 48/24 49/1| |
obstacles [1] 41/23 25/17 30/25 34/12 35/13 81/12 81/14 81/24 85/3 i
obtained [1] 69/25 36/14 36/23 44/4 45/14 opposed [6] 5/13 25124
i|
0 84/1 84/3 84/786/9 92/5 | 50/19 50720 88/12 88/12
ones
aSa ean 9317 88/14 88/15
opposed... [4] SSILG8/L |come 181 39/9 73/1 74/1 partition [1] 46/10
80/1 23/12 74125 88/10 88/17 88/21 [parts [1] 2/19
opposition [1] 2/15 80125 party [9] 18/18 21/1 46/19
optics
opton [3]2] 43/6 43/7 4618 |outlet
3118505 oct)4) 3s
3300 50/23
fs 57/18 82/1 87/6 8812
order [4] 3516 56/12 92/18|oined [2] 271182912 [passed [3] 8/19 3877 53/6
ss outreach [1] 67/23 past [1] 11/19
jordinary [2] 326 75/6 |ae 1) 18124 patient [1] 29/19
organization [1] 6/6 | 16] 4143753819 [Pause [1] 43/13
original [4] 34/14 60/8 cy)37015 80/8 Payne [1] 91/4
Sait7 86/3 overarching [1] 1U17 [Pearce [1] 50/7
originally [1] 43/14 overlap [1] 39/17
PEARSON [27] 1/19 4125
other [40]10/12
9/11 10/4 618 6/19
1372 8/24
14113|"Ya
0% 29m 72s| 513
Yn5/11 SI1S
aan 11/18
rt 13/4
upsisnstearmys| SB IATA
1021915280153616 [P| 2m 2msa8024
AIBA 417 SUS |pGST ay S18 Sana sats
S0136521
64/5 50022.67156721
52/9 S714 |p|pAC[1]2] 41720
70/6 7018 43/16 86/241)92/12
omen 385892120
723 696 TAIT vaca 1] S06 ene on
76/23 79/19 82387122 |pACK [1] 77/2 pending [1] 89722
OLI9 91/11 91/16 page [6] S/1551859/10
jothers [4] 40/2 43/753/9 | 79/4 81/19 91/3
(people [32] 3/10 13/11
15/9 16/17 19/24 20125
bin page7 [1] 5/15 20/423/24 26/9 26120
otherwise [4] 26/15 49/4 |pages [1] 94/10 27/23 29/14 30/15 30/16
SS/11 814 pains (1] 35/7 33/24 36/3 38/20 40/9 41/4
ought [4] 819 S320 84/5 |painting (1) 49/20 46120 48/10 59/1 6177
oz paragraph [1] 44/5 61/14 63/11 63/19 63/24
our
unos[27] 23227s
20110 22/18 |parameters
(IT [1] 559
ne |
| 64116
Sa 66/22 6716 6718
2914349381038 ['90r5 ne 1519
38/25 41/9 52/9 S813 66123 |part [12] 5/20 2419 30/3 |nercent [1] 11/24
74/4 8112 85/5 85122 86/1 49/13 54/10 58/4 60/4 60/5|perception [1] 55/18
SLL BTISSTISSIG | G55 7604 80S 8417 [Penner Fs 0 Benz
89/14 89/20
lout [41] 2124 5123 6217/6 participation
Sigg [2] 1122 |gg/15
aps 3] 1012 48112
13/814/9 2412 26/8 26121 oqyticular [5] 15/21 35/15| 91/9
33/2372 3712 38/13 4017 763/5 63/12 51 EL OTIS
SUL 4UL1 SUL S013 352 particulary [5] 71152472 |frs
SS/855120 60/11 6012 |'sgp 63/14 63/16 i 1] 7/8
GUA GUT 65124 6525 ari [5] 222 14/5 39723 Sioa 1] 69120
661166470225 [gris sano eo ors
TU TIILTSAGSUA |partisan [8] 42/12 46/13
P political (29] 19/15 44/13 | S714 57/15 64/18 6524 |
person [8] 371
Tz | 4524522 4624604 | TARSAL
ea on agiiL fort | 46716 47/1 4824 49/1 4919 pressure [1] 40/14
ann 50/5 50/22 50/23 52/2 53/7 [presumably [1] 69/17
person's [1] 1972 571857725 58/47123 presumptive [1] 66/6
Personal [2 4373 4310 |SS3STASTR08IRL pretty [3] 3125 42016
erspective [7] 11S 11/7 |ST2388/188288/15 | 76121
18/1 25/14 20720 4210 |politically
sort 3819 [5] 47/19 65/12 previously
[primary [1][1]22/5
60/10 ;;
persuasive [1] 4477 65/13 71/24 8715 [prime [1] 93/20 |
Peterson's 1] 11/4 politicization [5] 87/15 [print [1] 62/23 |
pore [5] 341532 |STABSTASST2LEOR prior 2] 24120 81128
ee Tay politicized [2] 28/1 28/3 |privilege [4] 11/12 13/2
oes 21 317900 poliicizing [1] 8720 | 15/23 31/19
Rivet bi] 4143971 pool [2] 3123/19 privileges [1] 20/13
Bluce 5] 13/22 157 1723 [portion [2] 187418 proactive [1] 24125
Dy position [2] 20/2022/18 |probably [6] 6/24 9/4
es i] 26125 possible [2] 5495721 | 11/13 68/10 69/10 92/22
Blan [4] 15722 16/5 92725 [Post [2] S023 5173 problem [2] 75/5 81/14
ny postman [1] 18/12 problematic [3] 46/18 47/5
planet [1] 61/7 posture [1] 49/6 583
Eianned [1] 1518 [potential [4] 4/14 13/15 |procedure [2] 14/9 30/1
Place 1 4122 1425 58/19 proceeded [1] 65/20
Played 3] 1/8 61/4 4/17 [Potentialy [1] 43/5 proceeding [2] 45/12 56/18]
Hays 3] 6218/4568 [Power 2 26/10 5418 proceedings [4] 2/1 1220
eos [6] 45/8 saa4 [powerful 2] 31253202 | 1221 STL
TLL os Gort sats [powers [1] 22/11 process [10] 6/8 23/19 37/6
please [4] 12/4 51/6 53/23 [Practical 2] 6167312 | 41/11 426 52120 52120
ease precedence [1] 29/6 57/22 8424 89/8
lensed [1] 8212 precedent [3] 20/13 28/18 [processed [1] 22/13
Fog [1] 48 ZZ processes [2] 69/18 87/16
eignandy [1] 1211 [Preceding [2] 45720 5910 |product 2] 81528112
oiet 34] 925 62 logo [Preferable [1] 7471 professional [4] 21/6 27/14]
1am1217 1522| |prepared [1] 66/23 29/11 71/4
0 ays yeaa [preparing [1] S619 proffer [3] 19/21 24/15
242224732502
F334 auto29016 dye [Present LU) 707
presentation 2913 [1] 10/8
[6] 69/12 [prohibited
8723 39/6 Sons Sih 55/1|6972076122 8325 84/9 [prominent [2] 87/6 88/4 |
55/2 64123 65/10 7414 80/4|86/23
81/12 81/16 85/5 86/7 presented [1] 69/16
proof [1] 61/25
proper [2] 34/8 91/14
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pointed [4] 2618 657 66/5 [Presenting 1] S619 properly [3] 16222616 | |
py preserve [1] 70120 3215
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L/98 €/%8 VBL Tz/zL| SVOTSTOT GES [91] 3nd £78 [1] anoad
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6U/PL TIE| €/Z0V/L S/T [67] osodund)| L1/88
UST SILT YUVT VIL 81h [1] popaodand|SU9S S/ey [€] wopnoasoxd
PET 9T/LT 1/91 EV/ST L/s8 [1] poysyund| £8
TST LTT SULT UTE YRTET [7] yound| SUT YI/IB OTR GIIS.
02TI sit [91] suogsonb ‘ip [1] Syd] SUSY Ep [1] Supnosoad
PY/EL 1/0L [x] pornd| 91/88 [1] paynoasoud|
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81/26 Y2/16 £T/68 PL[1]
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USB BIBL 01/S9 EU/SS| 61/68 $US [6] pousyiand 3
R regard [9] 10/9 13724 32/3 [reported [1] 7/21 .
read. 2] 71/138470 |58/8 66/11 68/17 69/1 80 [reporter [12] 1/23 S913
reading [3 33/13 55/16 | 89/13 60/11 60/17 60125 62/7
yy regarding [2] 3120 86/6 | 80/25 81/2 82118 86/1 94/8
ready [1] 8/20 regardless [1] 87 9423
real 1] 7307 regrets [1] 63/11 reporting [2] 61/17 94/15
really [10] 3/3 39 21/13 |egular [3] 323 32/9 33/22 reports [1] 911
241/12 48721 6421 [regularized [1] 378 represent [4] 4571149724
a regulations [1] 216 |59/14 6024
reason [9] 2417 24/9 29/5 [Felted [1] 9110 representation [3] 60/9
"l0r25 69/14 78/3 83/20 [relates [1] 7120 69247812 |
on release [4] 8/8 9/1193/12 [representatives [1] 118 | |
reasons [1] 69 93/18 represented [2] 45/1985/8
received [15] 2/16 516 |rleased [4] 9729316 93/14 representing 3] 4/3 4117
S871 s8/1718/5508
520524 sya 6yn 5572 |9315.
[releasing [1] 57/8 hd [1] 55/9
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4/11 64/14 84/21 8810 [relevance [6] S04 77/11 [republican [9] 1818211
receives [1] 71/7 TIS 723 1921 19024 | 87/6 88/4 88/4 8/8 88/9
receiving [1] 79/23 relevant [5] 19/1856/9 | 88/15 89/5
recipient [2] 3113 79/22 |TUS 71/1080 republicans [1] 89/1
recogaize [4] 20/21 20/10 ["elef [4] 44/19 87/12 90/3 |republish [1] 33/6
a 9073 request [3] 29/15 60/5 69/4
recoguizes [1] 45/17 [reluctant [1] 4013 requests [2] 36/16 53/3
reconection [1] 7074 [Tey [4 1619 691 78/24 [require 3] 14/14 53/21
recommend
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[3] 7/19 56/25| remarkable [1] 892 sett [1] 83/12
[required
recommendation 2] 616 [remarks [1] 4912 requirement [1] 83/5
Seno remedial [3] 53/22 61/21 requirements [2] 53/16
recommended
record [9] 223/21 [1] 90/5 78/23 [6] 4S/S47110 requires
3/5 |[remedy aad [2] 43/1 74/5
a 00s 2/13 764 | S10 TO TII BOI [requiring [2] 23/13 28/20
prehen remember [1] 18720 [resign [1] 33/7
records [4] 30/5430 [reminded [1] 718 respond [2] 12/2 26/4
as 63d reminding [1] 7111 [responded [1] 36/11 !
recusal [3] 51125114 [remote [1] 1424 response [7]2/175/22
Shs repeat [2] 3/13 67/10 | 55/21 72/16 72/16 83/1
reduced [1] 3958 repeating [1] 92/17 822
reference [3] 47120 51/3 [replacement [1] 89/10 [responses [1] 3/23
ae reply [1] 72/5 responsibilities [1] 71/9
referred (1) 746 report [21]3/9 6/15 7118 _ responsibilty [2] 24/7
Feforring [3] 11/14 79710 | 725815 888209/11 9/12| 71/5
refrain [1] 117 49/466/1 67/7 67/10 8077 [responsive [2] 2424 4223 |
refused [1] 42/1 907219223 93/4 93/14 [rest [1] 382 !
refusing 1] 51720 93/19 93/20 9419 result [3] 915 49721 6319
R S |ecrint[2] 231145020
retains [1] 31/18 said [19] 3/18 177251978 [cal [1] 94/15
revelations [1] 58/1 25129011 357143520 [Sean [1] 2022
reviewed [2] 83/183/1 |39/13 53135713 59/16 [*¢A¢ [1] 42/6
reviewing [1] 76/17 59/17 60/12 66/21 66/22 |%eCond [5] 8/6 18/4 22/1
revisit [1] 27/8 ema Ts srs san1 | 4716 T32S
rewarded [1] 85/6 same [16] 9/16 13/22 33/14|S€CTecy [2] 20/3 68/8
rich [1] 35/14 37/2.39/20 45/9 50/1 50/8 [Secret [1] 38/13
ridicule [1] 86/21 50095023 51/4 60/17 [Secretary [1] 91/9
ridiculous [1] 19/10 6025747158511 87/9 [S6€ [22] S/18/19 19/17
right [37] 4/13 5/9 7/5 8/24|satisfied [1] 85/16 23/5 35/17 37/17 4112 48/1
10/24 15/3 15/7 17/8 20/12 [saw [1] 45/8 $4121 60/7 62/23 62125
21/2523/325/1825/20 [say [35] 7/13 13/16 13/20|63/20 66/19 70/19 73/17
31/4 31/8 31/16 34/17 3511| 15/5 15/7 15124 16/9 16/12|76/23 78/17 79/1 84/5 90/8
351138243901 42/5 | 17/8219 22/8 22122 24/13|9322
51/25 53/11 58/3 60/9 25192524 281230015 [seeing [1] 75117
61/13 61/15 68/6 69/13 |3023381848/7doj11 [Secking [S} 2/7 157778123
78/13 78/16 80/19 82/10 | 53124 56/8 58105824 | 9029073
92/4 92/15 93/1 6324 66/12 73/12 73/18 [Sem [2] 3825 87/8
rights [8] 4/6 14/7 19/20 |7320 74/15 89/14 89/17 |Se°ms [2] 8415 88128
192120/125/122515 | 90/2 91/12 seen [3] 49/9 59/7 60/2
27/12 saying [20] 724 12124 [Seized [1] 17/13
rise [1] 65/13 1472518/5 18/11 19/8 [selected [1] 7512
ROBER [2] 1/11 68/19 |2272326/1726/1828/21
T [Sif [1] 3120
role [5] 8418/191972 |30183124 33/16 5621 [Sclf-incrimination [1]
52/16 56/18 56122 64/11 6724 83/9 | 3120
rolled [1] 33/2 85/190/4 [senate [1] 20/23
room [2] 11/8 12/22 lsays [18] 7/18 12/12 26/8 [senator [67] 1/18 2/6 2/8
routine [4] 45224524 | 26/8 28/19 3012 30/8 30/16|2/104/17 5123 6/8 6/22 7/8
50/14 51/18 30117 30/21 3024 32/10 |7/19 9/4 9/6 9/10 1012 10/9
routinely [2] 82/22 83/8 | 33/25 34/2 34/5 48/13 10/13 14/16 15/13 20/6
rule [11] 2233132353 | 62/25 86/23 23/11 2920 42/15 43/5
3/5 3/9 3/103/1433/9 33/9 [scene [1] 43/16 47/11 47/21 47125 48120
7119 Schafer [1] 20/24 4917 49023 50/9 50/11 53/9
rules [11] 10/721/721/8 |Schaffer [1] 18/18 55/2 57/7 5819 6172 61124
28/15 29/11 3017 32/7 71/4 [scheduled [2] 41/3 41/3 | 64/12 64/14 65/8 65/25
71/5 83/24 84/1 scheme [3] 11/23 14/10 | 66/11 66/12 66/16 66/21
ruling [3] 37/24 39/14 78/8| 17/10 67/24 68/10 72/11 73/3
run [1] 81/16 scope [1] 22/23 74/12 75/9 75/17 7611
running [1] 43/21 Scotia [2] 16152502 | 81/24 83/2 84/8 8421
runoff [4] 72/9 81/18 82/3 |screen [12] 54/8 54/11 | 4/23 86/10 87/11 87/12
8372 54122 54124 59/16 50/18 | 89/11 90/5 90/9 90/17
SUB 621 TIA TIE [202492710
77120 85119 jsend [1] 24/11
. i
s 1040 17/19 1924 20/15 | 19/12 39/16 39/16 39/20
sen ding|2L0 21/13 21/16 25/5 27/4| 85/10
[I]S070
sense [3 16/24 45115 dg/t3| 279 28/19 3414 40/18 45/1 situation 5] 11/16 16/18
sont [3] 51/22 51/23 S318 |S0/21 SU22 S122 GUS | 19/1 1913 22/7 39020 45/16
LIE 61/21 69/14 7116 85/17 | 51/15 90/6
sentence [4 312531 |SG238BSI0899 six [3] 10018 S823 6217
23315 9077 90123 skill [1] 94/12
separate [1] 92/1 should [6] 13/16 17720 [skip [1] 31/25
Serial [2 362 386 24/824132502624 [slammed [2] 5814673 | ©
sores (6) 477 Sy2 6/3 [Shouldn't 2] 1076/1 sap [1] SYS
6/4 Tad show [6] 17/20 21/14 63/11late [3] 61/189/18 9124 |
serve [1] 26116 77/13 85/11 88/11 slide [4] 58/17 58205823| |
[Showed [1][1] 80110 cd |
St [3] 41/19 5222 showing
session 56/11 slightly [1] 33/12 |
tl) 270 dong ssn [shown 1] 7671S small [2] 62025 63/14 |
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Sorta 73 Smith [10] 68/19 68125
shadowboing [1] 65/18 _[#hred [1] 82120 69/12 69/16 76/22 82/11
Shactter [1] $75 side [9] 10/4 10/4 24119 | 82113 82121 83/21 86/4
shaking [1] 2215 35/1538/10 4217202 [Smith's [4] 761228316 84/9 |
Shame 11] 86122 RIT 8622 :
Share [8] 17/4 40716 4210 [S20 12] 301 61/12 snippets [2] 71/14 71/15
[121][1] d612
58/13 60725 so[social
signed [4] [1]3/2 1979
3570 54/11 54/12 79/6 [Signature
S313
shared 60/10 s3/12 |$74
[7] 8161125
SAIL Sait [significant [1] 65/4 sole 3] [1]11/21
soclety 58313/9 22/5
Si signing [1] 19/8 solid [1] 74/10 ,
ake [37] S71 61179723 924 signs 1] 37720 some [37] 2123 324 6/5
a a10 2133 pup similarly [7] 18/11 18/14 | 10/12 11/10 1125 14/23
Tass a | 1971239715 39/1639120 | 14724 14125 17115 1816
Aosta sms | 8510 nae 2MI285 |
Ld 36/18 38/16 3qte [simple [3] 4/8 55/12 7419|31/4 352036253913 |
67 0 | 03
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Tse Tans | 1513 49/16 52/4 52/9 54/18 |
TAA Tena T9a0 sats [Since [3] 1472 42/7 43025 | S418 58/6 68/9 77/4 88/22
for single [3] 19/3 26/22 31/13| 92/15 |
ahe's [1] 2717 sv [7] 15/17 16/4 24/526/3/somebody [5] 631256420| |
Shite [1] 8122 49/10 76/4 78/12 75123 75125 7612 l
Shocked [1] 93/19 sit [7] 24/15 37/14 58/10 somehow [5] 37/20 43/8
shore [1] 76720 66/11 743 TAA TRIS |someone GLIL6 G16 TLS
hort 2) soneTae [sie lll 72 [21] 7/13 12/15
Short 13) 0/24 25 Gg [Situated [11] 1321 1725 | 13772820 3821 38722
Shonda (31) 3125 5107 ft | 18111 18718 18116 1823 | 3973 4673 4617 46/16 4772
s [specifically [4] 12/12 21/9 [statutory [2] 19/21 74/5
someon... [10] 5714 |30/6394 stay [1] 40/17
57117 65/1171/24 7477 |SPeculating [1] 64/7 stays [1] 93/2
77/1 82/6 82/21 85/4 88/20 [SPeculation [1] 64/18 steps [5] 8/18 36/2 39/1
someone's [2] 57/25 65/16 [Speculative [1] 43/2 88/22 88/23
someones [1] 58/1 jspelled [1] 12/7 Steve [1] 38/18
something [21] 62380 [spread [2] 372.4171 stick [1] 13/9
1211218192120 [SAUint [1] 62125 still [18] 11/2 16/14 17/6
211328017 280233721 [Stage [1] 15/5 20/22.20123 21/4 39/11
25a sys ess [stake [1] 88/16 39/17 44/18 47/9 47/9
6701170724 73/10 7321 [$1and [4] 25/18 25120 | 47/14 49/7 83/3 87/4 90/19
73/22 73/24 91/25 5171278121 90/21 91/16
Sometime [1] 82/4 standard [8] 45/3 45/4 stood [1] 31/23
sometimes [1] 16/16 51/13 51/14 55/19 5520 stop [2] 17/11 59/5
somewhere [3] 1218 |5614 85/12 stories [2] 64/7 67/17
74/11 93/5 Standards [2] 27/13 27/14 |story [5] 60/18 60/20 62/8
soon [2] 52/18 84/3 Standing [1] 15/3 64/10 81/4
Sorry [4] 51/13 50/4 S9/6 [Start [8] 320 519 11/2 11/4 streamline [1] 52/9
7958 17/23 44720 53/14 54/5 [streamlined [2] 37/8 42/3
sort [4] 314 63/23 Gano [Started 2] 421759021 strikes 2] 9/7 46/18
843 state [32] 1/2 1/15 1/16 [striking [1] 45/21
sought [2] 3/5 51/10 172114320 6/23 10/7 [strokes [1] 45/25
sounds [3] 1421 18/15 | 11/5 12/6 12120 16/12 18/9 [stronger [1] S6/11
19/10 19/20 23/25 25/20 26125 [subject [9] 7/9 7/12 713
source [7] 35/4 48/6 511| 29730203124 42022 | 19/22 20/16 51/11 56/14
625 690 TL TIL | SVATS2105224 532 | 83/18 91/23
sourced [1] 70/23 62/1475(20 75/22 85/1 [submission [1] 69/7
sources [2] 67/17 77/12 |36/7 94/4 9415 submit [3] 57/2 63/9 80/9
sourcing [1] 76/21 State's [5] 83/1383/15 submits [1] 3/14
sp [3] 61/4 79024 91/4 | 84/4 84/6919 submitting [1] 57/5
speak [3] 17/221/20 27/5 [Stated [1] 34721 |Subparagraph [1] 30/2
speaking [2] 2/22 52/15 [Statement [3] 10/16 15/6 subpoena [22] $120 12/15
speaks [1] 12/11 84/16 26/9 26/16 26/17 30/4 30/7
special [40] 15 U102/3 [Statements [1] 84/12 30/15 30123 30124 31/14
4/87/97/14 12/15 14/10 [States [1] 3715 32/5 32/15 32/22.33/1 48/1
21/726/9 30/1 32/6 32/14 [Statewide [1] 65/4 48/16 48/17 48/20 55/3
32/1933/1833/1833/23 [Station [1] 47/13 66122 68/15
341203424 35/10 36/5 [Status [8] 5/19 12/324722 [subpoenas [8] 5/16 3225
304 43/11 47724 481 48/5|2423252 25/6 SOS | 33/4 33/25 36124 4072 48/6
48/11 48/14 4825 50/12 | 86/10 92/17
0/15 67/19 74/3 74/8 85/7 [Statute [8] 21/1226/14 |substantial [1] 71/18
88/24 90/19 91/7 91/20 | 32/4 32/19 32/25 33/5 34/5 substituting [1] 77/1
93/3 4817 such [3] 19/22 23/1 52/23
specific [1] 40/13 statutes [1] 30/11 suddenly [3] 9/13 58/14
S T_ |targets[7) 1822717209
suddenly... [1] 93/11 table [2] 77/14 85/18 3077 30/21 30124 58/16
sufficient [7] 22/12 22/25 taints [1] 89/12 tasked [2] 6/15 75/17
2620 66/9 78122 87/13 [take [19] 31243311 [team [8] 17/217/523/16
90/22 3317376395404 |48/13 92/10
suggest [3] 35/14 61/7 74/4) 53/21 59/9 60/3 61/21 technically [2] 33/4 48/3
suggested [1] 23/9 691117025 76/9 76/19 tell [6) 3143/19 157
suggesting [3] 24/1 3321|78/22 80/8 80/10 85/19 | tempera 15/14 17/18 2822
83/6 9419 ture [1] 12/21
suggestion [1] 91/2 taken [6] 16/25 35/7 35/19 [tendered [5] 76/18 77/4
suggests [1] 43/9 4718 2 88/3 S119 7119 7721 82119
summer [1] 52/11 taking [3] 8/18 41/16 81/10 [1] 55/10 .
SUPERIOR [4] 1/1124 talk [22] 6/4 9/1 2211 23/11/‘50ins [4] 17732515 50/5
511794125 29183418 402.4023 |2V12
5 7inz [testifies [1] 3977 |
supervised [2] 81921 |272 425430
supervisory [3] 26/15 34/6| 53/20 66/13 6622 68/2 |(estfy [3] 23/1 29/10 31/20
52/16 6819 68/10 68/12 72/19 [testimony [5] 231202324
lsupport [8] 43/24 45/22 | 75/9 76/25 39/839/9 55/4
46/1 48724 4921 57/17 [talked [5] 11/14 19/16 24/3| than [24] 3123/2 1 6120
651171124 34123 67/14 824 9/12 16/6 28/1 28/15
supportings [1] 49/1 [talking [17] 27/1635/17 | 30/20 30/23 3972 41/18
suppose [1] 79/24 4020 47/4 501757015 |42/44307 49117 57/14
64/21 64/24 6572 65/3 72/9| S1/10 67/21 15/14
supposed [5] 29/332/25 | 72/10 75/15
37/1 66/19 68/7 81/22 8712287725 |S1/20 87/12 87/22 90/3
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Exhibit 13
August 25, 2022 Order Denying Motion to
Reconsider Disqualification Request, In re 2
May 2022 Special Purpose Grand Jury, Case
No. 2022-EX-000024 (Fulton Co. Sup.
Court).
[FILED
INOFFICE
IN THE SUPERIOR COURT OF FULTON COUNTY ac
STATE OF GEORGIA bm BE
1
reviewedthe recordaswellastheelevenalternateelectors’recentmotion,theCourtre-
affirms ts position and DENIES the motion to reconsider.:
The eleven alternate electors, despite their assertions to the contrary, are not
similarlysituatedwithSenator Jones. None is locked in a high-profilestatewidepolitical
campaign against someonewhomtheDistrictAttorney haspersonallyand professionally
endorsed.+ Indeed,thesealternate electorshave providednoevidencethattheDistrict
Attorney (orany member ofherstaff) hasdoneanything thatsuggestsa possible political
‘motivation for investigating them -- beyond the banal observation that they are active
Republicans andtheDistrictAttorneyisnots Plainlythatisnotenough. Nor isit
sufficienttopointoutthatthesealternate electorshavealldonatedto Senator Jones's
campaignforLieutenantGovernor(andthe DistrictAttorneyhas not). Theirlegal
campaign donations are no more disqualifying that the District Attorney's. See, eg.,
Caperton v. A.T. Massey Coal Co., Inc., 556 U.S. 868, 884 (2009) (“Noteverycampaign
contributionby alitigantorattorneycreatesaprobabilityofbiasthatrequires ..
recusal”); Gude v. State, 289 Ga. 46, 50 (2011) (same) (both cases involve judicial
recusals, where disqualification rules are more stringent).
+TheCourtalso declines
toprovide acertificate
ofimmediate review.
=Alternate lectorShawnSlsrunninfor aStateSenteseat. Hiscontest i localandrelatively
low
protle. Moreimportant,unlike Senator Jones, candidate Still offers noevidencethattheDistrictAttorney
Supported is 1tin anymanner (otherthan thebaldclaimthattheDistrictAttorney'spursuit
ofthe. nteroronceinvestgation is designedtoharm him and4dhis opponent).Thus, apartfrom
thedifferentpoliticalaffiliations oftheDistrictAttorneyandcandidate Stil,thereisnothingtosuggestany
‘political
inkto theDistrictAttorney'sinvestigationintoSHII'sactivities asanalternate elector.
3Remarkably,counselfortheeleven alternateelectorscitesasproofoftheDistrict Attorney'sbias“her
‘targeting
ofonlyRepublicans.” Mot.at10. Iteludestheundersignedhowaninvestigationintoallegations
‘ofRepublicaninterferenceinthe 2020generalelectionin Georgiawould haveanyotherlistoftargetsthan
Republicans.
2
IN THE SUPERIOR COURT OF FULTON COUNTY ESTR OFFICE
STATE OF GEORGIA m AD!
WL GELOC SEER
oust
Hp/
IN RE: ) pe
SPECIAL PURPOSE GRAND JURY) 2022.EX-000024
)
) Judge Robert C. 1. McBurney
)
Upon the petitionof Fani T. Wills, District Attorney, Atlanta Judicial Circuit, pursuant to
the Uniform Act to Secure the Attendance of Witnesses from Without the State, codified at
O.C.G.A. § 24-13-90 et seq, the Court issues the following Certificate under seal of this Court,
and further says as follows:
1. A Special Purpose Grand Jury investigation commenced in Fulton County, Georgia,
by orderofthis Court on May 2, 2022. See Order Impancling Special Purpose Grand
Jury Pursuant 0 O.C.G.A. § 1512-100, et seq., “Exhibit A”. The Special Purpose:
Grand Jury is authorized to investigate any and all facts and circumstances relating
directly or indircetly to possible attempts to disrupt the lawful administrationof the
2020 elections inthe Stateof Georgia. See Letter Requesting Special Purpose Grand
Jury, “Exhibit B”.
2. Based on the representations made by the State in the attached “Petition for
Certification of Need for Testimony Before Special Purpose Grand Jury Pursuant to
0.C.G.A. § 24-13-90 et 5cq.", the Court finds that Lindsey Olin Graham, born July 9,
Campaign, and other known and unknown individuals involved in the multi-state,
coordinated efforts to influence the results of the November 2020 election in Georgia
and elsewhere. Finally, the Witness's anticipated testimony is essential in that its
likely to reveal additional sourcesof information regarding the subject ofthis
investigation
5. The testimony of the Witness will not be cumulative of any other evidence in this
matter.
6. The Witness will be required to be in attendance and testify before the Special
Purpose Grand Jury on August 2, 2022, and continuing through and unil the
conclusionofthe Witness's testimony on or before August 31, 2022, at the Superior
Court of Fulton County, Fulton County Courthouse, 136 Pryor Street, 3rd Floor,
Atlanta, Georgia 30303.
7. The Officeof the Fulton County District Attorney, in and for the Stateof Georgia,
will pay all reasonable and necessary travel expenses and witness fecs required to
secure the Witness’s attendance and testimony, in accordance with O.C.G.A. §24-13-
90 et seq
8. The Witness shall be given protection from arrest and from service of civil or
criminal process, both within this State and in any other state through which the
Witness may be required to pass in the ordinary courseoftravel, for any matters
which arose before the Witness's entrance into this State and other states, while:
traveling to and from this Court for the purpose of testifying for this case
9. “The StateofGeorgia is a participant in a reciprocal program providing for the.
securingofwithsses to testify in foreign jurisdictions which likewise provide for
such methodsofsecuring witnesses to testify in thir courts.
10. This Certificate is made for the purpose ofbeing presented to a judgeof the Superior
Courtofthe DistrictofColumbia by the United States Attorney for the District of
‘Columbia or his duly authorized representative, who is proceeding at the request and
on behalf ofthe Officeof the Fulton County Distrit Attorney to compel the Witness
10 be in attendance and testify before the Special Purpose Grand Jury on August 2,
2022, and continuing through and until the conclusionof the Witness’s testimony on
orbofore August 31, 2022, at the Superior CourtofFulton County, Fulton County
Courthouse, 136 Pryor Stret, 3rd Floor, Atlanta, Georgia 30303.
WITNESS MY HAND AND SEAL as judge of the Superior CourtofFulton County,
Georgia,
“This the erof July, 2022.
Hon. 3 CL = furney \
Superior CourtofFulton County
Atlanta Judicial Circuit
:
Stateof Georgia
Exhibit A
HSE on Bea
I THE SUPERIOR COURT OF FULTON COUNTY
Dee: SPE
REQCIA
UEST FOR drei]
L PURPOSE Ll (DA
GRAND JURY
CREA
ORDER APPROVING REQUEST FOR SPECIAL PURPOS
GRAND JURY PUR E
SUANT 10 0.C.G.A, 815-12.100, eC sea, (
The District Atomey for the Atlanta Judicial Ciruit submited oth
ejudges ofthe
Superor Coue of Fulton Coun sees 0 mpanel special pupose
cy fo the purpose
orth n that request. Ths toques ws considered and spproved bya
majorityofthe total
umberofthe judges ofthis Cour, as required by O.C.G.A. $15-12-100()
.
TS THEREFORE ORDERED that a special purpose grandjury be dra
wn and
impaneled to serves provided in OC.0.A.§ 15-1262.1, 15-12-67, and
15-12-10, to
commence on bay 3, 2022, and conning for period nt to exce
ed 12 mots, Such paid
shall no include any time periods when the supervisingjudge determin
es that the special
ppase grand jury caanot meet or say o other reasons, or aay
ime periods when normal
cout operons ace suspended by order ofthe Supreme Cor
tofGeorgi or the Cie ge of
the Supecor Court. The special puose granfry shall be auth
orizedtoinvestigate anya al
facts and irounstances relating ivelyo indirectly o alle
ged violationsofthe laws ofthe
Sate ofGeorgi, e set for in the request ofthe Distict Aton efer
enced hereinabove,
Fresuant 10 O.C.G.A. § 15-12:101(0), the Honarble Robert
C. | MoBurmeys hey
sssgned to supervise and assist the special purpose grand fry,
ndshallcharge seid special
purpose grand jury and receive is ceportsa provided by law.
“This suthorization shal include the investigationof any overt acts or predicate acts
seating tothe subject of the special purpose grand jury's investigative purpose. The special
pupose grandjury, when making its resentments and reports, pursuant t0 0.CG.A. §§ 15.12-
71 and 1512-101, may make recommendations conceming criminal prosecution as it shall
sco
it. Furthermore, the provisions of 0.C..A. § 15-12:83 shall apy.
“This Conc lso tes tht the appointment ofa special purpose grand jury will permit
the
time, efforts, and atenionofthe regula grand jury(ies) impaneld inthis Citi to continue
to
be devoted to the consideration of the backlogofcriminal matters that bes accumulated
gs 3
felt of the COVID-19 Pandemic.
IT IS FURTHER OF RED tisOrde sll be ed in the Offic ofthe Clock of
the Superior Court of Fullo Couatyl, +
SO ORDERED, f or) Tr 22.
nd
= 4
Fanl/T VAs
Diirict Attorozy, Atlanta Judicial Circuit
.
/wateh?v=B71cBRPgt9k)
Exhibit B: Proposed Order
COMES NOW the State of Georgia, by and through Fani . Willis, District Attorney,
Atlanta Judicial Circuit, Fulton County, Georgia, and petitions this Honorable Court for a
Certificate of Need for Testimony Before Special Purpose Grand Jury, pursuant 10 0.C.G.A. §
24-13-92 et seq, and in support thereofsays as follows:
1. A Special Purpose Grand Jury investigation commenced in Fulton County, Georgia,
by order ofthis court on May 2, 2022. See Order Impancling Special Purpose Grand
Jury Pursuant ©0 O.C.G.A. § 15-12-10, Et Seq, “Exhibit A”. The Special Purpose
Grand Jury is authorized to investigate any and all facts and circumstances relating
directly or indirectly to possible attempts to disrupt the lawful administrationof the
2020 elections in the StateofGeorgia. See Letter Requesting Special Purpose Grand
Jury, “Exhibit B”.
2. While Georgia law authorizes special purpose grand juries to conduct both civil and
criminal investigations, the Special Purpose Grand Jury's investigation is criminal in
nature in tha it was requested for the purpose of investigating criminal disruptions
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South Carolina.
4. Based on the representations made by the State in the attached “Petition for
CertificationofNeed for Testimony Before Special Purpose Grand Jury” the Court
finds that the Witness is known to be affliated with both former President Donald
Trump and the Trump Campaign.
5. Based on the representations made by the State in the attached “Petition for
Certificationof Need for Testimony Before Special Purpose Grand Jury” the Court
findsthat romMarch 31, 2020, to Jamary 20, 2021, the Witness servedas Chief
of
Staffto former President Donald Trump and was in constant contact with former
6. Based on the representations made by the State in the attached “Petition for
CertificationofNeed for Testimony Before Special Purpose Grand Jury” the Court
findsthaton December21,2020,theWitnessattended a meetingattheWhiteHouse
with former President Trump, membersofCongress, and others to discuss allegations |
ofvoter fraud and the certificationofelectoral college votes from Georgia end other
states. The Witness confirmed this meeting in aTweet onDecember 21, 2020, when
he stated, “Several members of Congressjut finished a meeting inthe Oval Office
with President@realDonaldTrump, preparing to fight back against mounting
evidenceofvoter fraud. Stay tuned.”
7. Based on the representations made by the State inthe attached “Petition for
Certificationof Need for Testimony Before Special Purpose Grand Jury” the Court
finds that on December 22, 2020, the Witness made a surprise visit o the Cobb
County Civic Center in Marietta, Georgia, where the Georgia Secretaryof State's
Office and the Georgia Bureauof Investigation were conducting an absentee ballot
signature match audit. Officials conducting the audit were unawareofthe Witness’s
trip to Georgia until shortly before he arrived at the Civic Center. The Witness
requested to personallyobservethe audit process but was prevented from doing so
because the audit was not open to the public.
8. Based on the representations made by the State in the attached “Petition for
Certification ofNeed for Testimony Before Special Purpose Grand Jury” the Court
finds that betweenatleast December 30, 2020, and January 1,2021, the Witness sent
e-mails to United States Departmentof Justice official, including Acting Attorney
General Joffrey Rosen, making various allegationsofvoter fraud in Georgia and
elsewhere and requesting thatthe Departmentof Justice conduct investigations into
these allegations. The e-mails were obtained by the United States Senate Judiciary
Committee and were released publicly.
9. Based on the representations made by the State in the attached “Petition for
Certification ofNeed for Testimony Before Special Purpose Grand Jury” the Court
finds that on January 2, 2021, former President Donald Trump and membersof his
team, including the Witness, participated in lengthy telephone call with Georgia
Secretaryof State Brad Raffensperger and others to discuss allegationsofvoter fraud
in Georgia. An audio recording ofthe telephone cal was widely broadcast. Dering |
the telephone call, former President Trump stated to Secretary Raffensperger, “Lust |
wast to find 11,780 votes” The Witness actively participated in and spoke on the
call, and the Special Purpose Grand Jury's investigation has revealed that the Witnoss
was involved in setting up the cell,
10. Based on the representations made by the State in the atached “Petition for
Certification ofNeed for Testimony Before Special Purpose Grand Jury” the Court
unique knowledge concerning the logistics, planning, and subject matterof the
‘meeting at the White House on December 21, 2020. The Witnesses possess unique
knowledge concerning th logistics, planning, and executionofhis vist to the Coby
County Civic Center on December 22, 2020. The Witness possesses urique. |
knowledge concerning the logistics, planning, and subject matter ofhis e-mails to
United States DepartmentofJustice officials. The Witnesses possesses unique
‘matter, {
12. TheWitnesswill berequiredtobeinattendanceandtestify beforethe Special
Purpose Grand Jury on Tuesday, September 27, 2022, at 9:00 a.ca. at the Superior
CourtofFulton County, Fulton County Courthouse, 136 Pryor Street, 3rd Floor,
Atlanta, Georgia 30303. The Court notes that the District Attorney anticipates that the
‘will pay all reasonable and necessary travel expenses and witness fees required to
secure the Witness's attendance and testimony, in accordance with 0.C.G.A. §24-13-
90etseq.
14. The Witaess shall be given protection from arrest and from serviceofcivil or
criminal process, both within this State and in any other state through which the
Witness
mayberequiredto passinthe ordinary courseoftravel,foranymatters
‘which arose before the Witness’s entrance into this State andotherstates, while. 1
travelingtoand from this Courtforthe purposeoftestifying for this case.
Exhibit A |
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ACS on : or
IN THE SUPERIOR COURT OF FULTON COUNTY
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| FILED IN OFFICE |
IN RE: REQUEST FOR
SPECIAL PURPOSE /Lp
Fh lg LIA)
GRAND JURY Tm
ORDER APPROVINGREQUEST FORSPECIALPURPOSE
‘GRAND JURY PURSUANT {
TO O.C.G. A. §15-12-100, ef seq.
The District Attorney forthe Atte Sua Crit submited to thefudgs ofhe
Superior Cou of Fulton County a request 0 impanel a special pupose jury fo the pusases st
forth thet request. This requestwasconsidered and approved by a majority ofthe total
umber ofthe judgesofthis Cour, as requiredby 0.C.G.A. §15-12-100(t). |
IT STHEREFORE ORDERED that
a specialpurposegrand jurybedrawnand
:
impaneled to serve as:provided in OCGA. § 15:12:62.1,
15-12-67, and 15-12-10, to ;
‘commence on May 2, 2022, and continuing for
a|period not to exceed 12 months. Suchperiod
tll tcl aay ime periods whenthesupervising fudge detemices hat he secil
pucpose grand jury cannotmeetfr sufty o ater reasons, any tine periods whensommal
cout apertonsas suspended byardorofthe Supreme Couto Geng theChie fudge of
the Superior Court. The special purpose.grand
jury shall be authorized to investigateanyand
all
fats and cirumstzacerelating dicey or ndieetly to allege violations of he laws
ofthe
Stateof Georgia, as set forth in the requestofthe
District. Attomey referenced herein above,
Pursuant to O.C.G.A. § 15-12-101(a), the Honorable
Robert C. L McBurney is|bereby
essgned to supevise and sist he special purpose grand ny, and shal chao ssid spel
purpose grand jury an recive ts reports as providedbylav,
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This authorization shell includtheavesigaionofany over acso preicte acs
:
ein to thesubject ofthe special pupose grand jy’ investigativepups, The special
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pose grand jury, when making ts presentments and report, pursuant 1 0.C.0A. 6
15.12.
71 nd 15-12-101, may make recommendations concerning rininal prosecution a t
shall ses
fit. Futhermoe, the provisions of0.C.G.A. § 15-1283 shal apply.
“This Couet ls testatthe appintnet of special pxpose gran ry wil permit th
time, effort, aad ationofthe regulargrand jus) paneled tis Cit 0 continuo
be devoted tothe consideration fthe backlog ofcriminal matters that has coumulted
as
esl ofthe COVID-19 Pandemic,
718 FURTHER ORDERED the tisOrde shal be ile intae Ofcofthe Clkof
the Superior Courtof uly Coun
$0 orERED, THis 2M ola or Rey 2022.
i \
CHRISTOPHER S. BRASHER,
Superior Courtof Fon County GHIEF JUDGE
Atlanta Judicial Circuit
Exhibit B |
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OFFICE OF THE FULTON COUNTY|
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DISTRICT ATTORNEY
ATLANTA JUDICIAL CIRCUIT |
136 PRYOR STREET SW, 3RD FLOOR 7
=wiv
DiSirict Attorney, Atlanta Judicial Circuit
1
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! EXHIBIT A
to Order of 16 February 2023
| 2022-EX-000024
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1 SPECIAL PURPOSE GRAND JURY REPORT
2
3 “This Special Purpose Grand Jury (herein referred to as ‘the Grand Jury") was
4 impaneled pursuant to an Order dated January 24, 2022 by Christopher S. Brasher,
5 Chief Judge of the Superior Court of Fulton County, Atianta Judicial Circuit. The
6 Grand Jury consisted of twenty-six Fulton County residents, three of whom were
7 afar. Onanpday estimonywasrecetvedorlpationswarehad Semaber
8 “fn present ranged between sixteen and twenty-four as availabilty allowed.
9 Pursuant to statute, ifwe had our needed quorumofsixteen jurors present, we could
10 dousiness with that
| The Grand Jury was impaneled to investigate a specific sue the fats and
12 circumstances relating directlyo indirectlytopossible attempts todisrupt the lawful
3 i ofthe 2020 presidential electionsinthe StateofGeorgia.
16 [This Grand Jury was selected on May 24 2022 and first heard evidence on
15 June1s, 2022. We continued to hear evidence and receive information Into
16 December 2022. The Grand Jury received evidence from or involving 75 witnesses
17 during the course of this investigation, the overwhelming majority of which
18 information was delivered in person under oath. The Grand Jury also received
19 information in the form of investigator testimony and various forms of digital and
20 lil media. Pursuant to Georgia law, a team of assistant district attorneys
21 provided the Grand Jury with applicable statutes and procedures. Any
22 recommendation set out herein is the sole conclusionofthe Grand Jury based on
23 testimony presented, facts received, and our deliberations.
u Following is the final reportofthe Special Purpose Grand Jury. We set forth
25 for the Court our recommendations on indictments and relevant statutes, including
26 thé votes by the Grand Jurors. This includes the votes respective to each toplc,
27 indicated in a “Yea/Nay/Abstain’ format throughout. The total number of
28 Grand Jurors who placed a vote on each topic has been indicated in each section.
29 Foomoteshavebeen added in certain places wherea juror requested the opportunity
30 to clarify their vote for any reason. Each applicable statute is referenced by citation
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| EXHIBIT B .
to Order of 16 February 2023
| 2022-EX-000024
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13 ! vin.
14 | Amajority of the Grand Jury believes that perjury may have been committed
15 by one or more witnesses testifying before it. The Grand Jury recommends that the
16 District Attorney
seekappropriate indictmentsfor suchcrimeswhere the evidences
17 compelling .
8 CONCLUSION
19 i
20 ‘The Grand Jury wishes to acknowledgethehardworkingattorneys and staff of
21 din County District Attorney's office. Any legal errors contained in this report
22 should notbe lad attheirfeet,however, because that Office had nothing to do with
2 ;recommendations contained herein.
24 Ifthisreportfailstoinclude any potentialviolationsofreferericed statutes that
25 wee shown In the Investigation, we acknowledge the discretion of the District
26 Atthrney to seek indictments where she finds suficien cause. Firthermore, this
27 Grp Jury contained no election law experts or criminal lawyers. me majority of
28 thif Grand Jury used their collective best efforts, however, to attend every session,
29 listen toeverywitness,and attempt to understand the facts as presented and thelaws
30 asexplained. |
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1 | Ifthe Court finds this report fo have satisfied the purpose of the Special
2 Purpose Grand Jury as imipaneled, we request that we be formally Hischarged from
3 outservice !
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5
6 This 15 dayofDecember, 2022
7
8 EE
9 ForepersonINN ©
10
uf —s -
12 { Deputy Foreperson[IEEE
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EXHIBIT C
to Order of 16 February 2023
~ 2022-EX-000024
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| ‘Addendum
to SpecialPurposeGrand Jury Final Repoft |
{ Theundersigned Spesial Purpose Grand Jury Forepersonand Deputy Forcperson hereby
‘make his Addendu to the Special Purpose Grand JuryFinal Report o clarify two matters:
1) Beto s disluto, th Special Pups GrandJory ytd to recomend ht he
| Special PurposeGrand fury Final Reportbo published: Te Special Puipose Grand Jury
{id notrecommend & manner or time fosuchpublication
2{Atno ime wece 24 ox morjurorsprssnt when evidte wes reosived. 2ors,
| including altermtes, were presentonly at an introductory meeting attheFutonCounty
| CourthouseonMay 12,2022.
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oreperson
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