Fulton County Superior Court

***EFILED***CL
Date: 4/1/2024 8:54 PM
Che Alexander, Clerk

IN THE SUPERIOR COURT OF FULTON COUNTY

STATE OF GEORGIA

STATE OF GEORGIA, )
) INDICTMENT NO. 22SC183572
v. )
)
JEFFERY WILLIAMS, ) JUDGE GLANVILLE
Defendant. )

MOTION TO ENFORCE THE DISQUALIFICATION OF PROSECUTOR LOVE WHO

HAS MADE HER CREDIBILITY CENTRAL TO THE TRIAL AND THUS, HAS
BECOME AN UNSWORN WITNESS IN VIOLATION OF (1) MR. WILLIAMS’
CONSTITUTIONAL RIGHTS TO DUE PROCESS; CROSS-
EXAMINATION/CONFRONTATION; AND A FAIR TRIAL AND (2) GEORGIA RULES
OF PROFESSIONAL CONDUCT 3.7(a) AND 8.4(a)(1)

COMES NOW, Mr. Jeffery Williams, by and through undersigned counsel, and hereby files

this Motion to Enforce the Disqualification of Prosecutor Love who has made her Credibility Central

to the Trial and thus, has become an Unsworn Witness in Violation of (1) Mr. Williams’

Constitutional Rights to Due Process; Cross-Examination/Confrontation; and a Fair Trial and (2)

Georgia Rules of Professional Conduct 3.7(a) and 8.4(a)(1). In support of this Motion to Disqualify

Prosecutor Love, Mr. Williams shows as follows:

1.

Mr. Williams is innocent of all crimes in the above-referenced Indictment.

2.

Under certain circumstances, an attorney who has first hand knowledge of events presented

at trial may impermissibly act as an unsworn witness. See United States v. Locascio, 6 F.3d 924, 933

(2nd Cir. 1993); Ciak v. United States, 59 F.3d 296, 304-305 (2nd Cir. 1995). Specifically, in Ciak v.

United States, supra, a defense lawyer acted as an unsworn witness when he sought to impeach a

Government witness regarding statements that the Government witness had previously made to

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counsel. A lawyer, who is not sworn as a witness, cannot provide first hand knowledge of events

presented at trial as that lawyer’s testimony and credibility would then be at issue without said

lawyer being put through the rubric of cross-examination as required by the Constitution of the State

of Georgia as well as the United States Constitution.1

3.

Without more, a prosecutor does not become an unsworn witness merely because she has first

hand knowledge of events that are introduced at trial. See United States v. Regan, 103 F.3d 1072,

1083 (2nd Cir. 1977). The Constitutional problem arises and disqualification of the prosecutor is

required when there is an indication at the trial that the prosecutor sought to use her first hand

knowledge of the case to influence the jury. See United States v. Regan, supra; United States v.

White, 545 Fed. Appx. 69(I) (2nd Cir. 2013). An attorney who acts as an unsworn witness must be

disqualified as counsel in part to prevent the attorney from imparting to the jury her first hand

knowledge of events without having to swear an oath and be subject to cross-examination. See

United States v. Locascio, 6 F.3d at 933.

4.

The unsworn witness rule is the reason that the prosecutor must always take care not to

unduly inject herself into the proceedings on trial. United States v. Gholston, 10 F.3d 384(IV) (6th

Cir. 1993).

5.

Prosecutor Love has become a witness in this case solely because Prosecutor Love has, for

1
Ciak v. United States, supra, was abrogated, in part, on other grounds in Mickens v. Taylor,
535 U.S. 162, 172 (fn. 3), 122 S. Ct. 1237, 152 L.Ed.2d 291 (2002). Hence, the proposition used in
this case cited in Ciak v. United States, supra, is valid law.

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some reason that only she is aware, voluntarily and continuously injected herself as an unsworn

witness in this case for which no other witness, investigator or otherwise, is available to answer the

questions that Prosecutor Love has forced Mr. Williams to ask. These questions include, but are not

limited to, the following topics:

(i) Why did Prosecutor Love announce in front of the jury that there will be absolutely

no witness at this trial and no witness named on a Witness List who would testify that

on May 12, 2013, Ms. Bennett was not Armed Robbed but unbeknownst to Mr.

Williams, drugs were stolen from her home by “Buc Buc” and later, Mr. Williams

learned of this theft, apologized for “Buc Buc’s” conduct and repaid Ms. Bennett

and/or Mr. Anderson for these stolen drugs? That Prosecutor Love declared her

inaccurate “facts” in front of the jury as an unsworn witness is amazingly incredible.

It now mandates that Prosecutor Love be subject to examination on her motivation

to misstate these facts to the jury. At a later point in the trial, when a witness or

witnesses testify consistent with the representations elicited through proper cross-

examination of Ms. Bennett (conducted by Attorney Keith Adams), the jurors will

be forced to decide, without the benefit of full cross-examination, whether Prosecutor

Love’s unsworn factual statement was credible or not;whether Attorney Adams was

credible or not; whether the yet to be called witness/witnesses are credible or not; and

whether Ms. Bennett was credible or not.

(ii) Prosecutor Love voluntarily and willfully introduced into evidence conversations that

she had while seated on a Courthouse bench outside of this Honorable Court’s

Courtroom while speaking with Ms. Bennett. During this conversation, Prosecutor

Love made Ms. Bennett so uncomfortable that Ms. Bennett announced that she was

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 going to hurt herself. Mr. Williams is forced to cross-examine Prosecutor Love on

these events to provide facts to the jury about the demeanor and tactics of Prosecutor

Love when attempting to have this witness testify against Mr. Williams (even though

this witness previously told Prosecutor Love that she had no information that Mr.

Williams committed Armed Robbery against her);

(iii) Prosecutor Love voluntarily and wilfully entered text messages between herself and

Ms. Bennett into evidence during re-direct examination while treating Ms. Bennett

as a hostile witness and employing leading questions. Undersigned counsel will

examine Prosecutor Love about these text messages to which only Prosecutor Love

and Ms. Bennett were party. This is especially needed because the text messages

introduced into evidence by Prosecutor Love appear, potentially, not to be complete2;

and

(iv) Prosecutor Love cross-examined Ms. Bennett and revealed to the jury that Prosecutor

Love asserted facts that Ms. Bennett stated in text messages or other communication

that (i) Ms. Bennett did not care what this Honorable Court Ordered since no one

could make Ms. Bennett testify and that (ii) Ms. Bennett gave explicit instructions

to tell this Honorable Court to “kiss [Ms. Bennett’s] a*s.” However, the text

messages introduced into evidence by Prosecutor Love between Ms. Bennett and the

Fulton County District Attorney’s Officials do not support Prosecutor Love’s

unsworn testimony in front of the jury.

Importantly, the four (4) instances above are only some examples of areas of necessary

2
This Honorable Court Ordered Prosecutor Love to produce all text messages with this
witness. Based upon reason and belief, these text messages may not have been fully produced.

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questioning and there is no other witness from whom similar information can be obtained, save

Prosecutor Love. See United States v. Watson, 952 F.2d 982, 986 (8th Cir. 1991)(the party seeking

testimony of the trial prosecutor must demonstrate that the cross-examination is vital to the case and

that there is no ability to present the same or similar facts from another source and therefore, this

creates a compelling need for testimony from the trial prosecutor and the disqualification of the trial

prosecutor). Prosecutor Love has failed to abide by the law and our ethical mandates that restrict her

comments only to matters on the Record. Prosecutor Love has made reference to her presence at

interviews and conversations with Ms. Bennett that occurred only between Prosecutor Love and Ms.

Bennett. Prosecutor Love’s alleged personal knowledge of these incidents which Prosecutor Love,

alone, placed in issue before the jury triggers Mr. Williams’ Constitutional right to cross-examine

Prosecutor Love. See United States v. Ashman, 979 F.2d 469(fn. 15) (7th Cir. 1992). Thus, Mr.

Williams will cross-examine Prosecutor Love on the above representations as same cannot stand

unchallenged in front of the jury and the only way to test the truth of these assertions is to cross-

examine Prosecutor Love, the maker of these statements.

6.

A prosecutor may not make herself an unsworn witness by supporting her case by her own

veracity and position. Moreover, a prosecutor may not introduce facts at trial without being sworn

as a witness. See New York v. Lovello, 136 N.E.2d 483 (1956).

7.

Prosecutor Love has placed her own veracity and credibility at issue in this case which is

impermissible, unethical and unlawful. See New York v. Paperno, 429 N.E.2d 797 (1981)(the

unsworn witness rule poses subtle problems in Courts’ efforts to preserve the Constitutional right

to a fair trial because the prosecutor may not inject her own credibility into the trial); New York v.

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Vann, 388 N.Y.S.2d 902 (1976). The primary rationale for limiting the prosecutor’s conduct is

rooted in the great concern that the criminal process be fair and such misconduct by the prosecutor

amounts to a subtle form of testimony against the criminally accused as to which the criminally

accused has no effective means of cross-examination. Therefore, the unsworn witness rule is founded

upon the danger that the jury, impressed by the prestige of the Office of the District Attorney, will

add great weight to the beliefs and opinions of the prosecutor. See New York v. Paperno, supra. The

unsworn witness rule protects and preserves the criminally accused’s Constitutional right to a fair

trial by recognizing that the prosecutor’s conduct and credibility will be an issue for the trial jury to

determine. Thus, in any case where the prosecutor’s veracity, believability and conduct is placed as

a material issue in the case, that prosecutor must be disqualified from going forward on the case. See

New York v. Paperno, supra. In the case at bar, this is not a pre-trial matter. Prosecutor Love, sua

sponte, before the petit jury and all to hear and see, voluntarily and knowingly and against the rules

of ethics and the law, injected her own credibility, veracity and memory of facts into the trial for the

jurors to scrutinize. Jurors must now decide whom they believe, i.e. Prosecutor Love, Ms. Bennett,

Attorney Keith Adams or the witness(es) yet to testify that Prosecutor Love already leveled is a liar

about “Buc Buc” stealing drugs from Ms. Bennett. Mr. Williams has no way to confront the

prosecutor as she has impermissibly and unlawfully become an unsworn witness and hence, now

must be disqualified.

8.

This prosecutor has become an unsworn witness and has introduced facts that now divert the

jury from its proper function. This seriously threatens Mr. Williams’ Constitutional rights to a fair

trial, to confront witnesses, to Due Process and to have the prosecutor impeach a witness based upon

her personal interactions without Mr. Williams being able to impeach the prosecutor. Prosecutor

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Love, without any assistance from anyone else, has made herself a witness in this case. If Prosecutor

Love is allowed to continue to represent the State of Georgia by and through the Fulton County

District Attorney’s Office, and she cannot be called as a witness, the jurors will have to determine

whether Prosecutor Love was truthful or not in her factual assertions referenced above and her

explanation of text messages, whether complete or not, without any questioning or examination by

the accused. This is unfair and violates the above-referenced Constitutional rights.

9.

In Georgia, Courts have discussed unsworn witnesses in relation to juror misconduct when

a juror introduced extrajudicial evidence into the province of the jury and therefore, essentially

became an unsworn witness against the criminally accused. This violates the criminally accused’s

Sixth Amendment right to a fair trial and his Constitutional right to confront that unsworn witness.

Georgia Courts have pronounced that when this unsworn witness rule is present in a criminal case,

there is a presumption that harm was present and reversible error must be found unless the State

proves, beyond a reasonable doubt, that no harm has occurred. See, for example, Chambers v. State,

321 Ga. App. 512(1), 739 S.E.2d 513 (2013). In the Constitutional sense, a trial by jury in a criminal

case mandates and necessarily includes, at the very least, that the evidence developed against the

criminally accused shall come from the witness stand in a public Courtroom where there is full

judicial protection of the criminally accused’s right to confrontation, of cross-examination, of

effective assistance of counsel, Due Process and the right to a fair trial. See Turner v. Louisiana, 379

U.S. 466, 472-473, 85 S. Ct. 546, 13 L.Ed.2d 424 (1965).

10.

Mr. Williams has the Constitutional right to confront and cross-examine witnesses against

him, now including Prosecutor Love. These Constitutional rights are fundamental to a fair trial. See

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Hammock v. State, 277 Ga. 612(2), 592 S.E.2d 415 (2004).

11.

As discussed above, the prosecutor injected her own personal knowledge of material facts

at issue in this case and has become an unsworn witness against the criminally accused since

Prosecutor Love has made factual assertions without having been sworn as a witness. When the

lawyer is a prosecutor who makes factual assertions without being sworn as a witness, the error goes

to the heart of fundamental fairness and Due Process of law under the Georgia Constitution as well

as the United States Constitution. Without mistake, this is a Constitutional issue and not an

evidentiary issue. See Dillon v. Kentucky, 475 S.W.3d (2015). Mr. Williams cannot receive a fair

trial with Prosecutor Love representing the State of Georgia since Prosecutor Love has injected her

own credibility into this case for the jury to determine. A lawyer shall not insert personal knowledge

of facts in issue except when testifying as a witness. Generally, a lawyer is prohibited from acting

as an advocate at trial where the lawyer is likely to be a necessary witness. There is no doubt that

assertions of facts from Prosecutor Love as to the content of prior conversations with a material

witness have the effect of making a witness of the lawyer and allowing her credibility to be

substituted for that of the witness. This practice is improper, unconstitutional and unethical. See

Dillon v. Kentucky, supra.

12.

Georgia Rule of Professional Responsibility 3.7, Comment 2, as well as Georgia Rule of

Professional Responsibility 8.4(a)(1), mandate that a lawyer shall not insert facts unless they are

testifying under oath. Pursuant to Rule 3.7, “The opposing party has proper objection where the

combination of roles may prejudice that party's rights in the litigation.” As demonstrated herein, Mr.

William’s Constitutional Rights are prejudiced where, as here, Prosecutor Love’s dual roles, as an

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advocate and an unsworn witness, allow her to inject testimony in the trial which will not be subject

to cross-examination Moreover, Georgia Rule of Professional Responsibility 8.4(a)(1) mandates that

a lawyer cannot do directly what they cannot do indirectly. Obviously, Prosecutor Love could not

be sworn as a witness and continue to carry the torch as trial prosecutor for the State of Georgia in

this case. Thus, she has successfully done indirectly what she could not do directly by testifying as

an unsworn witness through redirect questions, which were really a cross-examination since this

Honorable Court permitted Ms. Bennett to be deemed a hostile witness. In fact, this Honorable Court

permitted Prosecutor Love to treat Ms. Bennett as a hostile witness and cross-examine her based

upon incorrect factual assertions by Prosecutor Love that Ms. Bennett communicated/texted that this

Honorable Court could “kiss her a*s.” (See text messages introduced into evidence by Prosecutor

Love’s factual basis put forth at trial before the jury and this Honorable Court).

13.

Prosecutor Love asked Ms. Bennett a series of leading questions starting with “isn’t it

true you told me. . .?” as well as “isn’t it true that I told you. . .?” Prosecutor Love will be taken

to task on these questions which include, but are not limited to, the seeming misrepresentation

that Ms. Bennett was defiant and cursed at this Honorable Court in text messages. Same is not

born out by the text messages Prosecutor Love introduced at trial.

14.

In the case at issue, Prosecutor Love voluntarily, unequivocally, repeatedly and specifically

referenced conversations between herself and Ms. Bennett in a vehicle, on a Courthouse bench, in

text messages and relied upon her own memory and her own unsworn repetition of Ms. Bennett’s

statements. Prosecutor Love challenged Ms. Bennett as to material facts through her questioning.

Mr. Williams has the right to exercise his Constitutional mandates and cross-examine this

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prosecutor. Otherwise, a mistrial must be granted as Mr. Williams was goaded into requesting same

by the prosecutor.

15.

As held in United States v. Locasio, supra, this prosecutor has injected herself into

participating in events that have been exploited at trial and therefore, has conveyed first hand

knowledge of events without being sworn under oath as a witness subject to cross-examination. This

violates Mr. Williams’ above-discussed Constitutional rights. Moreover, by challenging the

Honorable Attorney Adams’ questioning of Ms. Bennett on proper cross-examination that this May

12, 2013, Mother’s Day incident was a theft by a third party of Ms. Bennett’s and Mr. Anderson’s

drugs and same was unknown to Mr. Williams and when Mr. Williams learned about this theft, Mr.

Williams apologized for “Buc Buc’s” theft and repaid for these drugs. However, the prosecutor,

being unsworn, improperly blurted out in front of the jury that Attorney Keith Adams’ question had

no factual basis, was not true and that there is no witness, whatsoever, on the Witness List or

otherwise that would support Attorney Adams’ inquiry. These “facts” testified to by unsworn

Prosecutor Love were not objections to a question posed during cross-examination but were

improper injections of testimony by the unsworn prosecutor which mandate that Mr. Williams must

confront the misstatement as well.

16.

Also, it is relevant that Brady was violated as Prosecutor Love failed to disclose to Mr.

Williams (until it came out when Ms. Bennett did not appear for trial testimony in March 2024) that

(1) Ms. Bennett stated in November, 2023, that she did not remember any of the events on May 12,

2013–a statement subject to be revealed under Brady v. Maryland, 373 U.S. 83, 83 S. Ct. 1194, 10

L.Ed.2d 215 (1963); (2) that Ms. Bennett felt threatened by Prosecutor Love to the point that she

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wanted to harm herself– (this Brady evidence goes to impeachment by mental health as well as

potential strong arm conduct by the prosecutor and her office). These text messages were not

revealed to Mr. Williams until Mr. Williams asked, on multiple occasions, for this Honorable Court

to Order the prosecution to reveal same pursuant to Ms. Bennett’s claim that she was being sexually

harassed by the District Attorney’s investigator. All of the above, plus other unstated topics, must

be confronted on cross-examination of Prosecutor Love as to why this exculpatory, impeachment

Brady evidence was not turned over to Mr. Williams in a timely manner. Further, Mr. Williams will

cross-examine Prosecutor Love on the fact that she potentially did not reveal all text messages when

Ordered to do so by this Honorable Court between her and Ms. Bennett and that the arrest of Ms.

Bennett, on video, was not given to Mr. Williams until Ordered by this Honorable Court, well after

Ms. Bennett’s direct testimony and cross-examination at trial already occurred.

17.

The practice of trial lawyers testifying at trial is not approved by the Courts except where

made necessary by the circumstances of the case. See Levin v. State, 222 Ga. App. 123, 473 S.E.2d

582 (1996). Prosecutor Love’s sworn testimony has been made necessary by Prosecutor Love’s own

voluntary conduct at trial. Ordering Prosecutor Love to become a witness in this case and

withdrawing as a trial prosecutor is necessary to preserve Mr. Williams’ above-referenced

Constitutional rights. Prosecutor Love voluntarily injected conversations that she had personally,

whether by text message or in person, with Ms. Bennett and hence, attempted to impeach Ms.

Bennett with prior inconsistent statements made to Prosecutor Love, alone, that Mr. Williams has

the Constitutional right to explore. See Galvin v. State, 330 Ga. App. 589(2), 768 S.E.2d 773 (2015).

18.

If a lawyer is both counsel and witness as Prosecutor Love has made herself in the case at bar,

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the opposing party, to wit: Mr. Williams, is handicapped in challenging the credibility of Prosecutor

Love since Prosecutor Love also appears as an advocate in the case. An advocate who becomes a

witness is in the unseemly and ineffective position of arguing her own credibility. The roles of an

advocate and of a witness are inconsistent as the function of an advocate is to advance or argue the

case of another while that of a witness is to state facts objectively. Furthermore, where the question

arises at it does in this case whether Prosecutor Love should be disqualified from continuing as a trial

prosecutor, doubts should be resolved in favor of the lawyer testifying and against her continuing

as an advocate. See Castell v. Kemp, 254 Ga. 556, 331 S.E.2d 528 (1985). Moreover, our Highest

Court has explained that when a lawyer becomes a witness in the case, the lawyer should leave the

trial of the case to other counsel. Castell v. Kemp, supra. Prosecutor Love has placed her credibility

as an unsworn witness squarely in front of the jury and this causes innumerable threats to the

integrity and reliability of our judicial process. Castell v. Kemp, supra. The rules of the Code of

Professional Responsibility do have the effect of law. Cambron v. Canal Insurance Co., 246 Ga. 147,

151, 269 S.E.2d 426 (1980). Although couched in aspirational terms, these Rules of Professional

Responsibility cannot be ignored if Courts are to maintain integrity and credibility of our judicial

process. Castell v. Kemp, supra.

19.

As noted by the Honorable Eleventh Circuit Court of Appeals, it would be improper for a

Government attorney who has independent and personal knowledge about facts that will be

controverted at the trial to act as a prosecutor if she uses that inside information to testify indirectly

by implying to the jury that she has personal knowledge or insight. See United States v. Hosford, 782

F.2d 936, 939 (11th Cir. 1986). Moreover, disqualification of Prosecutor Love is warranted since this

prosecutor made statements before the jury insinuating or eluding to personal knowledge. United

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States v. Prantil, 764 F.2d 548, 555-556 (9th Cir. 1985). In the case at bar, Prosecutor Love has

already influenced the jury or at least attempted to influence the jury to find her credible rather than

find Attorney Keith Adams credible or Witness Bennett credible through her personal involvement

in the facts of this case. This is not permissible and Prosecutor Love must be disqualified from

continuing as a trial prosecutor in this case.

WHEREFORE, Mr. Williams respectfully requests a hearing on this Motion and at the

conclusion of same, asks this Honorable Court

(i) to remove/disqualify Prosecutor Love as a trial prosecutor on this case;

(ii) that Prosecutor Love be made available as a witness or,

(iii) that a mistrial be declared based upon prosecutorial misconduct by Prosecutor Love

injecting herself into the controversy at issue, placing her credibility at issue to now

be decided by the trial jury which creates an unfair, unsworn witness problem for Mr.

Williams.

The prosecutor’s voluntary conduct denies Mr. Williams his right to confrontation, a fair trial

and Due Process under the applicable sections of the United States Constitution and Georgia

Constitution and it constitutes a violation of the above-cited ethical rules.

This 1st day of April, 2024.

Respectfully submitted,

/s/ Brian Steel

BRIAN STEEL
GA Bar No. 677640
The Steel Law Firm, P.C.
1800 Peachtree Street NW, Suite 300
Atlanta, Georgia 30309
(404) 605-0023 (office)

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 (404) 352-5636 (fax)
[email protected]

/s/ Keith Adams, Esq.

KEITH ADAMS, ESQ.
GA Bar No. 003655
Keith Adams & Associates, LLC
315 W. Ponce de Leon Avenue Suite 602
Decatur, GA 30030
(404) 373-3653

Attorneys for Mr. Williams

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 CERTIFICATE OF SERVICE

This is to certify that I have this day served a copy of the within and foregoing

MOTION TO ENFORCE THE DISQUALIFICATION OF PROSECUTOR LOVE WHO

HAS MADE HER CREDIBILITY CENTRAL TO THE TRIAL AND THUS, HAS BECOME

AN UNSWORN WITNESS IN VIOLATION OF (1) MR. WILLIAMS’ CONSTITUTIONAL

RIGHTS TO DUE PROCESS; CROSS-EXAMINATION/CONFRONTATION; AND A FAIR

TRIAL AND (2) GEORGIA RULES OF PROFESSIONAL CONDUCT 3.7(a) AND 8.4(a)(1)

via electronic filing as well as via e-mail to the following:

[email protected]
[email protected]
[email protected]
[email protected]
Demetrius Smith, Esq.
Adriane Love, Esq.
Simone Hylton, Esq.
Dane Uhelski, Esq.
Fulton County District Attorney’s Office
136 Pryor Street SW
Atlanta, GA 30303

This 1st day of April, 2024.

Respectfully submitted,

/s/ Brian Steel

BRIAN STEEL
GA Bar No. 677640
Attorney for Mr. Williams

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