Fulton County Superior Court

***EFILED***NY
Date: 2/21/2023 10:07 PM
Cathelene Robinson, Clerk

STATE’S MOTION FOR ORDER RE-ENFORCING COURT’S DIRECTIVE

PROHIBITING DISSEMINATION OF DISCOVERY PURSUANT TO
O.C.G.A. § 17-16-4(d)

The State of Georgia, by and through the District Attorney FANI T. WILLIS, hereby moves

this Honorable Court for an order re-enforcing the Court’s directive to ALL PARTIES

PROHIBITING THE DISSEMINATION OF DISCOVERY, pursuant to O.C.G.A. § 17-16-

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4(d), and for an order permitting the State to serve upon counsel for the defense any and all future

media containing witness interviews solely by making any said media available to the defense for

viewing only in the offices of the Fulton County District Attorney. Further, the State moves the

Court for an Order prohibiting any recording of any such media during review by counsel for

the defense and for an Order for an investigation into the person or persons responsible for

violating the Court’s Order Restricting Disclosure of Discovery Material dated September 9,

2022 and disseminating Discovery as shown below. In support of this motion, the State shows this

Honorable Court the following.

1. CHAIN OF EVENTS LEADING TO RESTRICTIONS ON DISCOVERY

On July 11, 2022 and August 2, 2022, the state provided Discovery to Defendants via

Dropbox links emailed only to counsel for the defendants, which included interviews of witnesses

whom the State intends to call during the trial of this case. Subsequent to Discovery being emailed

only to counsel for the defendants on trial in this case, one or more persons unknown to the

District Attorney and the State of Georgia disseminated copies of said Discovery and allowed for

it to be shared online at various public and social media sites.

As a direct result of this reckless dissemination of evidence to parties outside of the litigants

in this case, apparently intended to interfere with, hinder, or otherwise discourage witnesses from

testifying truthfully in these proceedings, the State moved this Honorable Court for an order

restricting further dissemination of Discovery as follows:

1) Exclusion of the contact information and home addresses of any and all State’s
witnesses not otherwise contained in the discovery;
2) Restriction of the information on proffers and statements of cooperating gang
members until 30 days prior to trial;
3) Counsel for defendants being prohibited from sharing any discovery material
with non-members of the defendants’ legal teams and all parties being
prohibited from publicly sharing any discovery material; and

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 4) Alternatively, should this Court require the State to provide the names and
contact information of all witnesses, the State requests this Court order all
defense counsels, as officers of the Court, to keep the witness lists in their sole
possession, and not provide those witness lists to their defendants, defendants’
family members, or any other individuals unless first ordered by the Court.

The Court granted the State’s motion to restrict Discovery and entered the Order Restricting

Disclosure of Discovery Material Pursuant to O.C.G.A. § 17-16-4(d) on September 9, 2022,

which, in pertinent part, provides the following:

4) Defense counsel is prohibited from sharing discovery with non-members of the

defense team. Defense counsel may meet with potential witnesses and show
discovery information to those potential witnesses as needed, but defense counsel
must prohibit those witnesses from recording, photographing, taking notes, or
receiving a copy of any discovery materials.
5) All parties are prohibited from sharing discovery material with any news media
sources, social media, or other public forums.

(Emphasis supplied).

2. RECENT VIOLATIONS OF THE COURT’S ORDER RESTRICTING

DISCOVERY

In early January 2023, counsel for the defendants moved the Court to require that the State

download all Discovery to a hard drive to be provided to counsel for the defendants. The Court

granted the defendants’ motion and mandated that the State download all available Discovery to a

hard drive and provide said hard drive to the defense. On January 25, 2023, the State served upon

the defense additional Discovery by sending to only counsel for the defendants on trial in this

case additional Discovery via electronic mail, and the State complied with the Court’s directive to

provide a hard drive containing Discovery to the defense. Included within the Discovery provided

to the defense on this date was an interview of a witness by two law enforcement officers. This

video interview had remained in the State’s possession for over a year without incident.

Less than 30 days after the video had been requested by and provided to the defense

in a medium that could be readily duplicated and released to the public, the entirety of this video

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 4) Alternatively, should this Court require the State to provide the names and
contact information of all witnesses, the State requests this Court order all
defense counsels, as officers of the Court, to keep the witness lists in their sole
possession, and not provide those witness lists to their defendants, defendants’
family members, or any other individuals unless first ordered by the Court.

The Court granted the State’s motion to restrict Discovery and entered the Order Restricting

Disclosure of Discovery Material Pursuant to O.C.G.A. § 17-16-4(d) on September 9, 2022,

which, in pertinent part, provides the following:

4) Defense counsel is prohibited from sharing discovery with non-members of the

defense team. Defense counsel may meet with potential witnesses and show
discovery information to those potential witnesses as needed, but defense counsel
must prohibit those witnesses from recording, photographing, taking notes, or
receiving a copy of any discovery materials.
5) All parties are prohibited from sharing discovery material with any news media
sources, social media, or other public forums.

(Emphasis supplied).

2. RECENT VIOLATIONS OF THE COURT’S ORDER RESTRICTING

DISCOVERY

In early January 2023, counsel for the defendants moved the Court to require that the State

download all Discovery to a hard drive to be provided to counsel for the defendants. The Court

granted the defendants’ motion and mandated that the State download all available Discovery to a

hard drive and provide said hard drive to the defense. On January 25, 2023, the State served upon

the defense additional Discovery by sending to only counsel for the defendants on trial in this

case additional Discovery via electronic mail, and the State complied with the Court’s directive to

provide a hard drive containing Discovery to the defense. Included within the Discovery provided

to the defense on this date was an interview of a witness by two law enforcement officers. This

video interview had remained in the State’s possession for over a year without incident.

Less than 30 days after the video had been requested by and provided to the defense

in a medium that could be readily duplicated and released to the public, the entirety of this video

3
the State moves this Honorable Court to order an investigation into the person or persons

responsible for the unlawful dissemination of the witness interview referenced in this motion.

3. CONCLUSION

For the reasons raised in the State’s July 5, 2022 and August 15, 2022 motions, and for the

reasons provided in the instant motion, the State urgently repeats its significant safety concerns

for all officers, lay witnesses, cooperating witnesses, and potential cooperating co-defendants who

may be called as witnesses in this trial. The State thus supplements its July 5, 2022 and August 15,

2022 motions and moves this Court to restrict Discovery pursuant to O.C.G.A. § 17-16-4(d) such

that all subsequent Discovery items provided by the State consisting of audio and visual tapes,

films, and recordings (and any associated transcripts) shall be made available to defense counsel

only by inspection within the Office of the Fulton County District Attorney at a time agreed to

by the parties or as ordered by the court and SHALL NOT be copied, duplicated, or reproduced

in any way by defense counsel. The State further moves this Court to order an investigation into

the person or persons responsible for leaking the aforementioned media evidence in direct violation

of this Court’s order.

Respectfully submitted this 21st day of February, 2023.

/s/ Fani T. Willis

Fani T. Willis
District Attorney
Atlanta Judicial Circuit
Georgia Bar Number: 223955

/s/ Adriane Love

Adriane Love
Deputy District Attorney
Atlanta Judicial Circuit
Georgia Bar Number: 458998

5
 IN THE SUPERIOR COURT OF FULTON COUNTY

STATE OF GEORGIA

STATE OF GEORGIA, )
) CASE NO.: 22SC183572
vs. )
)
KAHLIEFF ADAMS, et. al. )
Defendants )

CERTIFICATE OF SERVICE

I hereby certify that a copy of the foregoing:

STATE’S MOTION FOR ORDER RE-ENFORCING COURT’S DIRECTIVE

PROHIBITING DISSEMINATION OF DISCOVERY PURSUANT TO
O.C.G.A. § 17-16-4(d)

Was served via e-file to:

E. Jay Abt, Esq. (Deamonte Kendrick)

2295 Parklake Drive, Suite 525
Atlanta, GA 30345

Katie Hingerty, Esq. (Deamonte Kendrick)

The Hingerty Law Firm, LLC
2295 Parklake Drive, Suite 525
Atlanta, GA 3034

Doug Weinstein, Esq. (Deamonte Kendrick)

2295 Parklake Drive, Suite 525
Atlanta, GA 3034

Durante Partridge, Esq. (Derontae Bebee)

1372 Peachtree Street NE, Suite 3121
Atlanta, GA 30309

Brian Steel, Esq. (Jeffery Williams)

The Steel Law Firm, P.C.
1800 Peachtree Street, Suite 300
Atlanta, GA 30309

6
Bruce Harvey, Esq. (Quamarvious Nichols)
146 Nassau Street
Atlanta, GA 30303

Suri K. Chada, Esq. (Cordarius Dorsey)

The Chadha Jimenez Law Firm
4480 South Cobb Drive Suite H #181
Smyrna, GA 30080

Angela D’Williams, Esq. (Rodalius Ryan)

Supreme Law Firm
2180 Satellite Blvd, Suite 400
Duluth, GA 30097

This 21st day of February, 2023.

/s/ Fani T. Willis

Fani T. Willis
District Attorney
Atlanta Judicial Circuit
Georgia Bar No. 223955

/s/ Adriane Love

Adriane Love
Deputy District Attorney
Atlanta Judicial Circuit
Georgia Bar Number: 458998

8
Bruce Harvey, Esq. (Quamarvious Nichols)
146 Nassau Street
Atlanta, GA 30303

Suri K. Chada, Esq. (Cordarius Dorsey)

The Chadha Jimenez Law Firm
4480 South Cobb Drive Suite H #181
Smyrna, GA 30080

Angela D’Williams, Esq. (Rodalius Ryan)

Supreme Law Firm
2180 Satellite Blvd, Suite 400
Duluth, GA 30097

This 21st day of February, 2023.

/s/ Fani T. Willis

Fani T. Willis
District Attorney
Atlanta Judicial Circuit
Georgia Bar No. 223955

/s/ Adriane Love

Adriane Love
Deputy District Attorney
Atlanta Judicial Circuit
Georgia Bar Number: 458998

8
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