Fulton County Superior Court

***EFILED***NY
Date: 5/23/2022 12:00 AM
Cathelene Robinson, Clerk

IN THE SUPERIOR COURT OF FULTON COUNTY

STATE OF GEORGIA

STATE OF GEORGIA, )
) INDICTMENT NO. 22SC182273
)
v. )
)
JEFFERY WILLIAMS, ) JUDGE GLANVILLE
Defendant. )

BRIEF IN SUPPORT OF PRETRIAL RELEASE/PRETRIAL BOND

COMES NOW Defendant, Jeffery Williams, by and through undersigned counsel, and

hereby files this Brief in Support of Pretrial Release/Pretrial Bond in the above-referenced case.1 In

support of this Brief, Mr. Williams shows the below.

In the Great State of Georgia, unlike other States, for purposes of pretrial bond analysis, the

presumption of innocence remains with the person accused of an offense, even a capital offense,

from arrest and even during trial. See Vanderford v. Brand, 126 Ga. 67, 70, 54 S.E. 822 (1906). That

means, prior to trial, Courts view the criminally accused to be innocent of the charges waged against

him/her. It has been written that the most fundamental premise of our criminal justice system is that

the criminally accused cannot be punished for an offense until the prosecution proves guilt beyond

a reasonable doubt. 2 ABA, Standards for Criminal Justice 10-1.1 Comment (1980). Thus, the

granting of a reasonable pretrial bond must be preserved. Otherwise, the presumption of innocence,

secured only after centuries of struggle, would lose its meaning. See Stack v. Boyle, 342 U.S. 1, 4,

1
Mr. Williams also asks this Honorable Court to set bond in Case Number 22CP208957, that
charges Mr. Williams, via Warrants, with three (3) counts of Criminal Street Gang Activity,
Possession of a Firearm during the Commission of a Crime, Possession of Marijuana with Intent to
Distribute and V.G.C.S.A charges.

The Steel Law Firm, P.C. 1800 Peachtree Street, N.W., Suite 300, Atlanta, Georgia 30309 (404) 605-0023

1
72 S. Ct. 1, 96 L.Ed. 3 (1951). In order to protect our firm, foundational belief that the accused is

presumed to be innocent prior to a finding of guilt beyond a reasonable doubt, the prosecution, alone,

has the burden of persuasion in convincing this Honorable Court that there are no set of conditions

or circumstances that can be Ordered to permit Mr. Williams pretrial release on bond. 2 ABA,

Standards for Criminal Justice 10-5.10(d)(e)(Supp. 1986)(the State bears the burden of proving by

clear and convincing proof that pretrial detention is warranted); Ayala v. State, 262 Ga. 704 (fn. 4),

425 S.E.2d 282 (1993).This requires the prosecution to carry the burden of proving, by

preponderance of the evidence, that this Honorable Court must deny Mr. Williams’ Motion for bail,

outright, rather than set bond with conditions of same in order to ensure Mr. Williams’ presence in

Court and to protect the community. See Ayala v. State, 262 Ga. 704, 425 S.E.2d 282 (1993).

It is so significant to deny Mr. Williams pretrial bond, that the Honorable Supreme Court of

Georgia requires this Honorable Court to specifically explain why no bond could be set so our

Higher Courts can evaluate whether there was a flagrant abuse of discretion when reaching that

decision. See Lane v. State, 247 Ga. 387, 389, 276 S.E.2d 644 (1981). When considering pretrial

bond, alleged guilt is extraneous, is completely irrelevant and not considered for the pretrial bond

analysis as supposed guilt has no place in the bail proceeding since Mr. Williams is presumed

innocent. Cowards v. State, 266 Ga. 191(2), 465 S.E.2d 677 (1996); Yorker v. State, 266 Ga. 615,

469 S.E.2d 158 (1996).

Our Highest Court explained that in a pretrial bond hearing, Mr. Williams bears the initial

burden of producing evidence that he would:

(i) not pose a significant risk to flee the jurisdiction and would return to Court when

required;

The Steel Law Firm, P.C. 1800 Peachtree Street, N.W., Suite 300, Atlanta, Georgia 30309 (404) 605-0023

2
 (ii) not be a significant threat or danger to the community or to any person or property

in the community;2

(iii) not be a significant risk to commit a felony while on bond; and

(iv) not be a significant risk to intimidate witnesses or otherwise obstruct the

administration of justice.

See Ayala v. State, supra.

(i) Mr. Williams is Not a Flight Risk

To meet this burden, Mr. Williams must first present evidence showing his roots in the

community which would include the length and character of residence in the community,

employment status and past history of responding to legal process. See Dunn v. Edwards, 257 Ga.

458(1), 569 S.E.2d 525 (2002).

Mr. Williams was born and raised in the Jonesboro South section of Atlanta, Georgia. Since

birth in August, 1991, Mr. Williams has maintained residence in Atlanta, Georgia. Although Mr.

Williams has traveled the globe, has performed his music and artistry in every continent, save

Antarctica, he always returns to his homes in the Atlanta, Georgia area. In fact, on Sunday, May 8,

2022, the day before the return of the above-referenced Indictment and the arrest of Mr. Williams,

Mr. Williams returned to Atlanta, Georgia from the Country of Norway where he performed in front

of a large audience. Mr. Williams is one (1) of eleven (11) children and he is the father of six (6)

children, ages 14, 11, 10, 9, 7 and 7. All of Mr. Williams’ family lives in the Atlanta, Georgia area

including his parents. There is not many among us who has stronger roots in our community than

2
When the Trial Court makes a finding concerning a supposed threat to the community, this
finding is the equivalent to whether the accused would be a significant risk to commit a crime. See
Williams v. State, 228 Ga. App. 289, 491 S.E.2d 500 (1997).

The Steel Law Firm, P.C. 1800 Peachtree Street, N.W., Suite 300, Atlanta, Georgia 30309 (404) 605-0023

3
Mr. Williams.

Mr. Williams has been working since he was six (6) years of age. At age fourteen (14), he

was recognized and began performing his music for audiences. As a teenager, he had a manager and

within a few years, Mr. Williams was signed by Atlantic Records and was paid one million

($1,000,000.00) dollars. Mr. Williams is currently gainfully employed, tirelessly works at his artistry

and other lawful business ventures that include clothing lines, modeling, owner of a successful

record label and various investments. (See Exhibits F, G, H, I, J, K, L, M, N, O, P, Q, R and S,

attached hereto). Mr. Williams has demonstrated a strong history of lawful employment.

Mr. Williams has appeared in Courts in the past, represented by undersigned lead counsel,

Brian Steel, for approximately a decade, to wit: Mr. Williams’ entire adult life. Mr. Williams has

never missed nor been late for a Court appearance. Mr. Williams has a history of responding to the

legal process. (See Exhibit E, letter from Mr. Geoff Ogulesi, explaining, among other facts, how Mr.

Williams turned himself into custody when he was notified of a warrant). Undersigned counsel is

in possession of Mr. Williams’ passport and has permission to surrender this passport as directed by

this Honorable Court for purposes of bond. Furthermore, when a bonding company writes a bond

for the criminally accused, that company takes financial risk in ensuring the criminally accused’s

presence in Court. In the case at bar, Free At Last Bonding Company has agreed to write any bond

set by this Honorable Court and the representatives of Free At Last Bonding Company are motivated

to keep track of Mr. Williams and prevent any possible flight. See Easy Out Bonding v. State, 224

Ga. App. 706, 481 S.E.2d 834 (1997)(the bonding company is additional evidence that the accused

will return to Court when required to do so).

Mr. Williams intends to present witnesses to testify at the Monday, May 23, 2022, bond

The Steel Law Firm, P.C. 1800 Peachtree Street, N.W., Suite 300, Atlanta, Georgia 30309 (404) 605-0023

4
hearing. Specifically, Mr. Williams’ parents, managers, members of his record label, childhood

friends, business associates and the like will be present in Court to show support for the granting of

pretrial bond for Mr. Williams.

(ii) Mr. Williams is Not a Significant Threat to the Community or to Any Person or

Property in the Community3

Mr. Williams has taken the initiative to secure the commitment of full time off-duty sworn

law enforcement officers to watch his home and secure him in his home twenty four (24) hours/seven

(7) days a week, if house arrest is Ordered by this Honorable Court as a condition of pretrial bond.

Mr. Williams will also submit to wearing an ankle monitor if Ordered by this Honorable Court as

a condition of pretrial bond. Mr. Williams will submit to a condition that any person who would visit

him at his abode would have to be on an approved list provided to this Honorable Court as well as

the District Attorney’s Office and if the individual’s name is not on this list, that person will be

denied entry to his home. Moreover, any visitor will have to consent to being searched, physically

and electronically, by the off-duty sworn police officer and if the visitor does not agree to consent

to this search, the person will be prohibited from visiting with Mr. Williams. (See Exhibit A,

attached hereto, May 20, 2022, letter from Private Investigator Mittelstadt). Mr. Williams also agrees

that any of his text messages, telephone calls, e-mails or other forms of communication, in any

manner, can be secured and the information provided to this Honorable Court, if desired, as if Mr.

Williams was in custody and on a recorded line.4 The cost of the twenty four hour/seven days per

week off-duty sworn police officer detail as well as the cost of the ankle monitor (and any other

3
See Footnote 2, supra.
4
This, of course, would not apply to privileged communications.

The Steel Law Firm, P.C. 1800 Peachtree Street, N.W., Suite 300, Atlanta, Georgia 30309 (404) 605-0023

5
related costs) would be incurred by Mr. Williams. With these parameters in mind, it cannot be said

that Mr. Williams would be a threat or a danger to the community or any person or property in the

community. Undersigned counsel will agree to meet with Mr. Williams at his home to prepare for

Motions and trial.

The above conditions place Mr. Williams in custody in his home. See Brown v. State, 314

Ga. App. 1, 723 S.E.2d 112 (2012). Specifically, our General Assembly has provided for the creation

of electronic pretrial release to assist Sheriffs in alleviating jail overcrowding by creating alternative

methods of pretrial release, monitoring and home confinement. The Legislature found that electronic

pretrial release, monitoring and home confinement incorporates modern technology to accomplish

various purposes. Therefore, our General Assembly explicitly recognizes that Mr. Williams’ home

is a place where he can be confined and restricted in movement for the purpose of electronic pretrial

release on bond. See Brown v. State, 314 Ga. App. 1, 723 S.E.2d 112 (2012). Ordering Mr. Williams

to wear an ankle monitor and to be in “total lockdown” in his home is the equivalent to custody and

confinement and has been deemed lawful confinement without the punishment imposed by the

current County Jail conditions wrongly imposed on Mr. Williams. See Brown v. State, supra.

Currently, Mr. Williams endures the torturous conditions in the County Jail, to wit: twenty two (22)

out of twenty four (24) hours a day locked into a small cement cell with no contact with another

human being except when his counsel visits; inedible food; living in squalor-ant infested room and

unable to see any activity/movement out of the cell’s “windows.” Further, when Mr. Williams was

first arrested and housed in solitude/isolation, he was not permitted to shower day after day and had

The Steel Law Firm, P.C. 1800 Peachtree Street, N.W., Suite 300, Atlanta, Georgia 30309 (404) 605-0023

6
worn the same underwear day after day.5 Every forty five (45) minutes, a Sheriff’s Official bangs on

Mr. Williams’ cell door to ensure that he is alive, causing restful sleep impossible.

(iii) Mr. Williams is Not a Significant Risk to Commit a Felony While Out on Bond

Mr. Williams is not a convicted felon. This fact, alone, satisfies this bond factor. Moreover,

law enforcement officers executed a Search Warrant on or about Monday, May 9, 2022, after the

arrest of Mr. Williams on this Grand Jury Indictment and incident to the search, drugs and guns were

allegedly located in this home. At the time of this search there were numerous people at/in Mr.

Williams’ home. This is because others live at this home more often than Mr. Williams, who is at

this home intermittently, as Mr. Williams has several homes in the Atlanta area. Mr. Williams did

not own any illegal gun and was not in possession of any illegal drug. In fact, Mr. Williams has been

consistently drug tested since November 26, 2018 as part of his pending lower level DeKalb County

case. Mr. Williams does not use any Schedule II, III or IV drug. Witnesses are prepared to testify as

to who resides in this home and that the drugs and illegal guns did not belong to Mr. Williams.

Further, the licensed, highly respected counselor who personally drug tested Mr. Williams will be

present in Court to testify to the above, if needed. Thus, Mr. Williams is not a significant risk to

commit a felony while out on bond, especially with the use of the security and other conditions

offered above. Since Mr. Williams is not a significant risk to commit a crime, he is also not a

significant threat to the community, property or person in same. See Williams v. State, supra.

(iv) Mr. Williams is Not a Significant Risk to Intimidate Witnesses or Otherwise Obstruct

the Administration of Justice

5
Some, not much, of this treatment of Mr. Williams ceased shortly after the Emergency
Motion for a Bond Hearing and/or for More Humane/Non-Torturous In Custody Housing for Mr.
Williams was filed on Friday, May 13, 2022.
The Steel Law Firm, P.C. 1800 Peachtree Street, N.W., Suite 300, Atlanta, Georgia 30309 (404) 605-0023

7
 Mr. Williams has suggested as a condition of bond that all of his calls, text messages and

other means of communication are to be monitored, save privileged communications, and

additionally, he will be secured in his home. This will prevent any possibility to intimidate a witness

or otherwise obstruct the administration of justice via electronic means. In today’s times, the

Legislature has provided that ankle monitors are a humane method of incarcerating a criminally

accused, without the need for punishment that is endured by languishing in the County jail. See

Brown v. State, supra.

This Honorable Court’s foremost consideration with fixing the amount of bail should be the

probability that Mr. Williams, if granted bond, will appear at trial. See Hernandez v. State, 294 Ga.

App. 289, 669 S.E.2d 434 (2008). Mr. Williams is a respected, high profile artist who has positively

impacted lives of others who would otherwise never break the poverty line. Mr. Williams has made

a tremendous, positive impact in our community. (See Exhibits B, C, D and E). Mr. Williams is a

positive member of society. He will lawfully and ethically fight these baseless charges. Governed

by the above facts and law, Mr. Williams satisfies all four (4) prongs of the Ayala v. State, supra,

test.

Mr. Williams satisfies these four (4) bond factors and thus, the burden of production falls

onto the prosecution and the prosecution always retains the burden of persuasion that there are no

conditions of bond that can be crafted to permit Mr. Williams to be entitled to pretrial release,

whatsoever. See Dunn v. Edwards, 275 Ga. 458(1), 569 S.E.2d 525 (2002). In our society, liberty

is the norm. Custodial detention prior to trial is carefully limited to few people. See United States

v. Salerno, 481 U.S. 739, 755, 107 S. Ct. 2095, 95 L.Ed.2d 697 (1987). Indeed, the most important

element of liberty is to be free from physical detention by one’s own Government. See Hamdi v.

The Steel Law Firm, P.C. 1800 Peachtree Street, N.W., Suite 300, Atlanta, Georgia 30309 (404) 605-0023

8
Rumsfeld, 542 U.S. 507, 124 S. Ct. 2633, 159 L.Ed.2d 578 (2004); Carr v. State, 303 Ga. 853(3),

815 S.E.2d 903 (2018).

Based upon the above, Mr. Williams must be granted a reasonable bond with conditions of

same.

WHEREFORE, Mr. Williams respectfully requests a reasonable bond be set by this

Honorable Court with reasonable conditions of same.

This 22nd day of May, 2022.

Respectfully submitted,

/s/ BRIAN STEEL

BRIAN STEEL
GA Bar No. 677640

/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

The Steel Law Firm, P.C. 1800 Peachtree Street, N.W., Suite 300, Atlanta, Georgia 30309 (404) 605-0023

9
EXHIBIT A
ATTACHMENT “A”

The following is the list of officers on standby to assist Mr. Williams at his residence 24 hours a
day, 7 days a week:

NOTE: Several of these officers are SWAT and have experience transporting high-profile and
high risk defendants.
EXHIBIT B
Fulton County Judge & Courts May 18, 2022
Re: Jeffrey Williams

My name is Jamil Mitchell, and I’m a youth football coach,businessman,

music manager, music a&r and nonprofit organization owner. I’ve always
been big on doing the right thing for my community because as a child
growing up in a poverty stricken area a lot of people didn’t care about the
future of our children.Thats the main reason I started a nonprofit organization
called the Cleveland Avenue 49ers Youth Development Organization so that
the children knows it’s people that really care about their future and don’t
want them to go through hard times like us. I pride myself on being there for
anything positive coming from the neighborhood I was raised in. From
helping doing community clean ups to doing givebacks with some of the
great recording artist’s that come from my side of town. The whole goal is to
show the kids it’s more to life than the hard times and poverty they’ve seen
everyday.

I’ve known Mr. Williams for a long period of time and all I can really say
about him is really great things. He’s always been there for me with any
venture I’ve had coming up. From when I used to promote parties, he would
show up out of the love to come and check on me and make sure the event
was doing good. He would even perform and don't get paid for it cause he
wanted to see other people prosper. When I started my nonprofit organization
back in 2020 he helped give back by buying my whole organization of 75
boys uniforms. On banquet days he would buy trophies for my football
players and cheerleaders even if he wasn't in Atlanta he made sure the kids
were good.
During hard times when covid hit he helped me with my online bookstore by
giving me a donation to buy more books so I could still provide for my
family. The things this man has done for his community is astounding
because I’ve seen him do a lot of great things in private. A lot of kids' futures
became bright once Mr. Williams made it to the big stage because they got a
chance to see a person from their area become a super star and knew it was
possible for them to become one also. He’s the major motivation that we all
needed because he gave the neighborhood hope and showed us all that we
just have to believe and keep following our dreams and knock out the small
goals. Now we have kids becoming artist’s,producers,managers and even
actors because they’ve seen Mr.Williams do it and they know if he can
become a worldwide star then they can also. That right there changed the
community forever. Instead of them looking up to negative people as role
models they now have a person doing overly great to mold themselves after.

Mr. Williams is what I call the last of a dying breed because he’s actually
given children and grown ups hope to become financially stable to take care
of their families and loved ones. He’s donated to plenty of other people
givebacks and community events. He’s made plenty of people millionaires
and also six figures businessmen and women because he believes in giving
you a chance once he sees the passion and hard work. I feel like if Mr.
Williams was an athlete in the NFL he would most definitely get The Man Of
The Year Award because of all the work he does for his community silently
or in the media. I just hope yall see that the community needs him and look
up to him as a person who is a major motivator to the community, a person
who gives back and also is a loving father to his children and family
members. Thank you for taking your time to read this letter.

Sincerely,

Jamil Mitchell
EXHIBIT C
 May 17, 2002

The Honorable Ural Glanville

Fulton County Superior Court Judge
136 Pryor Street
Atlanta, GA 30303

RE: The State of GA vs Jeffery Williams II

Honorable Judge Ural Glanville,

My name is Amina Diop and I am the Founder and CEO of The Diop Agency. The
Diop Agency is a talent & management agency that represents several celebrities. I am also a
close family friend to the Williams and Grier families.

I had the pleasure of meeting Mr. Williams in 2013, in the beginning of his
professional career. I was immediately impressed by his talent, perfect-pitch, humility,
shyness, and all-around good nature. Mr. Williams has what we, in the industry refer to as,
“star quality”. He is always punctual, professional, and eager to work when he is sent on
assignment, and completes tasks in an exemplary fashion. These qualities catapulted him to
the very top of the music, entertainment, and fashion industries. He has won several awards
in this space and has contributed immensely to his community. Throughout our
acquaintance I have come to know Mr. Williams and his family intensely. He is very family
oriented and is a thoughtful father, brother, son, uncle, and cousin.

I understand that Mr. Williams has found himself in an unfortunate predicament.

However, I truly believe that he has learned from his life experiences and wants nothing
more than to be a good example to his fans, piers, community, and family members. Mr.
Williams is a very loving father and his six children, who are all based in Atlanta, need him.
Hopefully the court will take this letter into account upon his bond hearing. He is truly a
gem in our field and his voice is best served as a beacon of hope, inspiration, redemption,
and change.

Sincerely,

Amina Diop

THE DIOP AGENCY

4480 H South Cobb Driver #331
Smyrna, Georgia 30080
Office: 678-424-1210
HOURS OF OPERATION 11:00AM- 8:00PM
EXHIBIT D
From The Desk Of:
Trae Tha Truth
5202 Cedar St. Bellaire, TX 77401

traethatruthenterprises@outlook.com

Fulton County Judge & Courts May 16, 2022

Re: Jeffery Williams

My name is, Frazier Thompson, and I go by the stage rapper name of Trae Tha Truth.
I am a nationally acclaimed recording artist, philanthropist, activist, and
businessman. I pride myself on being hands on in then community with an intent to
not only assist in my immediate city of Houston, but the the entire U.S. For over 2
decades I have consistently led teams that have changed the lives of families with
an emphasis on those with at risk youth. I am a serial entrepreneur who has his
hands in a multiplicity of businesses My nonprofit organization, Angel By Nature's
mission is dedicated to improving lives for individuals who have been affected by
hardship and impoverishment.

Jeffery Williams has been like a little brother to me. Not only have we made music
and produced songs together but he has been alongside of me in some of my
most toughest times. I recently went through a custody battle with my child's
mother and Jeffery was instrumental in being a supportive factor that kept me
focused on the goals at hand, he provided emotional and mental health space to
keep me right. This man is bigger than a great rapper he is amazing human being.
As black men it is important to maintain a healthy support system. We come from
the struggle and we have to be the change we want to see. Jeffery has done just
that.

During our time knowing each other, Jeffery has been head first in my community
projects. This brother has been there through every hurricane, tornado, house fire,
and supply drives. He has flown to our city of Houston on his own dime to be a part
of change. During our annual Trae Day celebration, he does all that he can to put a
smile on the kids faces in our community. Not only that, but he turns right around
and does the same in the very community he is being held in jail at. Mr. Williams is
a loving person who cares about others and deserves to be free. With the efforts of
Jeffery every year we help over 100,000 across the country.

The community needs him as he gives daily to help the needs of others. I ask that
you please grant him a bond so he can get in and get back to serving the
community that he so greatly loves and cherishes. Thank you for taking the time to
review our letter.

Sincerely,

Frazier Thompson
Trae Tha Truth
 May 16, 2022
To: Fulton County Judge & Courts
Re: Jeffery Williams

Angel By Nature is a 501c3 nonprofit organization founded by rapper, Trae Tha Truth. The organization
was created in 2009 to bring change to the indigent, help those with financial deficits, and bring hope to
the community. The organization is dedicated to improving life for individuals who have been affected by
hardship and impoverishment, with emphasis on families with underserved youth. The mission that is
implemented provides help to the community and individuals in need despite any ailments. Annually we
provide a host of initiatives that Jeffery Williams has been a part of.

Our annual program initiative, Trae Day is our founder's Houstonian Holiday provides free concerts,
back to school supply giveaways, scholarships, medical health checks, and free immunizations to the
entire city. This event gives the area's children a chance to have a fun day for free with wild animals,
bounce houses, and much more. The event has a unique positioning as it allows area youth to connect and
have access to celebrities and artists that they couldn't afford concerts for. Jeffery has never missed an
opportunity to be a part of this event. He has signed autographs, passed out backpacks with supplies to
our program participants and given his time on many occasions. This makes a huge difference in the lives
of those we served. Many children have given testimonials saying that Mr. Williams has prevented talked
them into making healthy lifestyle choices due to his involvement with our program. Our Relief Gang
Initiative is where Mr. Williams goes above and beyond he has financially assisted us in the rebuilding of
homes, disaster relief efforts, our recent winter storm recovery efforts, and so much more. With his
finacial backing we have provided supplies and resources to over 100,000 people in 2021.

Jeffery has also assisted with boots on the ground in the community of Georgia, Fulton County, Houston,
and the other states that we have impacted throughout the years. Mr. Williams has been relentless with
implementing change to the lives of so many. We feel that his arrest is detrimental to the community.
There are so many people who count on him for assistance. Our own organization will be gravely
affected, We believe that if he is free he is a benefit to our community an beyond,

If you could please consider our letter as a support for Mr. Williams, we would appreciate it. Thank you
for considering this letter. I appreciate your time.

An ge l B y Nat u re & R e l ie f G a n g Team

EXHIBIT E
DocuSign Envelope ID: 56A5F31E-7FDF-4CF1-ABF8-75231DC1138B

May 20, 2022

The Honorable Judge Ural Glanville

Fulton County Superior Court
185 Central Avenue SW, T-8955
Atlanta, Georgia 30303

Re: State of Georgia v. Jeffery Williams et al., Case Number 22SC182273

Dear Judge Glanville:

My name is Geoff Ogunlesi, and I am currently Vice President of A&R for 300 Entertainment and Vice
President of Young Stoner Life Records, the record label created by Jeffery Williams and of which
Jeffery is the CEO. I have worked for 300 since its inception in 2014, and for Young Stoner Life Records
since its inception in 2016. With Jeffery and me at the helm, Young Stoner Life Records has become a
hugely-successful Black-owned company, enjoying millions of records sold. Additionally, since 2020, I
have been Jeffery’s personal manager. I have been working with Jeffery in one manner or another from
the start of his ascension to stardom, but our relationship transcends that of simply artist and label or
business partners: over the years we’ve also developed a deep friendship.

When I first met Jeffery, I knew right away he possessed the charisma and dedication to be a number one
artist. Shortly after his signing to 300, I vowed not to tweet until Jeffery had charted a number one record.
True to my word, I didn’t tweet until four years later, when he achieved the first of his three number one
albums since. And although Jeffery’s success as a recording artist and label owner is well documented
and he’s garnered critical praise from publications ranging from the New York Times to Rolling Stone,
what’s impressed me most over the years of our friendship is his unwavering dedication to his family and
sincere commitment to mentoring young talent.

Jeffery is the father of six children between the ages of seven and fourteen, first becoming a father while
still a teenager. Keeping his children close to him and remaining present in their lives is a priority for
Jeffery and he’s recently purchased a house in Atlanta so that they can live with him when he’s not on
tour away from home.

Jeffery has consistently prioritized the well-being of his family, even at the possible expense of his career.
For example, as a rising young artist in 2015, Kanye West reached out to Jeffery to collaborate. The
opportunity to work with an established superstar is rare and potentially transformative; however, when
Jeffery was told that his sisters could not accompany him to Kanye’s house, he declined the invitation to
work together rather than hurt his siblings’ feelings.

I have also personally seen how Jeffery’s generosity extends beyond just his relatives. He has, at his own
expense, mentored young artists who have then gone on to great success. When Sergio Kitchens p/k/a
“Gunna” was newly signed to Young Stoner Life Records, Jeffery paid out of his own pocket for Sergio
to travel on Jeffery’s UK tour with Drake so that the young artist could see what’s achievable by hard
work. Similarly, when Dominique Armani Jones, p/k/a “Lil Baby,” an artist who is not signed to or
associated with Young Stoner Life Records or 300, was a fledgling talent, Jeffery paid out of his own
pocket to keep him in the recording studio and off the streets. Both those young artists became two of the
most successful hip-hop artists in the world.
DocuSign Envelope ID: 56A5F31E-7FDF-4CF1-ABF8-75231DC1138B

Most importantly, Jeffery has shown respect for the law and has voluntarily complied with his legal
obligations in the past. In 2018, in the midst of his first ever US arena tour with J Cole, Jeffery learned of
a warrant for his arrest in Atlanta. Upon gaining this knowledge, he immediately left the tour, missing
several dates and significant income, in order to turn himself in. I have no doubt that Jeffery will similarly
comply with the obligations required of him upon his release if bail is granted.

I firmly believe that Jeffery is not a flight risk because of his commitment to his family and musical
career, both of which are firmly rooted in Atlanta. Jeffery has my full professional and personal support
as well as the support of 300, and I am confident that Jeffery would not risk damaging everything he has
built for himself by violating the terms of his bond.

On that basis, we respectfully request that Your Honor sets bail for Jeffery’s release.

Thank you,

Geoff Ogunlesi
EXHIBIT F
EXHIBIT G
DocuSign Envelope ID: 81681E8A-E460-472F-A6DE-F32D498FF45B

May 20, 2022

The Honorable Judge Ural Glanville

Fulton County Superior Court
185 Central Avenue SW, T-8955
Atlanta, Georgia 30303

RE: State of Georgia v. Jeffery Williams et al., Case Number 22SC182273

Dear Judge Glanville:

My name is Julie Greenwald, and I am the Chairman/COO of Atlantic Recording Corporation, a division
of the Warner Music Group. My company is a party to a long-term recording agreement with Jeffery
Williams, who is professionally known as “Young Thug.” Prior to Atlantic, I served as President of
Island Records and President/EVP of the Island Def Jam Music Group. Over the course of my thirty-year
career, I have helped advance the careers of an eclectic and successful roster of artists including Bruno
Mars, Coldplay, Ed Sheeran, Gucci Mane, Meek Mill, Kodak Black, Wiz Khalifa and Jack Harlow.

Jeffery Williams is a successful entrepreneur and visionary artist who explores themes like racial
prejudice, love, and his rise from a rough childhood to celebrity. Since signing to Atlantic in 2015, he has
grown to become one of the most successful recording artists in the world, achieving a nearly
unparalleled commercial and cultural relevance. Jeffery’s unrelenting dedication to his musicianship and
career has earned him three number one albums on the Billboard chart, over a dozen certified Platinum
and Gold records, numerous collaborations with decorated creators such as Camilla Cabello, Elton John,
Drake and the Weeknd (to name just a few), endorsement and partnerships with luxury fashion brands,
and sold-out world concert tours. Additionally, as CEO of Young Stoner Life Records, Jeffery has shown
himself to be an astute businessman and excellent judge of talent, building an exciting roster of young and
impactful artists and growing the label into a multi-million dollar enterprise.

In short, Jeffery’s career as a creative artist and entrepreneur is currently at an all-time high, none of
which would have been possible without his tireless pursuit of his art and business ventures. I have seen
firsthand how opportunity and a career in music can change the lives of individuals like Jeffery by
providing a creative outlet, as well as an opportunity to achieve financial freedom. And indeed, upon
achieving his success, Jeffery has become a valued, contributing member of the Atlanta community, and
is the sole financial support for many, including his parents, siblings, and six children.

I believe that Jeffery is not a flight risk because his priority has been, and remains, the development of his
career and his family. I am confident that he understands the severity of the charges he currently faces
and, if bail is granted, the obligations required of him upon his release. Jeffery has the full support of a
strong management team and a committed record company staff, all of whom can help ensure that he
complies with all of the Court’s orders. Jeffery Williams is more than simply a star artist on the Atlantic
roster, he is also a loving father and son.
DocuSign Envelope ID: 81681E8A-E460-472F-A6DE-F32D498FF45B

On that basis, we ask Your Honor to please consider setting bail for Jeffery’s release.

Thank you.

Julie Greenwald
Chairman/COO, Atlantic Recording Corporation
1633 Broadway
New York, New York 10019
EXHIBIT H
DocuSign Envelope ID: C8F78462-17BE-4568-916B-861250EC5951

May 22, 2022

The Honorable Judge Ural Glanville

Fulton County Superior Court
185 Central Avenue SW
T-8955
Atlanta, Georgia 30303

Re: State of Georgia v. Jeffery Williams et al., Case Number 22SC182273

Dear Judge Glanville:

My name is Benjamin Reynold Setsuo Ezaki, and I currently work at 300’s music publishing company
alongside its Vice President, Jennifer Essiembre.

I first met Jeffrey Williams p/k/a “Young Thug” in 2019 during my tenure as an artist manager at Roc
Nation. Along with my direct management clients, I also worked closely with Jeffrey’s management lead
at the time. I recall that Jeffrey was always curious about the complexities of the music industry and
seeking mentorship from the management team at Roc Nation. I sat with Jeffrey on numerous occasions,
and I remember so vividly how it felt like I was stepping into a family living room every time we met.
Whether it was in his studio in Burbank, CA where he worked around the clock, or in a dressing room in
Salt Lake City, UT while he was on tour, every time we met, there was a sense of warmth that seemed to
follow Jeffery and those travelling with him.

As if to repay the mentorship he received, Jeffery would bring all of his younger artists around and
educate them about the music industry. He would often call them into the room while we spoke about
intricate business dealings so they could sit, listen, learn, and absorb. He would have friends and family
around at all times, and even when they would leave to go to the store for a quick candy run, he would
express to them that he loved them and cared for them before they left. It became apparent to me that
Young Stoner Life Records was so much more than a successful record label; it was a family.

Even though my encounters with Jeffrey were limited, he left a deep imprint on me. Anyone who has
spent time with Jeffrey will tell you that he is full of, and overflowing with, nothing but love. I will never
forget that while visiting him on tour he introduced me to an old friend from Atlanta who he had just
flown out to come be on tour and see the world. Jeffrey started explaining that his old friend actually had
just gotten out of prison. As he continued with the story, he explained how the two of them had a falling
out, and after seeing Jeffrey’s rise to success and fame, his old friend had actually tried to get Jeffrey
murdered out of jealousy. As bizarre as it sounds, Jeffrey was ecstatic to have his friend-turned-foe out of
prison and back in his presence. He bounced around the backstage area like an overjoyed child
introducing his friend to everyone and explaining the story behind their friendship. I followed him
around, dressing room to dressing room, and every time the story ended the same way, Jeffery saying, “I
am filled with love.”

Jeffrey would exclaim this simple yet powerful statement in conclusion as he spoke about forgiveness, as
he told a story about forgiving a man that had tried to have him killed. As he paraded a former enemy
around backstage introducing him to his friends and family and draping him in jewelry and new clothes to
welcome him home from prison. I have been working in music professionally for 13 years, have worked
in every facet of the industry and have had conversations with every creative you could imagine and
never in my life have I heard a story such as Jeffrey’s. To this day I’m overwhelmed with emotions
DocuSign Envelope ID: C8F78462-17BE-4568-916B-861250EC5951

thinking about the grace and love that poured out of Jeffrey, not only in the one specific moment, but in
every single encounter we had.

If you were to ask me to describe Jeffrey in one simple word it would be just that, “Love.”

With that sentiment, “Love,” we would ask Your Honor to please consider setting bail for Jeffery’s
release.

Thank you,

Benjamin Reynold Setsuo Ezaki

EXHIBIT I
DocuSign Envelope ID: 9E6E12D6-88AB-4614-AE96-3060D77FE294

May 22, 2022

The Honorable Judge Ural Glanville

Fulton County Superior Court
185 Central Avenue SW, T-8955
Atlanta, Georgia 30303

RE: State of Georgia v. Jeffery Williams et al., Case Number 22SC182273

Dear Judge Glanville:

My name is Leesa Brunson-Boland, and I am the Senior Vice President/Head of A&R Operations at 300
Entertainment. I have worked at 300 Entertainment for two and half years, but have over 30 years of
experience working at labels such as Elektra Records, Def Jam Records, and across the music industry.
Throughout my career, I have overseen A&R operations for some of the biggest musicians in the world
including Mr. Jeffery Williams, professionally known as “Young Thug”.

As a seasoned professional who has worked with Jeffery and his label Young Stoner Life Records, I can
attest to his commitment to his craft as both an artist and entertainer. Since being at 300 Entertainment, I
have witnessed Jeffery clock thousands of hours of studio time; even spending consecutive 24-hour
rotations at the studio in which he would be recording and working on his music. In my 30 years of working
in A&R Operations, I can confidently say I have never seen an artist work as fervently and consistently as
Jeffery when it comes to his profession and art. Jeffery’s work ethic is something that he has embedded
into the foundation of his label and business, with many of his recording artists following suit by putting in
countless hours to hone their careers as musicians.

The way in which I’ve seen Jeffery wrap his arm around his artists in order to provide them with opportunity
has been a clear indicator of his commitment to seeing those around him succeed. Jeffery’s efforts have
allowed him to catapult many artists and family members into more positive situations and that became
even more evident to me overseeing the release of his album Slime Language 2 in 2021. The album featured
his friends, siblings, daughter, and developing artists and went on to debut at number one on
the Billboard Hot 200 chart. To me, this is a firm testament to his character as a businessman, mentor,
father, and friend.

I believe that Jeffery is not a flight risk and will fully comply with the conditions of bond, due to the high
regard in which he holds his family and career. With that, I kindly request for you to please consider setting
bail for the release of Jeffery Williams.

Many Thanks,

Leesa Brunson-Boland
SVP/Head of A&R Operations
300 Entertainment
EXHIBIT J
DocuSign Envelope ID: D9CF954B-4BAE-4258-A90B-0D025666F64C

May 22, 2022

The Honorable Judge Ural Glanville

Fulton County Superior Court
185 Central Avenue SW
T-8955
Atlanta, Georgia 30303

Re: State of Georgia v. Jeffery Williams et al., Case Number 22SC182273

Dear Judge Glanville:

My name is Aimie Vaughan, and I am currently the Executive Vice President of Promotion/Streaming for
300 Entertainment. I have worked at 300 for four years but have worked as an executive in the music
business for 30 years.

Jeffery Williams, who is professionally known as “Young Thug,” has always been an incredible artist to
work with. I have known him to be very respectful, kind and generous with his time and knowledge to
empower those around him.

I believe that Jeffery is not a flight risk and will comply with the bond conditions and that he would not
risk damaging his relationship with his family or his career.

On that basis, we ask Your Honor to please consider setting bail for Jeffery’s release.

Thank you,

Aimie Vaughan
Executive Vice President
Promotion/Streaming
EXHIBIT K
May 20, 2022

The Honorable Judge Ural Glanville

Fulton County Superior Court
185 Central Avenue SW, T-8955
Atlanta, GA 30303

Re: State of Georgia v. Sergio Kitchens et al., Case Number 22SC182273

Dear Judge Glanville:

My name is Aaron Romanello, and I am Vice President of Business and Legal Affairs at 300
Entertainment, having recently assumed that position after 300 Entertainment was acquired by Warner
Music Group. I have been an attorney at Warner Music Group since 2016, variously working in the
Business and Legal Affairs departments of Atlantic Records and the Elektra Music Group.
Under the agreement (the “Label Deal”), dated as of December 15, 2016, between Young Stoner Life
Records, LLC (formerly YSL Records, LLC), and Theory Entertainment LLC d/b/a 300 Entertainment
(“300”), Label, together with its CEO founder, Jeffery Williams, p/k/a “Young Thug” (“Williams”) as its
key executive, is required to exclusively render talent finding, artist development and record label
management services to 300.
Label agreements such as the one between Young Stoner Life Records and 300 are a common
arrangement in the music industry where an established record label with a distribution infrastructure, a
full-time creative and promotional staff, and substantial financial resources partners with a creative person
(and a company created by that person) with a strong grounding in a particular musical movement or
genre. Those creative people are usually artists or producers who are intimately and authentically part of
creating a particular musical scene and who need a larger company with the resources and organization to
share that expression on a world-wide scale.
The Label Deal works like this: Williams identifies available, unsigned musical artists with whom Young
Stoner Life Records desires to enter into long-term recording contracts. He submits such artists to 300 for
its approval, and if approved, 300 will negotiate with, and potentially sign the artist concerned, to a long-
term exclusive recording contract (each such signed artist, an “Accepted Artist”). For each Accepted
Artist, 300 will fund the creation, promotion and marketing of their recordings, and otherwise administer
the mechanics of the recording agreement (e.g., issuing accounting statements and paying royalties). In
turn, Young Stoner Life Records and Williams provide artistic direction, production and songwriting
services, and introduce those Accepted Artists to Williams' fans.
Over the course of the Label Deal, 300 has provided millions of dollars in funding for Young Stoner Life
Records and 300 to sign a bevy of talented and highly successful artists. To date, there are eleven
Accepted Artists under the Label Deal, some of whom, including Mr. Kitchens, have gone on to achieve
undeniable commercial success with Gold and Platinum certified records. Additionally, Williams releases
some of his own songs on Young Stoner Life Records projects, greatly enhancing the label’s reputation
and revenues.
Such shared success is made possible by the combination of 300’s global reach, powered by its 60+
employees who are daily working to amplify the expressions of its artists and the musical vision of the

1
artists signed to Young Stoner Life Records. However, as is always the case, it is the music that leads the
way. What is so unique about Young Stoner Life Records is that it is not simply an eclectic collection of
talented, but stylistically disparate artists, as many labels are, but that it’s a consistent and collective
expression of the musical moment located in Atlanta in recent years. Artists signed to Young Stoner Life
Records share an overall aesthetic presentation that includes not just the music, but their dress, image and
style, all of which are essential and authentic ingredients to their success. This is hardly surprising since
Mr. Williams actively mentors and guides the young artists signed to Young Stoner Life Records,
overseeing and participating in the writing, production and marketing of their music and the overall
imaging and tone of the label.
A new artist signing to Young Stoner Life Records receives the full embrace of the label, Mr. Williams
and the whole Young Stoner Life Records’s roster. The cultural cache of the label and its artists instantly
boosts the profile of any new artist and provides opportunities that simply don’t existent at labels with
less cultural influence. For example, the established Young Stoner Life artists frequently take the young,
less experienced artists, out on tour with them and perform as featured artists on the young artist’s songs,
using their popularity to draw attention to new talent. Because signing to Young Stoner Life Records
confers immediate credibility upon a new artist, they are given more opportunity to perform as a featured
artist on songs by established stars signed to other record labels. Such performances and associations are
essential to the success of a new hip-hop artist, and all of these opportunities come as a direct result of
their affiliation with Young Stoner Life Records.
Additionally, the label and its established stars frequently leverage their existing audiences as a call to
action for new artists. For example, Young Stoner Life’s releases and artists get full coverage on the
label’s branded social media platforms (its Instagram has over one million followers) as well as frequent
posts on their label mate’s pages (Mr. Williams’s Instagram has over nine million followers and Mr.
Kitchen’s has over four million). This increased exposure results in well attended release parties, live
concerts and promotional events and opens the door to celebrity involvement (e.g., as executive producers
on that artist’s projects) that simply would not be possible without proximity to Young Stoner Life
Records and its collective of creative artists. However, the marketing efforts of Young Stoner Life, its
artists and Mr. Williams extend well beyond social media posting and cultural association. Indeed, the
innovative combined marketing efforts of Young Stoner Life Records and 300 have resulted in industry-
wide praise and recognition. For instance, the marketing campaign around Mr. Kitchen’s smash single
“’pushin P” resulted in a Clio Music Award (an award honoring excellence in marketing and advertising)
and a Shorty Award (an award honoring producers of short-form content on social media platforms) in
2022.
Last, because all of Young Stoner Life’s grassroots efforts are bolstered and supported by 300’s
infrastructure, Young Stoner Life’s artists receive all of the benefits of a traditional record label as well.
The dedicated marketing and promotions team at 300 builds on Young Stoner Life’s endeavors to
coordinate and successfully implement full-scale international marketing, radio promotion and tour
promotion campaigns around Young Stoner Life’s releases. Simply put, signing to Young Stoner Life
Records tells the world that this is an artist to watch.
Young Stoner Life Records has released scores of records and has several new releases scheduled over
the next three months. The Label has been, and continues to be, an active record label engaged in the
business of finding, signing, developing and breaking new artists. Indeed, Young Stoner Life Records’s
successes have never been greater. Mr. Kitchen’s latest album entitled “DS4ever” debuted at number one
on the Billboard chart this past January; Mr. Williams’s last album, released in October 2021 entitled
“Punk” went to number one, and the last Young Stoner Life Records compilation album, released in April

2
2021, also went to number one. Sustained success such as this would be the envy of nearly any record
label in the world, and Young Stoner Life Records is positioned to continue to grow and thrive.
Very truly yours

Aaron Romanello
Vice President
Business and Legal Affairs
300 Entertainment

3
EXHIBIT L
DocuSign Envelope ID: CEC15413-AD64-4FBF-88F4-FA9FA5201B32

May 20, 2022

The Honorable Judge Ural Glanville

Fulton County Superior Court
185 Central Avenue SW, T-8955
Atlanta, Georgia 30303

Re: State of Georgia v. Jeffery Williams et al., Case Number 22SC182273

Dear Judge Glanville:

My name is Dee Sonaram, and I am currently the Executive Vice President of Promotion for 300
Entertainment. I have been with 300 Entertainment for the past seven years. Since 2016, I have had a
business relationship with Jeffery Williams, p/k/a “Young Thug,” who is the founder and CEO of Young
Stoner Life Records. As part of his agreement with 300 Entertainment, I have had the pleasure to work
with Jeffery on all his promotion campaigns.

In the past years I have watched Jeffery grow as an artist and more importantly a great human being who
is a pillar in his community. Jeffery has always pushed for ways in which he can use his star power and
influence to help others. Most recently Jeffery partnered to pay for bonds for families who could not
afford to bond their loved ones out. He has also performed and donated to many charities, including a
concert with 100% of the donations going to Planned Parenthood.

Young Stoner Life Records has created so many opportunities in the community and also for up-and-
coming artists in need of an outlet and direction to release their art. As a leader of and CEO of Young
Stoner Life Records, Jeffery has been on the forefront of grooming some of the biggest artists of our time.
I also would have to say in my opinion he is one of the most influential people in music at our time as he
has always pushed the creative to the next level. Jeffery’s point of view is always a beacon of light in his
community and I know he will continue to shine light on the issues that are affecting his community.

I believe that Jeffery is not a flight risk and will comply with the bond conditions set by the Court. I
know he has worked hard to build a great business and a better life for his family and would not
jeopardize that in any manner.

On that basis, we ask Your Honor, to please consider setting bail for Jeffery’s release.

Best regards,

Dee Sonaram
EVP of Promotion
300 Entertainment
EXHIBIT M
DocuSign Envelope ID: 4A7049F1-4C87-46C0-98E6-62FC69E9CA0F

May 20, 2022

The Honorable Judge Ural Glanville

Fulton County Superior Court
185 Central Avenue SW
T-8955
Atlanta, Georgia 30303

Re: State of Georgia v. Jeffery Williams et al., Case Number 22SC182273

Dear Judge Glanville:

My name is Jennifer Essiembre, and I am currently the Vice President, Publishing at 300 Entertainment. I
have been with 300 Entertainment since July 2021. Since joining 300, I have had a working business
relationship with Jeffrey Williams, p/k/a “Young Thug,” who is a 300 published songwriter, producer,
recording artist and bona fide executive of his own music publishing company, Young Stoner Life
Publishing.

I have been a music publishing executive for the past 12 years, and in that time, I have witnessed Jeffrey’s
rise to be one of the most celebrated contemporary songwriters of our time. He is undoubtedly responsible
for bringing global recognition to Atlanta-based talent, and he has written or co-written dozens of musical
compositions that have achieved top 20 positions on Billboard’s Rap, R&B and Hot 100 charts. Young
Stoner Life Publishing has built a catalogue of hit songs (including a portion of many of his own
compositions), and a roster of exciting young songwriters.

In his capacity as a publishing executive at Young Stoner Life Publishing, I have seen Jeffrey selflessly
give of his time, financial resources and experience in developing and mentoring young songwriting
talent, some of whom have gone on to achieve considerable individual success. I’ve known Jeffery to be
very generous, patient and kind in all his dealings – both personal and professional.

I believe that Jeffery is not a flight risk and will comply with the bond conditions set by the Court because
he would not risk jeopardizing his personal friendships, business relationships and the ongoing and
lucrative business of Young Stoner Life Publishing.

On that basis, we ask Your Honor to please consider setting bail for Jeffery’s release.

Thank you,

Jennifer Essiembre
Vice President, Publishing
300 Entertainment
EXHIBIT N
DocuSign Envelope ID: A1597EF5-CB6D-4DC5-922E-9ED5E36D3110

May 20, 2022

The Honorable Judge Ural Glanville

Fulton County Superior Court
185 Central Avenue SW
T-8955
Atlanta, Georgia 30303

Re: State of Georgia v. Jeffery Williams et al., Case Number 22SC182273

Dear Judge Glanville:

My name is Joshua D’Amore, and I am currently the Vice President of Streaming for 300 Entertainment.
I have worked at 300 since its inception in 2014. During that time, I have spearheaded digital marketing
and digital sales campaigns for some of the world’s most influential artists, including Jeffery Williams,
who is professionally known as “Young Thug.” I have worked closely with Jeffery since 2014 and have
seen him grow and develop, both as an artist and as a productive member of the Atlanta community.

As Jeffery’s digital marketing lead, I’ve seen a young man grow in his artistry, his confidence in his craft,
and in nurturing the people around him. Jeffery has generously used his platform to give voice to others,
providing a chance for aspiring musicians to start their careers in music and entertainment and to mentor
them on their journey. Jeffery has given generously of himself to his mother, sisters, brothers, cousins and
also to many of the various creative people that have worked closely with him.

Jeffery’s commitment to excellence and mentoring those around him takes precedence over anything else
he does. He loves his family, regardless of whether you’re related to him through friendship or kin, that’s
the person he is. I’ve had the opportunity to work with him for eight years. We would probably see each
other in person a handful of times a year, but each time he always greeted me with a big smile and a big
hug. He respects people who do the right thing, tell the truth, and look out for each other.

I believe that Jeffery is not a flight risk and will comply with the bond conditions and that he would not
risk damaging his relationship with his family or his career.

On that basis, we ask Your Honor to please consider setting bail for Jeffery’s release.

Thank you,

Joshua W. D’Amore
EXHIBIT O
DocuSign Envelope ID: F1C96514-0222-4DBA-9871-95A748BEE7E0

May 22, 2022

The Honorable Judge Ural Glanville

Fulton County Superior Court
185 Central Avenue SW
T-8955
Atlanta, Georgia 30303

RE: State of Georgia v. Jeffery Williams et al., Case Number 22SC182273

Dear Judge Glanville:

My name is Kevin Leong, and I am the Head of the Creative Department for 300 Entertainment. I have
been with 300 Entertainment for the last two and a half years. In this time, I have worked closely with
Young Stoner Life Records and its CEO Jeffery Williams, who is professionally known as “Young
Thug.”

In the short period of time that I have worked with Young Stoner Life Records, I have noticed a close-knit
collective spirit that genuinely has the best interests in mind for all involved, including their fans. In my
20 years of working in the music industry, I have never seen a group of people come together like Young
Stoner Life Records has. Jeffery has shown his associates, artists, family and fans the power of music and
the blessings that sharing your gifts with the world can bring.

Through all of his success in the music industry, Jeffery continues to give back to his community and
better the lives of the people around him.

I believe that Jeffery is not a flight risk and will comply with the bond conditions and that he would not
risk damaging his relationship with his family or his career.

On that basis, we ask Your Honor to please consider setting bail for Jeffery’s release.

Thank you,

Kevin Leong
EXHIBIT P
DocuSign Envelope ID: DC8AC6D9-3252-41CF-A26E-150F5C93B2D7

May 20, 2022

The Honorable Judge Ural Glanville

Fulton County Superior Court
185 Central Avenue SW, T-8955
Atlanta, Georgia 30303

Re: State of Georgia v. Jeffery Williams et al., Case Number 22SC182273

Dear Judge Glanville:

My name is Matt Signore, and I am currently the COO for 300 Entertainment. I have been with 300
Entertainment for the past seven years. Since 2016, I have had a business relationship with Jeffery
Williams, p/k/a “Young Thug,” who is the founder and CEO of Young Stoner Life Records. Under the
label agreement between 300 Entertainment and Young Stoner Life Records (the “Label Agreement”),
Jeffery, as the label’s key executive, renders his exclusive talent finding, artist development and record
label management services to 300.

Pursuant to the Label Agreement, Young Stoner Life Records has received millions of dollars in funding
from 300. Since the inception of that label, I have watched Jeffery deploy that funding to grow the label
into an on-going multi-million dollar concern. With the support of 300, he has signed and developed
nearly a dozen artists, several of whom have achieved Gold and Platinum certified records. Young Stoner
Life Records has also released hugely successful compilation albums, one of which achieved the top
position on the U.S. Billboard charts, and certified Gold singles. Last, Jeffery releases his own chart-
topping solo albums under Young Stoner Life Records together with Atlantic Records. The success of his
solo albums not only brings in further revenues to Young Stoner Life, but also enhances the label’s
reputation and serves as a beacon to emerging talent.

Young Stoner Life Records provides voice and a platform to many young artists to express their genuine
experiences, while creating an environment for its fans to reflect upon and identify with those artists'
experiences. The running of a successful record label is no different from any other entrepreneurial
endeavor: it requires may hours of sustained hard work, dedication and commitment. Jeffery has done,
and continues to do, just that. He has worked diligently to create, curate and expand Young Stoner Life
Records as a label, brand and destination for artists and fans alike.

I firmly believe that Jeffery is not a flight risk and will comply with the bond conditions set by the Court
because he would not risk jeopardizing all of the hard work and effort he’s poured into the creation and
continued maintenance of Young Stoner Life Records.

On that basis, we ask that Your Honor please consider setting bail for Jeffery’s release.

Very truly yours,

Matt Signore
EXHIBIT Q
DocuSign Envelope ID: 4DF71CD3-51EE-452E-AC95-FAC5F94848BE

May 20, 2022

The Honorable Judge Ural Glanville

Fulton County Superior Court
185 Central Avenue SW, T-8955
Atlanta, Georgia 30303

Re: State of Georgia v. Jeffery Williams et al., Case Number 22SC182273

Dear Judge Glanville:

My name is Rayna Bass, and I am currently the Senior Vice President for 300 Entertainment. I have
worked at 300 since 2014. During that time, I have spearheaded marketing campaigns for some of the
world’s most influential artists, including Jeffery Williams p/k/a “Young Thug.” I have worked closely
with Jeffery since 2014 and have seen him grow and develop both as an artist and as a productive member
of the Atlanta community.

As Jeffery’s marketing lead, I’ve gained a clear understanding of his artistry as well as what he truly
values most as a person. Without exaggeration, Jeffery is one of the most unique, intuitive and interesting
artists with whom I have ever worked. Over our years working together, Jeffery has accumulated a much-
lauded body of work, routinely being listed on critics best-of lists and achieving sustained commercial
success. But what’s most impressed me about Jeffery is that since achieving his remarkable success, he
has given back, both on an individual and community level, to positively impact the lives of others in
Atlanta and has remained fiercely dedicated to his family. Jeffery has partnered with anti-poverty
organizations such as Fight Against Poverty, performed at fund-raising concerts for the Atlanta
Community Food Bank, and, in 2021, used his own money to reunite dozens of families by posting bail
for thirty men and women charged with minor crimes who couldn't otherwise afford bail. I have seen how
Jeffery has used his life experience and improved situation to benefit his community through philanthropy
and activism.

On an individual level, I’ve known him to be a man who values family and who has been a positive and
encouraging force in the lives of many young artists. Jeffery is the loving father of six children and
remains in close contact with his parents, siblings and extended family. Jeffery works hard to be present
for his children and to be the kind of father he had when growing up. Despite his massive success
musically, he has made long term plans to make more time for his children in the future, knowing that
they will need him even more as they become young adults.

Jeffery also gives generously of his time, money and knowledge as a mentor to young artists, several of
whom have graduated into superstar careers of their own. In my experience, Jeffery is the kind of person
who quietly and easily commits his time and provides opportunities for his family and others, rather than
doing things that benefit only him. This is a rare quality in a world where personal ego and ambition often
rule the day. A prime example is the compilation album “Slime Language 2,” on which he provided space
for his sisters, brothers, nephew and lesser known artists on his label to contribute, freely sharing the
spotlight and earning each of them the accolade of a Billboard number one album.

As a family-oriented person, Jeffery and I have connected on the love we both have for our families. The
will to take care of others and to make the most of himself so that those that rely on him can be successful
is a driving force in his life choice.
DocuSign Envelope ID: 4DF71CD3-51EE-452E-AC95-FAC5F94848BE

I believe that Jeffery is not a flight risk and will comply with the bond conditions and that he would not
risk damaging his relationship with his family or his career.

On that basis, we ask Your Honor to please consider setting bail for Jeffery’s release.

Thank you,

Rayna Bass
Senior Vice President
EXHIBIT R
 EXHIBIT S
https://www.dropbox.com/sh/43zi6ztm601qrkd/AADrlbJgwjOydgc4ZgRbazLUa?dl=0
 CERTIFICATE OF SERVICE

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

SUPPORT OF MOTION FOR PRETRIAL BOND via electronic filing as well as via e-mail to

the following:

Don.Geary@fultoncountyga.gov
Don Geary, Esq.
Fulton County District Attorney’s Office
136 Pryor Street SW
Atlanta, GA 30303

This 22nd day of May, 2022.

Respectfully submitted,

/s/ BRIAN STEEL

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

The Steel Law Firm, P.C. 1800 Peachtree Street, N.W., Suite 300, Atlanta, Georgia 30309 (404) 605-0023

10