Fulton County Superior Court

***EFILED***TG
Date: 7/27/2023 2:10 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 IN LIMINE NUMBER TWENTY TWO

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

this Motion in Limine Number Twenty Two to exclude evidence of the arrest of Mr. Shannon

Stillwell on or about March 17, 2022, when being charged with Murder and other related offenses

involving Mr. Drinks. In support of this Motion, Mr. Williams shows as follows:

1.

Mr. Williams is innocent of any and all charges the above-referenced Indictment.

2.

Although this issue does not directly involve Mr. Williams as he was never involved/arrested

on March 17, 2022 nor charged with Mr. Drinks’ supposed murder, law enforcement officers

arrested Mr. Shannon Stillwell at 2481 Meadowlark Drive, East Point, Georgia, 30344, while in the

midst of a religious ceremony which involved supposed sacrifice of goats.

3.

There is absolutely no benefit/probative value and the prejudice is great to show this religious

ceremony to the jurors simply to show the arrest of Mr. Stillwell as well as Mr. Quamarvious

Nichols. See O.C.G.A. § 24-4-401; O.C.G.A. § 24-4-402; O.C.G.A. § 24-4-403. A reasonable person

can also view this as character evidence as well. See O.C.G.A. § 24-4-404(a).

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

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

conclusion of same, asks this Honorable Court to grant the above-requested relief as Mr. Williams

is on trial with co-Defendants and this evidence, even with a limiting jury instruction, will prejudice

the jury, wrongly, against Mr. Williams and all.

This 27th day of July, 2023.

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

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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 IN LIMINE NUMBER TWENTY TWO via electronic filing as well as via e-mail

to the following:

Demetrius.Smith@fultoncountyga.gov
Adrian.Love@fultoncountyga.gov
Simone.Hylton@fultoncountyga.gov
Demetrius Smith, Esq.
Adrian Love, Esq.
Simone Hylton, Esq.
Fulton County District Attorney’s Office
136 Pryor Street SW
Atlanta, GA 30303

This 27th day of July, 2023.

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