Fulton County Superior Court

***EFILED***CL
Date: 11/3/2023 9:53 PM
Che Alexander, Clerk

IN THE SUPERIOR COURT OF FULTON COUNTY

STATE OF GEORGIA

STATE OF GEORGIA, )
) CASE NO.: 22SC183572
vs. )
)
JEFFERY WILLIAMS, et al. )
Defendants )

STATE’S SECOND1 AMENDED PARTICULARIZED MOTION IN LIMINE TO ADMIT

EVIDENCE OF LYRICS AT TRIAL

The State of Georgia, by and through its counsel, FANI T. WILLIS, District Attorney for

the Atlanta Judicial Circuit, and the undersigned Chief Deputy District Attorney Adriane L. Love,

hereby further particularizes its previously made motions to admit evidence of lyrics at trial. In

support of this motion, the State shows the following.

The State will introduce evidence of the releases containing the words listed below at trial:

1. Young Thug – “730” (Posted on YouTube September 30, 2014)

• Young Thug: “Come and enroll to the YSL school, and I swear I’m the principal (slime!).
I do not care if you slime for a dollar and change, it’s the principle (slime!)

2. Young Thug – “Eww” (Posted on YouTube April 21, 2014)

• Young Thug: “Honestly, truth be told, YSL won’t fold pick his ass off from the balcony
… YSL, wipe a nigga nose.”

3. Young Thug (Feat. Yak Gotti) – “Dream” (Released April 17, 2015)

• Yak Gotti: “Hey, how you doing? I’m Yak Gotti, I got bodies on bodies…”

4. Young Thug – “F Cancer” (Released February 6, 2016)

• Young Thug: “Tried to be loyal to these foreigners, but I am a cheater; got, got a lot of
followers, a perfect leader … I’m a boss, I call the shots…”

5. Young Thug – “Slime Shit” (Released March 25, 2016)

1
This pleading is a supplement to, and does not supersede, the State’s October 26, 2023 Amended
Particularized Motion in Limine to Admit Evidence of Lyrics at Trial.
1
 • Young Thug: “Hey, this that slime shit (hey!) … YSL shit (hey!) … Killin’ twelve shit
(hey!) … Fuck a jail shit (hey!) …”

• PeeWee Roscoe: “…This that mob shit … YSL … this that mob life.”

6. Young Thug – “Anybody” (Released April 13, 2018)

• Young Thug: “I never killed anybody, but I got something to do with that body (shhh!) …
I told them to shoot a hundred rounds … ready for war like I’m Russia … I get all type of
cash, I’m a general true…”

7. Young Thug – “Thug N’ 30” (Posted on YouTube June 1, 2019)

• Young Thug: “Money longer than the world’s longest ruler, yeah, playing with YSL,
niggas gon’ shoot you (Boom! Boom!)…”

8. Young Thug – “Just How It Is” (Released August 16, 2019)

• Young Thug: “Ooh-woo, I done for the crew, ooh-woo, I done did the robbin’, I done did
the jackin’, now I’m full rappin’… I escaped everyone one of the licks ‘cuz I was supposed
to be rich, I don’t care nothin’ ‘bout no cop, I’m tellin’ you just how it is … Gave the
lawyer close to two mil’, he handle all the killins’… We don’t speak ‘bout shit on wax it’s
all mob business, we known to kill the biggest cats of all kittens.”

9. Young Thug – “Tick Tock” (Released August 20, 2021)

• Young Thug: “I was a capo in my hood way before a plaque or a mention…”

10. Tyga (Feat. Young Thug) – “Hookah” (Released January 1, 2014)

• Young Thug: “I’m a rich Blood by the way…”

11. DJ Esco (Feat. Young Thug) – “Who” (Released June 24, 2016)

• Young Thug: “I’m at the top with bro though, ooh, head honcho…”

12. Unfoonk (Feat. Slimelife Shawty & 24 Heavy) – “Mob Ties” (Posted on YouTube April 25,
2020)

• 24 Heavy: “And we be on some 2Pac shit, ‘Hit Em’ Up’ … nigga play with Unfoonk and
get hogtied, nigga play with Unfoonk, then they all die, talking ‘bout knocking off your
big homie, even he small fry, why would I lie?

• Slimelife Shawty: “Why would I lie? I got mob ties.”

13. Slimelife Shawty – “Where You From?” (Released May 28, 2020)

2
 • Slimelife Shawty: “Where you from? (I’m from Bleveland!) Throw yo’ set up. (YSL!)
…the opps hate the crew we getting this paper and we duckin’ cases … Free Lil’ Shannon
he the one that had them runnin’ with that cannon.”

14. Juice WRLD (Feat. Young Thug) – “Bad Boy” (Released January 15, 2021)

• Young Thug: “I shot at his mommy now he no longer mention me…”

15. Young Stoner Life (Young Thug & Gunna) – “Really Be Slime (Released April 16, 2021)

• YNW Melly: “My niggas really be slime and we committin’ them crimes … hop out and
shoot…

• BSlime: “You wanna be slime … go catch you a body.”

16. Young Stoner Life (Young Thug & Gunna) – “Take It to Trial (Released April 16, 2021)

• Yak Gotti: “I rep my life for real … for slimes you know I’ll kill.”

17. Big Bhris – “On the Block” (Posted on YouTube January 21, 2022)

• Big Bhris: “We keep switches on our glocks, them not the same poles.”

Untitled Social Media

18. Shannon Stillwell – “Untitled Social Media” (Posted July 22, 2019)

• Shannon Stillwell: “I just beat a murder rap, pay my lawyer 30 for that … me and my
slimes above the law.”

19. Damekion Garlington – “Untitled Social Media (Posted October 7, 2019)

• Damekion Garlington: I can’t fuck with you ‘cuz you told … rat … Blood, yea I earned
this stain.”

The State reserves the right to introduce evidence of the releases containing the above

statements for all purposes available under Georgia and other applicable law, including, but not

limited to, the grounds previously raised and briefed in the State’s October 24, 2022 Motion and

Memorandum of Law in Support of Admission of Gang-Related Evidence at Trial, the State’s

November 30, 2022 Preliminary Motion to Introduce Intrinsic Evidence of Criminal Street Gang

Activity, the State’s November 30, 2022 Preliminary Motion to Introduce Co-Conspirator

3
Statements and Statements Against Interest, the State’s December 1, 2022 Motion in Limine to

Admit Evidence of Lyrics, the State’s December 14, 2022 Supplemental Motion in Limine to

Admit Evidence of Lyrics at Trial, and the State’s November 3, 2023 Second Supplemental Motion

in Limine to Introduce Evidence of Lyrics at Trial.

The State, while not required to do so, provides this particularization to put all defendants

and their counsels on notice of the items contained herein to allow them to identify and locate same

in preparation for the upcoming hearing on the pretrial, conditional admissibility of these

statements, currently scheduled for November 8, 2023. Nothing in this particularization limits the

State’s ability to produce this and other similarly admissible evidence at trial for any other purposes

permitted under Georgia or other applicable law. To date, no particularized objections have been

made to any of the above-listed items, nor to those listed in the State’s October 26, 2023 Amended

Particularized Motion in Limine to Admit Evidence of Lyrics at Trial.

At the hearing, the State plans to call the following witnesses in connection with the

admissibility of the gang lyrics in this case.

• Det. Mark Belknap (Atlanta Police Department): Currently expected to identify certain

lyrics and explain related, contextual evidence; Detective Belknap’s CV has been

previously provided in discovery.

• Chief Investigator Jose E. Ramirez (Paulding County District Attorney’s Office):

Currently expected to explain, based on his work in investigating criminal street gangs and

consulting on criminal street gang investigations in various roles, to include President of

the Georgia Gang Investigators Association, that lyric evidence in gang investigations is

not strictly comprised of purely fictional portrayals; Chief Investigator Ramirez’ CV is

attached as Exhibit A; and

4
 • Special Agent in Charge Kenneth E. Howard (Georgia Bureau of Investigation):

Currently expected to explain, based on his work in investigating criminal street gangs and

consulting on criminal street gang investigations in his capacity as the Special Agent in

Charge of the Georgia Bureau of Investigation’s Gang Task Force, that lyric evidence in

gang investigations is not strictly comprised of purely fictional portrayals. Special Agent

Howard’s CV is attached as Exhibit B.

With the Court’s permission, the State intends to utilize a PowerPoint and other visuals at

the upcoming lyrics admissibility hearing. The State will tender hard copies during the hearing and

provide additional copies to the Defense as well. The State is not aware of any defendant’s

objection to this. Also with the Court’s permission, at the hearing, Special Assistant District

Attorney John Floyd and Executive District Attorney Mike Carlson will be jointly presenting on

behalf of the State. The State is not aware of any defendant’s objection to this, either.

Respectfully submitted this 3rd day of November, 2023.

/s/ Fani T. Willis

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

/s/ Adriane L. Love

Adriane L. Love
Chief 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. )
)
JEFFERY WILLIAMS, et al. )
Defendant )

CERTIFICATE OF SERVICE

I hereby certify that a copy of the foregoing:

STATE’S SECOND AMENDED PARTICULARIZED MOTION IN LIMINE TO ADMIT

EVIDENCE OF LYRICS AT TRIAL

Was served via e-file to:

Brian Steel
The Steel Law Firm
1800 Peachtree Street
Suite 300
Atlanta, GA 30309

Keith Adams
Keith Adams & Associates, LLC
315 W Ponce de Leon Avenue
Suite 602
Decatur, GA 30030

E. Jay Abt
Doug Weinstein
2295 Parklake Drive
Suite 525
Atlanta, GA 30345

Katie Hingerty
The Hingerty Law Firm, LLC
2295 Parklake Drive
Suite 525
Atlanta, GA 30345

Maxwell Schardt
1800 Peachtree Street NW

6
Suite 300
Atlanta, GA 30309

R. David Botts
146 Nassau Street
Atlanta, GA 30303

Careton R. Matthews
4820 Redan Road
Suite B
Stone Mountain, GA 30088

Bruce Harvey
146 Nassau Street
Atlanta, GA 30303

Angela D’Williams
Supreme Law Firm
2180 Satellite Blvd
Suite 400
Duluth, GA 30097

This 3rd day of November, 2023.

/s/ Fani T. Willis

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

/s/ Adriane Love

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

7
 Jose E. Ramirez
280 Constitution Blvd  Dallas, GA 30132  (770) 443-7561  jose.ramirez@paulding.gov

EDUCATION

Columbia Southern University – Orange Beach, AL

B.S. Criminal Justice Administration

GPSTC Regional Academy – Savannah, GA

Basic Peace Officer Certification

Savannah Technical College – Savannah, GA

Criminal Justice

Windsor Forest High School – Savannah, GA

High School Diploma

PROFESSIONAL EXPERIENCE

Paulding County District Attorney’s Office, Dallas, GA 9/2022 – Present

Chief Investigator
• Investigated criminal cases and alleged crimes under my jurisdiction of the Office of the District Attorney.
• Assisted ADA’s with Criminal Cases for Prosecution
• Conducted interviews and interrogations, located witnesses, conducted searches and seizures, and gave
testimonies when needed.
• Assisted Law Enforcement Agencies with Criminal Investigations
• Attended Public Meetings
• Planned, managed, and supervised the implementation of law enforcement activities, allocated resources to
achieve organizational goals, and established Department goals and objectives.
• Made recommendations on hiring and other personnel matters, while assuring proper training of all personnel,
monitored performance evaluations and took corrective action when necessary.
• Provided operational reports and assisted the Chief of Police with Department Budget preparation and
administration.
• Reviewed criminal activity data and trends to modify enforcement efforts and activities that needed to be
accomplished to meet community needs.
• Issued general and special orders, addendums, and memorandums to my General.
• Provided interoffice correspondence to determine department policies and procedures as well as charting the
overall course of the department.
• Maintained personnel files, scheduled, and trained officers
• Training Coordinator, Quartermaster, Fleet Management Coordinator, Armor, Special Events Coordinator,
Recruiter, Certification Coordinator, Inventory Pricing, Public Relations, and Internal Affairs.
• Member of the Attorney General’s Anti-Gang Network
• Gang Subject Matter Expert for G.A.S.R.O.E.
• Advisory Board for Atlanta Redemption Ink (Sex Trafficking and Gang Non-profit)

Georgia Public Safety Training Century, Forsyth, GA 3/2019 – 9/2022

Staff Instructor
▪ Georgia Police Academy – Forsyth (July 2019 – Present)
o Coordinator for all Gang and Drug Courses for the Georgia Public Safety Training Center.
o Coordinate scheduling of courses, students, and adjunct instructors. Design, develop, research, and
implement on-site, online, and podcast training courses. Attend meetings with the Governor’s Office,
Attorney General, House Committees, and U.S. Attorney’s Office on behalf of the director.
o Assist local, state, and federal agencies with presentations, investigations, and intelligence regarding
criminal street gangs, hate and extremists groups, and drug violations.
o Gang Subject Matter Expert for G.A.S.R.O.E.
o Advisory Board for Atlanta Redemption Ink (Sex Trafficking and Gang Non-profit)
o Member of the Attorney General’s Anti-Gang Network
 ▪ Basic Division – Savannah Regional Academy (Mar. 2019 – July 2019)
o Train police cadets on all POST requirements for Peace Officer Certification.
o Instruct on Criminal Procedure, Stress Management, Criminal Law, Traffic Law, Use of Force,
Emergency Vehicle Operations, Building Clearing, etc…
o Coordinate scheduling of classes, and adjunct instructors.
o Maintain inventory of equipment and maintenance of department vehicles.

Rincon Police Department, Rincon, GA 10/2007 – 1/2019

Lieutenant 2015 – 2019
Sergeant 2012 – 2015
Interim Police Chief (7/2018 – 10/2018)
• Planned, managed, and supervised the implementation of law enforcement activities, allocated resources to
achieve organizational goals, and established Department goals and objectives.
• Made recommendations on hiring and other personnel matters, while assuring proper training of all personnel,
monitored performance evaluations and took corrective action when necessary.
• Provided operational reports and assisted the Chief of Police with Department Budget preparation and
administration.
• Reviewed criminal activity data and trends to modify enforcement efforts and activities that needed to be
accomplished to meet community needs.
• Issued general and special orders, addendums, and memorandums to my General.
• Provided interoffice correspondence to determine department policies and procedures as well as charting the
overall course of the department.
• As Patrol Commander, I managed and oversaw a Patrol Division that consisted of 20 officers, three civilian
personnel, the Criminal Investigations Division, and the K9 Unit.
• Managed all Open Records Request, maintained personnel files, scheduled, and trained officers
• Training Coordinator, Quartermaster, Fleet Management Coordinator, Armor, Special Events Coordinator,
Recruiter, Court Security Coordinator, Certification Coordinator, Inventory Pricing, Public Relations, Council
Reports, and Internal Affairs.
• Entrusted as Acting Chief of Police on several occasions since 2012.
• Adjunct instructor for the Georgia Public Safety Training Center (Garden City, GA) regarding Gangs.
Corporal 2009 - 2012
• Shift Supervisor: approved reports, prepared and reviewed case files, and conducted traffic enforcement.
• Planned scheduling, enforced Policy & Procedure applications,
• Conducted performance evaluations and investigated complaints.
Patrol Officer 2007 - 2009
• Wrote incident/accident reports, conducted traffic enforcement, field interviews, and trained police recruits.

Chatham County District Attorney’s Office, Savannah, GA 9/2005 – 10/2007

Criminal Investigator
• Investigated criminal cases and alleged crimes under my jurisdiction of the office of the District Attorney.
• Assisted ADA’s with Criminal Cases for Prosecution
• Conducted interviews and interrogations, located witnesses, conducted searches and seizures, and gave
testimonies when needed.
• Assisted Law Enforcement Agencies with Criminal Investigations
• Attended Public Meetings

Savannah Chatham Metro Police Department, Savannah, GA 1/2000 – 9/2005

Law Enforcement Officer
• Patrol Officer (2000 – 2002)
o Wrote incident & accident reports, traffic enforcement, and field interviews. Officer of the Year ’02
Police Training Officer (PTO)
• Crime Suppression Officer (2002)
o Undercover Operations, drug enforcement, patrol high crime areas, and high-risk warrant service.
• Robbery Detective (2002 – 2003)
o Investigated robberies, armed robberies, home invasions, bank robberies, conducted interviews,
worked with and managed informants
• Homicide Detective (2003 – 2004)
o Investigated crimes against persons (aggravated assault, aggravated battery, kidnapping, and
murder), conducted interviews, and worked with and managed informants.
• Gang Investigator (2004 -2005)
o Identified & investigated criminal street gangs/members, intelligence gathering, and surveillance.
o Undercover Operations and assisted the Criminal Investigation Division.
o Worked with and managed informants, and spoke at community meetings.
o Was a gang instructor and expert witness on criminal street gangs.
 o Vice President of the East Region of the GA Gang Investigators Association.

GANG EXPERT WITNESS TESTIMONY

• State of Georgia v. Dereck Justin Horne

Chatham County Superior Court
Gangster Disciples

• State of Georgia v. Troy Lamont Simmons

Wayne County Superior Court
Bloods

• Juvenile Case
Chatham County Juvenile Court
Crips / Gangster Disciples

• State of Georgia v. Quamane Montey Carr

Wayne County Superior Court

• State of Georgia v. Brinden Corey Barker & Nakoda Hayden Fermine

Haralson County Superior Court
Crips & Gangster Disciples

GANG ASSOCIATIONS
• Georgia Gang Investigators Association
• International Outlaw Motorcycle Gang Investigators Association
• National Alliance of Gang Investigators Association
• International Latino Gang Investigators Association

CERTIFICATIONS

• Basic Law Enforcement (PBLE000848S)

• Georgia POST General Instructor (I13358)
• Georgia Association of Chiefs of Police’s Chief Executive Training
• Managerial Certification (PA0420200100S)
• Supervisory Certification (PA0320200163S)
• Defensive Tactics Instructor
• Driver Training Instructor
• Use of Force Instructor
• Below 100 Instructor
• Crisis Intervention Instructor (CIT)
• Emergency Medical Instructor (First Aid/CPR)
• Georgia Gang Investigators Association Basic Gang Investigator
• Gang Instructor and Expert Witness
• Undercover Operations and Drug Enforcement Instructor
• Gang Resistance and Education Training Instructor (G.R.E.A.T.)

AWARDS

• (8) Certificates of Merit from the Savannah Chatham Metro Police Department
• Officer of the Year 2002 (SCMPD)
• City of Rincon Mayor’s Choice Humanitarian Award (2010)
• City of Rincon Public Safety Humanitarian Award (2011)
• Officer of the Quarter, Rincon Police Department (1st. Quarter 2012)
• Chief of Police Award of Excellence, Rincon Police Department (2014)
• Award from Mothers Against Drunk Driving (2002)
• Voted by the Citizens of Effingham as Most Fabulous Public Safety Officer (Effingham Living, 2016, 2017,
2018)
• Voted by the Citizens of Effingham as Most Fabulous City Employee (Effingham Living, 2016)
• Voted by the Citizens of Effingham as Most Fabulous Man (Effingham Living, 2018, 2019)
• Vice President of the Georgia Gang Investigators Association
Kenneth E. Howard – Special Agent in Charge
Georgia Bureau of Investigation- Investigative Division/Metro Gang Task Force
2148 Iris Dr, Southwest, Conyers, Georgia 30094
770.602.2864 (O)
ken.howard@gbi.ga.gov

Summary
• Experienced Multi-Agency task force leader. Built two task force groups responsible for international
organized crime and gang investigations.
• Experienced gang and organized crime investigator with over twenty-seven years of law enforcement
experience including gang investigations. Lead investigator in multiple criminal street gang investigations,
with an emphasis on Hispanic Drug Trafficking Organizations (DTOs)-linked criminal street gangs.
Assisted in hundreds of investigations targeting DTOs, criminal street gang members, including short-term
street-level and long-term high-level investigations.
• Extensive foundational training in general and gang investigations specifically, including up-to-date
information on current gang trends. Regularly creates and presents training for law enforcement officers,
attorneys, and judicial officials regarding the identification, documentation, and prosecution of organized
criminal syndicates, gang-related and gang-motivated crimes. Has provided related training to thousands of
law enforcement officers nationwide and in foreign countries. Georgia P.O.S.T.-Certified Instructor.
• Substantial consultation experience regarding organized crime investigations across multiple local, state,
and federal jurisdictions from street level investigations to international RICO investigations.
• Qualified to provide expert testimony regarding DTOs and Criminal Street Gangs. Experienced witness
in gang-related and gang-motivated proceedings throughout the State of Georgia and federally, including
cases with a national profile.

Education and Training

Georgia Gang Investigator’s Association Training Conference 2020-present

Georgia Gang Investigator’s Association (Savannah, GA)

Prosecuting Attorney’s Counsel of Georgia-Winter Conference 2020-present

Prosecuting Attorney’s Counsel of Georgia (Hiawassee, GA)

Gang Intelligence Update Training 2018- Present

Georgia Gang Investigator’s Association (State of Georgia)
• Metro Atlanta Gang Intelligence Network
• Griffin Judicial Circuit Intelligence Network
• Coweta Judicial Circuit Gang Intelligence Network

Basic Gang Investigator’s Course 2019

Georgia Gang Investigator’s Association (Morrow, GA)

Criminal Interviews and Interrogations 1999 & 2014

(Reid Technique)

Mexican Drug Trafficking Organizations 2007

Page | 1
 International Money Laundering 2007

Masters in Public Administration 2014

Columbus University

Bachelor of Arts in Criminal Justice 1995

University of Georgia

Total POST Training Hours: 4,084 Hours (Current 7/25/2023)

Career History & Accomplishments

Instructing Advanced Investigation and Prosecution Practices 2019-Present

• Developed and provided instruction to International Association of Chiefs of Police, International

Association of Women in Policing, United States Embassy – Republic of Georgia State Police
(former Soviet Republic), Federal, State, and Local Gang Investigators, Prosecuting Attorneys, and
State Probation Officers on the following topics:
o Fundamentals of Gang Investigations
o Gang Investigative Techniques
o Confidential Source Management
o Criminal Interviews and Interrogations
o Search and Seizure
o Title III (Wiretap Investigations)
o Exploiting Sources for Gang Validations
o RICO Indictments for Criminal Enterprises
o Recognizing Gang Members and Symbology
o Sureños Criminal Street Gang-Introduction
o Search Warrants and Affidavits
o Clandestine Drug Laboratory Investigations
o Synthetic Drug Investigations
o Drug overdose investigations (emphasis on Opiates)

Gang Investigation Intelligence and Criminal Consultant 2019-Present

Founding Member and architect of GBI - State Gang Task Force 2019-Present
Georgia Bureau of Investigation 1999-Present
• State Gang Task Force 2019-Present
• West Metro Regional Drug Enforcement Office (WMRDEO) 2018-2019
• Appalachian Regional Drug Enforcement Office 2014-2018
• GBI Region 8 Field Office 2012-2014
• GBI Canton RDEO 2002-2012
• GBI State Drug Task Force 1999-2002

Page | 2
Brunswick Police Department 1995-1999
Uniform Patrol Division
Memberships & Awards

• Member of Georgia Gang Investigator Association (GGIA)

• Member of California Gang Investigator’s Association (CGIA)
• Member of International Latino Gang Investigator’s Association (ILGIA)
• Member of East Coast Gang Investigator’s Association (ECGIA)
• GBI Deputy Director for Investigations Investigative Excellence Award, Operation Caged Doves
(2020)
• GBI Deputy Director for Investigations Investigative Excellence Award, Operation Crankster
Gangster (2019)
• United States Attorney’s Office Western District of North Carolina, Excellence in the pursuit of
Justice Award, Outstanding Case Operation “Unicoi Pipeline” (2020)
• Multiple Letters of Commendation- Brunswick Police Department (1995-1999) and Georgia Bureau
of Investigation (1999-Present)

Page | 3