Discussion with god, why are they only attacking one or in reference to mr. To mr. Wade . And then she goes on. To say, god isnt it them playing the race card when they only question one. Now, if she had been truthful with that congregation, truthful with the community, she wouldve said i had a relationship with him good, bad, forgive me. Whatever thats what she should have said. But she chose to deflect and say the them the reference to them and the others and they saw obviously a reference to that motion filed by him by ms merchants. They choose to go after the black man and she then goes on again deflecting away and deflecting to the what i call the third rail in american society, choosing somebody on the other side of being a racist so and so is a racist. Theyre racist she was the one playing the race card in a way to try to deflect from her own conduct she goes on to say in discussions with the lord, god, is that is it that some some will never see a black man is qualified, no matter his achievements. Again, the deflection. What is, what is she saying . The listener is not necessarily in that audience in that church. The listener is in Fulton County. The potential jurors who will come into a courtroom and say whether or not they can fairly judge the evidence or judge the but the defense in this case, she chose to inject race into the minds of the listeners and virtually everybody in this community, and literally everybody in this country has reviewed and analyzed her speech that she made an a premeditated way and bringing in not only the race card, but also in bring in the religious matter. This is exactly what hammonds v. State and our Supreme Court talks about condemning is an inflammatory appeal to the jurors, private religious beliefs why would she do that to deflect but now, not only is she deflecting, but she is then going forward. And in a way telling the community telling the congregation that god is on her side. Not on the side of these fetal god. She said in when shes talking and shes saying god, pray for their souls. I, meaning god qualified you i qualified youre in flawed self. I see you in every hour do my work as though shes telling the folks in her very, very, very implicit way, injecting into the minds of the jurors god wants me to win this case god wants me to prosecute this case. And why is he going and why are these others going after the black man . Well, the answer is very simple, as we said in our brief, we didnt mention mrs. Krause, mr. Cross, the white female, or mr. Floyd . The white male, because there was absolutely no evidence and is no evidence of a personal romantic relationship with them in which he obtained these benefits. Thats the reason why we did not do that. She goes forward with her with the deflections thats exactly what she does when she goes forward and she talks about a planned interviews time and time again with authors of a book, find me the votes, where shes talking about a case is going to be tried in this courtroom. Its reprehensible. So in that excuse me Instance Setting aside the fact that she was willing to go on the record before a case that even reach the jury. What specific statements from that book do you contend cross the line . Well, for example, shes saying she goes on to talk about all the calls that shes gaetz, you get from people calling her racial terms. And all the calls are racist, which hes trying to do. And i think theres a reference in there too, maga people, whatever in that which hes really saying is that those people calling me up and making those claims or those those horrible racial slurs to me are really people on their side of the fence thats what shes doing. And theres no reason, your honor, ever for a prosecutor to sit down and go forward with this this kind of interview. She did it and find the votes, but then they then they what really happened here . Is this hiding of the relationship. Because in hiding in the relationship, they have done such a good job. Mr. Wade filed false documents in his divorce case when well on met one on may the 23rd and may of 2023, talking about have you ever had a sexual relations with a person . Now, during the course of the marriage or including the period of separation, he still married he doesnt have a divorce decree, but he has answer is none. Then hes asked whether or not on any occasions hes entertained or ben entertained by by someone from a woman a member of the officers section, this case, a woman from the date of the marriage to the present talking about place and time and all that. What does he answered . None. Why does he do that . He does that because he doesnt want to tell about the relationship that he has with ms willis and the benefits that he has gotten and that he gave to her thats exactly what these answers are absolutely reprehensible that a member of the State Bar Of Georgia would file these these answers that are that are that are inaccurate what does what does ms way do as he mean this ms willis to ms willis on her financial for whether or not she has gotten anything of 100 or more in value from a prohibited source. The court asked earlier about what a threshold might be. Well, if for the financial board, its 100, thats if she doesnt report any of all of the benefits its that that she received from mr. Wade all the trips, all the entertainment, all the the the three nights in the luxury suite in aruba. All of that none of that is here. And they say, oh, well, maybe it all balanced out, even though i can we have prove it with the cash. Well, thats like saying, did i give the court a Christmas Present . Well, maybe i gave the Court Christmas present in the court gave me one back. The court has to fill out a form whether you got a Christmas Present from anybody, you say i got one from mr. Gillen. You dont say now . Well, i gave him one back, so it really evens out they are false reports and because theyre false when they had to do is they had to say oh, ms merchant has caught us. And so what were going to do is were going to get in our response, were going to get mr. Wade to file a false declaration, which he does his declaration in this case is false. And the evidence showing that that is false as it relates to the timing. And the court asked earlier why does it matter . We know if the relationship was before or after november 1, 2021 . The answer is they think its important and frankly, i do too, because when shes hiring somebody and shes not telling the people are gonna be paying in the tab up to 700,000. Hey, i just hired my boyfriend whos taking me on trip to the caribbean and taking me down to aruba and taking me to california. Hope you dont mind no disclosure whatsoever. And the money flows on but because they got caught, they then commit what i think is forensic an additional component of Forensic Misconduct. And that is fraud on this court. When they when they file that affidavit and now its been proven. I think beyond virtually any doubt any doubt that the relationship occurred prior to november 1, 2021, and the benefits that were there, and we dont have to run around. And i love the you know, weve got all the records showing from mr. Wade about the payment for these its trips for the cruises, for the flights, all this stuff. Whats the only way as they sat around and met together before they testified and came up with her story. Whats the only way that they can save themselves . Pay no attention to the records, pay no attention to the airlines into the flights and vacations and the cruises i paid him back in cash. Show us your receipts. Where did you take cash out of the bank ever . I dont have any will show us the deposits that he had. Well never we dont have any what we have here is a fraud on this court which has been shown i think overwhelmingly by the evidence in overwhelmingly through not only the testimony of yeartie, the testimony of the of the emails on the text from from mr. Bradley to ms merchants, as well as all the documents that they had no answer to other than the just trust me, i gave him money, evaporated. I dont know where it came from and he doesnt know what he did with it. Just please trust us and believe us because its our only way out of the trap that they set for themselves. These people, sadly, and i hate to sound as a forum, as a coordinate as i was i was a prosecutor for about threeandahalf million years. It seems in the Federal Building and i was an assistant da beforehand prosecutors dont act like this. Lawyers dont act like this these people, your honor, is a systematic misconduct and they need to go. Thank you. Your honor, im going to cover a few factual details without overly rehashing what has already been said during the, pendency of this investigation in this case mr. Wade and ms willis basically lived rotten leeches lifestyle of the rich and famous. And they did this riding on the backs of the defendants in this case funded by the taxpayers of Fulton County and the State Of Georgia with the money that was paid to mr. Wade through the contract that ms willis got him, that money flow. That is the personal interests of you asked about. She was personally benefiting from the position from the job, from the scope of the investigation, from the scope of the indictment, and how they conducted it. And we know this we know from the records that have been submitted before the court that mr. Wade paid at least 17,095 towards this relationship . That does not even include the various dinners that day trips that both wade and willis admitted to. That number is likely even higher. We know from the documents that ms willis only paid 1,394 for an Airline Ticket we know from ms yeartie who was pretty much uncontested. There was no evidence presented by the state disputing her timeframe that that relationship started in 2019 she saw them kissing. She saw them hugging. Now whether or not they had sex before january of 2022, i do not know they admitted sometime in early 2022 and i found it curious that they both wade and willis just went straight to the sex. So maybe thats when they started having sex. I do not know. But the Relationship Predated that there combined in overly suggestive. Focus on that is a red herring to this court into the defense that thats where they want you to focus on. They want you nor all the evidence that the Relationship Predated that the relationship started in 2019. The relationship continued through 2020. The relationship continued through 2021. Looking at the Cell Phone Communications just in the first 11 months of 2021 over 2000 calls, almost 9,800 texts i dont even think loves struck teenagers communicate that much. The november 29 in november 30, escobedo phone call from ms willis between ms willis and mr. Wade 11, 32 that night shortly after midnight the phone starts traveling down from what where mr. Wade lives and ends up where ms will staying. And hes there until roughly 04 55 a. M. None of the excuses none of the explanations that mr. Wade gave go into the porsche experience go into dinner go into the airport. None of that explains that. Im pretty sure the porsche experience is an open in the middle of the night im pretty sure that there werent a restaurants that he drove 30 to 45 minutes to go eat at in the middle of the night right after he talked to ms willis teenagers have a name for those kinds of calls and those kind of expats, i wont go into it. But the Documentary Evidence, the objective evidence undercuts everything that both wade and willis set when you look at ms yeartie again, she unequivocally said that relationship began in 2019 she saw physical evidence of a romantic relationship mr. Bradley in the text messages, which are substantive evidence, says that relationship began in 2019 again, his january you temporary amnesia that somehow is triggered temporarily after a gabe banks called him we can question that, but we do have statements from him that specifically said that Relationship Predated mr. Wades appointment by ms willis you asked well and mr. Wade, you asked what the materiality would be. How much is enough well, clearly 17,000 is enough but Fulton County has told us has told mrs. Willis what the materiality is. Its 100 a year. She twice signed Declarations Certifications that she did not receive any gifts and even under her strained her strained explanation there were monies that were gifts, there were dinners, there were excess contributions flowing her way that exceeded 100 her excuse or im sorry, her explanation well, i just paid in cash that just does not stand a reason. It does not hold up to the light of truth anyone that has ever been in a moneylaundering trial of forfeiture trial. If thats the explanation we give the state, they laugh. Oh, i just gave cash. I have no records for it. I have no source for it the only thing that she could say that was a source for the money because at times she said she was down to 500,000 dollars. The only explanation she have as well. Sometimes i go to publix and i may get an extra 50. That shows up on your debit card or your credit card. Did they bring those records in know . They bring her Bank Accounts in . Know did they bring any document area . Documentary. Evidence in know they did not. And why is that important, judge . Yes, the burden is ours but under ocga ocga 24 dash 14, dash 22 if. A party has evidenced in such partys power and within such parties reach by which he or she may repel a claim and they had that power. And this willis had that power. Mr. Wade had the power that they can repel the claim that we have made against them but they admit to produce it. Or if they produce weaker evidence, do then you as the factfinder, judge, it is in your power to disregard that in a presumption arises that that Documentary Evidence that is in their possession that they failed to produce supports our claim and that is something that the state relies on regularly in criminal trials and that is something that the court should rely on in this case when formulating. Its factual findings and we know that both mr. Wade and ms willis have some difficulty expressing the truth when it comes to their relationship in these cases, we know mr. Wade light and his interrogatories multiple times. We know ms willis falsely certified that she hadnt received any gifts from anybody. And mr. Wade clearly was a prohibited source. He was someone Doing Business with Fulton County. Anything over 100 a year. She had to put down and she put zero it defies imagination that she could somehow forget about all these trips, all these dinners all these day trips, and not put that money down you would ask, i think it was mr. Gillen did she say in that Church Speech or anywhere else that the defendants were guilty and i think she did not charge speech. Xi said in that Church Speech. And she was talking about a conversation that she apparently had with god talking about herself she said this leader has a trial Conviction Rate of 95 she said the trial team this leader put together has a Conviction Rate of 95 i do not see how anyone and i think that was purposefully intended by ms willis. I do not see how anyone can listen to those two statements. And not take that ms willis is telling everyone in that church and everyone thats going to hear that in the media afterwards, that these defendants are guilty that is what she was saying. She is a prosecutor. Shes familiar with the us v. Burger every single product, every single attorney thats ever been a prosecutor is familiar with the diktats, dictates of that us Supreme Court case. That is a foul blow that is improper. And she violated pretty much every tenant. A prosecutor, must bide by to seek truth and justice. And in particular case so judge, when youre looking at this uncontroverted evidence, shows that they had a relationship prior. The uncontroverted evidence shows that mr. Wade lavishly spent on ms willis the uncontroverted evidence shows that the money that he was spending on ms willis came from this contract that he had. And im not just talking about the contract as a Special Prosecutor, but theres also those other questionable contracts that no matter whom his partner seem to be, they also guide there is a direct financial benefit that ms willis received from this judge looking back at what ms judgment furnish said if merely hosting a fundraiser for a political opponent of a putative defendant creates not only the appearance, but an actual conflict than what ms willis has done since then in this case, creates an actual conflict, but again, as prior counsel is stated, we only need to show the appearance of the conflict and we have done that by a preponderance of the evidence. In fact, i believe weve shown an actual conflict, but nonetheless, the results should be that ms willis and her office should be disqualified from this case. We still have a few more minutes. I think mr. Cromwell may have something to say thank you, your honor. Thank you good afternoon, your honor. Harry macdougald for mr. Clarke im going to talk further about conflicts and im going to assume the most difficult standard for us to me, which is actual conflict but before i begin that i want to add just a little bit to what has already been said. About the standards that apply to prosecutors are Appellate Courts have said, often, the administration of the law and especially that of the criminal law, should like caesars wife the above suspicion and should be free from all temptation bias, or prejudice so far as it is possible for our courts to accomplish it. The first occurrence of that, then i can find as nichols phi state more than 100 years ago, 1915 the most recent riggi stay the state in the Supreme Court in 2010 although they dont refer to caesars wife, that requirement is also embedded in the prosecutors statutory oath 15 dash 18 dash to which requires impartially and without fear or favor discharge my duties as District Attorney and take only my lawful compensation. So help me god the general rule on conflicts of interests fo