They only attacking one in reference to mr. Wade. And then she goes on to say, god, is it them playing the racecar where they only question one . No, if she had been truthful with the congregation, truthful with the community she would have said i had a relationship with him. Good, bad, forgive me, whatever. That is what she should have said. But she chose to deflect and say them, the reference to them and the others and they. It is obviously a reference to the motion filed by Miss Merchant. 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, the american society. Accusing somebody on the other side of being a racist. So and so is a racist. They are 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 and her discussions with the lord, god, is that is it that some will never see a black man as qualified no matter his achievements . Again, the deflection. 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 court room and say whether or not they can fairly judge the evidence or judge 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 as reviewed and analyzed her speech that she made in a premeditated way. And bringing in not only the race card but also in bringing in the religious matter, this is exactly what happened v estate in our Supreme Court talks about, condemning is an inflammatory appeal to the jurys private religious bel 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 people. God, she said, in which she is talking and she is saying, pray for their souls. I, meaning god, qualified you. I qualified your imperfect flood self. I see you in every hour. Do my work. As is 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 what are these others going after the black man . Well, the answer is very simple. As we said in our brief. We do not mention misses cross mr. Cross, the white female or mr. Floyd, the white male, because there was absolutely no evidence in is no evidence of personal or a romantic relationship with them in which she obtained these benefits. That is the reason why we did not do that. So she goes forward with her with the deflection. That is exactly what she does when she goes forward and she talks about a planned Interview Time and time again with authors of the book find me the votes where she is talking about cases tried in this courtroom. Judge mcafee so in the specific excuse me, instance, setting aside the fact that she was willing to go on the record for a case that havent even reached the jury, what specific statements from that book do you contend crossed the line. Craig for example, she goes on to talk about all the calls that she gets from people calling her racial terms. And, you look all the calls are racist, what she is trying to do and i think theres a reference in there to maga people, or whatever. What she is saying is those people calling me up making those claims or those horrible racial slurs to me are really people on their side of the fence. That is what she is doing and theres no reason, your honor ever for a prosecutor to sit down and go forward with this kind of interview. She did it. But then what really happened here is this hiding of that relationship because in hiding that relationship, they have done such a good job. Mr. Wade filed false documents in his divorce case. On may the 23rd, may of 2023, talking about, have you ever had central relations with a person during the court of the marriage or including the period of separation . He still married but he does not have a divorce decree. But his answer is none. Then he is asked whether or not on any occasions he has entertained or been entertained by someone, a member of the opposite sex, in this case, a woman, talking about place and time and all that. What is the answer . None. Why does he do that . He does that because he does not want to tell about the relationship that he has with miss willis and the benefits that he has gotten and that he gave to her. That is and what these answers are absolutely reprehensible that a member of the state board part of georgia would file these answers that are inaccurate. What does ms. Wade to miss willis do . Miss willis on her financial report, was not she has gotten anything of 100 or more in value from a prohibitive source, the court asked earlier about what a threshold might be applicable, if the financial part gets 100, that is it. She does not report any of all of the benefits that she received from mr. Wade. All the trips, all the entertainment, all the three nights in the luxury suite in aruba. None of that is here. And they say, oh, well, maybe it all bounced out even though i cant prove it with the cash. Will, that is like saying, did i the court a Christmas Present. Well, maybe i the court a Christmas Present and the court gave me one back. You say i got one from mr. Guillen. You dont say, no, well, i give you one back. So it really evens out. They are false reports and because they are false, what they have to do is they had to say, Miss Merchant has caught us and so we are going to get in our response, were going to get mr. Wade to file a false declaration which she does. The declaration in this case is falls. And the evidence showing that that is false as it relates to the timing, inner, and and the court asked earlier, why does it matter, you know, if that relationship was before or after november 12021 . The answer is, they think it is important. And frankly, i do, too because when she is hiring someone and she is not telling the people who are going to be paying the tab to 700,000, hey, i just hired my boyfriend who is taking me on trips, the caribbean and taking me down to aruba and taking me to california hoping i hope you dont mind. No disclosure whatsoever, and that money flows off. But because they got caught, they then commit what i think is forensic an additional component of forensic misconduct, and that is a fraud on this court. When they filed that affidavit that has now been proven i think beyond virtually any doubt, any doubt that the relationship occurred power to november 1, 2021 and the benefits that were there and we dont have to run around and i love the you know, we got all the records showing from mr. Wade about the payment for these trips or the cruises to the flights, all of this stuff. What is the only way is a set around and met together before they testified and came up with their story. It is the only way that they can save themselves. Pay no attention to the records. Pay no attention to the airlines and to the flights and the occasions and 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. Well, it shows the deposits that he had. Well, never. But we dont have any. What we have here is a fraud on this court, which has been sh shown, i think, overwhelmingly by the evidence and overwhelmingly through not only the testimony, the testimony of the emails, of the text from mr. Bradley to Miss Merchant, as well as all the documents that they had no answer to other than the just trust me, i gave them money, evaporated, i dont know where it came from and he does not know what he did with it, just please trust us and leave us because it is our only way out of the trap that they set for themselves. These people exactly and i hate to say this as a former i was a prosecutor for about 3 1 2 Million years it seems in the Federal Building and i was an assistant d. A. Before hand. Prosecutors dont act like this. Lawyers dont act like this. These people, your honor, it is a systematic misconduct and they need to go. Thank you. [papers rustling] 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 miss willis basically lived the 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 morning that was paid to mr. Wade to the contract that miss willis got him. That money flow, that is the personal interest that you asked about. She was personally benefiting from that 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 the day trips that both wade and willis admitted to. So that number is likely even higher. We know from the documents that miss willis only paid 1,394 for an airline ticket. We know from security 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 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 that is what they started having sex. But the relationship predated that. And their combined and overly suggestive focus on that is a red herring to this court and to the defense that is what they want you to focus on. They want you to ignore all the evidence that the relationship predated that. The relationship started in 2019. The relationship continue through 2020, the relationship continued through 2021. Looking at the cell phone communications, just in the first 11 months of 2021, over 2,000 calls, almost 9800 texts. I dont even think lovestruck teenagers to make it that much. November 29th, novemb november 30th, escapade. Phone call from miss willis. Between ms. Willis and mr. Wade. 11 32 that night. Shortly after midnight the phone starts traveling down. From where mr. Wade lives and end up where ms. Willis is staying and he is there until roughly 4 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 [indistinct] in the middle of the night. Im pretty sure that there were not any restaurants that he drove 30 to 45 minutes to go eat at in the middle of the night right after he had gone to willis. Teenagers have a name for those kind of calls and those kind of exploits, i will go into it. But the Documentary Evidence, the objective evidence, undercuts everything that both wade and willis said. When you look at miss serie d, 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 that relationship began in 2019. Again, his january, you know, temporary amnesia that somehow is triggered temporarily after the phone call. We can question that. But we do have statements from him that specifically said that relationship predated mr. Wades appointment ms. Willis. You asked well, mr. Wade you asked what that materiality would be. How much is it, huh . Well, clearly, 70,000 is enough. But Fulton County has told us, has told mrs. Willis what that materiality is. It is 100 in a year. She was signed declarations, certifications that she did not receive any gifts. And even other her strained explanation, there were monies, there were gifts, there were dinners, there were excess contributions flowing her way that exceeded 100. Her excuse or im sorry to her explanation, well, i just paid it in cash. That just does not stand to reason. It does not hold up to the light of truth. Anyone that has ever been in a Money Laundering trial, a forfeiture trial, if that is 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 can see that was a source for money because at times she said she was down to 510,000. The only explanation she has is, 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 . No. Did they bring her Bank Accounts in . No. Did they bring any documentary Documentary Evidence in . No, they did not take why is that important . Yes, the burden is ours. But under ocg a 241422, if a party has evidence and such partys power and within such partys reach by which he or she may repel a claim they had that power and mr. Wade had the power that they could repel the claim that we have made against them they admit to produce it or if they produce weaker evidence, then you as the factfinder, judge, it is in your power to disregard that in a resumption presumption arises in what is in their possession, it 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 miss willis have some difficulty expressing the truth when it comes to their relationship in these cases. We know, mr. Wade lied in his multiple times. With no ms. Willis falsely certified that she hadnt received any gifts from anybody at mr. Wade clearly was a prohibitive source. He was someone doing the width Fulton County. Anything over 100 in a year, she had to put down. And she put zero. And it defies Imagi Imaginationt she could somehow forget about all these trips, all these dinners, all of these day trips and not put that money down. You had asked, i think it was mr. Gilman. Did she say in that Church Speech or anywhere else that the defendants were guilty . And i think she did in that Church Speech. She 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 Leader put together has a Conviction Rate of 95 . I do not see how anyone and i think that was purposely intended by miss willis, i do not see how anyone can listen to those two statements and not take that miss willis is telling everyone in that church and if with that is going to hear that in the media afterwards that these defendants are guilty. That is what she was saying. She is a prosecutor. She is familiar with the u. S. Case. Every single attorney that has ever been a prosecutor is familiar with the dictates of of the u. S. Supreme court case. That is a foul below. That is improper. And she violated pretty much every tenant a prosecutor must abide by to seek Truth And Justice in a particular case. So judge, when you are looking at this, the uncontroverted evidence showed that they had a relationship prior. The uncontroverted evidence shows that mr. Wade lavishly spent on miss willis. The uncontroverted evidence shows that the morning that he was spitting on miss willis came from this contract that he had and im not just talking about the contract as a Special Prosecutor, but theres also other questionable contracts that no matter whom his partner seem, they also got. There is a direct financial benefit that miss williams received from this. And judge, looking back at what the judge said, if merely hosting a fundraiser for a political opponent of a putative defendant creates not only the appearance of an actual conflict, then what ms. Willis has done since then in this case creates national conflict. But again, as part of counsel has stated, we only need to show the appearance of the conflict. And we have done that by preponderance of the evidence, the fact in fact, i think we have shown actual conflict. But nonetheless, the results should be that miss willis in her office should be disqualified for this case. Judge mcafee we have a few more minutes. I think mr. Cornwell may have something to say. Thank you, your thank you your honor. Judge mcafee thank you. Good afternoon, your honor. I am representing clark. Im going to talk 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. Our Appellate Courts courts have said often the administration of the law and especially that of the criminal law should like caesars wife be above suspicion and should be free from all temptation, bias, or prejudice so far as it is possible for our courts to accomplish. But first, the occurrence of that that i can find his michael if he stayed more than 100 years ago, 1915, the most reason in the Supreme Court in 2010 although they dont refer to at seasons wife. That requirement is also embedded in the prosecutors statutory oath 15182. 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 Interest for lawyers is in role of professional conduct 1. 7. And we all know it is all drummed into us that we cannot have a Conflict Of Interest. And if we do, we have to withdraw or we will be disqualified. The basic idea is that a Conflict Of Interest impairs the lawyers independent professional judgment. That i