22sc183572 Motion in Limine 22
22sc183572 Motion in Limine 22
22sc183572 Motion in Limine 22
***EFILED***TG
Date: 7/27/2023 2:10 PM
Che Alexander, Clerk
STATE OF GEORGIA
STATE OF GEORGIA, )
) INDICTMENT NO. 22SC183572
v. )
)
JEFFERY WILLIAMS, ) JUDGE GLANVILLE
Defendant. )
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
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
1
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
Respectfully submitted,
The Steel Law Firm, P.C. 1800 Peachtree Street, N.W., Suite 300, Atlanta, Georgia 30309 (404) 605-0023
2
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:
[email protected]
[email protected]
[email protected]
Demetrius Smith, Esq.
Adrian Love, Esq.
Simone Hylton, Esq.
Fulton County District Attorney’s Office
136 Pryor Street SW
Atlanta, GA 30303
Respectfully submitted,
The Steel Law Firm, P.C. 1800 Peachtree Street, N.W., Suite 300, Atlanta, Georgia 30309 (404) 605-0023