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IN THE SUPERIOR COURT OF [XXXX] COUNTY
STATE OF GEORGIA

STATE OF GEORGIA

vs                                    Case No. [xx]

[Client]

NOTICE TO PROSECUTING ATTORNEYS
[Client], THE ACCUSED IN THIS CASE, ELECTS TO PROCEED UNDER THE DISCOVERY PROVISIONS OF
O.C.G.A. §17-16-1, et seq.
ALSO, OTHER NOTICES TO THE STATE OF GEORGIA

[Client], provides the following notices to the State of Georgia and the prosecuting attorney of this case.

First Notice to the Prosecuting Attorney, Thurbert E. Baker

[Client] committed no criminal acts.

[Client] is a hard working, medically competent professional who fulfilled all of her obligations to the State of Georgia during her employment. As a matter of financial accounting, the State of Georgia is indebted to [Client] for annual leave which was not paid upon her resignation.

During [Client]'s employment by the State of Georgia this State was never required to employ any outside private professional or other persons to perform the work tasks of [Client]. Never did a task of [Client] go unperformed. Never were the services rendered by [Client] performed negligently.

The prosecuting attorney, Thurbert E. Baker, cannot truthfully make the same statement about his employment with the State of Georgia or the employment of persons whom he supervises. Thurbert E. Baker employs law firms and lawyers in private practice to perform tasks assigned to him by law. Thurbert E. Baker negligently supervises lawyers working for him to the extent that the State of Georgia forfeits money because of his employees’ negligent conduct. It might be wise and beneficial to the persons of this State if Thurbert E. Baker shovels out his home base before he starts fly-specking the efficiency of one of this States’ most dedicated workers, [Client].

The prosecuting attorney has sloppily investigated this case and deceptively put together a case with smoke and mirrors. This sloppy investigation directed by the prosecuting attorney resulted from the acts of employees who wasted numerous hours of state compensated time. These state employees padded their work schedules with unproductive, unnecessary work guised as investigation of this case.

In part, these employees of this prosecuting attorney, Thurbert E. Baker, performed this incompetent investigation in an effort to give the appearance of fulfilling a job. These employees were so sloppy they did not even look at the entries in the files of the patients who [Client] attended on the days these prosecuting attorneys charge she did not work. Sloppy, Sloppy, Sloppy.

The real problem with the charges against [Client] stems from the fact that the employees of the prosecuting attorney are not around people with a strong work ethic like that of [Client]. These employees of the prosecuting attorney are unable to envision people who regularly work as much as eighty hours a week. These employees do not know what it is like to earn money working on a real job where they must produce something in return for their pay. [Client] returns ten fold to society by providing care for the sick, preventative care for the well and instructive guidance to all of her patients. [Client] heals. [Client] attempts to make people's lives better with her medical skills.

Even worse than the sloppy investigation by these government purse drainers with a low work ethic, Thurbert E. Baker, the prosecuting attorney, has allowed these employees to use the court of this county in pursuit of the employees’ personal goals of maintaining a make-shift job away from the half-opened eyes and the office of the Attorney General. This make-shift job fraud unit site is but one of the ways that these improperly supervised state workers employees keep a job for themselves near their homes in exchange for occasional favorable publicity for the Attorney General.

An efficiently operated prosecutor’s office would not have brought these charges against [Client]. The citizens of this State could benefit in many ways from an efficiently, non-politically operated office of Attorney General. Thurbert E. Baker, as Attorney General and prosecuting attorney in this case, deprives the people of the opportunity for good government that an efficiently operated office of Attorney General could provide. This Attorney General's staff is composed of so many unproductive and professionally unqualified legal personnel that it could not handle a complex legal matter even if Thurbert E. Baker did not wish to send case out of his office as a method of distributing State of Georgia money to private attorneys.

This Prosecution is Hypocrisy All' Ultimo While Also Being a Most Shamefully, Ill-Motivated Act Birthed in a Cradle of Political and Xenophobic Conduct

This Attorney General, Thurbert E. Baker, spends hundreds of thousands of dollars of money belonging to the State of Georgia in hiring private lawyers to perform the obligations of his office. Thurbert E. Baker spends these hundreds of thousands of dollars each year hiring private law firms and private lawyers with whom Thurbert E. Baker wishes to gain political favor and repay for political, monetary and other contributions. This money is spent to perform the tasks constitutionally assigned to Thurbert E. Baker. This conduct raises “sick leave” to a sickening level of “legalized” corruption. This conduct is Sick, Sick, Sick. From government, this type of conduct should Leave, Leave, Leave.

These private law firms and lawyers who are paid to perform the work of the Attorney General, Thurbert E. Baker, do the work of Thurbert E. Baker while this Attorney General spends his time politicking both within and outside of his office. The Attorney General of Georgia is the lawyer for the people of Georgia in matters concerning this State. On a very regular basis, Thurbert E. Baker farms out this responsibility. In farming out his responsibilities Thurbert E. Baker receives in return political and economic benefits in the form of political contributions and political support. Now, these acts such as paying an attorney general and his staff for work that is performed by private lawyers should be investigated by a judicially appointed independent counsel rather than spending this time with the acts of [Client], a hard working and dedicated medical professional.

Thurbert E. Baker employs these private law firms and private lawyers to perform his official duties as the Attorney General for the State of Georgia, all the while, the State of Georgia pays money to employees who, at best, are inadequately trained, mediocre legal professionals who cannot get or hold jobs with good law firms. These mediocre lawyers and employees who are employed by Thurbert E. Baker, the Attorney General for the State of Georgia, not only do not get the State of Georgia’s work done professionally, they fail in their tasks while using their sick leave as he has falsely accused [Client] of doing in this case.

[Client] works using her professional medical skills to heal people and to prevent people from having medical problems.

Counsel for [Client]. do not Waive a Future Right to Disqualify the Prosecuting Attorney, Thurbert E. Baker or His Employees in this Litigation -- [Client] is Entitled to an Unbiased Prosecution

Now, counsel for [Client] are prepared to support their statements about the wrongdoings of the prosecuting attorney in this case. The question in issue is whether Thurbert E. Baker will continue to camouflage the wrongdoing of his political allies with sloppily prepared accusations such as these against [Client], or whether Thurbert E. Baker will start tending to the State of Georgia’s business with well-qualified legal professionals employed by the State of Georgia and not use private law firms and lawyers with conflicting interests to the State of Georgia.

Second Notice to the Prosecuting Attorney, Thurbert E. Baker

The State of Georgia did not charge [Client] using her legal name. [Client] has married since the time she was employed by the State of Georgia. At the time of her marriage in May of 1989, [Client] took the name of her spouse. The Assistant Attorney General involved in this case has likewise changed her name from Nancy Allstrom since her initial participation in these charges. Just as this Assistant Attorney General wishes to be addressed by her legal name, so does [Client]. This is a miniscule problem, but is certainly worth stating in this initial Notice to the Prosecuting Attorney.

Third Notice to the Prosecuting Attorney, Thurbert E. Baker

Put Up or Fold

Counsel for [Client] is now ready to see the information that Thurbert E. Baker used to make the charges against [Client]. Has the sloppy “investigation” by Thurbert E. Baker’s employees produced smoke from the fires of prejudice, or is the smoke produced only the smoke from the spinning tires of the notoriously, poorly managed office of Attorney General?

Fourth Notice to the Prosecuting Attorney, Thurbert E. Baker

[Client] provides the prosecuting attorney this written notice as allowed by O.C.G.A. §17-16-2 that she elects to have the provisions of O.C.G.A. §17-16-1, et seq., apply in this case.

Relevance of the First and Third Notice to the Prosecuting Attorney in Perfecting this Fourth Notice for the Purpose of Obtaining Relevant Documents Necessary Litigate the Issues between the State of Georgia and [Client].

There are two notices to the prosecuting attorney here that the prosecuting attorney may deem extraneous. The prosecuting attorneys in this case will only deem these notices extraneous if they are unaware of the facts in this case that will demonstrate the sloppy, unprofessional, incompetent investigation made before these charges were lodged.

Issues that will be litigated pretrial that are relevant to be discovered by the election of [Client] include, but are not limited to the following.

1. The selectively unconstitutional prosecution of [Client] for conduct that was approved by her supervisor at the Georgia Regional Hospital at Atlanta, a facility that relies upon this prosecuting attorney for legal advice;
2. The selectively unconstitutional prosecution of [Client] for conduct that is the same conduct that has been engaged in by the prosecuting attorney and people employed by and with the prosecuting attorney;
3. The selectively unconstitutional discriminatory prosecution of [Client] due to her ethnic background;
4. The presentment of incorrect, inadequate and sloppily prepared information to the Grand Jury;
5. By the illegal and unconstitutional presentment of information to the Grand Jury;
6. The disqualification of these prosecuting attorneys because they maintain that one of their attorneys is a factual witness in this case;
7. The disqualification of these prosecuting attorneys because of ex parte conversations with judicial officers in this case;
8. The disqualification of this prosecuting attorneys because of a pattern of exchanging political favors with judicial officials in this Court;
9. The disqualification of this prosecuting attorneys because of "educational" instructions and publication of information of ex parte information to judicial officers in this Court;
10. The slanderous, untruthful and libelous statements made by these prosecuting attorneys and their employees about [Client];
11. The inadequate, sloppy investigation in this case;
12. The money received by the office of the prosecuting attorney that motivated these false charges against [Client];
13. The prosecuting attorney, Thurbert E. Baker, followed Michael Bowers into the Office of Attorney General. Michael Bowers not only engaged in illegal conduct with an employee of the State of Georgia working under his supervision, but obtained employment for this person with King & Spalding, a private law firm doing business with the State of Georgia. Thurbert E. Baker did nothing to prosecute this wrongdoing, but worse, he retained many of Michael Bowers’ top employees who know of the wrongdoing of Michael Bowers;
14. Thurbert E. Baker has known for over a year of the wrongdoing of Norman Johnson, a person with political ties to friends of Thurbert E. Baker. Thurbert E. Baker has done nothing to prosecute this and other persons with political ties to friends of Thurbert E. Baker; and,
15. Thurbert E. Baker exercises the prosecutorial functions of his office in an unconstitutional discriminatory manner. Admittedly, the Office of Attorney General of Georgia has always been operated as a political arm of the Attorney General, but this is not a legal function of this constitutional office. The Attorney Generals of Georgia have fought to keep the schools of Georgia racially segregated and have fought to perpetuate discrimination in many aspects of our society. This prosecution is but a blip in the continuum of discriminatory conduct by Attorneys Generals of Georgia.

This prosecuting attorney, Thurbert E. Baker wants to send [Client] to prison and strip her of her medical license. Prisons and employment deprivation are not tools that should be in the hands of political hacks that don't perform their constitutional assignments. The citizens of Georgia need good [Professional] like [Client]. It does not need junky lawyers whetting their political stones.

Thurbert E. Baker, quit spending the money of the people of the State of Georgia on private law firms and private lawyers to do your work. Clean house and hire competent lawyers and quit dealing with your political hacks. The people of Georgia deserve clean government, especially by those in charge of legally representing them.

Millard Farmer
Georgia Bar No. 255300
Joseph M. Nursey
Georgia Bar No. 548025
P.O. Box 1728
Atlanta, GA 30301-1728
(404) 688-8116

COUNSEL FOR
[Client]

 

 
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