Note: My computer/Word has gone crazy…       

                      BEFORE THE GWINNETT COUNTY ETHICS BOARD

                                                            STATE OF GEORGIA

December 10, 2019

D.A. King

PETITONER

vs

Marlene Fosque

RESPONDENT

MOTION FOR LEAVE TO SUBMIT SUBPOENA LIST FOR WITNESSES

Plaintiff was presented with a list of witnesses at the Monday, December 9, 2019 preliminary hearing that he had not seen before or knew existed. Until that time, Plaintiff was working under the mistaken belief that Respondent had submitted exhibits, but no request for subpoenas for witnesses.

Plaintiff received exhibits and Answer to Complaint via FedEx delivery on November 29, 2019 but has no knowledge or record of receipt of List of Witnesses until being notified and handed said list in preliminary hearing. Plaintiff can offer no explanation for this fact but does ask for remedy in disparity and believes he has good cause for approval.

Plaintiff would have requested subpoenas for witnesses if he were armed with knowledge of Respondent having requested witnesses and asks the Board to allow submission of list of the below names and seeks and requests subpoenas for following witnesses for Plaintiff:

1) Gwinnett County Commissioner Marlene Fosque

Gwinnett County Commission offices

75 Langley Drive

Lawrenceville, Ga. 30046

2) Gwinnett County Sheriff Butch Conway

Gwinnett County Sheriff offices/jail

2900 University Parkway NE

Lawrenceville, GA. 30043

3) Mr. Everett Robinson

102 Valdosta Avenue

Canton GA 30114

Each of the foregoing would be called to give testimony as to their knowledge of Plaintiff’s activities and reputation as a pro-enforcement immigration activist and the mission of the Dustin Inman Society. In addition, Plaintiff will examine these parties as witnesses to the allegations in the complaint, the publicly stated mission of Respondent’s witnesses and reputation of sources cited by Respondent in her August 6, 2019 speech regarding Plaintiff.