Thomas William Healan Jr.

℅ 194 Etheridge Road

Auburn, Georgia 30011

STATE COURT OF GWINNETT COUNTY

STATE OF GEORGIA ) Case # 2016D-00833-1

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Vs. )
THOMAS WILLIAM HEALAN ) Request for discovery and Brady
AKA THOMAS WILLIAM HEALAN JR
) Request
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Comes now alleged defendant THOMAS WILLIAM HEALAN who hereby requests counsel for
the alleged plaintiff to provide discovery All my interactions with government employees are
under threat, duress and coercion, only to avoid further aggression against me and are not a
waiver of jurisdiction. This is also a Brady request. Alleged defendant requests the following:
1. The names of every witness the prosecution relies on to prove:

A. Alleged defendant's presence within the plaintiff STATE OF GEORGIA;

B. Alleged defendant's presence within the CITY OF LAWRENCEVILLE ;Alleged
defendant is subject to the laws of the plaintiff STATE OF GEORGIA;
C. The constitution and laws of the plaintiff state apply to alleged defendant just
because alleged defendant is physically in Georgia;
D. A valid cause of action (injury and damage, corpus delecti) has been presented to the
court.

2. The name of any witnesses who are experts in the interpretation and application of Georgia
law, including Georgia traffic laws, the prosecution relies on.

3. Any and all evidence, known to the complaining agent proving alleged defendant was
present within the plaintiff STATE OF GEORGIA.
4. Any evidence (facts, not argument/allegation/opinion), known to the complaining agent
proving alleged defendant was within the CITY OF LAWRENCEVILLE..

5. Any evidence (facts, not allegations/opinions) alleged defendant is subject to the constitution
and laws of the plaintiff STATE OF GEORGIA just because alleged defendant is physically in
Georgia..

6. Any evidence (not allegations/opinions) a valid cause of action (legal injury and damage) has
been presented to the court.

7. The names of any other witnesses with personal first hand knowledge the prosecution relies
on to support any element of the alleged crime or cause of action against alleged defendant and
which elements the witness is specifically relied on to testify to.

8. The police officer’s reports and notes regarding the stop and arrest, including any
video/audio recordings of the stop, such as a dash cam video. This includes true copies of the
original complaint written by the police officer submitted to the court, front and back.

9. Evidence you have to prove the witnesses relied on have personal, first-hand knowledge of
the matter(s) they are to testify to.

10. The names of any witnesses relied on by the prosecution that have been dishonest during
investigations and trials and anything relevant to guilt or punishment and is exculpatory or
favorable to the defense. This includes, but is not limited to any information regarding the
truthfulness, bad character and reputation of any of the prosecution’s witnesses. This includes,
but is not limited to all criminal records, contempt citations, incidents of violence and any history
of mental illness. This also includes any complaints filed against witnesses who are
government employees (i.e., police), whether or not the complaints were investigated or
subsequently confirmed.

11. Any material including, but not limited to videos, audio recordings and written reports that
may be used to impeach prosecution witnesses.

Submitted this FIFTH day of APRIL 2016

Certificate of service

This is to certify that a true and correct copy of the foregoing has been hand delivered to the
office of solicitor this FIFTH day of APRIL 2016 , to the plaintiff at the following address:
OFFICE OF THE SOLICITOR-STATE COURT
GWINNETT JUSTICE AND ADMINISTRATION CENTER
75 LANGLEY DRIVE
LAWRENCEVILLE ,GA 30046-6900