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politics. the superior court in fulton county, georgia held a hearing. the lead prosecutor in georgia selection interference case against former president trump and others. in this hearing, terrence bradley, a former law partner in divorce attorney for prosecutor nathan wade, is questioned about his knowledge of mr. wade's romantic relationship with the district attorney. he was questioned by defense attorney ashley merchan about his knowledge of the relationship. this is just over two hours.

on behalf of mr. clark? >> we also waive his appearance. >> good afternoon, your honor. richard rice. he waves his presence. >> good afternoon. quex on behalf of mr. schafer? on behalf of mr. floyd? >> good afternoon. we also waive mr. floyd's appearance. >> on behalf of miss latham? anybody here on behalf of miss latham?

before we had mr. cromwell, and i had not heard anything from him. >> i believe mr. cromwell is in a deposition in south georgia. that's all i know. >> that's helpful to know. mr. cromwell, can you hear us? we will keep an eye on that to see if he does join us and we will take it up as it comes. so, just a few preliminaries. i have been under the weather so i will try to speak up. if anyone can't hear me, i will try to talk close to the microphone. but we're here today for the sole purpose of which is that the conclusion of the hearing on february 16. that meeting with mr. bradley to assess the validity of his assertion of attorney-client privilege.

i have now been able to do that, i also allow mr. wade the opportunity to weigh in and respond. after considering the testimony, not only in but what came out at the hearing. i found mr. -- neither mr. wade or mr. bradley had met their burden on establishing the attorney client privilege -- privilege applied specifically as it relates to mr. bradley's knowledge with any relationship that existed between miss willis and mr. wade. and, particularly that it wasn't established that his specific knowledge came at further ends of legal advice. having made that determination, i did not see any choice but to allow the parties to have an opportunity to explore that topic. there is really, in my mind, it with that topic only, if there's anything else we have covered, i'm not here to do it again.

with that, is there anything else we need to cover before kicking that off. >> mr. wade is still a potential witness. >> i believe mr. wade was released when we concluded his testimony at the last hearing unless he has been re-subpoenaed, i have no knowledge of that. >> i think, procedurally, that would be accurate. at this point i don't see a means where he would need to be recalled, but if it is, than that is something you could take up. all right, mr. bradley through his attorney informed me he would be here in person. i don't see him in the gallery, doing know if he's out in the hallway. if we could call for mr.

bradley. quex would it be permissible to sit in the jury box? >> that's fine. quex mr. bradley, deputy scott will swear you and again. click saito last name for the court. >> terrence, bradley. >> thank you, judge. good afternoon, mr. bradley. good to see you, sorry under the circumstances. i will go to where we left off before. fani willis and nathan wade were in a romantic relationship, correct? >> correct. >> it began at the time they were both municipal court

judges, correct? >> objection, your honor, based on privilege. >> i do not have knowledge of it starting or when it started. >> you told me that it started when they were both municipal court judges, correct? >> that is incorrect. >> you never confirmed in writing that it was instead of magistrate court it was municipal court when they started dating? >> if you are speaking of the text message, you can go to that text message and you can read that text message and i will explain that text message to you where you and i did not have a conversation about when it started. you asked a compound question of magistrate court versus -- you said it was magistrate court -- you said magistrate court conference, i'm sorry, then you

asked another cop -- another question. i said, no, municipal court, nothing else. >> i'm referring to a different conversation. i ask you, do you think it started before she hired him. >> i'm going to object the previous hearing were mr. bradley said he had no personal knowledge. speaking of an actually used in attempt to refresh his recollection, he explained exactly what was repetitive and unnecessary. i would object to asked and answered. >> perhaps we will get there, i think she has a right to jot his attention. >> thank you, judge, may i approach him. >> it's overruled. >> enter purposes of the record,

i believe we use the entire text exchange as an exhibit. >> i only have a few. this one was not tendered. i'm happy to tender it. >> we will take it as it comes. >> i think will -- we are at 39. i will wait to market. may i approach, judge? >> you may. collect serum of her telling me and start it left the das office? >> i see the message there but i don't recall, i do see that message, but i do not recall.

>> you do not recall texting this? >> i looked back at my text messages through -- that we've had, i see that message, but i do not recall that, no, ma'am. click i asked you if you thought it started before she hired him and you responded, absolutely. >> mr. bradley allegedly gathered this from. there has been no foundation based on the arguments that a lot of this is based on gossip, innuendo, assumption and privileged information. she has not provided a foundation as to how mr. bradley would have any information that she keeps referring to. >> i didn't ask about the source of the information. under rule 621 i can impeach him with any inconsistent facts. i can impeach him with any contrary facts. >> why would it be a relevant impeachment if he has no personal knowledge of this?

i think you have to lay that foundation. >> do you remember telling me when it began? i was just asking if you remember telling me. do you remember telling me that it began? >> no, then he going to substance, which we haven't determined whether he actually knows or how he knows. >> you told me, in fact, you corrected me when i said magistrate court. you said it was mean a civil court. do you remember that? he has an answer that question yet. >> the relevance of whether he remembers it isn't established until we know how he remembers it or how he knows it. if that makes sense. i guess not. >> sorry.

how he knows it? i'm just asking if you told me that. so i wasn't asking how he knew that, i was in asking the source of that knowledge, i was asking if you told me that. >> that's the point, how he knows it with his knowledge. it's hearsay because it's gossip, which is what might be hearsay. >> we don't know how he knows what apparently he is telling her and we need to figure that out before we go forward. >> wended the relationship start? >> i cannot answer that. >> one was your first knowledge of the relationship ? >> he said he had no idea of the timeline or when it occurs. that was one of the first question. >> he testified he has knowledge they had a relationship, i asked when he got knowledge of that. >> ok, so the question is, when did you first get knowledge.

i think we can start there. >> that was the question. thank you. >> when did you first get knowledge of the relationship? >> i've said over again that i was not -- i did not have any personal information where i could personally say when it started. i've set that time and time again. i don't know when the relationship started. >> that wasn't my question. my question is, why did -- when did you first gain knowledge. i did not ask you to comment on the ability of the knowledge. -- validity of the knowledge. >> note the objection and overrule it. >> he said he has no personal knowledge, so it's clear he had to gain the knowledge not from hearsay. >> most of us learn things from hearsay. the question of whether it's admissible. that's what we've got to get to. >> i apologize.

>> when did you first get knowledge question mark or not qualifying what type of knowledge, i'm just asking when you first knew about the relationship. >> i will object to this line of

questioning because he does not know. >> i'm overruling that, i think we can try to see if you can narrow it down based on goalposts. >> thank you. >> i would probably say, no. i don't have anything that -- there was a specific date, there wasn't a football game, there wasn't something that i could attribute it to him telling me, whatever. so, you're asking for a date, you're asking for a year, it's still a date. at this time, i am still telling you i do not have the date. >> let's try this them. you received a contract from miss willis january 2021, correct? >> yes, i think so. if it was from the exhibit, i

think it was 20, yes. >> those documents you looked at last time said january 2022? >> january 2021. i think it was renewed in 2022. >> using that date, at that point, had they begun their romantic relationship? >> of 2022? >> 2021, when you got your first contract? >> i don't recall, i don't recall any specific dates. no, ma'am. >> you remember when you got that contract? you told us last week where the

week before now, you told us mr. wade brought you that contract, essentially told you about that contract. so miss willis is not the one who brought that contract. at that point in time there were already engaged in a relationship. >> objection to wet mr. bradley just said, he said he does not remember. there's nothing specific. >> he doesn't remember the exact date. maybe tie it to another event you might remember. >> he says he does not remember any specific date after signing the contract, that's what he said, asked and answered. >> you don't have much more to pull on here, but he answered that last question, so what's your next one? >> i did not hear the answer if they were in a relationship. >> i recall the question and i cannot tell you whether or not they were in a relationship at the time.

you asked me about him bringing a contract and i said he did bring me a contract and that is accurate. >> do you remember knowing this villas prior to her taking office at the da? >> i had very little contact with miss willis. i knew her through my business of coming out to fulton, if that's what you are asking, yes. lexi knew her through the business, so you hadn't met her prior to your contract? >> i am going to object to relevance. quex he doesn't remember much of anything, so i'm trying to create a timeline to hopefully pieces together. quex all right, well -- >> alright, well, i'm not saying the likelihood of that will have any success on asking a few more questions, but if he does not have a date, i don't know that you will be able to create one today. >> thank you.

so the time that you had this contract from january 2020 12 january 2022 did you come in and out of the das office? >> yes. >> did you witness their interaction during this time? >> i'm going to object. the last hearing about mr. brown please access to and from the specific room, mr. bradley says that he rarely saw them together. >> i think the only avenue that was closed at the last hearing was personal knowledge potentially through -- actually no, if he testified he had no personal knowledge, it was knowledge conveyed to him cut off at the last hearing. that's the only thing we had not been able to explore. correct me if i'm wrong. that he claimed at the time was privilege. that's what we are here to

explore. >> do you remember telling me that not many people knew where they met? >> i'm going to object to relevance to his personal knowledge. >> we are back to the same point. >> i'm asking him what he told me. >> but he hasn't told you how he knows that. unless you can establish why he should be testifying on this at all. >> i don't know how he knows that. >> then ask him how he knows it. >> i have to establish that he said that. >> no you don't, you can go the other way around. >> when you told me that it started when she left the das office and went to judge and south fulton, where did you gain that knowledge from? >> i'm going to object, his

testimony a few minutes ago was that he did not recall making that statement. >> answer the question if you can. >> repeat the question. >> when you told me their relationship started when she left the das office and was a judge in south fulton, where did you obtain that knowledge from? >> >> i was speculating, i did not have a -- no one told me i was speculating. >> no one told you that. you were speculating based on things that had been told to you. >> i am going to object that, the nature of this line of questioning because the witness

has made it clear he was speculating as to how or what he knew. speculation is inadmissible for this court. >> the motivation for his reason for speculating as --, so i will overrule that. >> was it speculation when you told me that? was that based on things that had been told to you? >> i never witnessed anything. so, it was speculation. i cannot tell you anything specific, if that's what you are asking. >> you can't tell me anything specific as to why you speculated about that? >> this was however many years ago. i don't recall, but, no. i don't know speculation is lying, but -- >> show me where on this text it

says you are speculating. >> you did not asked me if i was speculating. >> tell me if it says anywhere here? >> if it's the same one you just showed me, it does not. >> is there anywhere in here that indicates you do not have knowledge? >> i am going to object the line of questioning. he has explored that, he said it speculation, he didn't get it from any source other than his own speculation. >> i think we are fleshing it out. i think it's her right to have a little leeway on this if he's an adverse witness. >> these directions are clearly from the witness because he's regurgitating. >> i take offense to that,, i'm objecting based on the law and i'm making a record for the court. i take offense for that,, it's

judge mcafee: i think we can start with the question, and if i need anymore, i will ask. ms. merchant: what did nathan tell you about the relationship? >> objection, hearsay. ms. merchant: nathan has testified. >> it is still hearsay. judge mcafee: this would be for impeachment which would be an exception to the hearsay rule. the privilege issues are overruled. ms. merchant: thank you, judge. >> we don't know when he is talking about. judge mcafee: that is something covered in the in camera hearing, and based on what you told me in that hearing, i do not believe any statements to this effect were covered by privilege. ms. merchant: i want for the record because the record does not sometimes reflect where people are looking, and when i

ask a question, mr. bradley is looking at mr. wade and his lawyer, and they are interacting in the court. i want the record to reflect that. judge mcafee: the question was put to you. mr. bradley: one of my lawyers is sitting right in the back -- judge mcafee: you can look wherever you want. mr. bradley: i never looked at mr. wade or his attorneys. judge mcafee: the question was put to you. mr. bradley: repeat the question, please. ms. merchant: i asked you, the last question i asked you was what did nathan wade tell you about the relationship? >> objection. judge mcafee: that has already been ruled upon. mr. bradley: i recall him stating that at some point they were dating. i cannot tell you what date that

was. it was made in confidence, we were in the back of our office. our offices were the only two in the back, there was no one else present. that is all i can tell you at this time. ms. merchant: one time? mr. bradley: one time. ms. merchant: you only had a conversation with him one time? >> objection, that is an answer. mr. bradley: i do not recall any other time that he mentioned that they were in a relationship, no. ms. merchant: you talked about this one time and said you do not know when it was, correct? mr. bradley: that is correct. ms. merchant: was it before you

got the contract for fulton county? mr. bradley: i do not recall. ms. merchant: how did it come up? mr. bradley: i do not recall how it came up. it was in the back. i know where it occurred. in the offices in the back. i cannot tell you what we were discussing prior to that. ms. merchant: did you receive any mail from me on january 6 with a motion attached? mr. bradley: i think i did, yes. i know i received -- i do not know if the date is january 6 -- but i received that. ms. merchant: you remember receiving that? mr. bradley: yes. ms. merchant: you reviewed it, then you and i spoke about it, do you recall that?

mr. bradley: did we speak over the phone or through text? ms. merchant: that is what i'm asking you. mr. bradley: i cannot remember whether it was text, phone -- ms. merchant: you recall us speaking? mr. bradley: one way or another, yes. ms. merchant: i was trying to confirm the facts in that filing. mr. bradley: i would think i would remember, there was a line about the accuracy of how much money that my office, the law office had received. and whether or not that was going to be in the motion or not. ms. merchant: i had kept that

out and you asked me to put it back in? mr. bradley: i don't -- i recall you -- that may be accurate, yes. ms. merchant: [indiscernible] mr. bradley: no, i think -- we discussed that it should reflect the accuracy because the accuracy was that i received, i had a contract and received 74,000, and i think you had put in there that mr. campbell received a certain amount, and mr. wade had received a certain amount.

but there was not anything in there originally, and i said it needed to be accurate as far as i had received 74,000. ms. merchant: because you do not want anyone knowing you had talked to me? >> objection. judge mcafee: overruled. mr. bradley: i wanted it to be accurate as far as the accuracy of our message or your filing. ms. merchant: ok, so your interest was in accuracy in the filing? mr. bradley: i did not reach out to you and say to send me a copy of your motion. i do not reach out to you to say that you were -- that i am going to be in your motion. ms. merchant: right, i asked you to review it for accuracy. mr. bradley: and i stated it was inaccurate. ms. merchant: and the thing that

was inaccurate was how much you had made? mr. bradley: that was an inaccuracy that i saw that jumped out, the fact that i felt i was left out when you put the firm moneywise. i did not, when i responded to that, it was for that specific reason. ms. merchant: i agreed i would put that section back in. mr. bradley: correct. ms. merchant: i did put it back in, then i sent it to you again. mr. bradley: i do not recall the second email from you. ms. merchant: but you are happy i agreed to put it back in. >> objection, irrelevant. judge mcafee: we need to get to more material aspects. ms. merchant: yes, i moving along. you did ask me to put that back in?

>> irrelevant. judge mcafee: you did not mention that last question, overruled. ms. merchant: you confirm you did ask me to put that back in, or to be accurate. mr. bradley: yes, that is correct. yes. ms. merchant: and then i asked you if everything was accurate, and you said it looks good. correct? mr. bradley: i recall you asking that, but "it looks good" was applying to the accuracy of the 74,000, that is it. ms. merchant: when you reviewed the motion and specifically pointed out the one thing you found inaccurate, you did not point anything else out inaccurate in that motion? mr. bradley: no, i did not. ms. merchant: that motion alleged their relationship began when ms. willis was in municipal

court? mr. bradley: i would have to reread the motion but i do not recall if that is what it says, but my saying that it looks good was when you put back in the 74,000 into your motion. ms. merchant: ok, that is not what i was asking. i was asking, you did not tell me there was anything else inaccurate in the motion? mr. bradley: but i did not state that anything was accurate other than the 74,000. ms. merchant: when i told you that i had this motion i was preparing, you asked me to send rough draft? mr. bradley: no, that is incorrect. ms. merchant: may i approach the judge? the number is january 6.

ms. merchant: you asked me to send a rough draft, but i told you i did not want it leaked before i filed it. mr. bradley: correct. ms. merchant: you asked me to send a rough draft? mr. bradley: yes, that is correct. ms. merchant: that was at 10:08, saturday, january 6.

then you've got an email from me with the rough draft at 10:45 that same day, correct? mr. bradley: yes. if it says 10:25, i know you sent an email. >> while you are looking at it, i am going to object. he sent a copy of the motion whether it was rough draft or not, then asked about the accuracies, explain his answer. judge mcafee: we are getting there. overruled for now. ms. merchant: i responded, we were talking about that, i said i took it out, and you said to add it back. mr. bradley: i said that, yes. ms. merchant: i said, anything else, and you responded "looks good."

do you recall that? i do not know where the exhibits are. does that refresh your memory? mr. bradley: it says "looks good," but as i stated before, i was responding to you putting me back into the motion for receiving $74,000 in the contract? ms. merchant: that is not what this says. you said, "yes, add it back," and i said, "anything else?" >> i'm going to object. judge mcafee: overruled. mr. bradley: i have said twice if it looks accurate, or i have said more than twice, that was the 74,000.

ms. merchant: do you remember telling me about nathan and fani coming to your office and spending time to your office? mr. bradley: no, i mentioned i do recall testifying on the 16th that she had come to our office. ms. merchant: that was before she was elected as district attorney, correct? mr. bradley: i recall that was when she was district attorney. because i said there was a meeting held at my office. ms. merchant: who was at that meeting? mr. bradley: i cannot tell you that, i don't recall. ms. merchant: you know ms. willis and mr. wade were there? mr. bradley: it was at our office, ms. willis was there, and other people were there. mr. wade was not in that meeting. he was in the back.

i was not even in that meeting. ms. merchant: why did she hold it at your office? mr. bradley: i have no idea. ms. merchant: even women were telling me about them spending time together at her law office before she took her job? i don't recall. do you have something -- ms. merchant: what i'm asking, let us back up a sec, willis rented a law office from andrew evans. you have knowledge of that? >> object, hearsay. how does he know the information would be the correct question? judge mcafee: ok. ms. merchant. ms. merchant: i don't know how to respond to that, i am asking -- judge mcafee: he may have seen a business card at some point.

mr. bradley: i've never been to ms. willis's office in private practice and i have never dealt with where she rented. i did not even know where her office was. ms. merchant: do you remember knowing she rented an office? mr. bradley: yes, that is correct. ms. merchant: do you remember telling me mr. wade and ms. willis would rendezvous at that office? >> i'm going to object. again, hearsay as to how he knows that information. he says he has no personal knowledge. ms. merchant: he did not say he has no personal knowledge, he has not even answered it. >> he will not establish the source because he has never been to her office. judge mcafee: ms. merchant, i know you are trying to impeach him with an inconsistent statement, but if you cannot back up and show what each

statement, the acknowledgment -- ms. merchant: i'm not even there yet. i can anticipate the response next. i did not ask anything objectionable but these objections are approaching the witness. i asked if he had knowledge, that is it. i did not ask if someone said it to you. judge mcafee: you are asking if he had knowledge, then something specific. ms. merchant: once i get an answer, then i will follow up with where that knowledge came from. judge mcafee: let's try again. ms. merchant: do you have knowledge of the meeting at that office? >> objection, foundation. judge mcafee: overruled. ms. merchant: do you have knowledge of the meeting at the office? mr. bradley: i have no personal knowledge. ms. merchant: i did not ask that, i asked if you had any knowledge. >> objection. judge mcafee: overruled. how do you know, mr. bradley?

mr. bradley: any knowledge that i would have received would have come from my client at the time. ms. merchant: you had knowledge of this place that ms. willis works. what did you know about them meeting at the office? >> objection, hearsay. judge mcafee: overruled. she has already asked the next question. ms. merchant: how do you have knowledge? you just told us mr. wade told you. tell us what mr. wade told you about ms. willis and mr. wade meeting at the other office? >> objection, your honor. privilege. the time after december 18 is covered by privilege. judge mcafee: overruled.

do you recall the question, mr. bradley? mr. bradley: i do not. ms. merchant: what did you learn from mr. wade about mr. wade and ms. willis meeting at the evans office together? >> objection -- judge mcafee: he has not answered. >> he had one conversation with mr. wade. judge mcafee: and his answer may change. mr. bradley: i can't recall what the conversation was. i do recall knowing that he

would go down to the office, or had been down to the office, but i can't tell you in what capacity or when. ms. merchant: mr. wade told you they had sex at that office? mr. bradley: i don't recall him saying that, no. ms. merchant: you do not recall, so it is possible he did say that. do you remember one way or another? mr. bradley: i do not remember him saying that. ms. merchant: do you recall that he had a garage door opener to her house or condo or something like that? mr. bradley: i've never seen a garage door opener. i've never been to ms. willis' house, and i am trying to explain, i have never been. i do not have any personal knowledge of him having a garage

door opener. ms. merchant: let me ask again, do you have any knowledge at all from mr. wade or any source that he had a garage door opener to access one of ms. willis' residences? >> i will object -- judge mcafee: overruled. mr. bradley: i do not have any knowledge. ms. merchant: when you told me that, did you make it up? mr. bradley: do you have something that shows that i told you that. ms. merchant: we will go through all the texts we have. >> i'm going to object -- i don't have that text message or any text messages that indicate that, your honor. ms. merchant: i actually think it was when he was on speakerphone but i am not sure. if i am asked to qualify where

that is from -- judge mcafee: rule of completeness would be that you need to introduce other text to show the context. if you do not have a copy yet, ms. merchant needs to do that before you decide the next step. ms. merchant: that is what i was asking him, if that is something he remembers making up. if he doesn't, fine. judge mcafee: you don't have a text message? ms. merchant: i would need time to look through and i do not remember if i have a text or that was a conversation, it was one of those. judge mcafee: he says he has no knowledge. on to your next question. ms. merchant: did mr. wade tell you about the trips he and ms. willis took? mr. bradley: no. ms. merchant: do you have any knowledge of the trips that he and ms. willis took. >> objection, hearsay. judge mcafee: overruled. mr. bradley: i do now. ms. merchant: but you did not before this proceeding. mr. bradley: i do not know -- i

did not know until you texted that you found in the deposition of his divorce, not deposition but something from his divorce. ms. merchant: ok. when you responded, "doesn't surprise me, they took many trips to florida, texas and florida," those are your words? >> objection -- ms. merchant: he said he learned about certain trips from ms. merchant. judge mcafee: if you can tie it down. >> no information on any trips, that he learned it all from ms. merchant was his testimony. judge mcafee: i think she will ask more than one question. ms. merchant: judge, so we can be clear, if he said more than one version, that is all relevant. we are allowed to talk about the different versions he has told. do you a member telling me, it

did not surprise you that that they took the trips because they took many trips to florida, texas and california. then you told me they took a trip to california when she moved her daughter, do you remember that? mr. bradley: i don't recall that, i don't recall. ms. merchant: it is in one of the ones i gave you. ms. merchant: [indiscernible]

ms. merchant: let me know if that refreshes your memory. mr. bradley: yes. ms. merchant: it is true that you told me they took trips to florida. mr. bradley: yes, but one of the messages is cut off, and you asked about other trips, and i said, "no, i didn't." specific to the top of that, it says, "no, i didn't." that was to the trips you asked about, and before that when you mentioned that you found all these trips, i think i said, "oh wow." ms. merchant: you did not know about all the trips that were taken. then the next text or on the

phone, whatever refreshes your memory, you said, after -- >> objection, irrelevant. judge mcafee: overruled. ms. merchant: you told me those were after, correct? mr. bradley: i think you mentioned they were after i left, maybe, or whenever you found them. i said i did not know about those trips. ms. merchant: you believe i mentioned that it was after you left? mr. bradley: i'm sure you have the text message, and i will refresh my memory. ms. merchant: is it easier for you to refresh your memory with your own phone, or my print outs? the reason i'm asking is because i'm getting objections that i cut things off, and it is the nature, and i am happy for him to refresh his memory with his own phone. judge mcafee: i don't know if that is him accepting your offer. mr. bradley: you can just

provide the documents. ms. merchant: ok. mr. bradley: may i have some water? judge mcafee: we will see what we can do. ms. merchant: i'm going to pull out all the messages he may need. judge mcafee: at some point we are reaching the chemo the point where we do not need to go through the entire six month text chain. you are making the point that he made some comments that he may have more knowledge than he is testifying he has had, so if you have hit the high points, i do

not know what we can cover that moves the needle. ms. merchant: i will move on. does that refresh your memory? based on your knowledge from mr. wade? mr. bradley: that would have been based on anything my client had told me. i do not have personal knowledge if they went or not. ms. merchant: the trips to texas, was that based on your knowledge from mr. wade? mr. bradley: it would have been something that came from the client. i cannot tell you i have any personal knowledge of any trip other than what would have been said by the client. ms. merchant: obviously, i'm not asking if he went on a trip but if you have knowledge. you also said california, was that something you gain from mr. wade? mr. bradley: it would have been from the client. ms. merchant: and when you told

me [indiscernible] was that something you gain knowledge from mr. wade? mr. bradley: any knowledge that i have of any trip would have come from my client at the time. ms. merchant: you told us last week mr. wade used your credit card one time. do you know when that was? mr. bradley: i do not. judge mcafee: this would be an impeachment of his testimony if he testified he did not use anyone's credit card. >> [indiscernible] ms. merchant: i did not ask did he, i asked when did he? mr. bradley: i do not have any date of one mr. wade used my credit card. i testified that we used a card

for business, and throughout the business we would order paper or supplies or the filing of depositions. the cost factor of cases is what i said, and that still applies today. did he use my credit card? he did, but i cannot tell you who he used that card, what the trip was for, i cannot even tell you where he went. ms. merchant: but he used it for a trip? mr. bradley: yes, for a trip, but i cannot tell you where, when, why, or anything to that nature, correct. ms. merchant: and we take you back -- he paid you back. mr. bradley: i never testified in cash, but he paid me back. i do not recall, sometimes he

would write checks or pay cash, and that still applies today. i do not recall him paying me back cash but i recall him paying me back. ms. merchant: this was when -- before your partnership split up, correct? mr. bradley: it would have been before i left the firm. ms. merchant: we can narrow down the dates to that. mr. bradley: before i left the firm, yes. ms. merchant: mr. wade give you details about meeting ms. willis in hapeville? mr. bradley: that is incorrect. he did not give me details. ms. merchant: he did not tell you meeting with ms. willis at an apartment?

mr. bradley: at this time i don't recall. no, i don't recall. ms. merchant: where did you get that information from then? >> he testified he did not recall. ms. merchant: i asked if he got it from mr. wade, he said he does not recall, so i asked where he got it from. mr. bradley: i do not recall where i got that information from. ms. merchant: you and mr. wade were friends as well as business partners, correct? mr. bradley: we were friends in the sense that i have known him for years. yes, we were friends. ms. merchant: you definitely did not want to come and be a witness in this case, correct? mr. bradley: that is correct. ms. merchant: and we talked

about this earlier, nathan wade called one of your friends, after that you hired for assistance in this matter, correct? mr. bradley: was it after that? i hired mr. chopra and mr. graham. mr. graham is here. when i received a subpoena, mr. graham was at the last hearing but he had to go out of town, but he was present. mr. graham i called and started getting calls from media, and i told him to respond to the

media. i think that was somewhere around whenever you subpoenaed me. i cannot tell you it was that instance of those calls for mr. chopra, but i had engaged mr. chopra and mr. graham at that time. ms. merchant: i will ask the question again because i did not get an answer. after you got the phone call from gabe banks and nathan wade -- mr. bradley: i think it was before that, i think it was before that is what i am stating. ms. merchant: when you got the call from gabe banks, you called me immediately, actually texted, then you called me immediately. mr. bradley: i did not call you immediately but we did speak.

ms. merchant: and you texted me about it as well. mr. bradley: that is correct. ms. merchant: then we spoke after mr. wade called your friend, and we talked about that as well, correct? mr. bradley: that is correct. ms. merchant: you did not mention anything to me about being represented by mr. chopra. mr. bradley: i did not mention anything about mr. chopra, that is correct. judge mcafee: ms. merchant, five more minutes. 3:05 i'm cutting you off. ms. merchant: thank you.

may i approach? [indiscernible] mr. bradley: are these supposed to go together? these are two separate things? all right. ms. merchant: [indiscernible]

do you recall me asking you, do you think it started before she hired him, and you said, absolutely. mr. bradley: i see that in a text message, yes. ms. merchant: do you also recall me asking you how they would react as this was happening, and you said, "no, they will deny it. " >> objection -- judge mcafee: it goes to the motivations of the witness, overruled. ms. merchant: you told me they will deny it. mr. bradley: that is written in there, yes. ms. merchant: you are an officer of the court, and you are under oath, is there any of your testimony from today or the previous days that you want to correct? mr. bradley: that i want to correct? no, i told you everything, i have answered everything that you have asked. ms. merchant: [indiscernible]

judge mcafee: if they need to be tendered, we will make them part of the record. let me turn it over now. >> thank you, your honor, i have a few questions. would like to know whether the court reporter has defense exhibits 26 and 27 -- judge mcafee: we have a different court reporter, we had someone fill in on short notice but i could potentially send those to you if you need them. >> i think i have working copies but i want to make sure the witness has a copy to look at. judge mcafee: all right, we can try to work through that. 26 and 27? >> i believe that is correct. 26 is the same text messages that ms. merchant was just

asking about, it was two pages. i stapled it together, and it is dated january 5 of this year. judge mcafee: all right, i can print off a copy now, but start with the questions that you have. >> that is where i'm going to start, but i will see what i can do to work through it. judge mcafee: mr. sadow, let's start with your question, then we will see if we need to get copies in front of the witness. mr. sadow: all right. mr. bradley. mr. bradley: yes, i am here. mr. sadow: all of a sudden i have lost you on the screen.

there we go, you are on the zoom. you are on youtube but not zoom itself. not that i can see. mr. bradley: i'm here and i can hear you. judge mcafee: his visuals may be different. hold tight, mr. sadow. mr. sadow: he was on when ms. merchant was asking questions. judge mcafee: we need to add a spotlight to the witness stand and mr. sadow, and we do not need the other boxes. mr. sadow: thank you very much. judge mcafee: now we are ready. mr. sadow: thank you, sir. mr. bradley, you have referred to mr. wade as your client, correct? mr. bradley: correct. mr. sadow: you understand that

the court has ruled that communications that you had with mr. wade are not privileged, correct? mr. bradley: no, i'm aware that the court ruled that one specific dealing with the timeframe of one specific conversation was not privileged. mr. sadow: i'm going to ask your honor, if the statute of limitations -- judge mcafee: you asked whether all communication's with mr. wade recovered. that was not the extent of the ruling. the only ones i deemed not covered that i asked about in the in camera hearing that were relevant were any communication's mr. wade made regarding the existence or nonexistence of a romantic

relationship with ms. willis. mr. sadow: thank you, your honor, i understand. going back to live in court, when you say you do not have personal knowledge, what i want to ask you to start with is very simple. did you have communications with mr. wade about the relationship between mr. wade and ms. willis? it is a simple yes or no. mr. bradley: yes. mr. sadow: and is it your testimony that during the time you are representing him, which i understood started in 2018, is that correct? mr. bradley: that is the timeframe that i remember, yes. mr. sadow: is it your testimony under oath that with regards to conversations with mr. wade about his relationship with ms. willis, that she had only one such conversation during the time you represented mr. wade? mr. bradley: one conversation of

what? i apologize. mr. sadow: the only thing i'm asking about is that area the court said is not privileged, the relationship between mr. wade and ms. willis. you have testified that during the time you represented mr. wade from 2018 on that you only had one conversation with him in reference to the relationship and mr. wade, is that correct? out of the entire time talking 2018-2019, 2020, 2021, when did you stop representing mr. wade? mr. bradley: a few months after i left the firm.

i left maybe june, july of 2022. mr. sadow: that would suggest, assuming 2018, 2018, 2020, 2021, and half of 2022 which is in the vicinity of 4.5 years, you are testifying under oath, you had one conversation about a relationship between mr. wade and ms. willis, is that correct? mr. bradley: i don't recall having any other conversation with mr. wade about him and ms. willis. mr. sadow: is it your testimony there was not any other conversation, or you do not remember any conversation? ? >> objection. judge mcafee: overruled. mr. bradley: i don't recall, i

would say it was the one, but i don't recall. mr. sadow: you testified you did have communications with mr. wade about him visiting with ms. willis at a condo or apartment, correct? mr. bradley: i don't think i testified i had a conversation, i testified that any knowledge i would have known anything about any condo would have come from that, but i don't recall any conversation about that. i do not recall the conversation about that. mr. sadow: do you recall any of the thing at this point in time, under oath, that would indicate when the relationship started between mr. wade and ms. willis? mr. bradley: i do not know when the relationship started between mr. wade and ms. willis. i cannot recall. mr. sadow: i'm going to drill down on that, ok?

mr. bradley: yes, sir. mr. sadow: mr. wade was hired as the special prosecutor on november 1, 2021. you are aware of that, correct? mr. bradley: i have my contracts to show when i started. no one showed me the contract of when he started. if he has a contract for november 1, 2020 one, then that is correct. mr. sadow: i'm going to suggest to you that the record will reflect the contract between ms. willis and mr. wade was november 1, 2021. i want you to accept that, ok? is it your testimony that you don't know, under oath, whether or not there was a relationship between mr. wade and ms. willis before the contract? mr. bradley: i do not recall any dates of when the relationship

started. so, whether you are pinpointing a date of when his contract started or not, i am telling you i do not recall any specific date that he flat out said anything about a relationship with ms. willis. mr. sadow: based on what you just said, let us go to defense exhibit 26. in defense exhibit 26, which i showed you last time, was two pages of text messages between you and ms. merchant, correct? now, the first page starts off by saying, ms. merchant, just date, do not hire him. you think it started before she hired him? do you see that?

mr. bradley: i see it, yes. mr. sadow: and your response to that was "absolutely," correct? >> object. judge mcafee: mr. sadow, we went through a lot of these texts mr. sadow:. we did not go through this whole pme/ one. judge mcafee: you said we did not go through this particular one? mr. sadow: we stopped right t here. mr. bradley: i answered what she just stated a few minutes ago. judge mcafee: you are saying both of these exhibits were not covered by ms. merchant? mr. sadow: this particular language was not gone into. i'm doing it based on the exhibit itself. let's do it this way, i now move

into evidence defense exhibit number 26. judge mcafee: i have to search through my notes -- mr. sadow: it was only presented to your honor to take back into chamber ex parte to speak to mr. bradley and his counsel. judge mcafee: ms. merchant is indicating it was admitted. ms. merchant: i'm organizing, [indiscernible] judge mcafee: defense exhibit 26 and 27 are being tendered. mr. sadow: 26 at this time. judge mcafee: any objection from the state? >> 26. >> objection, authentication, it was used in the last hearing,

and it is my recollection that it did not refresh his recollection. judge mcafee: as to foundation authentication esther bradley has recognized this text is his, based on admissibility from other counsel and defense exhibit 26 is now admitted. mr. sadow: thank you. after you said the word, "absolutely," on your own you said "it started when she left the das office." >> objection, asked and answered. judge mcafee: we will have a few minutes on this, then go from there. mr. bradley: i did answer this, i answered it for ms. merchant. i stated that i was speculating.

this was the exact same language. judge mcafee: i will give him a little leeway to do that. mr. sadow. mr. sadow: i hesitate to start back where i was but after the word "absolutely," you on your own said it started when she left the das office, and they met at the municipal court cle conference. that is what you said, correct? mr. bradley: that is correct. mr. sadow: it is your testimony so far that when you come on your own, gave those two statements in the text that you were merely speculating, and did not have that knowledge from mr. wade. is that your testimony under oath? mr. bradley: yes, that is what i testified to.

mr. sadow: you on your own came up with the whole notion that it started when she left the das office and was judge in south fulton, that is according to you, that is speculation on your part, correct? judge mcafee: answer the question, mr. bradley. mr. bradley: yes, speculation on my part. mr. sadow: it had nothing to do with what mr. wade told you? mr. bradley: i answered your question, i was speculating to the answer, that is correct. mr. sadow: maybe you can tell the court in your own words why in the heck would you speculate in this text message and say it started when she left the das office and was a judge in south fulton? why would you speculate and say that in a text? mr. bradley: i knew they had met

at the municipal court conference. mr. sadow: how did you know that? mr. bradley: i answered that -- mr. sadow: i'm asking you now. i'm asking you questions and you are in a situation where you give answers. i'm asking you how did you know that? mr. bradley: how did i know when they met? mr. sadow: somebody told you that, right? mr. bradley: yes, correct. mr. sadow: who told you? mr. bradley: mr. wade told me when they met. mr. sadow: so you had more than one conversation because he told you where he met her? mr. bradley: incorrect. mr. sadow: incorrect? mr. bradley: incorrect. mr. sadow: let's go back to the exhibits. why would you speculate that that is when they started the

relationship? what would cause you to put that down as speculation? mr. bradley: i don't recall why i thought it started at that time, but i do recall he only met her, and i testified to that, that he met her at that conference which was in 2019. mr. sadow: you knew that ashley merchant represented a defendant in this case when you were text messaging with her, correct? mr. bradley: yes, i did. mr. sadow: and you knew the reason she was asking you questions about mr. wade was because she was trying to show when the relationship began, correct? mr. bradley: no, that is not correct. mr. sadow: that is not the beginning of the text message.

mr. bradley: what messages were before this before she said that? mr. sadow: i can't answer that question because i do not have them. i only have what is in front of you. she says, do you think it started before she hired me? you knew as counsel for defendant in this case that ms. merchant was asking you specifically about the knowledge that you had regarding the timing of the relationship between wade and ms. willis, correct? mr. bradley: based on this, yes. mr. sadow: and in response to that, you answered directly on your own what you now claim to be speculation? mr. bradley: that is correct. mr. sadow: i ask you one more time, why would you speculate

when she was asking you a direct question about when the relationship started? mr. bradley: i have no answer for that. mr. sadow: except for the fact that you do in fact know when it started and you do not want to testify to that in court, that is the best explanation. >> objection. judge mcafee: overruled. mr. sadow: that is the true explanation because you do not want to admit it in court? mr. bradley: no, i have no direct knowledge of when the relationship started. mr. sadow: i'm not going to go back through that again, but if you did not know and you are asked specifically as this exhibit shows, can you explain why you would not say, "i don't know"? mr. bradley: is that a question? mr. sadow: yes, a definite

question. mr. bradley: state that again, i apologize. mr. sadow: if you are being asked, as we have gone through with this text message from ms. merchant as the attorney for a codefendant, and she is asking you about the relationship, and clearly asking about the timing, why wouldn't you just have said in response, "i don't know when it started"? mr. bradley: i don't know why i did not say "i don't know." mr. sadow: maybe because you know what the truth is, and that is why you answered the way you did in defense exhibit 26, correct? mr. bradley: no, i cannot sit here and tell you what you just stated was correct. mr. sadow: what you want the court to believe in what you want the rest of us to believe is for some unknown reason upon being asked a direct question about when the relationship

started, you decided on your own to simply speculate and put it in a text message as opposed to putting down what you actually knew. that is what you want the court to believe, correct? mr. bradley: that was a lot, can you break that down? i apologize. you are asking me if i want the court -- mr. sadow: to believe that instead of saying nothing, you decided on your own to speculate? mr. bradley: yes, i speculated. i state that i speculated, yes sir. mr. sadow: that is what you want the court to believe, correct? mr. bradley: correct. mr. sadow: when you go to the next page of that, ok, you see it starts in south fulton. is that what you have in front

of you? second page. mr. bradley: the second page that i have says that is what i figured. mr. sadow: that may be cut off from the ones i have. i'm looking, my opening line says south fulton, is that on your second page? mr. bradley: no, if you are going in order of the pages, no, neither page starts with south fulton. mr. sadow: don't get caught up in whether it starts that way. does the second page have a line that says "in south fulton"? mr. bradley: yes, i apologize. mr. sadow: that is fine, just want to make sure we are on the same page. you say after in south fulton

they met at the municipal court cle conference, right? mr. bradley: yes, that is correct. mr. sadow: then ms. merchant says, that is what i figured when he was married. is this accurate? willis and wade met while both were serving as magistrate judges and begin a romantic relationship at that time, you see that is what she said? mr. bradley: no, it says they met at municipal court cle. the only other thing here says, that is what i figured when he was married. there is no response from me on that day, then there is another response -- a question that says, is this accurate? mr. sadow: that is what i want to avoid. mr. bradley: i don't have anything in that if it is

accurate at all. it just says, "is this accurate? " i don't have anything following that. mr. sadow: you do not have willis and wade met while both were serving as magistrate judges -- mr. bradley: i apologize, it goes to the next page. mr. sadow: no problem. mr. bradley: i see that now, yes. mr. sadow: what i just read is exactly what ms. merchant said to you in the text, right? mr. bradley: yes that was in the text. mr. sadow: again, since you told us you were speculating when you gave the answer previously, on this one you don't say, "i don't know," you simply correct her by saying,

>> yes, she asked if it was accurate and i said no, it was not accurate, it was municipal court. >> you did not say that is not accurate, they did not start a romantic relationship at? that time, correct? >> no, i was referring to the municipal court, it wasn't accurate as it was applied. i was answering no, municipal court, not magistrate court. >> ok. but you did not say that the rest of what she asked you was accurate. you did not say it is not accurate, it is not true, it is not accurate. you simply said the only thing that wasn't accurate was "municipal court" should be there instead of "magistrate," right? >> so i was answering the

question. it was a compound question. i was answering the question of she wrote "magistrate court" and i said no, municipal court. >> i think you have adequately made your point. i don't think we need to belabor it much longer. let's move on to the next issue. >> ok. mr. bradley, prior to coming into court today did you and , your lawyer meet with anyone from the district attorney's office? mr. bradley: i did not meet with anyone. >> did you have any conversation? mr. bradley: i did not.

>> so you have not spoken if i understand you correctly prior to coming into court today, you have not spoken with the prosecutor's, right? mr. bradley: no. i have not spoken to the prosecutors. i've not spoken to defense. >> have you spoken to mr. wade? mr. bradley: no. >> so as far as just getting into the courtroom today, there's been no contact or conversation in it with any of the parties we just went over . right? mr. bradley: there has not been any contact with defense or the state at all. >> i think i basically just have one or two more questions. why would you see the need to speculate when you were texting with ms. merchant? judge mcafee: we did cover that one.

i think the exact question was already put to him. what would be the next one? mr. sadow: i'm trying to look. let's go to 27. defense exhibit 27. do you have that now, sir? >> i do. mr. sadow: would you look at it and tell me whether or not the defense exhibit 27 appears to be accurate? because i want to seek to introduce it into evidence. it consists of an email to you from ms. merchant and the text response from you. correct? mr. bradley: but the text response was not in response. so yes, it does consist of the email and a text response. i'm not saying that the text response applies to the entire

email that was sent. mr. sadow: all i've asked you right now, is the email and text are those accurate in the , interaction that makes up defense exhibit 27? mr. bradley: as it applies to the stapling of the email and the stapling of a text message chain, yes, that is defendant's exhibit 27. it is accurate. mr. sadow: ok. i would move the defense exhibit 27 and i believe it was treated the same way as 26 last time. judge mcafee: all right, overruled any other rejections from defense counsel. seeing none defense exhibit 27 , is admitted i don't know. mr. sadow: i don't know whether

you find my objection or not, but i will ask it. mr. bradley you realize that if , you were to testify under oath that you knew from mr. wade, that the relationship between him and ms. willis existed before the contract in november 1 of 2021 that if you testified that you knew that from mr. wade, that would show that both ms. willis and mr. wade had lied under oath. you know that, don't you? >> i think that's going to call for an opinion on the credibility of another testifying witness. so i don't think that would be an appropriate question. >> that is all i have. judge mcafee: thank you. >> do i understand from your prior testimony that ms. merchant sent you a motion to review prior to her filing answers? >> objection. judge mcafee: i'm going to give

him just a little bit. >> did ms. merchant send you a motion prior to january 8th of 2024 for you to review? mr. bradley: that is correct. >> did you infect review that motion? mr. bradley: that is correct. >> and did you indicate to ms. merchant that the contents of the motion seemed ok to you? mr. bradley: you're referring to exhibit 27, which as i stated a few minutes ago, one is an email, the other a text chain. i never responded to the email that it looks good or anything to the mail that was sent to me. however, in the text chain, what you are trying to merge together is the fact that i was asked about the contract and that contract was $74,000 and me

being added back to that. so when i said, and i think before in that text, it referred to me being added back and at that time i said, yes, looks good. >> and you're aware and you recall that when ms. merchant presented you with that motion, she asked you not to disclose it to anyone until she filed it. is that correct? mr. bradley: -- >> we are covering, i think the last five or six questions we've covered ground. let's get to that point. >> i'm trying to get that. i promise you. mr. bradley: repeat the question. >> she asked you not to disclose that motion to anybody until she filed it. correct? mr. bradley: i think so.

that was in the text message, yes. >> and you knew, in fact it was her intention to file that motion, correct? mr. bradley: the actual motion that she sent? >> yes. mr. bradley: i knew she was going to file a motion, yes. i do not think that was the final draft or it could have been that she was working on it, but yes i knew that she was , going to file some motion. yes. >> and you knew that she presented that motion to you for your review so that she could make sure it was accurate. correct? >> i'm gonna eject. judge mcafee: noted. i think mr. stockton is getting to the next point. what we just ask that one? >> is that correct? judge mcafee: can we combine that with the next question so that we are not having to lay but by bit -- bit by bit? >> you knew ms. merchant was

relying on your review to ensure the accuracy of that motion prior to filing it, correct? >> speculation as to what he knew that ms. merchant knew. judge mcafee: i overrule that. mr. bradley. mr. bradley: no. so once again, i was excluded from the footnote of that notion and my review of it in the chain was could you add me back to the footnote because i did have a contract and i did receive 74,000.

mr. stockton: and if i may help you out, let's talk just about that part of the motion that deals with the relationship between the district attorney willis and mr. wade. when you reviewed that, you knew that she was that. mr. bradley: no, i did not know that she was relying on me to for any accuracy other than what was put in there, the 74,000.

mr. stockton: mr. bradley if , there was something patently false in that motion, you would have told ms. merchant, would not you? mr. bradley: i can't say i would have or wouldn't have, i don't know what i would have told ms. merchant. mr. stockton: if there was something pat patently speculative, you would have told ms. merchant, would not you? mr. bradley: i don't know what i would have told ms. merchant. if she asked me if it was accurate. we were discussing the 74,000 that was left out. mr. stockton: if i may direct you just to that portion, dealing with her, the relationship between ms. willis and mr. wade. judge mcafee: nest question, mr. stockton. mr. stockton: you did not see anything that was speculative in their? i just want to ask you one more question.

i'm coming at it from the other way mr. saito did. did anybody from the district attorney's office or any witnesses in this case contact you about ms. merchant's motion from january 8 20 -- 2004 until today? mr. bradley: did anyone contact me about her motion? mr. stockton: yes, from the district attorney's office or any witnesses or anybody else involved with the case besides the defense. mr. bradley: other than the call, the only personal call i had was with gay banks. i've never spoke to anyone else and to my knowledge, he's not a part of it, so that's all. -- mr. stockton: that is all, judge. judge mcafee: thank you, mr. stockton. mr. durham, if you are still

with us. no, thank you sir, mr. mcdougall. >> good afternoon, mr. bradley. you have certain information about the relationship between mr. wade and ms. willis that is not privileged, correct? >> that was my determination. i think he disagrees with that. i will say the witness's opinion is a little irrelevant on that point. >> do you understand that the court has ruled that certain information that you have about the relationship between ms. willis and mr. wade is not privileged? mr. bradley: i have the courts ruling, as i understood it and as my lawyers and i understood it, of the privilege not existing was based off of a conversation that was had in my office, in the back of my office, which was confidential,

between mr. wade and i. that is what was asked of me on yesterday and that's what the ruling to my knowledge, unless i am being corrected here now and saying that it is more, it was that particular piece that the judge said did not have privilege. >> and have you testified already today to the sum total of your knowledge of the relationship that is outside the scope of the privilege according to the court's ruling? mr. bradley: can you ask that again? i'm sorry, i did not understand it. >> referring to what you understand to be the information that is not privileged, have you testified to the sum total of that information? mr. bradley: i think i have. i think i've testified to that. yes. >> all right, sir. that's my questions. judge mcafee: thank you, mr.

mcdougall. mr. rice. mr. rice: mr. bradley, at least as of february 15 when you first testified, you said you still consider yourself [inaudible] mr. bradley: yes, i think i did. mr. rice: and you have been friends with mr. wade for over 10 years, correct? mr. bradley: that would be fairly accurate, yes. >> and you recall communicating with ms. merchant about this case and about mr. wade and ms. willis relationship, correct? >> objection. judge mcafee: we can put the foundation when we combine it with the next question where you've got a new point to make . mr. rice: mr. bradley when you

, communicated with ms. merchant did you tell her any lies about , mr. wade and ms. willis's relationship? mr. bradley: did i lie? mr. rice: it's a simple question, mr. bradley. you are a lawyer. did you like to ms. merchant when you told her facts about mr. wade and ms. willis's relationship? mr. bradley: not that i recall. i do not recall, i mentioned earlier that i speculated on some things. i have testified to what i did know. so i cannot recall whether or not i, no. mr. rice: mr. bradley,

speculation is kind of a weasel lawyer word. let's speak truth here, under oath. when you were communicating different details of the relationship between ms. willis to ms. merchant, did you lie to her about any of those details? mr. bradley: i do not recall ever come up whether any of it was a lie or not. mr. rice: at the time you were communicating with ms. merchant, you were still friends with mr. wade, correct? mr. bradley: yes. mr. rice: at the time you were communicating with ms. merchant, you knew she was talking to you in her role and capacity as an attorney in this case, correct? mr. bradley: correct.

mr. rice: and you knew she was going to use that information to somehow benefit and file a motion to benefit our client, correct? mr. bradley: i did not know that . i did not. i'm sorry. mr. rice so as as an attorney : yourself, you are testifying here under oath that you had no idea what ms. merchant was going to do with all the details that you were giving her about wade and willis's relationship? mr. bradley: at the time, no i did not. i knew ms. merchant was gathering information, that is correct. mr. rice: ok. and did you lie to her when you told her that the relationship began before 2020? judge mcafee: the specifics have been covered as -- at a high level. i do not think we are going to get much out of this. mr. rice: mr. bradley, the only thing that has really changed, when you were speaking to ms. merchant by text or telephone, you never said to her that i do not remember or that i am speculating, correct?

mr. bradley: i do not recall. mr. rice: you have looked through a whole lot of text messages. do you remember ever seeing any communication from you that said, "i don't remember." mr. bradley: through the messages, i do not have all the messages in front of me, but i do not recall if i ever said i don't remember. mr. rice: do you recall seeing any text messages where you replied to her any details where you said, i am speculating about this detail? mr. bradley: i never used the word speculating, no. mr. rice: and the only thing that has changed between then and now is that phone call from nathan wade's friend greg banks, -- gabe banks, correct?

mr. bradley: gabe was my friend. i actually stated that the first day i was here, was that i have known gabe for a few years and that we are fraternity brothers. so i never said that anything changed behind gabe then -- gabe banks. mr. rice: so you never told ms. merchant that you were worried that they were threatening you? >> objection. asked and answered february 16 and today. mr. rice: just to be clear, you did not attend college with mr. banks, did you? mr. bradley: i did not attend college with him. mr. rice: you just both happen to have pledged the same fraternity, different colleges,

different chapters. mr. bradley: that is what we consider a fraternity brother, yes. mr. rice: and as a normal course of real relationships with your friends, do you pass on lies about your friends? mr. bradley: have i passed on a lie about a friend, is that what you are asking? mr. rice: is it something you normally? do, mr. bradley? tell lies about your friends? mr. bradley: have you told lies about -- have i told lies about my friends? i could have, i don't know. mr. rice: i notice you are not looking at me. mr. bradley: i am looking at you on the screen only because i was accused of, i did the same thing with two mr. seto. judge mcafee: next question, mr.

rice. mr. rice: no further questions but i think it is clear. >> good afternoon, mr. bradley. a lot of folks have taken up questions that i wanted to ask but i have a few left ear. we will see. mr. bradley, you said that you did not know what ms. merchant was going to be doing with the motion she sent you. do you remember that testimony a few minutes ago? mr. bradley: i think i said i knew she was gathering information, yes. >> let's look at the title of the motion she sent you. do you remember reading defendant michael roman's motion to dismiss grand jury indictment is fatally defective and motion to disqualify the district attorney, her office, and the special prosecutor from further prosecuting this matter? do you remember seeing that in the draft that you read and reviewed? mr. bradley: yes. >> so when you tell this court

that you didn't know what she was going to do, she kind of gave you a hint, didn't she in the title of the motion that she sent for you to read, didn't she? yes or no? mr. bradley: i read the title of what the motion was. >> there wasn't anything in the title that threw you off pretty straightforward as speaking title, is not it? mr. bradley: correct. >> so you knew that what she wanted was information from you so that she could then file a motion to dismiss the grand jury indictment to motion to disqualify the district attorney and her office and the special prosecutor from further prosecuting the matter, right? >> objection. speculation. judge mcafee: overruled. >> you knew that, did not you? yes or no? mr. bradley: when she sent that motion, yes. >> ok. and you knew that the special prosecutor that to, to whom she was referring in that motion was mr. wade, correct?

mr. bradley: yes. >> because you read the motion, you said you reviewed it, correct? mr. bradley: yes. >> and we're not going to go over all of the, you know, number one because we don't have time and number two that the court wouldn't let me. but there are a few things i want to ask you about in that aspect. in that motion you said you reviewed on page six of that motion, on page five, it starts off with "how do we know this?" judge mcafee: mr. galen, i appreciate what you were doing and i think that is something you can do in an argument. he said as a whole that he got the motion and he's had his responses on his opinion of how he handled it. i do not see again this really being necessary to go through line by line. >> a little indulgence, your honor. this is not going to be a 40

minute death march for the motion. i would like to ask about a few bullet points they capture on this and then i will move on but i will ask the court's indulgence in that respect. judge mcafee: i think we have covered it and i think you will be able to argue that this was in this motion and he had a chance to read it and he never objected to anything in their. >> we did earlier with mr. wade and then -- judge mcafee: i hear you. we have mr. control on zoom. >> yes, your honor. i just have a few questions. judge mcafee: ok, can we add a spotlight to mr. couture? we have been going two hours. let us come back at 4:00.

i will also note for the record that we received notification from mr. cromwell on behalf of ms. latham and he said he was waving her presence. i do not know if he later decided to join us by zoom, but i do not think he was electing to login. so after mr. couture, just in terms of timing, do you have any expectation of how long, if any questioning would last? >> i do not imagine my question would be very long. judge mcafee: ok. let's get back to it at 4:00. you can just step out of the room.