Does Georgia's reckless conduct statute provide adequate notice of prohibited conduct and raise constitutional concerns under due process and Brady v. Maryland?

1. Does Georgia ’s reckless conduct statute, O.C.G.A. 16-5-60(b), provide adequate notice of prohibited conduct and sufficient guidance to prevent arbitrary enforcement? 2. Is Georgia ’s reckless conduct statute, O.C.G.A. 16-5-60(b), consistent with constitutional protections as applied to the facts of this case? 3. Should considerations of a judicial emergency and public health concerns during the COVID19 pandemic inform the application of legal standards in this case? 4. Does the nondisclosure of evidence related to a mandatory Department of Family and Children Services (DFCS) report raise issues under the due process requirements of Brady v. Maryland, 373 U.S. 83 (1963)? 5. Is the petitioner ’s claim of ineffective assistance of counsel barred from consideration for not raising the issue at the earliest opportunity, even though his attorney failed to withdraw from the case despite alleged conflicts of interest? I.