NEW ORLEANS — The high-profile case against Cardell Hayes in the killing of former Saints star Will Smith has already sparked fierce legal skirmishes between prosecutors and defense attorney John Fuller. Now the tension has been ratcheted even higher as Fuller tries to get the DA’s office removed from the case, arguing that the office can’t be fair to him or his client.

At the heart of that recusal motion is a document painstakingly compiled by the office of District Attorney Leon Cannizzaro. It lays out a case of serious misconduct against Fuller, including accusations of witness tampering, misrepresentation and exposing confidential informants.

WWL-TV obtained an exclusive copy of the 206-page dossier, which outlines potentially criminal allegations against Fuller.

The file contains transcripts, investigative reports, jailhouse visitation logs and even security camera video images used to outline five separate allegations of improper meetings between inmates and Fuller and his associates.

Addressed to “Members of Law Enforcement,” the memorandum begins:

“The Office of the Orleans Parish District Attorney has become aware of several instances in which John Fuller has contacted criminal defendants that were co-defendants of his own clients without consulting with counsel for those co-defendants. Further, our office has also become aware of instances in which Mr. Fuller or his associates may have broken confidences with his clients, identifying them as working with law enforcement officers and, thereby, endangering their safety.”

WWL-TV legal analyst Chick Foret said he doesn’t think a recusal will be granted based on the document, but it could be used as the basis or a bar complaint – or even a criminal complaint – against Fuller.

“This has specifics that are talked about in here as to the allegations of potentially tampering with witnesses,” Foret said. “They contend that John Fuller has operated allegedly improperly. That he’s gone into the jail, that he’s met with witnesses that he should not have met with.”

None of the meetings were connected to the Cardell Hayes case.

Two of the five incidents involved improper talks with confidential informants. Two others involved contacts with witnesses in murder cases who were not Fuller’s clients, including one witness held in jail in Jefferson Parish.

And one of the cases was a high-profile murder prosecution in which Fuller and his team won a not guilty verdict at trial.

Foret said some of the allegations are laid out like criminal charges.

“These are very serious allegations that are laid out in great detail. And many specifics are given about cases, times, places, meetings, prospective witnesses, the nature of their testimony. It’s almost like a draft indictment,” Foret said.

The volume on Fuller has been distributed to state and federal law enforcement. As soon as Fuller found out about it, he filed his motion to recuse, calling the allegations “baseless and inflammatory.”

He also wrote that the dossier demonstrates Cannizzaro’s “personal animosity” toward him.

Fuller was not available for an interview, but said he feels he did nothing improper and that the document came out as a result of sour grapes by Cannizzaro after losing the murder trial. Gregory Carter, another attorney involved in the trial, posted a response to the DA’s allegations on his Facebook page:

“This is a political attack meant to demean and degrade my efforts to combat police misconduct and the systematic targeting of the young men and women of our community,” Carter wrote.

The recipients of the document would not talk about what they may do with it. But its contents will be front and center at the recusal hearing in the Cardell Hayes case scheduled for Friday morning in front of Judge Camille Buras.

Fuller has also filed for the DA’s recusal in several other cases. A denial by Judge Byron Williams has already gone up to the state Supreme Court, which upheld the denial. But another judge, Ben Willard, granted to the recusal.