Mark Geragos filed his response to the D.A.'s scathing motion ... and claims prosecutors omitted some key facts.
In his docs, Geragos refutes the D.A.'s claim that "no human being ever witnessed" Chris performing community labor -- claiming Richmond's deputy police chief "observed Brown working very hard at cleaning the brush at the [police] stables."
Geragos' filing also includes invoices and checks indicating Chris paid $31,534.70 to the Richmond PD for providing security during his labor details -- which the D.A. claimed Chris didn't pay ... according to Geragos.
According to the documents ... Richmond PD's general counsel also sent the D.A. documents showing Chris did some of his required community service -- back in 2009 and 2010 -- at various police precincts.
Nowhere in the filing does Geragos refer to the Tappahannock Children's Center ... where Chris says he frequently performed odd jobs. The D.A. has questioned the bookkeeping of Chris' hours there because Chris' mom filled out his paperwork, and was once the director of the center.
Geragos adds in the filing ... he's just begun investigating the D.A.'s allegations, and says "what we've uncovered so far should shock the conscience of the court. And this is only the tip of the iceberg."