24-K-478 Nonprecedential Denied in part, Granted in Part Processed

State of Louisiana Versus Carolina Morales

Louisiana Court of Appeal, Fifth Circuit · Filed November 8, 2024

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Opinion text

STATE OF LOUISIANA NO. 24-K-478

VERSUS FIFTH CIRCUIT

CAROLINA MORALES COURT OF APPEAL

STATE OF LOUISIANA

November 08, 2024

Linda Wiseman
First Deputy Clerk

IN RE CAROLINA MORALES

APPLYING FOR SUPERVISORY WRIT FROM THE TWENTY-FOURTH JUDICIAL DISTRICT COURT,
PARISH OF JEFFERSON, STATE OF LOUISIANA, DIRECTED TO THE HONORABLE NANCY A. MILLER,
DIVISION "I", NUMBER 23-0196

Panel composed of Judges Susan M. Chehardy,
Marc E. Johnson, and John J. Molaison, Jr.

WRIT DENIED, IN PART; GRANTED, IN PART; JUDGMENT
VACATED, IN PART

In this writ application, defendant, Carolina Andrea Morales, seeks this

Court’s supervisory review of the district court’s August 19, 2024 judgment

granting the State of Louisiana’s notice of intent to introduce other crimes

evidence under La. C.E. art. 404(B) pertaining to evidence of a prior July 2022

altercation involving Morales, and photographic evidence of various firearms. For

the following reasons, Morales’ writ application is denied, in part, and granted, in

part, with instructions. The portion of the district court’s August 19, 2024

judgment granting the State’s 404(B) notice of intent pertaining to evidence of a

prior July 2022 altercation involving Morales is denied. The portion of the district

court’s August 19, 2024 judgment granting the State’s 404(B) notice of intent

relating to the admission of photographs is hereby vacated.

24-K-478

FACTUAL BACKGROUND AND PROCEDURAL HISTORY

On May 4, 2023, a Jefferson Parish Grand Jury returned an indictment

charging defendant, Carolina Andrea Morales,1 with the second-degree murder of

Carlos Galvez, a violation of La. R.S. 14:30.1 (count one), attempted second-

degree murder of A.G., a seventeen-year-old,2 a violation of La. R.S. 14:27:30.1

(count two), and obstruction of justice in a murder investigation by tampering with

evidence used in a murder and attempted murder, a violation of La. R.S. 14:130.1

(count three). Morales pled not guilty.

On January 8, 2023, Jefferson Parish Sheriff’s Office (“JPSO”) deputies

responded to a shooting at the La Rumba Bar & Grill (“La Rumba”), in Harvey,

Louisiana. Upon arriving, the officers found two victims—one deceased from a

fatal gunshot wound, and another with a gunshot wound to the neck. Law

enforcement’s investigation, including eyewitness accounts, revealed that a

Hispanic male and a Hispanic female entered into a heated verbal argument that

escalated, which led to the shooters arming themselves, and subsequently shooting

the victims. Morales and Ramos, who both fled the scene, were identified by

multiple witnesses as the perpetrators. There were no other weapons recovered at

the scene. Forensic analysis confirmed that two separate 9mm firearms were used

to shoot the victims. Morales and Ramos were later arrested on warrants for

second-degree murder, attempted second-degree murder, and obstruction of justice.

According to the State, both defendants downplayed their actions, claiming self-

defense or manslaughter.

Subsequent to the indictment, the State filed a notice of intent to introduce

other crimes evidence pursuant to La. C.E. art. 404(B). Specifically, the State

1
On the same indictment, the State charged Maynor Ramos with the same three offenses. On May
22, 2024 the district court granted a motion for severance filed by the State.
2
In this writ application, the initials of the minor child are used to protect and maintain the privacy
of the minor child involved in this proceeding. See Uniform Rules–Courts of Appeal, Rule 5–1 and Rule
5–2.
2

noticed its intent to introduce evidence of a prior altercation occurring at a

nightclub in July 2022, involving both Morales and Ramos, which escalated to the

point where one of them allegedly fired a gun. Additionally, during their

investigation, officers discovered numerous images and videos of firearms on

defendants’ cell phones, including photographs of defendants holding weapons,

including a 9mm firearm, which is the type of weapon fired at the scene based on

the ballistic evidence. In their notice of intent, the State advised that it intended to

introduce at trial the images and videos extracted from defendants’ cell phones.

According to the State, the evidence is admissible as it fits squarely within La. C.E.

art. 404(B) in that these alleged prior bad acts tend to prove intent, modus

operandi, opportunity, and identity, in addition to rebutting any claim of self-

defense or defense of others.

In response, Morales filed a motion to exclude the other crimes evidence on

the basis that the acts at issue were rendered irrelevant by the severance of the two

cases, and that any probative value is substantially outweighed by the risks of

confusing the issues, misleading the jury, undue delay, and causing significant

unfair prejudice to Morales. Ramos also filed an opposition to the State’s notice.

A hearing on the State’s 404(B) motion was held on July 18, 2024, and the

district court took the matter under advisement.3 On August 19, 2024, the district

court issued judgment, granting the State’s 404(B) notice as to both Morales and

Ramos regarding the July 2022 incident that occurred at a nightclub involving both

defendants, and granted the State’s notice as to Morales, relative to the images of

weapons that were extracted from both defendants’ cell phones, but denied the

State’s notice as to Ramos, since none of the photographs depicted a male’s face.

In particular, the district court determined that ample evidence existed between the

3
The State filed a single notice of intent addressing both Morales and Ramos, and a joint hearing
took place on July 12, 2024, resulting in one judgment.

3

two incidents as Morales and Ramos are alleged to have escalated a verbal

altercation at a local bar into a physical altercation, and a shooting. The court ruled

that the prior incident constituted evidence of intent, knowledge, identity, and/or

absence of mistake or accident. The court further ruled the value of the evidence is

not outweighed by the danger of unfair prejudice. As to the photographs, the court

determined that as to Morales, the photographs are admissible under La. C.E. art.

404(B) to establish Morales had access to, and was familiar with, the types of

firearms used in the charged offense.

This writ application followed.4

DISCUSSION

Applicable Law

A trial court’s ruling as to the admissibility of other crimes evidence is

reviewed for an abuse of discretion. State v. Kiger, 13-69 (La. App. 5 Cir.

10/30/13), 128 So.3d 552, 557. Generally, evidence of other crimes or bad acts

committed by a criminal defendant is not admissible at trial. State v. Neveaux, 23-

477 (La. App. 5 Cir. 11/10/23), 377 So.3d 749, 757, writ denied, 23-1633 (La.

3/12/24), 381 So.3d 56. Courts may not admit evidence of other crimes, wrongs,

or acts of a criminal defendant in order to show that the defendant is a person of

bad character who has acted in conformity therewith. La. C.E. art. 404(B); State v.

Hardy, 14-1569 (La. 11/21/14), 154 So.3d 537, 538. However when evidence of

4
It is noted that the ruling in this case was on August 19, 2024. Defense counsel filed a notice of
intent to seek supervisory review on September 17, 2024, requesting thirty days from that date, or until
October 17, 2024, to file a writ application. The district court granted counsel’s notice of intent and set a
return date to be filed “within the delays allowed by law.” Instead, the district court should have specified
a date for the return as required by Uniform Rules–Courts of Appeal, Rule 4–3, which provides that the
return date should not exceed thirty days from the date of the ruling, and “[i]n all cases the judge shall set
a specific return date.” Here, the thirty dates from the August 19, 2024 ruling elapsed on September 18,
2024. Defense counsel filed a motion for extension on September 27, 2024, which was granted giving
counsel until October 14, 2024, to file the writ, which was ultimately filed on that date. The district court
does not have the authority to grant an untimely motion for an extension of the return date that has been
filed outside the original or extended return date period. See State v. Fisher, 18-K-98 (La. App. 5 Cir.
3/19/18) (unpublished writ disposition), writ denied, 18-608 (La. 6/15/18), 257 So.3d 676. See also State
v. Goppelt, 08-576 (La. 10/21/08), 993 So.2d 1188, where the Supreme Court held that refusing to
consider an application under Rule 4–3 should apply to cases sparingly, especially when the State does
not object. Here, the State urged no objection to defense counsel’s delayed filing.
4

other crimes tends to prove a material issue and has independent relevance other

than to show that the defendant is of bad character, it may be admitted by certain

statutory and jurisprudential exceptions to this rule. State v. Jenkins, 18-645 (La.

App. 5 Cir. 4/3/19), 267 So.3d 203, 207, writ denied, 19-1223 (La. 10/21/19), 280

So.3d 1169. The State may introduce evidence of other crimes, wrongs, or acts if

it establishes an independent and relevant reason for its admissibility, such as to

show motive, opportunity, intent, preparation, plan, knowledge, identity, or

absence of mistake or accident. La. C.E. art. 404(B); Hardy, supra. The evidence

must tend to prove a material fact at issue or to rebut a defendant’s defense. State

v. Martin, 377 So.2d 259, 263 (La. 1979). Courts have allowed the admission of

other crimes evidence to rebut a defendant’s self-defense claim. State v. Gasser,

18-531 (La. App. 5 Cir. 7/3/19), 275 So.3d 976, 993.

If the element of intent is at issue, evidence of similar unrelated conduct is

admissible to negate a defense theory that the accused acted without criminal intent

and to show that he intended to commit the charged offense. State v. Kennedy, 17-

724 (La. 9/29/17), 227 So.3d 243, 244. The supreme court has recognized the

principle that where the element of intent is regarded as an essential ingredient of

the crime charged, it is proper to admit proof of similar but disconnected crimes to

show the intent with which the act charged was committed. State v. Jackson, 625

So.2d 146, 150 (La. 1993). For evidence of a prior criminal act to be admitted as

proof of intent, however, three prerequisites must be satisfied: (1) the prior act

must be similar, (2) there must be a real and genuine contested issue of intent, and

(3) the probative value of the evidence must outweigh its prejudicial effect.

Kennedy, supra.

The fact that the other acts or crimes happened some time before the offense

for which defendant is on trial is not sufficient, in and of itself, to require the

exclusion of the evidence. State v. Guidroz, 98-377 (La. App. 5 Cir. 10/14/98),

5

721 So.2d 480, 486, writ denied, 98-2874 (La. 2/26/99), 738 So.2d 1061.

Remoteness in time, in most cases, is only one factor to be considered when

determining whether the probative value of the evidence outweighs its prejudicial

effect. Generally, a lapse in time will go to the weight of the evidence rather than

to its admissibility. Id.

Finally, the probative value of the extraneous evidence must outweigh its

prejudicial effect. State v. Page, 08-531 (La. App. 5 Cir. 11/10/09), 28 So.3d 442,

451, writ denied, 09-2684 (La. 6/4/10), 38 So.3d 299. Although relevant, evidence

may be excluded if its probative value is substantially outweighed by the danger of

unfair prejudice, confusion of the issues, or misleading the jury, or by

considerations of undue delay, or waste of time. La. C.E. art. 403. Clearly,

evidence of other crimes or bad acts is prejudicial since all evidence which tends to

make it more probable than not that an individual committed a criminal offense is

necessarily prejudicial. State v. Williams, 02-645 (La. App. 5 Cir. 11/26/02), 833

So.2d 497, 507, writ denied, 02-3182 (La. 4/25/03), 842 So.2d 398. However, the

underlying policy is not to prevent prejudice, since evidence of other crimes is

always prejudicial, but to protect against unfair prejudice when the evidence is

only marginally relevant to the determination of guilt of the charged crime. Id. As

used in the balancing test, “prejudicial” limits the introduction of probative

evidence of prior misconduct only when it is unduly and unfairly prejudicial. State

v. Rodgers, 16-14 (La. App. 5 Cir. 10/26/16), 202 So.3d 1189, 1201, writs denied,

16-2189 (La. 9/15/17), 225 So.3d 479 and 16-2093 (La. 1/29/18), 235 So.3d 1104.

Absent an abuse of discretion, a trial court’s ruling on the admissibility of evidence

pursuant to La. C.E. art. 404(B)(1) will not be disturbed. Jenkins, supra.

A. The July 2022 nightclub incident and shooting involving Morales and
Ramos

6

In its notice of intent, the State sought to introduce evidence of a prior 2022

nightclub altercation involving both Morales and Ramos during which a gun was

fired and a person was injured. The State averred that on January 11, 2023, a

witness, A.D., contacted the JPSO after seeing an online post about the arrests of

Morales and Ramos for the shootings at La Rumba, and advised officers that she

recognized the couple from a prior altercation occurring in July of 2022. A.D.

reported encountering Morales, whom she suspected was having an affair with her

husband, at a nightclub. A.D. described that a verbal altercation that turned

physical ensued, during which she heard a “pop.” She claimed she saw Ramos

throw a chair at her. She did not see Morales with a firearm. A.D. reported that

she no longer saw defendants, but later discovered a wound to her hip consistent

with a graze wound from a gunshot. During its investigation, officers found a

damaged projectile on the floor of the nightclub, subsequently concluded to be a

.40 caliber bullet. Attached to the State’s notice of intent was the Gretna police

report and a supplemental police report from the July 2022 incident, the JPSO

Crime Lab Firearms report, and A.D.’s identification of Morales and Ramos.

In her writ application, Morales argues that the July 2022 incident is not

probative of the current January 2023 murder, particularly since Morales was never

charged as the shooter in the July 2022 incident. Morales contends that there is no

evidence that she had any knowledge of the alleged gunshot, or that her

involvement in the prior incident proves the element of intent that she committed

the charged offenses. Specifically, Morales avers the State presented no law

enforcement testimony or witness testimony to show that Morales had the intent to

commit the current crimes in light of the prior altercation. In short, Morales argues

there is simply no connection, and thus, the district court erred in its determination

that the similarities between the incidents supported the admissibility of the

evidence without a substantial risk of unfair prejudice. We disagree.

7

Here, the evidence shows that both Morales and Ramos were involved in

altercations that escalated into physical confrontations occurring in bar or

nightclub settings. As to the charged offense occurring on January 8, 2023, at La

Rumba, a verbal dispute escalated into a shooting where witnesses confirmed that

Morales and Ramos were the perpetrators. Similarly, in the July 2022 incident, a

confrontation between Morales and the victim at a nightclub also escalated into

physical violence, during which it is suspected, based on the testimony of

eyewitnesses and the grazing wound sustained by the victim, that a firearm was

discharged. Comparing the factual circumstances of the incidents, even though

there are some differences between the January 8, 2023 charged offense and the

July 2022 incident,5 and when considering Morales’ involvement in both

confrontations and the escalation of conflicts into violence, we find no abuse of the

district court’s discretion in determining the evidence of the July 2022 incident is

admissible to refute Morales’ self-defense claim in the instant case. See Gasser,

supra; Sate v. Clanton, 19-316 (La. App. 4 Cir. 11/6/19), 285 So.3d 31. Moreover,

while evidence of the prior offense is necessarily prejudicial, we further find this

other crime evidence is not unduly and unfairly prejudicial, and is merely one

factor that will go to the weight of the evidence rather than its admissibility.

B. Admission of Evidence Obtained from Defendants’ Cell Phones

The district court granted admission of images obtained from the cell

phones of Morales and Ramos, showing defendants in possession of various

firearms, including a 9mm—the same type of weapon fired at the scene of the

January 8, 2023 shooting based on ballistic evidence—to establish their access and

5
The January 2023 incident resulted in one fatality and another critical injury, while the July 2022 incident
allegedly involved a graze wound. Additionally, it appears that Morales and Ramos in the January 2023 offense
were unfamiliar with the victims prior to the incident, whereas Morales and the July 2022 victim (A.D.) had prior
interactions. The January incident involved two firearms, while witnesses in the July 2022 altercation reported only
a “pop” without confirmed evidence of gunfire. Moreover, the January 2023 incident began with a verbal exchange
leading to a shooting it in the parking lot of La Rumba, whereas the July 2022 incident purportedly began with a
physical altercation inside a nightclub involving a thrown chair and a reported gunshot wound.
8

familiarity with the types of firearms used in the charged offense. We note that

although the State referenced videos depicted on the cell phones in its 404(B)

notice of intent and in the writ application, the writ application is devoid of any

videos. Further, the district court’s ruling only referred to the “photographs” of

weapons. Therefore, the admissibility of videos are not before this Court at this

time. See Uniform Rules–Courts of Appeal, Rule 1–3.

Attached to the State’s notice of intent were sixteen photographs depicting

multiple firearms in various settings, including two images showing unidentified

individuals holding guns. One of the photographs also depicts ammunition. These

photographs do not appear to constitute evidence of other crimes or bad acts

committed by Morales. See State v. Davis, 08-165 (La. App. 5 Cir. 7/29/08), 993

So.2d 295, 304, writ denied, 08-2188 (La. 5/1/09), 6 So.3d 810, and writ denied

sub nom. State ex rel. Davis v. State, 08-2200 (La. 5/1/09), 6 So.3d 811. Rather,

their admissibility appears to hinge on their relevancy. See State v. Butler, 15-89

(La. App. 5 Cir. 7/29/15), 171 So.3d 1283, 1289-90, writ denied, 15-1608 (La.

10/10/16), 207 So.3d 408.

Relevant evidence is defined in La. C.E. art. 401 as “evidence having any

tendency to make the existence of any fact that is of consequence to the

determination of the action more probable or less probable than it would be

without the evidence.” All relevant evidence is admissible, except as otherwise

provided by law, and irrelevant evidence is not admissible. La. C.E. art. 402.

However, relevant evidence may be excluded if its probative value is substantially

outweighed by the danger of unfair prejudice, confusion of the issues, or

misleading the jury, or by considerations of undue delay, or waste of time. La.

C.E. art. 403. Generally, photographs are admissible if they illustrate any fact,

shed light upon any fact or issue in the case, or are relevant to describe the person,

place, or thing depicted, subject to the test that their probative value outweighs any

9

prejudicial effect. State v. Battaglia, 03-692 (La. App. 5 Cir. 11/25/03), 861 So.2d

704, 710, writ denied sub nom. State ex rel. Battaglia v. State, 04-1701 (La.

4/29/05), 901 So.2d 1058. In general, an appellate court places great weight upon

a trial court’s ruling on the relevancy of evidence, and such a determination will

not be reversed absent a clear abuse of discretion. Id.

Here, some of the photographs attached to the State’s notice of intent depict

multiple firearms, while others show a single weapon, and two of the photographs

include unidentified individuals holding guns. The images also feature weapons in

various contexts, such as inside a vehicle, on a bed, next to a cell phone, held in

someone’s hand, and inside a waistband or pocket. In the notice of intent and writ

application, the State avers that the evidence was found on the cell phones of

Morales and Ramos. However, it did not specify whether the photographs came

from a particular defendant’s phone. Additionally, although the State generally

claimed that the photos showed each defendant in possession of firearms, including

a 9mm, it did not further specify which defendant was depicted in which

photograph or which specific photographs showed the 9mm. Also, at the hearing,

the State did not further elaborate on the photographs or identify which images

depicted the 9 mm handguns or showed Morales holding a firearm.

At the hearing, the State offered into evidence a JPSO police report related

to the January 2023 shooting. The report indicates that Morales’ cell phone was

seized from her person and that a gun was recovered from the driver’s side

floorboard. Morales admitted in a statement to firing her firearm, stating that one

shot went into the air. She also indicated that she believed Ramos owned a gun,

but did not have it on him at the time of the incident. Morales described Ramos’

firearm as a black and silver 9mm handgun, which she did not see after the

shooting. The report further reveals that a search warrant was executed on

Morales’ vehicle, resulting in the seizure of a 9mm semiautomatic handgun.

10

According to the report, the scientific analysis by the firearms examiner concluded

that one of the five 9mm cartridge cases collected from the crime scene was fired

by Morales’ Smith & Wesson handgun, while the remaining four were fired by an

unknown firearm.

Additionally, the report includes the results of downloads from the cell

phones of Morales and Ramos. A detective reviewed the digital content and

located photographs allegedly of Morales and Ramos holding firearms, including

an image on Morales’ phone of a hand holding a handgun. Although the detective

could not see the subject’s face in this image, he believed the individual to be

Ramos. Furthermore, a search of the downloaded material from Ramos’ phone

revealed a video of him wielding a handgun with another person while listening to

music in a car, as well as several photographs of guns in Ramos’ camera roll. The

report states that these images and video contradict Ramos’ claim that he has never

owned or possessed a firearm and corroborate a statement by Morales that she has

seen Ramos with a gun. As previously stated, there are no videos included in the

record before us.

After reviewing the photographs, particularly the photograph showing a

9mm and potentially depicting Morales, we find that some of the photographs may

be relevant to show that she had access to, and familiarity with, firearms similar to

those used in the incident. Courts have found photographs to be probative where

they demonstrated defendants’ access to weapons of similar types and their skill or

proficiency with firearms. See State v. Green, 19-123 (La. App. 5 Cir. 12/26/19),

286 So.3d 1230, 1238, writ denied, 21-51 (La. 3/9/21), 312 So.3d 583, cert.

denied, -- U.S. --, 142 S.Ct. 206, 211 L.Ed.2d 88 (2021); State v. Joseph, 16-349

(La. App. 5 Cir. 12/14/16), 208 So.3d 1036, writ denied, 17-77 (La. 4/7/17), 218

So.3d 109; State v. Everett, 11-714 (La. App. 4 Cir. 6/13/12), 96 So.3d 605, 632-

33, writ denied, 12-1593 (La. 2/8/13), 108 So.3d 77.

11

However, we find that very few details were provided at the hearing on the

State’s 404(B) motion, and that the record lacks sufficient information to

determine which specific photographs, among the several admitted, are relevant

and, thus, admissible in this matter. We find that admitting all of the photographs

at this time without more information may be unduly prejudicial to Morales

considering the unclear ownership of the weapons, not knowing from which phone

the photograph was extracted, who is depicted, where and/or when the photographs

were taken, the amount and type of guns depicted, and/or their connection to the

case sub judice. See State v. Anthony, 98-406 (La. 4/11/00), 776 So.2d 376, 388-

89, cert. denied, 531 U.S. 934, 121 S.Ct. 320, 148 L.Ed.2d 258 (2000) (holding

that “[a]s a general rule, before demonstrative evidence can be admitted into

evidence it must be shown that, more probably than not, the evidence is connected

to the case.”). Although the State argues these photographs demonstrate Morales

had access to and familiarity with firearms, we find that showcasing numerous

firearms, some equipped with magazines, as well as potentially unrelated firearms

and ammunition, risks creating unfair bias. Such images could lead to improper

inferences about Morales’ character.

Based on the limited record and lack of specifics about the photographs

before us, we find it difficult to ascertain whether some of these photographs might

be relevant at trial, such as for rebuttal or impeachment, if Morales denies

possessing or using a firearm. For these reasons, we grant Morales’ writ

application, in part, and vacate the portion of the August 19, 2024 judgment

granting the State’s 404(B) motion as it pertains to the admissibility of the

photographs obtained from the cell phones of Morales and Ramos. Further, we

hereby order the State to provide specific information, in writing, to the district

court and to counsel for Morales, within twenty-four (24) hours from the rendition

of this disposition, pertaining to each photograph it intends to introduce at trial—

12

i.e., from which cell phone the photograph was extracted; the person(s), if any,

depicted; the owner and type of the firearms or ammunition depicted; where and

when the photograph was taken; and the connection the photograph has to the

instant case—for reconsideration by the district court as to each photograph’s

admissibility at trial.

For the foregoing reasons, as discussed, Morales’ writ application is denied,

in part, and granted, in part, with instructions. Further, the portion of the August

19, 2024 judgment granting the State’s 404(B) notice of intent relating to the

admission of photographs extracted from the cell phones of Morales and Ramos is

vacated. Within twenty-four hours from the rendition of this ruling, the State is to

produce, in writing, to the district court and to counsel for Morales, the specific

information regarding each photograph as outlined above for the district court’s

reconsideration of the admissibility of this evidence.

Gretna, Louisiana, this 8th day of November, 2024.

SMC
MEJ
JJM

13

SUSAN M. CHEHARDY CURTIS B. PURSELL

CHIEF JUDGE CLERK OF COURT

SUSAN S. BUCHHOLZ
FREDERICKA H. WICKER
CHIEF DEPUTY CLERK
JUDE G. GRAVOIS
MARC E. JOHNSON
STEPHEN J. WINDHORST LINDA M. WISEMAN
JOHN J. MOLAISON, JR.
FIRST DEPUTY CLERK
SCOTT U. SCHLEGEL
TIMOTHY S. MARCEL FIFTH CIRCUIT
MELISSA C. LEDET
JUDGES 101 DERBIGNY STREET (70053)
DIRECTOR OF CENTRAL STAFF
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GRETNA, LOUISIANA 70054 (504) 376-1400

(504) 376-1498 FAX
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24-K-478
E-NOTIFIED
24th Judicial District Court (Clerk)
Honorable Nancy A. Miller (DISTRICT JUDGE)
Mark D. Plaisance (Relator) Thomas J. Butler (Respondent)
Darren A. Allemand (Respondent)

MAILED
Remy V. Starns (Relator) Cesar J. Vazquez (Relator) Marcus J. Plaisance (Relator)
Attorney at Law Attorney at Law Attorney at Law
301 Main Street 848 Second Street Post Office Box 1123
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Baton Rouge, LA 70825

Leo M. Aaron (Respondent)
Honorable Paul D. Connick, Jr.
(Respondent)
District Attorney
Twenty-Fourth Judicial District
200 Derbigny Street
Gretna, LA 70053

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7 □ 1b 2 □70 oaaa □ 954 8988 Restr1c:led Delivery Restr1cted DellYery

PS Form 3811, July 2015 PSN 7530-02-000-9053 Domestic Rettl'n Receipt ~