State of Louisiana Versus Ezekiel Brown

STATE OF LOUISIANA NO. 24-KA-16

VERSUS FIFTH CIRCUIT

EZEKIEL BROWN COURT OF APPEAL

STATE OF LOUISIANA

ON APPEAL FROM THE TWENTY-FOURTH JUDICIAL DISTRICT COURT
PARISH OF JEFFERSON, STATE OF LOUISIANA
NO. 23-4229, DIVISION "E"
HONORABLE FRANK A. BRINDISI, JUDGE PRESIDING

October 30, 2024

JUDE G. GRAVOIS
JUDGE

Panel composed of Judges Jude G. Gravois,
Marc E. Johnson, and Stephen J. Windhorst

AFFIRMED
JGG
MEJ
SJW

COUNSEL FOR PLAINTIFF/APPELLEE,
STATE OF LOUISIANA
Honorable Paul D. Connick, Jr.
Thomas J. Butler
Matthew R. Clauss

COUNSEL FOR DEFENDANT/APPELLANT,
EZEKIEL BROWN
Prentice L. White

GRAVOIS, J.

Defendant, Ezekiel Brown, appeals his conviction of felon in possession of a

firearm, a violation of La. R.S. 14:95.1, committed on or about August 1, 2023.

On appeal, he argues that, in the State’s rebuttal case, the trial judge erred when he

allowed the introduction of testimony in violation of the court’s previous ruling

denying the State’s request to admit evidence of other crimes, pursuant to La. C.E.

art. 404(B). For the following reasons, we find no merit to the assignment of error.

Defendant’s conviction and sentence are affirmed.

PROCEDURAL HISTORY

On September 7, 2023, the Jefferson Parish District Attorney filed a bill of

information charging defendant, Ezekiel Brown, with possession of a firearm by a

convicted felon, in violation of La. R.S. 14:95.1, on or about August 1, 2023.1

Defendant was arraigned and entered a plea of not guilty on September 8, 2023.

On October 17, 2023, the State filed several pretrial motions, including

“State’s Notice of Intent to Use Res Gestae Evidence/Request for Simultaneous

Trials.” The motion indicated that the State intended to try defendant for the

instant charge of La. R.S. 14:95.1, while simultaneously trying him in case number

23-4230 for violating La. R.S. 14:102.1(A), cruelty to animals.2

The State also filed “State’s Notice of Intent to Introduce Evidence as Res

Gestae or in the Alternative Under La. C.E. Article 404(B).” The motion argued

for the admission of defendant’s outstanding attachment. The motion was granted

1
The bill of information alleges that defendant possessed “a Raven Arms P-25 semi-
automatic handgun, SN: 595514.” The bill further alleges that defendant was previously
convicted of the crime of “Possession of Buprenorphine (Suboxone) (La. R.S. 40:968), under
case number 22-2797 on December 09, 2022, in Division L of the 24th Judicial District Court,
Parish of Jefferson.”
2
When defendant was arrested, nine pit bulls in poor condition were found on the
property. The motion stated that both crimes “occurred during the same transaction or
occurrence, at the same location, involve the same witnesses, and as such are res gestae.” The
motion was granted, with the trial judge stating he would “do it outside of the presence of the
jury.”

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in part and denied in part. The court allowed the State to mention defendant’s

attachment, but limited the State on introducing testimony regarding the nature of

the detective’s investigation surrounding the residence. The court stated it would

allow testimony regarding an investigation, but not a “narcotics investigation.”

The State also filed “State’s Notice of Intent to Introduce Evidence Under

La. C.E. Article 404(B).” The State argued for the admission of the evidence

seized from the residence in which defendant resided pursuant to the search

warrant, namely a .22 caliber long rifle. The court denied the motion.

A jury trial commenced the same day, October 18, 2023, after the

aforementioned pretrial rulings. On that date, the jury returned a verdict of guilty

as charged. After defendant waived sentencing delays, the court sentenced

defendant to five years imprisonment with the Department of Corrections without

the benefit of probation, parole, or suspension of sentence. A timely motion for

appeal was filed on October 19, 2023, which the court granted the next day.

FACTS

Detective Jeremy Budo, a detective with the narcotics division of the

Jefferson Parish Sherriff’s Office (“JPSO”), participated in an investigation on

August 1, 2023 of a residence at 324 Marrero Road in Jefferson Parish for

narcotics trafficking. Defendant, Ezekiel Brown, was observed standing outside

the residence by surveillance officers. Detective Budo testified that another

detective recognized defendant from a prior investigation. A criminal history

check was conducted, and an outstanding attachment for an arrest from Jefferson

Parish was discovered for defendant. Defendant was arrested once he left the

residence.

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After defendant was arrested, a loaded firearm was seized from his pocket.3

Ammunition and defendant’s cell phone were also seized. Defendant was read his

Miranda4 rights; he told Detective Budo that he had the firearm for “shooting

ducks.”5 Further investigation revealed that defendant had a prior conviction for

possession of Suboxone from December 2022, to which the parties stipulated at

trial.

Detective Cody Foret, a detective with JPSO’s narcotics division, testified

that he participated in the investigation involving defendant that took place on

August 1, 2023. He first encountered defendant while observing him exiting the

residence at 324 Marrero Road. Defendant was taken into custody because of an

attachment for him from Jefferson Parish. Detective Foret participated in the

arrest. A search of defendant’s person incident to his arrest was conducted, and a

silver firearm with a wood grip was recovered from his right pocket.

Detective Foret was equipped with a body-worn camera during defendant’s

arrest. The camera footage was played for the jury. The footage, identified by

Detective Foret, showed defendant walking and Detective Foret holding a taser in

his hands. The footage also showed a .25 caliber firearm being pulled out of

defendant’s pocket. The footage partially showed Detective Foret removing the

magazine from the firearm, which he testified was done to eject any rounds that

may have been in the chamber to ensure everyone’s safety. Detective Foret

testified that the gun was loaded.

3
Later testing at the crime lab revealed the firearm was fully functional.
4
Miranda v. Arizona, 384 U.S. 436, 86 S.Ct. 1602, 16 L.Ed.2d 694 (1966).
5
Detective Budo explained that defendant made the statement about using the gun for
shooting ducks while they were having a casual conversation at the investigations bureau. The
camera in the interview room was not turned on, and Detective Budo was alone with defendant
when he made the statement. On the date of trial, defense counsel stated that he waived any
substantive motions relative to the motion to suppress. Defense counsel agreed with the State
that no statement was unconstitutionally obtained.

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At trial, defendant did not dispute he had a firearm in his possession when he

was arrested on August 1, 2023. Defendant claimed he had a gun in his possession

because he had been shot in his leg two weeks after getting released from jail on

the Suboxone arrest. He testified he did not know who shot him and the gun was

for his protection. He explained the shooting occurred when he was walking home

from cutting grass one night, a car stopped, and someone started shooting at him.

He limped to someone’s house and got the person to call 9-1-1. He was taken to

West Jefferson Hospital, where he was treated for his gunshot wound. Defendant

testified he knew he could not possess a firearm while on probation, but the shooter

was never found, and he was dealing with “PTSD.”6 He stated he was scared to go

outside and was trying to protect his life. Defendant testified he filed a police

report, but nothing ever resulted from it. At that point, the defense rested.

Following defendant’s testimony, the State moved to present testimony to

rebut defendant’s statement that he was in possession of a firearm for his

protection after being shot in the leg. Defense counsel objected to the State’s

request, arguing that presenting such rebuttal testimony was improper cross-

examination because it would violate the court’s pretrial ruling on the La. C.E. art.

404(B) motion. The court overruled the objection and permitted the State to

present this rebuttal testimony to impeach defendant’s testimony.

The State recalled Detective Budo as a rebuttal witness. On rebuttal,

Detective Budo testified that defendant never made a statement to him that he was

the victim of a shooting or that he had a firearm for self-defense. He stated

defendant never told him he was afraid for his life and never gave him an item

number for an incident where he may have called the police. Detective Budo

testified that the nature of the investigation on August 1, 2023 was due to a

6
“PTSD” is an acronym for “Post-traumatic Stress Disorder.”

24-KA-16 4

complaint of narcotics trafficking from the residence located at 324 Marrero Road

where defendant was observed going in and out of repeatedly. A search of 324

Marrero Road was conducted and narcotics were located in the residence. Another

firearm was also located in the residence.7 Detective Budo testified that nine pit

bulls in poor condition were located in the rear of the residence in a partitioned-off

area. He learned that defendant resided in this area of the residence. Detective

Budo testified that in his experience as a narcotics detective, it was common for

someone who dealt drugs to have firearms to protect themselves and their business

due to the dangerous nature of the “profession.”

Following the rebuttal testimony, the case went to the jury, who returned a

verdict of guilty as charged.

ASSIGNMENT OF ERROR

In his only assignment of error, defendant argues that the State improperly

used its rebuttal witness to introduce “other crimes” evidence, in violation of the

court’s previous ruling to deny the State’s pretrial motion to admit other crimes

evidence pursuant to La. C.E. art. 404(B), to refute his testimony.

Defendant avers that based on his testimony of his reason for possessing a

firearm, the State did not prove he had the requisite general intent to violate the

court’s restriction of gun possession due to his 2022 felony conviction. Defense

counsel lodged an objection to the calling of Detective Budo as a rebuttal witness

because he believed his testimony would violate the pretrial ruling on the Article

404(B) motion. The court overruled the objection and permitted the State to

question the witness as to the purpose behind the surveillance of the Marrero Road

residence. Defendant contends the detective’s testimony alluded to the fact that

defendant was a person of “bad character” and he was shot because he was

7
The other firearm, a rifle, was admitted as State’s Exhibit 5. Detective Budo testified
that the rifle was found on the roof of an adjoining building on the property.

24-KA-16 5

“supposedly” engaged in illegal drug activities. Consequently, the jury convicted

him because “it considered the shooting as a consequence of his bad behavior.”

Defendant asks that his conviction be reversed because the trial court improperly

allowed the State to use “other crimes” evidence to support its burden of proof.

The State responds that defendant’s assignment of error was not preserved

for appeal. The State notes that the trial court declined to rule in advance on the

admissibility of the State’s witness’s rebuttal testimony, and instead instructed

defense counsel to object on a question-by-question basis. When the court stated it

would allow for impeachment purposes what it had previously excluded for Article

404(B) purposes, defense counsel did not object on any grounds. The State points

to occasions when defense counsel did object during the rebuttal testimony, none

of which were on the grounds of an Article 404(B) violation. As such, the State

argues that pursuant to La. C.E. art. 103, the argument is not preserved for appeal,

and the claim is thus procedurally defaulted.

Next, the State argues that defendant “opened the door” to rebuttal evidence

when he placed his reason for possessing the firearm into question, and the State

had a right to introduce contradictory evidence. The State argues that in the instant

matter, evidence tending to show defendant was engaged in narcotics trafficking

was evidence tending to show an alternative explanation for his gun possession.

The State also argues that additionally, because the evidence related to defendant’s

motive, the rebuttal testimony was specifically excepted under La. C.E. art.

404(B).

Finally, the State argues that any error in the admission of the State’s

rebuttal evidence was harmless because the verdict rendered was surely

unattributable to any error in the introduction of the State’s rebuttal evidence. The

State notes that through his own testimony, defendant admitted every element of

possession of a firearm by a convicted felon. The State further argues that

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defendant’s purported “defense” was not a defense as a matter of law because the

reason for possession a firearm was irrelevant to the offense.8 The State concludes

that defendant convicted himself without ever making a valid defense.

As previously noted, Detective Budo testified on rebuttal that defendant

never made a statement to him that he was the victim of a shooting or that he had a

firearm for self-defense. He also stated that defendant never disclosed to him that

he was scared for his life and did not give him an incident number for a past

occurrence where he may have made a report to the police. Detective Budo

testified that the nature of the investigation on the date of defendant’s arrest was

due to a complaint regarding narcotics trafficking from the residence that

defendant was observed going in and out of repeatedly. He testified that narcotics

and a rifle were located in the residence. Detective Budo explained that in his

experience, it was common for someone who dealt drugs to have firearms for

protection when drug dealing.

Defense counsel’s only lodged objections during Detective Budo’s

testimony on rebuttal were based on relevancy, hearsay, and scope.

La. C.E. art. 103(A) provides:

A. Effect of erroneous ruling. Error may not be predicated upon a
ruling which admits or excludes evidence unless a substantial right
of the party is affected, and

(1) Ruling admitting evidence. When the ruling is one admitting
evidence, a timely objection or motion to admonish the jury to
limit or disregard appears of record, stating the specific ground
of objection; or
(2) Ruling excluding evidence. When the ruling is one excluding
evidence, the substance of the evidence was made known to the
court by counsel.
La. C.Cr.P. art. 841(A) provides that an irregularity or error cannot be

availed of after verdict unless it was objected to at the time of occurrence. State v.

8
The State acknowledges two exceptions to the rule, justification and necessity, which it
argues do not apply in the instant matter.

24-KA-16 7

McGowan, 16-130 (La. App. 5 Cir. 8/10/16), 199 So.3d 1156, 1161, writ not

considered sub nom. State ex rel. McGowan v. State, 17-1675 (La. 10/27/17), 228

So.3d 1227; State v. Berroa-Reyes, 12-581 (La. App. 5 Cir. 1/30/13), 109 So.3d

487, 498. Defendant is not only limited on appeal to matters to which an objection

was made, but also to the grounds for his objection articulated at trial. See also

State v. Jackson, 450 So.2d 621 (La. 1984); McGowan, supra.

In State v. Patin, 13-618 (La. App. 5 Cir. 9/24/14), 150 So.3d 435, 443, writ

denied, 14-2227 (La. 4/22/16), 191 So.3d 1043, this Court found that the admission

of other crimes evidence was not reviewable where defendant failed to

contemporaneously object to its admission. The State filed a pretrial notice of

intent to introduce other crimes, wrongs, or acts committed by the defendant,

pursuant to La. C.E. art. 404(B), and the trial court granted the motion. Id. at 436-

37. On appeal, the defendant argued that the trial court erred when it allowed the

State to introduce evidence for his arrest for narcotics offenses in New Orleans,

which occurred less than a month prior to his arrest for the charges he was

convicted of. Id. at 442. This Court found that the defendant did not object to the

testimony regarding other pending charges or to the admission of related evidence.

This Court further stated that although the defendant had made a pretrial objection

to the trial court’s ruling granting the Article 404(B) motion, he consented at trial

to the admission of the evidence and therefore was precluded from raising the issue

on appeal.

As discussed, in the instant matter after the court ruled the State was entitled

to rebut the defense, the court stated it would take the police officer’s testimony

“one question at a time” and instructed defense counsel to object at each question.

The record does not reflect that defense counsel objected to the trial court’s ruling,

or that defense counsel objected to any questions asked by the State on rebuttal on

24-KA-16 8

the grounds of an Article 404(B) violation. We find that because the issue was not

preserved, defendant is precluded from raising the issue on appeal.

In any event, La. C.E. art. 404(B) provides, in pertinent part:

B. Other crimes, wrongs, or acts; creative or artistic expression.
(1)(a) Except as provided in Article 412 or as otherwise provided
by law, evidence of other crimes, wrongs, or acts is not admissible
to prove the character of a person in order to show that he acted in
conformity therewith. It may, however, be admissible for other
purposes, such as proof of motive, opportunity, intent, preparation,
plan, knowledge, identity, absence of mistake or accident, provided
that upon request by the accused, the prosecution in a criminal case
shall provide reasonable notice in advance of trial, of the nature of
any such evidence it intends to introduce at trial for such purposes,
or when it relates to conduct that constitutes an integral part of the
act or transaction that is the subject of the present proceeding. …9
La. C.E. art. 611(E) provides that the State in a criminal prosecution shall

have the right to rebut evidence adduced by their opponents. Rebuttal evidence is

that which explains or disproves. State v. Jones, 08-20 (La. App. 5 Cir. 4/15/08),

985 So.2d 234, 243-44 (citing State v. Tilley, 99-569 (La. 7/6/00), 767 So.2d 6, 23,

cert. denied, 532 U.S. 959, 121 S.Ct. 1488, 149 L.Ed.2d 375 (2001)).

The notice requirements of La. C.E. art. 404(B) do not apply to other crimes

evidence offered on rebuttal. Id., citing State v. Parent, 02-835 (La. App. 5 Cir.

12/30/02), 836 So.2d 494, 505, writ denied, 03-0491 (La. 10/31/03), 857 So.2d

472. The determination of whether the evidence is rebuttal evidence and,

therefore, is admissible is an issue that is addressed to the sound discretion of the

trial court. Id., citing Tilley, supra. The trial court’s determination will not be

disturbed except in extreme cases, as where the evidence has been kept back

9
In order for other crimes evidence to be admitted under La. C.E. art. 404(B)(1), the
“other crimes” evidence must be admitted for other purposes, such as those listed in Article
404(B)(1), having some independent relevance, or be an element of the crime charged in order
for the evidence to be admissible. State v. Prieur, 277 So.2d 126 (La. 1973). The fundamental
rule in Louisiana governing the use of evidence of other crimes, wrongs, or acts is that such
evidence is not admissible to prove the accused committed the charged crime because he has
committed other such crimes in the past or to show the probability he committed the crime in
question because he is a man of criminal character. State v. Shorter, 23-128 (La. App. 5 Cir.
11/29/23) 377 So.3d 421, 436 (citing State v. Lee, 05-2098 (La. 1/16/08), 976 So.2d 109, 139,
cert. denied, 555 U.S. 824, 129 S.Ct. 143, 172 L.Ed.2d 39 (2008)).

24-KA-16 9

deliberately and for the purpose of deceiving and obtaining an undue advantage.

State v. Amato, 96-606 (La. App. 1 Cir. 6/30/97), 698 So.2d 972, 987, writs denied,

97-2626, 97-2644 (La. 2/20/98), 709 So.2d 772.

In the instant matter, defense counsel asked defendant why he possessed the

gun, and defendant testified that it was for his protection. The court ruled that the

State was able to rebut the defense by presenting testimony of Detective Budo.

Upon review, we find that the court did not err in allowing the rebuttal

testimony of Detective Budo, once the door was opened by defendant’s trial

testimony.

Furthermore, even if the trial court erred in allowing admission of the

rebuttal evidence, the erroneous admission of the evidence is subject to a harmless

error analysis. See State v. Magee, 22-635 (La. App. 4 Cir. 3/20/23), 382 So.3d

155, 165 (citing State v. Session, 21-118 (La. App. 4 Cir. 12/14/21), 332 So.3d

729, 737). See also Jones, supra.10 In determining harmless error, it is “not

whether, in a trial that occurred without the error, a guilty verdict would surely

have been rendered, but whether the guilty verdict actually rendered in the trial

was surely unattributable to the error.” State v. Massey, 11-358 (La. App. 5 Cir.

10
In Jones, supra, the defendant argued that the trial court erred when it denied his
motion for a mistrial after a detective testified on rebuttal as to evidence of another crime. The
defendant claimed that it was elicited to portray him as a person of criminal character, the
testimony denied him a fair trial, there was no Prieur hearing, and it was not relevant. Jones,
985 So.2d at 242. This Court discussed La. C.E. art. 404(B), law regarding mistrials, and
rebuttal evidence. Id. at 243-44. This Court found that the State elicited the testimony of the
detective in order to impeach the defendant and rebut specific issues of fact raised during his
testimony that were not objected to by the defense. Id. at 244. This Court stated that even if the
testimony was improperly admitted, the introduction of inadmissible other crimes evidence was
subject to a harmless error analysis, and found that the State had presented overwhelming
evidence of the defendant’s guilt. This Court stated that the guilty verdict “was surely
unattributable to the statement made by Detective Peterson that might have alluded to another
crime allegedly committed by the defendant.” Id.
In the instant matter, Detective Budo’s testimony was in reference to the nature of the
investigation surrounding defendant (a narcotics investigation) and additional evidence found in
the residence. Whether the testimony is characterized as rebuttal testimony or “other crimes
evidence,” both are subjected to a harmless error analysis.

24-KA-16 10

3/27/12), 97 So.3d 13, 29, writ denied sub nom. State ex rel. Massey v. State, 12-

993 (La. 9/21/12), 98 So.3d 332.

Even if the trial court erroneously admitted the rebuttal testimony, the error

was harmless, given the other evidence of defendant’s guilt presented at trial. In

order to convict a defendant of possession of a firearm by a convicted felon, the

State must prove beyond a reasonable doubt that the defendant had: 1) possession

of a firearm; 2) a prior conviction for an enumerated felony; 3) an absence of the

ten-year statutory period of limitation; and 4) the general intent to commit the

offense. State v. Faciane, 17-224 (La. App. 5 Cir. 11/15/17), 233 So.3d 195, 205,

writ denied, 17-2069 (La. 10/8/18), 253 So.3d 797. Evidence was presented by the

State that defendant possessed a firearm at the time of his arrest. Defendant

admitted to possessing the firearm. The defense and the State stipulated that

defendant was previously convicted of a felony, namely La. R.S. 40:968(C),

possession of Suboxone. As pointed out by the State, defendant agreed he was

“the same Ezekiel Brown that pled guilty to possession of Suboxone in December

of 2022” and that he knew as part of the plea he would be giving up his right to

possess a firearm for up to ten years after the completion of his sentence.

Defendant also stated he knew he would be on probation for the first two years

after the conviction and he knew he was on probation on August 1, 2023.

Considering the other evidence presented at trial, we find that the guilty verdict

rendered by the jury was surely unattributable to the admission of the rebuttal

testimony and that any error in its admission was harmless.11

11
Defendant testified that he possessed the gun for protection. Defendant does not argue
on appeal that he possessed the gun for protection.
In State v. Crawford, 03-1494 (La. App. 5 Cir. 4/27/04), 873 So.2d 768, 785, writ denied
sub nom. State ex rel. Crawford v. State, 04-1744 (La. 5/6/05), 901 So.2d 1083, this Court
discussed the Louisiana Supreme Court’s decision in State v. Blache, 480 So.2d 304, 308 (La.
1985), which held that a felon may justifiably possess a weapon for self-defense situations. This
Court explained that per Blache, in order to prove the defense of justification, a “defendant must
show he was in imminent peril of great bodily harm, or reasonably believed himself or others to

24-KA-16 11

ERRORS PATENT REVIEW

The record was reviewed for errors patent according to La. C.Cr.P. art. 920,

State v. Oliveaux, 312 So.2d 337 (La. 1975), and State v. Weiland, 556 So.2d 175

(La. App. 5th Cir. 1990). We find no errors patent that require correction.

DECREE

For the reasons stated above, defendant’s conviction and sentence are

affirmed.

AFFIRMED

be in such danger. If so, then he may take possession of a weapon for a period no longer than is
necessary or apparently necessary to use it in self-defense, or in defense of others.” Id.
In the instant matter, defendant testified that he was shot two weeks after his release for
the possession of Suboxone conviction in December 2022. The arrest in the instant matter
occurred on August 1, 2023. Defendant did not testify that there was an imminent or apparent
threat of force at the time he was arrested that would lead to his possession of the firearm for his
protection.

24-KA-16 12

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
POST OFFICE BOX 489
GRETNA, LOUISIANA 70054 (504) 376-1400

(504) 376-1498 FAX
www.fifthcircuit.org

NOTICE OF JUDGMENT AND CERTIFICATE OF DELIVERY
I CERTIFY THAT A COPY OF THE OPINION IN THE BELOW-NUMBERED MATTER HAS BEEN DELIVERED
IN ACCORDANCE WITH UNIFORM RULES - COURT OF APPEAL, RULE 2-16.4 AND 2-16.5 THIS DAY
OCTOBER 30, 2024 TO THE TRIAL JUDGE, CLERK OF COURT, COUNSEL OF RECORD AND ALL PARTIES
NOT REPRESENTED BY COUNSEL, AS LISTED BELOW:

24-KA-16
E-NOTIFIED
24TH JUDICIAL DISTRICT COURT (CLERK)
HONORABLE FRANK A. BRINDISI (DISTRICT JUDGE)
MATTHEW R. CLAUSS (APPELLEE) THOMAS J. BUTLER (APPELLEE)

MAILED
PRENTICE L. WHITE (APPELLANT) HONORABLE PAUL D. CONNICK, JR.
ATTORNEY AT LAW (APPELLEE)
LOUISIANA APPELLATE PROJECT DISTRICT ATTORNEY
16731 CICERO AVENUE TWENTY-FOURTH JUDICIAL DISTRICT
BATON ROUGE, LA 70816 200 DERBIGNY STREET
GRETNA, LA 70053