SUPREME COURT OF LOUISIANA STATE OF LOUISIANA DOCKET NO

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1 SUPREME COURT OF LOUISIANA STATE OF LOUISIANA DOCKET NO WARREN MONTGOMERY, IN HIS OFFICIAL CAPACITY AS DISTRICT ATTORNEY FOR ST. TAMMANY PARISH PLAINTIFF/APPLICANT VERSUS ST. TAMMANY PARISH GOVERNMENT, BY AND THROUGH THE ST. TASvIMANY PARISH COiJNCIL; AND PATRICIA "PAT" BRISTER, IN HER OFFICIAL CAPACITY AS PARISH PRESIDENT DEFENDANTS/RESPONDENTS ON WRIT GRANT BY THIS COURT ON REVIEW FROM THE FIRST CIRCUIT COURT OF APPEAL DOCKET NO. CA 2017 CA 0136 ON REVIEW FROM THE 22nd JUDICIAL DISTRICT COURT PARISH OF ST. TAMMANY, STATE OF LOUISIANA CIVIL DNISION, DOCKET NO THE HONORABLE MARION F. EDWARDS, PRESIDING AD HOC MOTION FOR LEAVE TO ENROLL AND RE-URGE BRIEF AS AMICUS CURIAE ON BEHALF OF THE LOUISIANA DISTRICT ATTORNEYS ASSOCIATION IN SUPPORT OF THE APPELLANT, WARREN MONTGOMERY, ON WRIT GRANT BY THIS COURT and REQUEST FOR ORAL ARGUMENT Respectfully submitted,~-- V E. Pete Adams (Bar Roll No.02315) Executive Director Louisiana District Attorneys Association 1645 Nicholson Drive Baton Rouge, Louisiana Telephone: (225) Facsimile: (225) pete(a~ldaa.org ~,

2 MOTION FOR LEAVE TO RE-URGE BRIEF AS AMICUS CURIAE In lieu of filing a brief, the Louisiana District Attorneys Association ("LDAA"), through undersigned counsel, respectfully moves for leave to file copies of the brief filed as amicus curiae in support of the Application for Supervisory Writs by applicant, Warren Montgomery, pursuant to La. S.Ct. Rule 10 Sect. 8. The LDAA is an association that represents the interests of Louisiana District Attorneys and the assistant district attorneys. The LDAA, on behalf of its members, has substantial, legitimate interest that will likely be affected by the outcome of the case and that will not necessarily be adequately protected by the parties. See La. S.Ct. Rule 12. In particular, the LDAA is tasked with representing to this Honorable Court that the decision of it and the implication of the First Circuit decision is not only applicable to St. Tammany Parish and Mr. Montgomery but could open a gateway of unconstitutional behavior potentially affecting many parishes and many District Attorneys in Louisiana. Currently, fifteen of Louisiana local government bodies operate under a Home Rule Charter form of government. If the lower Court rulings are allowed to stand, these local government bodies could, without a vote of the people, re-organize and restructure the Charter and affect the duties and obligations of the District Attorney and his office. Furthermore, if the lower Court rulings are allowed to stand, the remaining local Governments would be enticed to adopt a Home Rule Charter, after which they could act virtually without the restraint of the voting public. T'he impact would be severe. In addition to seeking leave to have this amicus curiae brief considered on the merits, the LDAA also seeks leave to present oral argument. Respectfully submitted ~~L" E. Pete Adams (Bar Roll No.02315) Executive Director Louisiana District Attorneys Association 1645 Nicholson Drive Baton Rouge, Louisiana Telephone: (225) Facsimile: (225) Pete o,ldaa.org

3 t' 1 Considering the foregoing, IT IS HEREBY ORDERED that the Louisiana District Attorneys Association be permitted, on behalf of all District Attorneys of the State of Louisiana, to enter as Amicus Curiae before this Honorable Court in the above captioned matter. JUDGE, LOUISIANA SUPREME COURT CERTIFICATE I hereby certify that a copy of the above and foregoing motion has been served on all counsel of record by electronic mail and/or U.S. Mail on this 22nd y o Feb, THE HONORABLE RODD NAQUIN, CLERK OF COURT FIRST CIRCUIT COURT OF APPEAL POST OFFICE BOX 4408 BATON ROUGE, LA BENJAMIN P. KAHN JENNIFER LEIGH THORNTON RICHARD CHARLES STANLEY STANLEY, FLANAGAN & RE 909 POYDRAS STREET, SUITE 2500 NEW ORLEANS, LA ROSS F. LAGARDE 2250 GAUSE BOULEVARD EAST, SUITE 301 SLIDELL, LA WILLIAM J. FAUSTERMANN, JR LINDBERG DR. SLIDELL, LA EDWARD HART BERGIN JONES, WALKER, WAECHT 201 ST. CHARLES AVE., 49~ FLOOR NEW ORLENAS, LA JAMES C. PERCY NSTIN J. MAROCCO JONES, WALKER 8555 UNITED PLAZA BOULEVARD FOUR UNITED PLAZA, 5~ FLOOR BATON ROUGE, LA MANDIE M. CASH FOUR UNITED PLAZA 8555 UNITED PLAZA BLVD BATON ROUGE, LA THE HONORABLE JUDGE AD HOC, MARION F EDWARDS 22~ JUDICIAL DISTRICT COURT ST TASvI:MANY PARISH SLIDELL, LA E. Pete dams Louisiana District Attorneys Association

4 SUPREME COURT OF LOUISIANA STATE OF LOUISIANA DOCKET NO WARREN MONTGOMERY, IN HIS OFFICIAL CAPACITY AS DISTRICT ATTORNEY FOR ST. TAMMANY PARISH PLAINTIFF/APPLICANT VERSUS ST. TAMMANY PARISH GOVERNMENT, BY AND THROUGH THE ST. TAMMANY P.A.RISH COiJNCIL; AND PATRICIA "PAT" BRISTER, IN HER OFFICIAL CAPACITY AS PARISH PRESIDENT DEFENDANTS/RESPONDENTS ON WRIT GRANT BY THIS COURT ON REVIEW FROM THE FIRST CIRCUIT COURT OF APPEAL DOCKET NO. CA 2017 CA 0136 ON REVIEW FROM THE 22nd NDICIAL DISTRICT COURT PARISH OF ST. TAMMANY, STATE OF LOUISIANA CNIL DIVISION, DOCKET NO THE HONORABLE MARION F. EDWARDS, PRESIDING AD HOC MOTION FOR LEAVE TO WITHDRAW COUNSEL FROM AMICUS CURIAE ON BEHALF OF THE LOUISIANA DISTRICT ATTORNEYS ASSOCIATION Respectfully submitted E. Pete Adams (Bar Roll No.02315) Executive Director Louisiana District Attorneys Association 1645 Nicholson Drive Baton Rouge, Louisiana Telephone: (225) Facsimile: (225) Pete o,ldaa.org

5 MOTION FOR LEAVE TO WITHDRAW COUNSEL FROM AMICUS CURIAE ON BEHALF OF LOUISIANA DISTRICT ATTORNEYS ASSOCIATION NOW into Court comes the Louisiana District Attorneys Association, as Amicus Curiae, and respectfully requests that Angela B. Odinet, Bar Roll # 27370, be withdrawn as counsel of record from the foregoing matter, as she is no longer an employee of the Louisiana District Attorneys Association. Respectfully submitted, _~ ~ ~ ~~~/ E. Adams (Bar Roll No.02315) Executive Director Louisiana District Attorneys Association 1645 Nicholson Drive Baton Rouge, Louisiana Telephone: (225) Facsimile: (225) Pete,ldaa.or~

6 t' 1 ' Considering the foregoing, IT IS HEREBY ORDERED that Angela B. Odinet be withdrawn as counsel of record from the foregoing matter. JUDGE, LOUISIANA SUPREME COURT CERTIFICATE I hereby certify that a copy of the above and foregoing motion has been served on all counsel of record by electronic mail and/or U.S. Mail on this 22nd da of Febru 018. x ~,' ~,.~ E. Pete Adams Louisiana District Attorneys Association THE HONORABLE RODD NAQUIN, CLERK OF COURT FIRST CIRCUIT COURT OF APPEAL POST OFFICE BOX 4408 BATON ROUGE, LA BENJAMIN P. KAHN JENNIFER LEIGH THORNTON RICHARD CHARLES STANLEY STANLEY, FLANAGAN & RE 909 POYDRAS STREET, SUITE 2500 NEW ORLEANS, LA ROSS F. LAGARDE 2250 GAUSE BOULEVARD EAST, SUITE 301 SLIDELL, LA WILLIAM J. FAUSTER.~~IANN, JR LINDBERG DR. SLIDELL, LA EDWARD HART BERGIN JONES, WALKER, WAECHT 201 ST. CHARLES AVE., 49~ FLOOR NEW ORLENAS, LA JAMES C. PERCY JUSTIN J. MAROCCO JONES, WALKER 8555 UNITED PLAZA BOULEVARD FOUR UNITED PLAZA, 5TH FLOOR BATON ROUGE, LA MANDIE M. CASH FOUR UNITED PLAZA 8555 UNITED PLAZA BLVD BATON ROUGE, LA THE HONORABLE JUDGE AD HOC, MARION F EDWARDS 22ND NDICIAL DISTRICT COURT ST TAMMANY PARISH SLIDELL, LA 70458

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