crvapisricr cour ror THE rast or owas {LED STATE OF LOUISIANA upsee te $03 NO. 2018-6432 Divison Sejtign: 7 GE oisrRict COURT VERSUS NAAMAN STEWART, ET AL FILED:_ 2018 DEPUTY CLERK PLAINTIFF'S EX PARTE MOTION FOR LEAVE 70 FILE EVIDENCE IN SUPPORT 0 SINAL AND AMENDED AND SUPP RD AMAGES CLERK, CIVIL DISTRICT COURT NOW INTO COURT, through undersigned oiniel; Dunes slut 421 LOYOLAAVENUE- ROOM a2 pursuant to La. C.C.P. art, 961, who respectfully mavesthis Conable Chascio grant this motion 504-407-0060 for leave of cour to allow forthe fllowing of eviderss rggppor ote yrange amemict — and supperental pettion for damages into the rece SESYTIN 710417 a Alenneon Plaintiff avers thatthe Court should grant aftBBtihion to fle BEGeSe STR. Casenumbe 2019-06432 court on the grounds se forth below: Saata peace! 1, La. Cnt 102, Purpose and Consus YA ARES osteo see veipayment Ec fhimess and efficiency in administration of thatthe truth Payments Transaction lt may be ascertained and proceedings justly d0fematined 1013 ¥24.00 2, Le CE, art. 401, the evidence levant tothe fats of the petition for damages 3. La, CE. art 402, the evidence is admissible Hestuse ofits relevancy (GReaREts of feldise B31 Other Motloninoma $0.00 000" 40.00 and are not subject to any legal objections. “en “ hibit ak 36.00 $8.00 $0.00 4. The audio and documentary evidence wereSabiCEARyomited at MEAD OL EREA#0.00 plant's petition for damages 5 Plaintiff wil suffer prejudice ifthe evidenco is excluded from the record of the court 6 Defendants will suffer no prejudice f the evidence is allowed for ling into the record of. the court ‘This case isin its preliminary stages of itgation to determine its viability ot dispositive consequences. The information proffered for submission is actually and constructively known by defendants herein, and therefore, will eause no surprise or any type of prejudice, FI GilsWHEREFORE, plaintiff prays this Honorable Court deems this motion for leave sufficiently plead for filing of evidence into the record of court by issulgg ai ler prGntng same, ‘LENA RACHAL HINTON, E50, LSBA #32875, 2528 Tulane Avene New Orleans, Lousiana 70119, (604) 298-2203 ph (604) 298-2527 fax En: Ieuhintonesauite@zmai.comCIVIL DISTRICT COURT FOR THE PARISH OF ORLEANS ahr STATE OF LOUISIANA FILED WIG SEP | NooAont293 ex i aisTaticT 6ouRT VERSUS ‘NO. 2018-6432 Division: NAAMAN STEWART, ET AL FILED:__,2018 DEPUTY CLERK PROPOSED ORDER CONSIDERING THE FOREGOING MOTION IT IS HEREBY ORDERED, ADJUDGED AND DECREED, that Plant's Ex Parte Motion for Leave to File Bvidence in Support of Original and Amended and Supplemental Petition for Damages fied by attomey Lena Rachal Hinton on bekalf of plaintiff, MMB: above numbered and entitled cause is hereby Signed in chambers in New Orleans, Louisiana on this__day of September, 2018 JUDGE (CERTIFICATE OF SERVICE CERTIFY that on this 14% day of September, 2018, that a copy of the foregoing pleading has been served on opposing counsel of record by depositing same in the U.S. mail first class ‘with sufficient prepaid postage and properly addressed. "WAL HINTON ‘Attorney for Gemell Hulbert VERIFIED