CRIMINAL DOCKET NUMBER: 190,764-B

DIVISION B
12TH JUDICIAL DISTRICT COURT
PARISH OF AVOYELLES
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STATE OF LOUISIANA
VERSUS
NORRIS GREENHOUSE, JR.
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FILED:______________________________: ______________________________DY.CLK.
MOTION TO COMPEL ANSWER - BILL OF PARTICULARS
NOW INTO COURT, through undersigned counsel, comes Defendant, NORRIS
GREENHOUSE, JR., (hereinafter referred to as "Defendant") and for purpose of this Motion
moves this Honorable Court to compel a hearing with the State of Louisiana, as to whether or not
the States answer to the defendants Bill of Particulars has been satisfied, and states the
following:
1.
On January 12, 2016, the defendant, through Undersigned Counsel, filed a Motion for
Discovery and Inspection, a Brady Motion, and a Motion for Bill of Particulars.
2.
The State of Louisiana filed on February 3, 2016, the States Answer to Motions for
Discovery, Inspection and Bill of Particulars and States Motion for Discovery and Other PreTrial Notices.
3.
The State of Louisiana has failed to provide to defendant, NORRIS GREENHOUSE,
JR. a Bill of Particulars.
4.
Since the time of these filings, the State of Louisiana has tendered to Undersigned
Counsel hundreds of pages of documents via written discovery, derived from two separate flash
drives given to defense counsel on two separate occasions.
5.

Defendant through, Undersigned Counsel, contends that the short-form Grand Jury
Indictment is insufficient to inform the defendant, NORRIS GREENHOUSE, JR. adequately
of the allegations made against him by the State of Louisiana. (see attachment A - Grand Jury
Indictment)
6.
When a defendant has been charged by an information or indictment which follows the
short form, he has a right, after proper motion, to a bill of particulars. State v. Miller, Sup.1975,
319 So.2d 339. As stated by Louisiana jurisprudence, the purpose of permitting a bill of
particulars where a short-form indictment is used is to fully protect the accused, indicted under
such form, in his constitutional right to be informed of nature and cause of accusation against
him. State v. Barnes, Sup.1961, 242 La. 102, 134 So.2d 890.
7.
Both the State of Louisiana and Undersigned Counsel are well aware of the facts in this
case. Undersigned Counsel believes that all parties now have a clear understanding of the
ballistics, firearm patterns, etc.
8.
Based on the facts now known by the defense, a detailed Bill of Particulars should be
furnished by the State of Louisiana, specifying under what theory of law the State intends to
prosecute the defendant and detailing the nature, cause, and facts that form the basis of the
alleged charges against NORRIS GREENOUSE, JR.
9.
The defendant, NORRIS GREENHOUSE, JR., through Undersigned Counsel hereby
requests an order from this Honorable Court compelling the State of Louisiana to answer the
defendants Bill of Particulars with specificity and in writing as to their theory of prosecution in
charging NORRIS GREENHOUSE, JR. for the crimes of Second Degree Murder and
Attempted Second Degree Murder.

WHEREFORE, DEFENDANT prays that this Honorable Court order the State of
Louisiana to show cause why the defendant should not be furnished with the particulars requested
herein.

RESPECTFULLY SUBMITTED,
HIGGINS LAW OFFICE

BY:______________________________
GEORGE L. HIGGINS, III
Louisiana Bar Roll No. 06872
Post Office Box 3370
Pineville, Louisiana 71361-3370
(318) 473-4250
ATTORNEY FOR DEFENDANT
NORRIS GREENHOUSE, JR.

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CERTIFICATE

I HEREBY CERTIFY that a true and correct copy the above and foregoing Motion has
been sent to Mr. Jonathan Blake at the Louisiana Attorney Generals Office, by placing a copy
of same in the United States Mail this

day of July, 2016.

________________________________________
GEORGE LEWIS HIGGINS, III

CRIMINAL DOCKET NUMBER: 190,764-B

DIVISION B
12TH JUDICIAL DISTRICT COURT
PARISH OF AVOYELLES
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STATE OF LOUISIANA
VERSUS
NORRIS GREENHOUSE, JR.
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FILED:______________________________: ______________________________DY.CLK.

ORDER
The above and foregoing Motion considered:

IT IS ORDERED BY THIS HONORABLE COURT:

That a hearing be conducted on the _____ day of________________, 20

, at ____

o'clock ___.M., as to whether or not the States answer to the defendants Bill of Particulars has
been satisfied.

THUS DONE AND SIGNED at Marksville, Avoyelles Parish, Louisiana, on this

_______day of July, 2016.

___________________________________________________________
JUDGE - 12TH JUDICIAL DISTRICT COURT