SCARLETT A. MARTIN CIVIL DOCKET NO. 656513; SEC.

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VS. 19rn JUDICIAL DISTRICT COURT

JEFF LANDRY, IN HIS OFFICIAL PARISH OF EAST BATON ROUGE

CAPACITY AS ATTORNEY GENERAL
OF THE STATE OF LOUISIANA STATE OF LOUISIANA

DEFENDANT'S SECOND MOTION IN LIMINE

AND INCORPORATED MEMORANDUM IN SUPPORT

MAY IT PLEASE THE COURT:

NOW INTO COURT, through undersigned counsel, comes Defendant Jeff Landry, in his

official capacity as Attorney General of the State of Louisiana, who files a motion in limine related

to potential witnesses that were former Information Technology (IT) employees that were

terminated from the Department of Justice, including but not limited to Etienne Carriere and

Rindus Pittman, and any documents produced or introduced by Plaintiff, originating from or

printed out by former IT employees (such as Exhibit A to the Plaintiffs "Supplemental

Memorandum in Opposition to Motion to Quash Subpoenas"1) for the reasons discussed below:

1. The Plaintiff was late in disclosing Etienne Carriere and Rindus Pittman as witnesses.

These individuals were not disclosed until December of 2018, well after the trial date

for this matter had been set and leaving no time for depositions or discovery related to

these witnesses.

2. Any emails produced by the Plaintiff or introduced as an exhibit by the Plaintiff that

were printed out by Etienne Carriere or former IT employees, such as the Exhibit A to

the Plaintiffs Supplemental Memorandum, are subject to the attorney-client 2rivilege.

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A former IT employee cannot waive a privilege that belongs to the Attorney General

or the Department of Justice. This office has reason to believe that doct1111�J}ts were

surreptitiously removed from th� J\,tt9i:ney General's offi.�e,

3. IT employees execute confidentiality agreements that prohibit them from talking about

matters they work on at the Attorney General's office. For example, Mr. Caniere

signed two confidentiality agreements. By providing testimony in this matter about

work he performed during the course of this litigation or by printing out documents and

providing them to Plaintiffs counsel, the agreements would be violated. This

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Defendant's maintain the position that the Plaintiff has no right to file a supplemental memorandum in opposition to
a motion to quash without seeking leave of court. This pleading is improper and should be stricken from the record.