MATTHEW THOMASSEE VERSUS LAFAYETTE PARISH SHERIFF’S OFFICE, MICHAEL NEUSTROM, individually and as Sheriff, ROB REARDON, individually and as Director of Corrections, DEPUT(IES) JOHN DOE, individually and as Deputy Sheriff(s), XYZ INSURANCE COMPANY, Defendants

CIVIL DOCKET NO. 2011-2573G 15TH JUDICIAL DISTRICT COURT PARISH OF LAFAYETTE STATE OF LOUISIANA JURY TRIAL REQUESTED

PLAINTIFF’S FIRST AMENDED PETITION FOR DAMAGES

The petition of MATTHEW THOMASSEE (hereinafter referred to as “petitioner”), a person

of the full age of majority, and a resident of Youngsville, Lafayette Parish, Louisiana, respectfully

submits to this Honorable Court his first amended petition, accordingly:

1.

Made defendants herein are:

A. LAFAYETTE PARISH SHERIFF’S OFFICE, a political subdivision duly organized

and existing under the laws of the State of Louisiana and the Parish of Lafayette.

B. SHERIFF MICHAEL W. NEUSTROM, an individual of full age of majority,

resident and domiciliary of the Parish of Lafayette, State of Louisiana. Upon

information and belief, Michael Neustrom was the duly elected Sheriff of Lafayette

Parish and was serving in that capacity at the time of the events out of which this action

arises. This action is brought against Michael Neustrom individually and in his official

capacity as Sheriff of Lafayette Parish.

C. ROB REARDON, based upon information and belief, an individual of full age of

majority, resident and domiciliary of the Parish of Lafayette, State of Louisiana. This

action is brought against Rob Reardon individually and in his official capacity as

Director of Corrections for the Lafayette Parish Sheriff’s Office.

D. JOHN DOE, based upon information and belief, an/all individual(s) of full age of

majority, resident(s) and domiciliary(ies) of the Parish of Lafayette, State of Louisiana.

This action is brought against Deputy(ies) John Doe in both his/their individual and

official capacities. The petitioner reserves their right to supplement and amend their

Petition once the true identity(ies) of any other party(ies) involved is/are ascertained.

E. XYZ INSURANCE COMPANY, an unknown insurance company, duly licensed and

doing business in the Parish of Lafayette, State of Louisiana, and providing insurance

coverage for the acts and/or omissions of the defendants.

2.

The petitioner shows the he was hired by the Lafayette Parish Sheriff’s Office on July

28, 1999.

3.

The petitioner shows that prior to May 7, 2010 his personnel folder did not

contain any evidence of any employee misconduct or performance deficiencies.

4.

The petitioner shows that his annual performance evaluations have never

indicated any employee misconduct or performance deficiencies.

5.

The petitioner shows that he served as a supervisor with the Lafayette Parish

Sheriff’s Office from December 3, 2001 until May 7, 2010.

6.

The petitioner shows that he served as the Accreditation Manager for the

Lafayette Parish Correctional Center from October 1, 2004 until June 30, 2008.

7.

Upon information and belief, sometime between September 16, 2004 and May 5,

2005 the petitioner believes Rob Reardon may have committed a violation when he

witnessed him sign a document entitled “Staffing, Space, Equipment Assessment

Review” dating it January 6, 2003. Deputy Brian McCarley presented the document to

Director Reardon at which time Director Reardon stated ‘did I do this? I don’t remember

doing this.’ Deputy McCarley responded by saying ‘It is needed for the A.C.A. files.’

Director Reardon remarked ‘well in that case’, signed the document and handed it to

Deputy McCarley. Lafayette Parish Correctional Center Policy – 01-0100 Facility

Administrator required an annual review of staffing, space and equipment in order to

demonstrate compliance with American Correctional Association (A.C.A.) standards.

8.

The petitioner shows that on or about January 25, 2008 he reported by e-mail

employee misconduct by Sgt. Sonia Guilbeau to Director Rob Reardon, Capt. Mike

Rules, Lt. Cher Holland, Lt. Freddie Laque, Lt. Joseph Miller, Jr. and Lt. William

LeFevre. The e-mail message contained an attachment of scanned images of what the

petitioner believes was more forged documents. Upon information and belief, an

administrative investigation into the alleged misconduct was not conducted, a criminal

investigation into the alleged illegal activities was not conducted and Sgt. Guilbeau did

not receive disciplinary action.

9.

The petitioner shows that between January of 2010 and March of 2010 he was

asked on several occasions by Rob Reardon to purchase a ticket to the Sheriff’s Steak

Dinner Election Campaign fundraiser while at work with the Lafayette Parish Sheriff’s

Office. Rob Reardon solicited contributions from Corrections Supervisors during a

monthly staff meeting. Rob Reardon, while in the office and presence of Capt. Myra

Mouton asked the petitioner to contribute and the petitioner refused. Rob Reardon

approached the petitioner while in the office he shared with Sgt. Gregory Mitchell and in

his presence and asked the petitioner to contribute. The petitioner stated that he would

‘think about it’. Rob Reardon responded ‘you better think about it.’

10.

The petitioner shows that on or about March 15, 2010 the plaintiff was

interviewed by Sergeant Kevern Stoute, investigator for the Lafayette Parish Sheriff’s

Office - Internal Affairs section, in reference to an internal investigation (I.A. Case # 10-

06) regarding the falsification of documents at the Lafayette Parish Correctional Center.

Based on information and believe the investigation was a result of allegations indicating

that Lt. Michael Carriere had instructed Deputy John Lapointe and Deputy Lawrence

Mossier to alter documents so that they would be in compliance with A.C.A. standards.

During that interview the petitioner informed Sgt. Stoute that he was aware of individuals

that had falsified documents at the agency in the past. Sgt. Stoute did not question the

petitioner regarding the identity of those individuals. The incident was not forwarded to

an impartial agency for investigation and criminal prosecution.

11.

Upon information and belief, on or about March 25, 2010 Captain Myra Mouton

contacted the petitioner while he was off-duty and advised him that Lt. Michael Carriere

was being re-assigned from Shift Lieutenant of Security Shift A to a newly created

position of Video Visitation Lieutenant following the conclusion of an internal

investigation regarding the possible falsification of records at the Lafayette Parish

Correctional Center. Capt. Mouton advised the petitioner that he would need to meet with

Lt. Carriere and provide him with information regarding the operation of the Video

Visitation Center. Capt. Mouton advised the petitioner that although Lt. Carriere would

be overseeing the video visitation center his main job duties would consist of conducting

foot patrols of the premises and issuing parking citations to parking violators around the

compound. The petitioner expressed to Capt. Mouton his disappointment in the

disciplinary sanctions taken and the lack of a thorough investigation into others

employees who may have falsified records. The petitioner informed Capt. Mouton of his

intention to notify outside sources of those acts which petitioner believed could have

possibly been illegal.

12.

Upon information and belief, on April 21, 2010 the petitioner was called to

provide a statement in an internal affairs investigation (I.A. Case # 10-36) regarding the

alleged falsification of records at the Lafayette Parish Correctional Center. The petitioner

met with Lt. Todd Credeur on the second floor of the Lafayette Parish Sheriff’s Office

Administrative Building and was escorted to a criminal investigation

interview/interrogation room. Prior to the interview the petitioner asked Lt. Credeur who

would be on the board reviewing the case. Lt. Credeur stated that Rob Reardon and other

division heads would likely be selected to review the investigation. The petitioner

informed Lt. Credeur of his belief that Rob Reardon may have falsified records at the

Lafayette Parish Correctional Center. The petitioner advised Lt. Credeur of his fear that

reprisals would be taken against him if he were required to make that statement on the

record and Rob Reardon were allowed to review that statement. The petitioner advised

Lt. Credeur that he could produce a copy of one document that he believed Director

Reardon may have falsified. Lt. Credeur advised the petitioner that due to the length of

time that had passed it would be hard to investigate. Lt. Credeur advised the petitioner

that he was not under investigation in this matter, that he needed to be honest about

everything and that he had received advanced approval from the Sheriff to polygraph any

employee suspected of lying to him. A taped interview was conducted and during that

interview Lt. Credeur made several inquiries into the petitioners work habits while

serving in the capacity of Corrections Accreditation Manager and his personal

relationship with co-worker Captain Myra Mouton. During the taped statement Lt.

Credeur did not make any inquiry into the matter concerning whether or not Rob Reardon

had falsified documents despite the petitioner previously reporting the misconduct to him.

Prior to the end of the interview the petitioner again advised Lt. Credeur of his belief that

Director Reardon may have falsified records and advised him that he had concerns about

reprisals being taken against him. Upon information and belief, the petitioner had

previously informed Capt. Myra Mouton, Lt. Cher Holland and Sgt. Greg Mitchell on his

belief that Rob Reardon may have falsified documents and believes that Lt. Credeur may

have already been aware of this information prior to the interview.

13.

The petitioner shows that at the time of his statement to Lt. Credeur the Lafayette

Parish Sheriff’s Office had in effect a policy; General Order #103 – Complaint Handling /

Internal Investigations which states the following:

A. “Fair and impartial investigations of all complaints” shall be conducted.

B. “All complaints against the Office and its employees will be documented

and investigated”, including “anonymous complaints”

C. “All Sheriff’s Office employees are charged with the responsibility of

courteously receiving all complaints that may be lodged against the Office

or any employee, regardless of nature.”

D. Interviews shall be conducted in the “investigation authority’s office

unless the seriousness or urgency of the allegations requires otherwise.”

E. “Each employee shall be advised in writing of the nature of the nature of

the investigation, the names of the complainants, if not anonymous”.

F. “Complaints that involve criminal violations are referred to the

appropriate investigation section with the approval of the Sheriff or his

designee” and should run “concurrent” with administrative investigations.

G. “Upon completion of the investigation and approval of the Sheriff or his

designee, the complainant shall be notified in writing of the results of the

investigation.”

The petitioner shows that these procedural guidelines were not followed. Upon

information and belief, despite the allegations made by the petitioner an administrative

investigation into the possible misconduct of Rob Reardon was never conducted. Upon

information and belief, the incident was not forwarded for criminal persecution or

investigation by impartial agency. Upon information and belief, the only inquiries made

by Lt. Credeur into the complaint of possible misconduct by the petitioner against Rob

Reardon were directed to Lt. Cher Holland. Lt. Credeur did not conduct any follow-up

with petitioner, did not request any additional details that may have been needed to

further investigate the allegations and did not ask the petitioner to produce any evidence

substantiating the allegations.

14.

The petitioner shows that on May 7, 2010 an employee review board selected by

Lt. Todd Credeur and consisting of Rob Reardon, Michael Patin and Francis Green was

impaneled to review information obtained during the course of the investigation

mentioned in paragraph 12 and to make recommendations on employee discipline.

Sheriff Michael Neustrom also participated in the decision making process. Lt. Credeur

and Jules Broussard also attended the meeting.

15.

The petitioner shows that on May 7, 2010 the plaintiff was issued a written

notification of the findings of the employee review board by Captain Jules Broussard.

Capt. Broussard informed the petitioner that he was not under investigation in this matter.

Capt. Broussard indicated that he was the disciplinary authority in this matter and stated

that the employee review board reviewing the case felt that the petitioner should be

disciplined in this matter due to a “performance of duty” violation while he was the

Accreditation Manager (October 2004 through June 2008). The petitioners discipline

consisted of demotion from the rank of Lieutenant to Deputy, re-assignment from

Corrections to Human Resources and probation for one year. The petitioner made a

verbal request to review the investigation and Capt. Broussard advised the petitioner that

his request would not be honored. The following individuals were also disciplined for

“performance of duty” violations as a result of the internal investigation and received the

following sanctions, all of which were less severe than that of which the petitioner

received even though the sanctions were for similar policy violations as said petitioner

was claimed to have violated.

A. Capt. 1– Demotion from Captain to Sergeant, re-assignment within the

Corrections Division and 365 days of probation

B. Lt. 1 – 7 days suspension, remedial training and 365 days of probation

C. Lt. 2 – 7 days suspension, remedial training and 365 days of probation

D. Lt. 3 – 7 days suspension, remedial training and 365 days of probation

E. Lt. 4 – 7 days suspension, remedial training and 365 days of probation

F. Lt. 5 – 7 days suspension, remedial training and 365 days of probation

G. Sgt. 1 – 5 days suspension, remedial training and 365 days of probation

H. Sgt. 2 – 5 days suspension, remedial training and 365 days of probation

I. Deputy 1 – letter of reprimand, remedial training and 180 days of probation

The following individual was disciplined for “unsatisfactory performance”

violations as a result of the internal investigation and received the following sanctions,

which were less severe than that of which the petitioner received even though the

sanctions were for similar policy violations as said petitioner was claimed to have

violated.

A. Lt. 6 – 4 day suspension

16.

The petitioner shows that at the time the internal affairs investigation previously

cited as being conducted the Lafayette Parish Sheriff’s Office had a policy in effect;

General Order #103 – Complaint Handling / Internal Investigations, which list

“performance of duty” violations as being “level II” offenses. Under this same policy

complaints regarding level II offenses “will be accepted up to one year after the date of

occurrence” and are punishable by a range of discipline which includes “letter of

counseling through suspension without pay, not to exceed 180 hours.” The sanctions

imposed on the petitioner were clearly outside the range of disciplined established by the

agency for the offense.

17.

The petitioner shows that on May 10, 2010 the personnel action form authorizing

his demotion and re-assignment was authorized and signed by Rob Reardon under the

authority of the Sheriff.

18.

Upon information and belief, around May of 2010 following the conclusion of

Lafayette Parish Sheriff’s Office Internal Affairs investigation #10-36 Director Reardon

and Capt. Colby Barbier conducted a review of the A.C.A. files. Those files have since

been destroyed.

19.

The petitioner shows that he was subjected to disparate treatment and of at least

ten other employees subjected to disciplinary action in the aforementioned matter, none

faced penalties as severe as him.

20.

The petitioner shows that on May 11, 2010 he filed an appeal of the disciplinary

action taken against him based on several procedural guidelines that were ignored in

deciding the discipline taken against him.

21.

The petitioner indicates that on May 17, 2010 he was summoned by Michael Patin

to meet with him in his office. Mr. Patin advised the petitioner that he needed to let go of

what happened and move on. The petitioner feels this was an effort to persuade him not

to seek a redress of grievances.

22.

The petitioner shows that on May 31, 2010, Lt. Michael Carriere was transferred

back to the position of Shift Lieutenant of Security Shift A.

23.

The petitioner shows that on June 2, 2010 he met with Lt. Todd Credeur who

provided him with an opportunity to review the disciplinary recommendations made by

Francis Green, Rob Reardon and Michael Patin. The administrative insight comments

section on the forms signed by Rob Reardon and Michael Patin were left blank and did

not provide any reasoning for the recommended disciplinary action. The administrative

insight comments section on the forms signed by Francis Green read: “Lt. Thomassee

was in charge of the ACA accreditation process between 2004 and 2008. He left over

1,100 proofs needed to complete the audit process. His position was turned over to Lt.

Holland with less than a year to complete the audit requirement. His actions or lack of

actions concerning obtaining the required proofs was evidence of incompetence, laziness

or dereliction of duty. His inability to communicate in an effective manner with other

employees regarding what proofs were required and where to obtain them was probably

one of the contributing factors in justification of other employees forging proofs.” The

petitioner had previously provided over 60 e-mail messages to Lt. Todd Credeur for

inclusion in the investigation case file demonstrating that monthly updates and other

communication between other managers and his supervisors was continuous and that all

parties were aware of the status of the accreditation process at all times. The petitioner

shows that the reasons provided justifying discipline being taken against him are clearly

under false pretext.

24.

The petitioner shows that on June 2, 2010 he met with Art Lebreton to discuss his

appeal. Major Lebreton indicated that he did not see a “performance of duty” violation.

He indicated the he felt the petitioner was just caught up in the “wake of another

investigation”. He stated that the appeal decision would ultimately be left to Sheriff

Neustrom and that he would be preparing a report and forwarding a copy to the Sheriff

for review. The petitioner informed Major Lebreton that he would be submitting a written

request to meet with the Sheriff before he rendered a decision in the matter.

25.

The petitioner shows that on June 2, 2010 he hand delivered a written request to

the Sheriff’s Administrative Assistant Suzanne Eason asking to meet with the Sheriff

regarding his appeal before a final decision was reached. Despite the Sheriff’s open door

policy, to date petitioner has not been afforded the opportunity to meet with Sheriff

Neustrom regarding the matter aside from the course of this litigation, nor has the Sheriff

responded or acknowledged receiving the petitioner’s request.

26.

The petitioner shows that on June 22, 2010 he met with Major Lebreton. Major

Lebreton asked the petitioner if he had the opportunity to meet with Sheriff Neustrom.

The petitioner advised Major Lebreton that he had not met with Sheriff Neustrom. Major

Lebreton delivered the final findings to the petitioner indicating that his appeal was

denied and that the discipline taken against him was going to remain the same.

27.

The petitioner shows that in or about June of 2010 an internal affairs investigation

was conducted into allegations that Lt. 7 was illegally obtaining money from the agency

through getting double compensated by working extra security details for additional

money while being compensated for his regular work time. Upon information and belief,

those incidents were not forwarded to an independent agency for investigation and

criminal prosecution by an impartial agency.

28.

Upon information and belief, on or about September 7, 2010 Sgt. 3, a Patrol

supervisor with the Lafayette Parish Sheriff’s Office, received disciplinary action for

falsifying Taser training records. Sgt. 3 did not receive penalties as severe as the

petitioner.

29.

The petitioner shows that on October 15, 2010 he was approached by Virginia

Veazey who indicated that the two Corrections Clerks positions were being eliminated

and replaced with a single deputy position entitled “A.C.A. Compliance Deputy”. Part of

the job duties for this position include: “Collect documentation for and maintain the

accreditation files.” This job duty previously was not contained in the existing A.C.A.

related job descriptions.

30.

The petitioner shows that on or about October 22, 2010 Michael Patin met with

the petitioner concerning additional assignments he wished for the petitioner to begin

performing. Mr. Patin indicated that he felt the petitioners work performance has been

"great" and several others have commented in the same manner. Mr. Patin indicated that

he was surprised with the level of cooperation the petitioner had received from others in

the performance of his job duties. Mr. Patin stated that Major Art Lebreton had spoke to

him regarding the petitioner assisting him with conducting job analysis and workload

assessments in his area. Mr. Patin stated that he did not know if the petitioner would ever

be able to return to Corrections due to Director Reardon and what had transpired. Mr.

Patin also thanked the petitioner for not harboring any resentment over the situation. Mr.

Patin indicated he would be willing to talk to the Sheriff about getting the petitioner into

another position in the future.

31.

The petitioner shows that in or about October of 2010 an administrative

investigation was conducted into the misconduct of Robert Lawrence and other

employees of the Lafayette Parish Sheriff’s Office for racing in a Patrol vehicle and

ultimately submerging it into a pond. The patrol unit received damage. The incidents

were not forwarded to an independent agency for investigation and criminal prosecution.

32.

The petitioner shows that on or about March 14, 2011 the Corrections

Accreditation section was transferred from the supervision of the Corrections Division

and Director Rob Reardon and merged with the Sheriff’s Office Accreditation Section

under the supervision of the Human Resources Division and Director Mike Patin

33.

The petitioner shows that on or about April 19, 2011 he sent letters to Sheriff

Michael Neustrom and Rene Judice, Risk Manager for the Lafayette Parish Sheriff’s

Office, attempting to resolve the dispute over the disciplinary action taken against him

without proceeding to litigation and requested to be re-instated to the rank of Lieutenant,

provided with back pay and have records of the disciplinary action removed from his

personnel folder.

34.

The petitioner shows that on April 20, 2011 Rene Judice requested to meet with

him. Mr. Judice indicated that he had received the petitioner’s letter mentioned in

paragraph 26 and had provided Sheriff Neustrom with a copy. Mr. Judice informed the

petitioner that Sheriff Nesutrom requested that he meet with him to discuss the letter.

During that conversation Mr. Judice indicated that he had been discussing with “Mike”

the possibility of the petitioner working in the Risk Management section and ultimately

replacing him eventually. Mr. Judice indicated that he didn’t think that it was going to a

possibility any longer.

35.

The petitioner shows that on or about May 10, 2011 he submitted a letter to the

Louisiana Office of the State Inspector General requesting an investigation be conducted

related to the forging of documents by members of the Lafayette Parish Sheriff’s Office

in order to deceive the A.C.A. The petitioner further explained by maintaining A.C.A.

status through deception the agency was avoiding regular audits by the Louisiana

Department of Public Safety and Corrections for compliance with the Louisiana Basic

Jail Guidelines, allowing the agency to house state prisoners and receive state funds.

36.

The petitioner shows that on or about June 5, 2011 he submitted letters to the

American Correctional Association, National Commission on Correctional Healthcare,

and Commission on Accreditation for Law Enforcement Agencies regarding the

falsification of records at the Lafayette Parish Sheriff’s Office. To date no one from the

A.C.A., N.C.C.H.C. and C.A.L.E.A. has responded or contacted the petitioner regarding

these allegations.

37.

Upon information and belief, on or about September of 2011 allegations were

made that Lieutenant 8 was illegally obtaining money from the agency through getting

double compensated by working extra security details for additional money while being

compensated for his regular work time. These incidents were not forwarded to an

independent agency for investigation and criminal prosecution.

38.

Upon information and belief, on or about October of 2011 allegations were made

that Deputy #2 had drugged and sexually assaulted a female. Previous allegations had

been made against Deputy #2 alleging that he had assaulted and held another female at

gun point. Upon information and belief, these incidents were not forwarded to an

independent agency for investigation and criminal prosecution.

39.

Upon information and belief, on or about December of 2011 allegations were

made that Deputy #3 was introducing contraband into the Lafayette Parish Correctional

Center. Deputy #3 was previously investigated regarding similar allegations. Upon

information and belief, these incidents were not forwarded to an independent agency for

investigation and criminal prosecution.

40.

The petitioner shows that on or about February 2, 2012 he submitted a letter to the

Lafayette Parish Sheriff’s Office requesting permission to inspect and obtain copies of

the three Internal Affairs cases cited above related to the falsification of records by

employees of the Lafayette Parish Sheriff’s Office. On or about February 18, 2012 the

petitioner received an unsigned and undated letter on Lafayette Parish Sheriff’s Office

letterhead indicating that his request was denied due to the files containing “confidential

data that may be harmful and could violate deputies’ privacy rights” and also “may be

privileged and not subject to Public Information Requests”.

41.

Upon information and belief, on or about May of 2012 allegations were made that

Deputy 4 had sexually assaulted a male prisoner in custody at the Lafayette Parish

Correctional Center. Upon information and belief, that incident was not forwarded to an

independent agency for investigation and criminal prosecution.

42.

The actions of the defendant caused much emotional and mental stress on the

petitioner resulting in mental injury.

43.

Upon information and belief, the defendants’ actions complained of herein were

made with malice and/or reckless indifference to the petitioner federal and state

constitutionally protected rights, constituting a violation of those rights.

44.

The misconduct alleged above occurred under color of state law.

45.

Upon information and belief, the defendant’s actions were in violation of La. R.S.

23:967 and La. R.S. 42:1169, which protect employees who in good faith report

violations of law from reprisals.

46.

At all times herein, the defendant’s were acting out of and in the course and scope

of their employment with the Lafayette Parish Sheriff’s Office thereby invoking the

doctrine of respondent superior.

47.

On the dates of these incidents, defendant Lafayette Parish Sheriff’s Office had a

policy of liability insurance with defendant, Xyz Insurance Company, which covered

them for incidents complained of herein.

48.

The petitioner declares that as a result of the adverse employment action taken

against him, the defendants are liable to him for damages which consist of the following:

A. Suffering injury to his reputation;

B. Pain and suffering;

C. Mental anguish and emotional distress;

D. Humiliation and embarrassment;

E. Inconvenience and interruption of lifestyle;

F. Loss of enjoyment of life;

G. Loss of wages; and

H. Any other particulars that may come about at a trial of this matter.

WHEREFORE, petitioner prays that the defendants be served with a certified

copy of this petition for damages and cited to answer same, and after legal delays and due

proceedings had, there be judgment rendered in favor of the petitioner and against the

defendants, for all sums that are due and as allowed by law, including all court costs,

attorney’s fees and expert fees, including legal interest thereon, until paid and for all

general and equitable relief deemed appropriate by this Honorable Court under the

circumstances.

Respectfully submitted:

L. CLAYTON BURGESS, A P.L.C. 605 West Congress Street Lafayette, Louisiana 70501 Telephone: (337) 234-7573 Facsimile: (337) 233-3890

______________________________ L. CLAYTON BURGESS (22979) Attorney for Plaintiff

Please Serve:

LAFAYETTE PARISH SHERIFF’S OFFICE Through its attorney of record Greg Guidry 1200 Camellia Boulevard, Suite 300 Lafayette, LA 70502 SHERIFF MICHAEL W. NEUSTROM Through his attorney of record Greg Guidry 1200 Camellia Boulevard, Suite 300 Lafayette, LA 70502 ROB REARDON Through his attorney of record Michael D. Skinner 600 Jefferson Street, Suite 810 Lafayette, Louisiana 70505