Michel Jackson Miller, Individually and as Natural Tutrix of her minor son VS The State of Louisiana Department of Corrections, Rodney Strain, Sheriff of the Parish of St. Tammany, Northshore Workforce, L.L.C., Victory Bible Church, A Louisiana Religious Corporation

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STATE OF LOUISIANA COURT OF APPEAL, FIRST CIRCUIT MICHEL JACKSON MILLER, INDIVIDUALLY, AND TUTRIX MINOR OF HER AS NO. 2020 CW PAGE 1 2 NATURAL OF 0772 SON VERSUS THE STATE OF DEPARTMENT RODNEY THE LOUISIANA OF CORRECTIONS, SHERIFF STRAIN, PARISH OF NORTHSHORE ST. OF TAMMANY, OCTOBER 26, WORKFORCE, L. L. C., VICTORY CHURCH, A 2020 BIBLE LOUISIANA RELIGIOUS CORPORATION In Northshore Re: 22nd writs, BEFORE: WRIT L. L. C., Workforce, Judicial for applying District Court, supervisory Parish of St. 201511850. Tammany, No. WHIPPLE, C. J., WELCH AND CHUTZ, JJ. DENIED. VGW WRC Welch, trial natural tutrix for trial as motion 2) and ( new the after judgment filed the plaintiff the hearing warranted by these the find the diligence lead that the that motion testimony to for is additional See Development, Finally, locate that to from to the new and clearly to Article key This on the the State, v. extent the La. Next, Department trial court the of 800 relied 1, 8- 9 plaintiff asserted establish was clearly fails. When that evidence, hearing on a the no the Transportation & So. 2d on Estates, and contention at 11/ 28/ 01), the motion the these reasonable will and hearing So - 3d is 1972( 1) law no locate 300 argument one is exercised that witnesses" contrary be presented may 2001- 0961 ( the based she to witnesses. Wadsworth all Northshore' s evidence. is trial Rivet new " granting law evidence the do the these timely v. evidence.) minimally sent of was efforts There 2/ 26/ 20) , Cir. to pursuant judgment judgment motion. to party a the of mail after trial new hearing and establish 1st that a continuance attempting App. discovery trial new the contrary La. requires the to for moved to in a her First, Plaintiff' s the See Beverly Construction L. L. C. 2019- 0911 ( L. L. C., for summary located undeliverable." enable failed diligence to for L. L. C. were a 1972( 1) art. motion that searches moved to P. Workforce, such prior returned " motion the disagree. I internet plaintiff due witnesses. to the filed plaintiff Civ. witnesses" motion 1972( 2). plaintiff Code granted key witnesses was Northshore' s requisite that " Article that Due find I writ. The son. La. to Northshore Northshore' s on witness I the grant minor court relator, unsuccessful indication her of trial included on would pursuant asserted per locate to and court abused its discretion by granting the motion for new filed by plaintiff, Michel Jackson Miller, individually trial and dissents J., 777, argument of 781. STATE OF LOUISIANA COURT OF APPEAL, FIRST CIRCUIT Northshore' was Tour 12/ Cir. COURT for OF new FOR CL court' s RK THE FIRST O COURT COURT Larre, 738. judgment CIRCUIT La. matter v. 735, So. 3d trial. APPEAL, DEPUTY 267 18), trial the reverse motion 6/ no L. L. C. to I 2020 CW PAGE 2 2 OF judgment the judgment, pursuant counsel, of Holdings, in error summary discretion of Argument evidence. for motion abuse an 1973. 1st s find to counsel plaintiff' s NO. Code how Civ. artful, 2018- 0503 ( Consequently, granting the granting find likewise 0772 P. is La. I this art. not App. would plaintiff' s

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