Petition for Writ of Certiorari — Elijah D. Brown, Petitioner v. United States

No. ________________

______________________________________

IN THE

SUPREME COURT OF THE UNITED STATES

______________________________________

ELIJAH D. BROWN,

Petitioner,

versus

UNITED STATES OF AMERICA,

Respondent.

__________________________________________________________________

On Petition for a Writ of Certiorari

to the United States Court of Appeals for the Fifth Circuit

__________________________________________________________________

PETITION FOR A WRIT OF CERTIORARI

__________________________________________________________________

REBECCA L. HUDSMITH

Federal Public Defender

DUSTIN C. TALBOT

Appellate Chief

Federal Public Defender’s Office

Middle and Western Districts of

Louisiana

102 Versailles Boulevard, Suite 816

Lafayette, Louisiana 70501

Telephone: (337) 262-6336

Attorney for the Petitioner

QUESTION PRESENTED

Whether the Fifth Amendment’s Due Process Clause permits a district court

to base a sentencing determination on technical and factual assertions that were

never introduced into evidence or subjected to adversarial testing, a question that has

divided the circuits?

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TABLE OF CONTENTS

QUESTION PRESENTED ........................................................................................... 1

TABLE OF CONTENTS ............................................................................................... 2

APPENDIX INDEX ...................................................................................................... 3

TABLE OF AUTHORITIES ......................................................................................... 4

OPINIONS BELOW ..................................................................................................... 5

JURISDICTION............................................................................................................. 5

STATUTORY PROVISIONS INVOLVED .................................................................... 5

STATEMENT OF THE CASE....................................................................................... 7

I.

Brown's terminal medical condition ............................................................. 7

II.

The criminal conduct and charges ................................................................ 8

III.

The sentencing proceedings .......................................................................... 9

IV.

The district court's extra-record reliance and upward variance ............... 10

V.

The Fifth Circuit decision............................................................................ 11

REASONS FOR GRANTING THE WRIT ................................................................. 13

I.

The decision below creates a square circuit split on a recurring question

of constitutional magnitude ...................................................................... 13

A.

Sister circuits prohibit reliance on extra-record information in

sentencing determinations ............................................................... 13

B.

The Fifth Circuit's decision explicitly permits outcomedeterminative reliance on extra-record speculation ........................ 14

C.

The split is acknowledged, entrenched, and demands this Court's

resolution ........................................................................................... 15

2

II.

III.

The question presented is exceptionally important and recurs frequently

.................................................................................................................. 15

A.

The constitutional question is fundamental and recurring ............ 15

B.

The question affects numerous cases and has broad practical

significance ........................................................................................ 16

This case is an ideal vehicle for resolving the circuit split ........................ 17

A.

The case presents a clean vehicle with no procedural obstacles ..... 18

B.

The human consequences demonstrate the constitutional stakes.. 19

CONCLUSION ............................................................................................................ 20

APPENDIX INDEX

Fifth Circuit order denying rehearing en banc, August 20, 2025 ....................App. 001

Fifth Circuit opinion, May 30, 2025 ..................................................................App. 002

District court judgment, April 8, 2024 ..............................................................App. 025

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TABLE OF AUTHORITIES

Holguin-Hernandez v. United States, 589 U.S. 169 (2020) ................................. 11, 18

Townsend v. Burke, 334 U.S. 736 (1948) ............................................................... 15-16

United States v. Brown, No. 24-30214, 2025 WL 1540953 (5th Cir. May 30, 2025)

(unpublished) ............................................................................................passim

United States v. Meyer, 790 F.3d 781 (8th Cir. 2015............................................ 13-14

United States v. Roy, 88 F.4th 525 (4th Cir. 2023) ............................................... 13-14

United States v. Thompson, 864 F.3d 837 (7th Cir. 2017).................................... 13-14

United States v. Tucker, 404 U.S. 443 (1972) ............................................................ 16

United States v. Warren, 720 F.3d 321 (5th Cir. 2013) ....................................... 11, 18

United States v. Watts, 519 U.S. 148 (1997) .............................................................. 16

STATUTES

U.S. Const. amend. V............................................................................................passim

18 U.S.C. § 922(o)........................................................................................................... 8

18 U.S.C. § 3553(a) ...............................................................................................passim

26 U.S.C. § 5861(d) ........................................................................................................ 8

28 U.S.C. § 1254(1) ........................................................................................................ 5

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OPINIONS BELOW

The opinion of the United States Court of Appeals for the Fifth Circuit

affirming petitioner’s conviction and sentence can be found at United States v. Brown,

No. 24-30214, 2025 WL 1540953 (5th Cir. May 30, 2025) (unpublished), and is set

forth at App. 002. The opinion of the United States Court of Appeals for the Fifth

Circuit denying rehearing en banc on August 20, 2025, can be found at App. 001.

JURISDICTION

The judgment of the court of appeals was entered on August 20, 2025. App.

001. The jurisdiction of this Court is invoked under 28 U.S.C. 1254(1).

STATUTORY PROVISIONS INVOLVED

Fifth Amendment to the United States Constitution:

No person shall be held to answer for a capital, or otherwise infamous

crime, unless on a presentment or indictment of a Grand Jury, except in

cases arising in the land or naval forces, or in the Militia, when in actual

service in time of War or public danger; nor shall any person be subject

for the same offence to be twice put in jeopardy of life or limb; nor shall

be compelled in any criminal case to be a witness against himself, nor

be deprived of life, liberty, or property, without due process of law; nor

shall private property be taken for public use, without just

compensation.

18 U.S.C. § 3553(a) (Factors to be considered in imposing a sentence):

(a) Factors to be considered in imposing a sentence.--The court shall

impose a sentence sufficient, but not greater than necessary, to comply

with the purposes set forth in paragraph (2) of this subsection. The

court, in determining the particular sentence to be imposed, shall

consider-(1) the nature and circumstances of the offense and the history and

characteristics of the defendant;

(2) the need for the sentence imposed-5

(A) to reflect the seriousness of the offense, to promote respect for

the law, and to provide just punishment for the offense;

(B) to afford adequate deterrence to criminal conduct;

(C) to protect the public from further crimes of the defendant; and

(D) to provide the defendant with needed educational or

vocational training, medical care, or other correctional treatment

in the most effective manner;

(3) the kinds of sentences available;

(4) the kinds of sentence and the sentencing range established for—

(A) the applicable category of offense committed by the applicable

category of defendant as set forth in the guidelines-(i) issued by the Sentencing Commission pursuant to section

994(a)(1) of title 28, United States Code, subject to any

amendments made to such guidelines by act of Congress

(regardless of whether such amendments have yet to be

incorporated by the Sentencing Commission into amendments

issued under section 994(p) of title 28); and

(ii) that, except as provided in section 3742(g), are in effect on

the date the defendant is sentenced; or

(B) in the case of a violation of probation or supervised release,

the applicable guidelines or policy statements issued by the

Sentencing Commission pursuant to section 994(a)(3) of title 28,

United States Code, taking into account any amendments made

to such guidelines or policy statements by act of Congress

(regardless of whether such amendments have yet to be

incorporated by the Sentencing Commission into amendments

issued under section 994(p) of title 28);

(5) any pertinent policy statement—

(A) issued by the Sentencing Commission pursuant to section

994(a)(2) of title 28, United States Code, subject to any

amendments made to such policy statement by act of Congress

(regardless of whether such amendments have yet to be

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incorporated by the Sentencing Commission into amendments

issued under section 994(p) of title 28); and

(B) that, except as provided in section 3742(g), is in effect on the

date the defendant is sentenced.

(6) the need to avoid unwarranted sentence disparities among

defendants with similar records who have been found guilty of

similar conduct; and

(7) the need to provide restitution to any victims of the offense.

STATEMENT OF THE CASE

The Petitioner Elijah D. Brown was a 24-year-old first-time offender suffering

from congestive heart failure when the court below sentenced him to an upward

variance sentence for his possession of two firearms that contained Glock switch-type

devices. That upward variance sentence, based entirely on extra-record judicial

speculation, is the subject of this appeal.

I.

Brown’s terminal medical condition

When Brown was only 19 years old, he was diagnosed with congestive heart

failure, a severe condition in which the heart does not pump blood efficiently. To treat

this life-threatening condition, Brown has been fitted with a left ventricular assist

device (LVAD) implanted in his chest and an intra-aortic balloon pump (IABP)

attached to his heart. A controller unit and battery pack are worn outside his body

and connected to the LVAD through his skin. ROA.252.

Brown’s prognosis was grim—approximately ten years to live from diagnosis.

At sentencing, several years had already passed. Brown explained to the court that

his condition had forced him to withdraw from college and that he realized “I don’t

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got long, so I need to get back in school, finish what I was doing, and just live the rest

of my life the best I can.” ROA.167.

Despite these difficulties, Brown had no criminal history—juvenile or adult—

until this case. ROA.249-50. He graduated from high school where he participated in

ROTC, worked multiple jobs, and tried to pursue higher education before his medical

condition intervened. ROA.250, 253.

II.

The criminal conduct and charges

On September 23, 2022, Shreveport Police responded to an “armed person” call.

Officers found Brown’s stepfather, Tedric Ratcliff, and another individual in a stolen

vehicle containing multiple firearms. Two of the firearms were registered to Brown:

(1) a Palmetto Arms 7.62 AR rifle with a drop-in auto sear device and (2) a Glock 19

9mm pistol with a Glock switch conversion device. Brown was located sitting on

apartment steps approximately 30 yards from the vehicle. ROA.189, 246-47.

Brown was not a prohibited person under federal firearms laws, but the

conversion devices were not registered in the National Firearms Registration and

Transfer Record as required. ROA.190. Brown was charged with two counts of illegal

possession of a machinegun under 18 U.S.C. § 922(o) and two counts of possession of

an unregistered firearm under 26 U.S.C. § 5861(d). ROA.20-21. After an unsuccessful

suppression motion, Brown pleaded guilty to one count each. ROA.81.

During the pendency of the district court proceedings, due to the seriousness

of his heart condition, Brown was transported from the Caddo Correctional Center in

Shreveport, Louisiana, to Plaquemine Parish Detention Center in Davant, Louisiana,

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to be housed closer to Ochsner LSU Medical Center in Jefferson, Louisiana, where he

was receiving ongoing treatment. This means that Brown was housed nearly 400

miles (and a nearly 6 hour drive) away from his family and where his legal case was

proceeding. While in pretrial custody, Brown suffered swollen ankles, shortness of

breath, weight loss, chest pain, and bed sores due to multiple inpatient medical

treatments over the past five years. ROA.252.

III.

The sentencing proceedings

The presentence report detailed Brown’s terminal medical condition and noted

he had no criminal history. ROA.249-50, 252. Under the Guidelines, Brown received

a total offense level of 15, yielding a guideline range of 18-24 months imprisonment.

ROA.255. The PSR noted that similarly situated defendants received an average

sentence of 14 months and a median sentence of 13 months. ROA.257. Neither the

probation office nor the government sought an upward departure or variance.

ROA.257-58. Neither party objected to the PSR or filed a sentencing memorandum.

ROA.259.

At the April 3, 2024 sentencing hearing, Brown personally addressed the court

about his terminal condition, explaining that he had approximately six years left to

live and needed a heart transplant. His counsel’s sole argument was that the court

should consider Brown's medical condition in determining the sentence. ROA.169-70.

The government made no argument regarding the appropriate sentence.

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IV.

The district court’s extra-record reliance and upward variance

The court imposed a 42-month sentence—75% above the high end of the

guidelines range. In justifying this substantial upward variance, the court made

detailed technical assertions about firearms that found no support in the record. The

court explicitly stated these technical characteristics justified the upward variance:

It is designed to send a message to other people in Shreveport who

convert ordinary firearms into automatic weapons that are, A,

inaccurate when they are fired; B, the magazines can empty within a

period of two seconds. And they are fired with the casings spread all over

everywhere wherever they’re fired. And there's no aim and there's no

control over this.

ROA.172.

The court also made broad assertions about community violence, claiming that

Brown was “part of the problem with the gun violence in Shreveport” and that “people

who have nothing to do with the encounters for which these weapons are maintained

are shot and killed.” ROA.171-72. Additionally, the court claimed that “Glock

switches are all over the place” and “drop-in auto sears 3d-printed are all over the

place.” ROA.174.

The court acknowledged that there was “no indication [Brown was] involved in

that kind of conduct” involving violence or harm to others. ROA.172. The record

contains no expert testimony, ballistics analysis, crime statistics, or other evidence

supporting any of these technical or sociological assertions. The presentence report

did not contain such information. Without these unsupported technical claims, no

basis existed in the record for any upward variance—neither the government nor

probation sought departure from the guidelines range.

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Brown’s counsel objected “to the severity of the Court’s sentence” and

immediately noticed an intent to appeal. ROA.178. Brown’s objection to the “severity

of the Court’s sentence” preserved his substantive reasonableness challenge under

Holguin-Hernandez v. United States, 589 U.S. 169, 174 (2020), which encompasses

whether the sentence gives significant weight to an irrelevant or improper factor.

United States v. Warren, 720 F.3d 321, 332 (5th Cir. 2013).

V.

The Fifth Circuit decision

On May 30, 2025, a divided panel of the Fifth Circuit affirmed Brown’s

sentence. United States v. Brown, No. 24-30214, 2025 WL 1540953 (5th Cir. May 30,

2025) (unpublished). The majority found Brown’s 42-month sentence substantively

reasonable despite being an upward variance from the 18-24 month guidelines range.

The court held that the district court properly considered Brown’s serious medical

condition (congestive heart failure requiring an LVAD device) but reasonably chose

not to give it controlling weight. App. 005-006. The majority found no error in the

district court’s reliance on general knowledge about the dangerousness of automatic

weapons and the need for deterrence in addressing gun violence in Shreveport, noting

that sentencing judges may draw upon their experience and community knowledge.

App. 006-008. The court emphasized that Brown failed to demonstrate the district

court’s statements about converted firearms were “materially untrue,” and that the

75 percent upward variance was within the range of departures previously upheld by

the Fifth Circuit. App. 007-010.

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The Honorable Judge Graves dissented and argued the sentence was

substantively unreasonable on multiple grounds, characterizing it as essentially a

“near-life sentence” for someone with limited life expectancy. App. 011. Judge Graves

contended the district court failed to adequately account for Brown’s terminal heart

condition, which should have received significant weight given his projected 6-year

remaining lifespan. App. 013-015. The dissent criticized the court for relying on facts

outside the record about gun violence and the characteristics of automatic weapons,

arguing this violated due process requirements. App. 016-018. Additionally, the

dissent emphasized troubling aspects of the case circumstances - that Brown was

found 90 feet from the vehicle, had no criminal history, and that his stepfather (with

extensive criminal history) was the actual possessor of the weapons, yet received a

lower sentence. The dissent concluded this represented a clear error in balancing the

sentencing factors and called for vacatur and remand. App. 021-024.

Brown petitioned the Fifth Circuit to rehear his case en banc and that petition

was denied on August 20, 2025. App. 001.

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REASONS FOR GRANTING THE WRIT

I.

The decision below creates a square circuit split on a recurring question of

constitutional magnitude

This case presents a clean circuit split on whether the Fifth Amendment

permits district courts to base outcome-determinative sentencing decisions on extrarecord information that has not been established through proper evidentiary

procedures. The Fourth, Seventh, and Eighth Circuits prohibit such reliance, while

the Fifth Circuit’s decision here explicitly endorses it. This conflict affects thousands

of federal sentencings annually and undermines the constitutional guarantee that no

person shall be deprived of liberty without due process of law.

A.

Sister circuits prohibit reliance on extra-record information in

sentencing determinations

The Fourth, Seventh, and Eighth Circuits have established a clear

constitutional rule distinguishing between referencing and relying on extra-record

information at sentencing. As the Fourth Circuit recently explained: “a district court

may reference information from outside the record at sentencing so long as the court

does not rely on such extrinsic information in its sentencing determination.” United

States v. Roy, 88 F.4th 525, 531 (4th Cir. 2023) (emphasis in original). The Seventh

and Eighth Circuits apply identical formulations. See United States v. Thompson,

864 F.3d 837, 842 (7th Cir. 2017); United States v. Meyer, 790 F.3d 781, 783 (8th Cir.

2015).

These circuits recognize a crucial constitutional distinction. District courts

need not feign ignorance of matters beyond the record, but when determining an

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appropriate sentence, due process requires reliance only on information subject to

adversarial testing. This rule protects defendants’ rights while preserving judicial

discretion to acknowledge context. The distinction is outcome-determinative: in Roy,

the court found constitutional error where a judge’s personal anecdotes about

fentanyl exposure drove the sentencing decision, 88 F.4th at 531; in Thompson, the

circuit prohibited reliance on undisclosed discovery materials as sentencing facts, 864

F.3d at 842; in Meyer, the court barred case-specific information from a concurrent

proceeding, 790 F.3d at 783.

B.

The Fifth Circuit’s decision explicitly permits outcome-determinative

reliance on extra-record speculation

The decision below squarely rejects this constitutional framework. The panel

majority acknowledged that the district court relied on extra-record information to

impose a substantial upward variance but found such reliance constitutionally

permissible. App. 006-008. The majority reasoned that sentencing judges may draw

upon their “experience and community knowledge” and that Brown failed to prove

the court’s technical assertions were “materially untrue.” App. 007-010. This holding

directly contradicts the rule established by sister circuits.

The panel’s approach eliminates any meaningful distinction between reference

and reliance. Under the Fifth Circuit’s framework, a district court may base outcomedeterminative sentencing increases on unsubstantiated technical claims, sociological

assertions, and personal beliefs, so long as the defendant cannot affirmatively

disprove them. This shifts the constitutional burden, permitting deprivation of liberty

based on judicial speculation rather than reliable evidence.

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C.

The split is acknowledged, entrenched, and demands this Court's

resolution

Judge Graves’s thoughtful dissent recognized the constitutional problem,

noting that the district court impermissibly relied on “facts outside the record about

gun violence and the characteristics of automatic weapons” in violation of due process

requirements. App. 016-017. The dissent’s analysis aligns with the Fourth, Seventh,

and Eighth Circuits’ approach but could not command a majority.

The en banc court’s denial of rehearing has entrenched this split. Federal

defendants facing sentencing now receive fundamentally different constitutional

protections depending on which circuit hears their case. In the Fourth, Seventh, and

Eighth Circuits, judges may not rely on extra-record speculation to impose upward

variances. In the Fifth Circuit, such reliance is explicitly permitted and may be

outcome-determinative. This conflict affects every federal sentencing and cannot be

resolved without this Court’s intervention.

II.

The question presented is exceptionally important and recurs frequently

This case raises a pure question of constitutional law that affects thousands of

federal sentencings each year and strikes at the heart of due process protections in

criminal proceedings.

A.

The constitutional question is fundamental and recurring

The Fifth Amendment’s guarantee that no person shall be deprived of liberty

without due process of law applies with full force to sentencing proceedings, where

the liberty interests at stake are substantial and the potential for arbitrary

government action is acute. This Court has long recognized that due process requires

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reliability in the information upon which sentences are based. See Townsend v.

Burke, 334 U.S. 736, 740-41 (1948) (due process violated where sentence based on

“assumptions concerning his criminal record which were materially untrue”); United

States v. Tucker, 404 U.S. 443, 447 (1972) (sentence based on unconstitutionally

obtained prior convictions violated due process).

The adversarial system depends on parties having notice of information that

will be used against them and opportunity to contest its accuracy. When courts base

sentencing determinations on extra-record speculation about technical matters

requiring expert knowledge or sociological claims amenable to empirical verification,

these fundamental protections become meaningless. The constitutional requirement

of reliability is rendered a nullity if judges may impose substantial sentence increases

based on personal beliefs rather than evidence subject to adversarial testing.

The government bears the burden of establishing aggravating sentencing facts

by a preponderance of the evidence. United States v. Watts, 519 U.S. 148, 156 (1997).

This burden cannot be satisfied by judicial assumptions or personal beliefs about

technical matters requiring expert testimony. To hold otherwise would eviscerate the

adversarial process and permit arbitrary sentencing based on individual judges’

unsubstantiated views rather than reliable evidence.

B.

The question affects numerous cases and has broad practical

significance

Federal district courts conduct approximately 60,000 criminal sentencings

annually. Every one of these proceedings implicates the question presented. The Fifth

Circuit’s framework creates a license for outcome-determinative reliance on judicial

16

speculation in any case, affecting defendants’ liberty interests and undermining

public confidence in the fairness of federal sentencing.

The impact is particularly acute in cases involving technical questions beyond

common knowledge. Firearms cases, drug cases involving chemical compositions or

potency, fraud cases involving complex financial instruments, and technology crimes

all require specialized knowledge. Under the Fifth Circuit’s approach, judges may

impose substantial sentence increases based on their personal understanding of these

technical matters without any expert testimony or evidentiary foundation.

Defendants have no opportunity to present contrary evidence or cross-examine the

basis for these beliefs.

The arbitrary nature of this system violates core due process principles.

Sentences should not depend on individual judges’ backgrounds, personal

experiences, or assumptions about technical or sociological facts. The Constitution

requires a neutral arbiter applying law to facts established through reliable

procedures, not a system where judges may base liberty-depriving decisions on

unsubstantiated speculation.

III.

This case is an ideal vehicle for resolving the circuit split

This case presents the constitutional question in its cleanest possible form, free

from procedural complications or alternative grounds for decision. The record

demonstrates a stark due process violation, and the human consequences illustrate

why the constitutional protection matters.

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A.

The case presents a clean vehicle with no procedural obstacles

The constitutional issue is squarely presented and properly preserved. Brown

timely objected to the severity of the sentence. ROA.178. This objection preserved his

substantive reasonableness challenge under Holguin-Hernandez v. United States,

589 U.S. 169, 174 (2020), which encompasses whether the sentence gives significant

weight to an irrelevant or improper factor. United States v. Warren, 720 F.3d 321,

332 (5th Cir. 2013).

The district court’s reliance on extra-record information was explicit and

outcome-determinative. The court detailed technical assertions about weapon

ballistics, claiming the firearms “empty within a period of two seconds,” are

“inaccurate when they are fired,” and have “no aim and there’s no control.” ROA.172.

The court also made broad sociological claims about community violence and the

prevalence of conversion devices. ROA.171-72, 174. The court acknowledged these

factors justified the 75 percent upward variance from the advisory guidelines range.

ROA.172-74.

No evidentiary support exists in the record for these claims. The presentence

report contains no expert testimony, ballistics analysis, or crime statistics. Neither

the probation office nor the government sought an upward variance. Without the

court’s extra-record speculation, no basis existed for any variance from the guidelines

range. The panel majority acknowledged the district court’s reliance on extra-record

information but found it constitutionally permissible, thereby squarely presenting

the question whether such reliance violates due process. App. 006-008.

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B.

The human consequences demonstrate the constitutional stakes

The facts of this case illustrate why the constitutional protection matters.

Elijah Brown was twenty-four years old at sentencing and had never before been

arrested. ROA.249-50. He suffers from congestive heart failure diagnosed when he

was nineteen. ROA.252. This terminal condition requires him to carry external

devices to keep his heart functioning, and his life expectancy is severely limited.

Despite his devastating illness, Brown had maintained his dignity and pursued

education and employment until his medical condition intervened. ROA.250, 253.

At sentencing, Brown spoke about confronting his mortality and his desire to

make the most of his remaining time. ROA.167. He explained he had approximately

six years left to live and needed to finish school and live the remainder of his life

productively. The district court acknowledged Brown's medical condition but imposed

a 42-month sentence—75 percent above the guidelines range—representing a

substantial portion of Brown's remaining life. As Judge Graves observed, this

constitutes “essentially a near-life sentence for someone with limited life expectancy.”

App. 011.

The sentence rests entirely on the district court’s unsubstantiated technical

and sociological assertions. Brown had no opportunity to present contrary expert

testimony about weapon ballistics or crime statistics. The court only disclosed its

extra-record claims after Brown had allocuted and counsel had addressed the court.

This violation of fundamental fairness resulted in Brown spending years of his

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limited remaining life in custody based on judicial speculation rather than reliable

evidence.

Moreover, the circumstances of the offense highlight the arbitrary nature of

extra-record reliance. Brown was found 90 feet from the vehicle containing the

firearms. App. 021. His stepfather, who had extensive criminal history and was the

actual possessor of the weapons, received a lower sentence despite being a prohibited

person. App. 022. These facts suggest Brown may have been constructively possessing

his own legally registered firearms that happened to have illegal conversion devices.

Yet the district court imposed a near-life sentence based on unsubstantiated claims

about the technical characteristics and societal impact of such devices.

CONCLUSION

The petition for a writ of certiorari should be granted.

Respectfully submitted this November 18, 2025,

REBECCA L. HUDSMITH

Federal Public Defender

BY:

s/ Dustin C. Talbot

DUSTIN C. TALBOT

Appellate Chief

Federal Public Defender’s Office

Middle and Western Districts of Louisiana

102 Versailles Boulevard, Suite 816

Lafayette, Louisiana 70501

Telephone: (337) 262-6336

Attorney for the Petitioner

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