IN THE FIFTIETH JUDICIAL DISTRICT, PARISH OF PEINE DE MORT
STATE OF LOUISIANA
No. _____

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STATE OF LOUISIANA, Plaintiff
v.
JOHN CLIENT, Defendant

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NOTICE OF INTENTION TO USE
PRIOR STATEMENTS OF GOVERNMENT
REPRESENTATIVES AS SUBSTANTIVE EVIDENCE IN THIS CASE

COMES NOW, JOHN CLIENT, by counsel, and moves this Court pursuant to the Fourth, Fifth, Sixth, Eighth and Fourteenth Amendments to the United States Constitution, and Article 1, Sections 2, 3, 5, 13, 14, 16 & 17 of the Louisiana Constitution to use prior statements of government representatives as substantive evidence in this case. In support of his motion, Mr. CLIENT states as follows:
1. Mr. CLIENT hereby gives the prosecution notice that he may very well use different statements made by government representatives in different cases as substantive evidence in this case. As the Mississippi Supreme Court has held, the rules of evidence allow "'the evidentiary use against' the state 'of a[ prosecuting] attorney's seemingly inconsistent statement at an earlier trial' against a co-indictee. . . .'" Hoover v. State, 552 So. 2d 834, 839 (Miss. 1989) (quoting United States v. McKeon, 738 F.2d 26, 30 (2d Cir. 1984)). The same is obviously true of prior statements used in a trial against the individual himself or herself.
WHEREFORE, Mr. CLIENT gives notice of his intent to use prior statements of various government representatives as substantive evidence in this case.
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