Blake Dubroc (first row, second from left) and a few of his family and friends are the only five (5) people in attendance at the January 6, 2022 SMPG Zoning Commission meeting to lift hands opposing any “bailing of hay by farmer Billy Broussard.”
While the St. Martin Parish Government (SMPG) and Billy Broussard largely sleepwalked through the March 2, 2022 Council meeting during which Broussard’s zoning application was denied, the fireworks started almost immediately thereafter.
The next day, Thursday, March 3, 2022, the two sides exchanged the filing and/or serving of legal documents to one another in their ongoing legal battle. Specifically, and not unexpectedly, the SMPG filed this petition to reset a date for Preliminary/Permanent Injunction. What may not have been expected is that Broussard would serve SMPG with this First Set of Interrogatories and this First Set of Requests for Admissions of Fact.
Having looked over each document served upon SMPG by Broussard, we found Request for Admission of Fact Number Twenty-Seven (27) to be the most intriguing of all. Here’s that specific request Broussard makes of SMPG:
REQUEST FOR ADMISSION NUMBER TWENTY-SEVEN:
Please admit that, upon permission being sought and granted by Defendant, Plaintiff did haul its own debris to Defendant’s property at 1676 (sic) Duchamp Road, Broussard, Louisiana 70518 on the following dates and at the approximate times of:
1. February 22, 2022 at 11:33 a.m.
2. February 22, 2022 at 12:00 noon.
3. February 23, 2022 at 1:02 p.m.
4. February 24, 2022 at 8:51 a.m.
5. February 24, 2022 at 9:17 a.m.
6. February 24, 2022 at 11:27 a.m.
7. February 24, 2022 at 12:59 p.m.
8. February 24, 2022 at 1:24 p.m.
9. February 24, 2022 at 1:47 p.m.
10. February 24, 2022 at 2:17 p.m.
11. March 2, 2022 at 10:16 a.m.
12. March 2, 2022 at 11:14 a.m.
We believe it will be difficult for SMPG officials to attempt to deny those loads were hauled in by SMPG officials and dumped onto Broussard’s property given that Broussard has time-and-date-stamped video pictures of the activity. Furthermore, for the record, there were actually two (2) loads subsequent to # 12 listed above, one of which (# 13) took place on Wednesday, March 2, 2022 at 11:47 p.m. and the other (# 14) took place on Wednesday, March 2, 2022 at at 12:27 p.m. What the heck, let’s go ahead and provide the evidence of those hauls, shall we?
So, here’s what we have: 2 1/2 hours prior to convening a Council meeting to deny Broussard an application to haul in debris, SMPG is engaging in that very activity itself! Nobody can make this stuff up, folks!
So, what’s the legal impact of SMPG’s flaunting its own ability to haul in debris vs. telling the property owner, Broussard, that he cannot? Well, the first thing that came to our minds is the Doctrine of Unclean Hands. Essentially, the Doctrine says that, if one initiates action against another party, the one initiating the action cannot come into court with illegalities of its own. As we’ll demonstrate shortly, SMPG has indicated Broussard’s “acts are unlawful.” We’ll be curious to see how SMPG asserts Broussard’s acts are “unlawful,” and maintain with a straight face that their own identical acts are somehow “lawful.” Importantly, from the link above:
The unclean hands doctrine typically applies only to equitable claims such as requests for injunctive relief or specific performance…….
Well, SMPG has unquestionably made a “request for injunctive relief,” so it sure looks to us like the Doctrine of Unclean Hands ought to be exploited by any attorney representing Broussard!
Now, Broussard certainly (in what appeared to us to be reding from notes likely prepared by an attorney) informed the Council that he’d agreed to let them haul materials to his property (see from the 2:42 – 2:59 mark of the video just linked) at the sleepwalking March 2, 2022 Parish Council meeting, let everyone in the room know that SMPG officials had been hauling in its debris to his property. Now, we have little doubt this came as a shock to more than a few Council members; however, as we indicated in the March 2, 2022 Council meeting link above, that meeting was a pre-planned dog-and-pony show.
The episode had been carefully rehearsed and scripted prior to the meeting. Furthermore, since the Council never provided notice of any intent to enter into Executive Session nor appropriately call for a vote to enter into Executive Session, which they could have done given the litigation that exists, it’s a virtual certainly that the Council Members blatantly violated Louisiana’s Open Meetings laws in scripting the dog-and-pony show.
That fact notwithstanding, and notwithstanding the fact that Council Chairman Tauzin managed to botch badly the script when he sought a motion, nobody could say a word when Broussard referenced SMPG hauling in debris to his site because they’d been pre-programmed to sleepwalk through that segment of the meeting and not to say one word!
Now, things didn’t stop with the filing for injunctive relief on Thursday, March 3, 2022. The next day, Friday, March 4, 2022 at around 5 p.m., Broussard neighbor Blake Dubroc called the SMPG Sheriff’s Office and indicated that Broussard was in violation of a Temporary Restraining Order which Dubroc told the Sheriff’s Office had been signed by a judge the day before.
St. Martin Parish Sheriff deputies showed up on the scene. After spending a few minutes on the property, Deputy Romero allegedly asked Broussard if he owned the property, to which Broussard responded that he did. He then allegedly indicated that he didn’t see where the problem lies. He allegedly stated, “If you own this property, why can’t you haul in debris if you own the property?” Broussard indicated that the SMPG had filed a restraining order restricting him from doing so.
After first indicating that such an action seemed “silly,” Romero allegedly indicated, “That’s a civil matter. It’s not a criminal matter.” Romero then inquired of Broussard whether he’d been served with the restraining order at that point. Broussard indicated that he had not, to which Romero allegedly stated, “Once you are served, read what it says and adhere to it.” With that, Romero was on his way. He did indicate to Broussard, however, that his supervisor, Sgt. Johnson, was working on the matter and attempting to contact SMPG officials.
Broussard permitted a few minutes to go by, then he reached out to speak with Sgt. Johnson. In that phone call, Johnson states that SMPG officials did in fact tell him that Broussard is totally barred from going to his own property! Let’s take a listen in on that phone call, shall we?:
March 4, 2022 telephone call between St. Martin Parish Sgt. Johnson and farmer Billy Broussard during which Sgt. Johnson indicates that SMPG officials indicated Broussard is banned from setting foot on his own property.
Now, near the end of that phone call, Broussard references his neighbor, Blake Dubroc, whom Broussard indicates has clear animus toward Broussard. Broussard indicates Dubroc has been arrested numerous times entailing the St. Martin Parish Sheriff. Let’s take a moment to refresh everyone’s memory entailing Dubroc’s past escapades, shall we?:
|Date of Dubroc Event and Notation of Criminal or Civil Matter||Nature of Dubroc Event|
|March 15, 2001 - Civil||Marcus Andrus: alleged redhibitory defect on auto sold (also claimed Dubroc sought to “backdate extended service agreement” to which Andrus responded: “I want no part of your illegal and fraudulent scheme.”)|
|June 26, 2001 - Criminal||Disturbing the peace while intoxicated.|
|June 19, 2004 - Criminal.||Refusing to leave a bar at the required closing time.|
|September 2, 2004 - Criminal.||Simple assault and battery.|
|October 13, 2004 - Criminal||Illegal burning (only specifies "solid waste").|
|November 3, 2004 - Criminal.||Not leaving bar at required 2 a.m.. closing time (arrested due to other outstanding warrant(s)).|
|March 9, 2005 - Civil.||Files restraining order against his wife, Melissa.|
|April 25, 2005 - Civil.||Iberia Bank files suit for unpaid credit card ($7,600).|
|April 29, 2005 - Civil.||Ideal Auto Sales, $1,000 worth of auto work allegedly performed, $500 payment made, after which stop-payment immediately issued.|
|June 10, 2005 - Civil.||Harley Davidson files suit for unpaid note on motorcycle ($11,200).|
|August 12, 2005 - Civil.||His wife Melissa files restraining order against her husband, Blake.|
|February 21, 2006 - Criminal.||Felony charge of assault with a firearm. On 11/13/08, DA case nolle prossed (not prosecuted). SMPG President Cedars, who was Assistant DA at the time, likely made the call NOT to prosecute Dubroc!|
|March 15, 2007 - Civil.||Garnishment filed on 4/29/05 entry above.|
|July 15, 2008 - Civil.||Jessica Broussard affidavit for alleged $2,500 in “car repair work.” (Answer filed denying and that was that).|
|June 15, 2009 - Civil.||Bank of America, Garnishment & Executory Judgment from Lafayette Parish, ($23,800).|
|March 16, 2019 - Civil.||Filed TRO against then-son-in-law (who lived with Dubroc’s daughter in a mobile home behind his house) allegedly engaged in harassment and that son-in-law “blocked access to and from the used car lot.”|
Broussard met the next morning, Saturday, March 5, 2022 with St. Martin Parish Deputy Toups for purposes of obtaining a complaint form to file against Dubroc for him (Dubroc) having allegedly, “dumped trash at the back of my (Broussard’s) property.”
That conversation was also quite interesting, and obviously the St. Martin Parish deputies are very supportive and empathetic to Broussard’s plight. Let’s listen in on how that conversation went:
March 5, 2022 face-to-face meeting between farmer Billy Broussard and St. Martin Parish Deputy Toups regarding Broussard obtaining the paperwork to file a complaint against Dubroc for the alledged act of, “dumping trash on my property.”
Now, we have previously indicated that the St. Martin Parish Zoning meeting of January 6, 2022 was a step down from a Jerry Springer episode. The conduct and content of that meeting is inexcusable for any governmental officials to have engaged in, and we have tried to spare residents of St. Martin Parish from being embarrassed by the conduct of some of its officials.
Nevertheless, we feel compelled to present an 11-second episode of the meeting in order to further demonstrate the animus that Dubroc has for Broussard. During the meeting, Parish Attorney Allan “Sprinky” Durand, who, in our opinion, had absolutely no business WHATSOEVER posing this question to the audience (but it goes to our “Jerry Springer” commentary), asked the entire audience to demonstrate by show of hands, who all was opposed to Broussard “bailing hay” on his property. First, NO, that is NOT a joke!! The result: Only Dubroc and his friends and/or family members raised their hands (and a total of five hands rose). Here’s the 11-second segment of that kangaroo zoning commission meeting:
Dubroc makes it clear he opposes Broussard bailing hay by being almost alone (except for his family and friends) to raise his hand in opposition to Broussard bailing hay when Parish Attorney Allan “Sprinky” Durand asked for a show of hands.
We have evidence to suggest that Broussard isn’t the only neighbor with whom Dubroc has animus. As Broussard mentions in the second audio above, they both have some Laotian neighbors. That’s an Asian nationality from a country located adjacent to Thailand.
The Dubrocs allegedly texted those Laotian neighbors the following two texts, the first of which is a lady screaming (as the Laotian neighbors drive on a servitude which they have legally acquired to get to their property), “That’s when you get a bomb and you just throw it in front the damn car!” A male voice immediately responds that, “You get a bunch of nails and tacks all over that road.” Here’s that video allegedly sent as a text message to those Laotian neighbors:
Video file of a threatening action allegedly sent by a relative of Dubroc to one of the Laotian neighbors soon after they legally drove down a servitude to go to property they own.
There was yet another text allegedly sent soon thereafter. On it, a very young man is heard bragging about having, “chased after them with a hammer.” Let’s take a look at the video from that text, shall we?:
Another video file sent to the Laotian neighbors wherein one young man brags of having, “chased after them with a hammer in my hand.”
Just our opinion here, but we believe the sending of those texts given their threatening words, needs to be investigated as a hate crime. We have seen numerous headlines over the last several years about hate crimes committed against Asian residents in the United States and, if substantiated that those texts were in fact sent to the Laotians, and the sending of them doesn’t constitute hate crimes, then such acts certainly should qualify as hate crimes.
As Broussard mentions in the second audio file above, Dubroc allegedly went to the center of the road and gave Broussard, with his oldest daughter riding with him in his vehicle, the “middle finger salute” using both hands earlier this week.
We want to reemphasize that Dubroc, along with LSP Trooper Scott Lopez, on whom we continue to await the fulfillment of a public records request of LSP to examine his entire personnel file, are SMPG’s star witnesses in their litigation against Broussard. We want to also again emphasize that Lopez specifically recruited Dubroc to assist him in efforts to shut down Broussard’s farming operations!
As we stated at the January 6, 2022 Planning Commission meeting, we were very disappointed not to be able to attend the September 14, 2021 hearing to convert what several attorneys whom we KNOW to be very, very bright have characterized as a “flatly illegal” restraining order to a preliminary injunction. Even as anticipatorily as we looked forward to that hearing, we are even more looking forward to the upcoming one for the brand new TRO filed on Thursday, March 3, 2022.
In conclusion, everyone will recall the fact that we indicated that we would not hire the Gibson Law firm nor Michael Adley to represent us over a matter as trivial as “two pieces of bubble gum.” We made that statement due to Adley and his firm agreeing to go along with this whole Jerry Springer extended drama when he certainly should have seen the depths to which Parish President Chester Cedars would stoop by even relying upon someone like Dubroc as his star player in this saga. The fact that Adley didn’t go ahead and punch the ball over the goal line when he had that chance on September 14, 2021 is, at least in our minds (and we might add in the minds of several highly-knowledgeable attorneys whom we spoke with on the matter), inexcusable.
Likewise, we would certainly not hire St. Martin Parish attorney Lee Durio. Let’s take just a few moments to dissect some of the elements of his filings linked above:
St. Martin Parish Government sent a Cease-and-Desist Letter to Defendant on or about July 21, 2021, through undersigned counsel.
It’s a good thing he stated “on or about July 21, 2021,” because the letter, which he admits he drafted, is dated JUNE 21, 2021! That sort of rank sloppiness is absolutely inexcusable! Of course, one may argue the little “slip” on the month may be an attempt to help protect Lopez since Lopez’s texts to Calder Hebert had this mysterious gap from mid June of 2021 to “July 29, 2021.” We’ll assume Durio was just sloppy beyond words, but the fact remains that, had his letter been forward-dated to July 21, 2021, the timeframe of June 21, 2021 to July 21, 2021 would miraculously vanish. That would be very convenient since it seems FAR, FAR more probable than not that Lopez was “working with” Parish officials during that timeframe, and that would cause a problem for Lopez regarding what he placed on his timesheets which we’ve been in possession of for quite some time.
The requirement of proof of irreparable injury, lose, or damage, under Louisiana Civil Code of Procedure Article 3601 is dispended with in this matter because the Petitioner seeks injunctive relief because the acts sought to be enjoined are unlawful. Desselle vs. Acadian Ambulance Service Inc., 83 So. 3d 1253 (La. App. 3d Cir. 2012).
Obviously, “lose” above should be “loss,” but we can only assume that is yet more pure rank sloppiness on Durio’s part. Further, we’re going to be anxious to hear Durio argue that Broussard’s activities are “unlawful,” yet the same identical activities by SMPG officials depicted through the fourteen (14) pictures above are somehow “not unlawful.” It’s that little issue about “unclean hands” we referenced previously.
Now for some more pure rank sloppiness on Durio’s part:
The Defendant/s are opening operating a business commercial in nature in an area zoned a Stickley residential pursuant to the St. Martin Parish Code of Ordinances. Any commercial activity is Stickley prohibited.
We assume that Durio meant to insert the phrase “and/or” between “opening operating” above. Even given that edit, however, he writes “Stickley” (with a freaking capital “S”) for what should obviously be “strictly.” Further, Dubroc, again being Durio’s star witness, operates a used car lot (at which money without question changes hands whereas Broussard continues to assert that there is no commercial activity taking place on his farm and that certainly no money has changed hands entailing any farming activities in which he is engaging) immediately adjacent to Broussard’s property.
Legal experts tell us that Durio is on “extremely shaky ground” in indicating that the requirement of irreparable harm “is dispensed with,” when they assert it most certainly should not have been dispensed with in this instance and therefore the TRO is “flatly illegal.”
Given that Cedars is such a stickler for detail and pinpoint accuracy, it’s more than a little surprising that he would employ an attorney with this level of pure rank sloppiness! Then again, it may just be that Durio may need the work. After all, his Facebook page indicates that, on February 26, 2022, he was “hacked.” Computer technicians don’t come cheap just like many attorneys don’t. Well, at least Durio is making some progress. He managed to get the property address correct this time, which certainly wasn’t the case in his August, 2021 pleadings. Nevertheless, it’s obvious Durio is far from attentive to detail. Here’s another recent post on his Facebook page:
This was the day I can back from taking the Louisiana Bar Exam after being gone a week from my lil family!
We assume visitors should know to change “can” to “came.”
Having entered Southern University’s Law School in 2013 and graduating in 2016, Durio now has about five and a half (5 1/2) years of practicing law under his belt. Give him time! He’s still a relative rookie in the legal profession, and we have no doubt that, despite the rank sloppiness depicted in his pleadings above and the very questionable legal ground upon which he may be on right now in filing the Restraining Order, he’ll gradually get the hang of things! He may even likely enhance the security on his computer system to avoid future “hacks.”
We’re aware of other problems with Durio’s pleadings, but we’ll leave that for the professionals as they argue this case in court, and we certainly await producing a feature soon thereafter alerting subscribers to the outcome of that court hearing!
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