Hamilton II vs United States of America, Texas, & Harris County, "Request for Admission" on Harry C. Arthur Esq. et al

In The United States District Court

For the Eastern District of Texas

Beaumont Division

Louis Charles Hamilton II
(Negro African American)

Pro Se Plaintiff Case No. 1-11-CV-122

Vs.

United States of America et al,
Defendant

And

Vs.

State of Texas et al,
Co-Defendant(s)

Vs.

And
Harris County Texas et al,
Co-Defendant(s)

PLAINTIFF'S INTERROGATORIES

REQUESTS FOR ADMISSIONS AND REQUESTS FOR PRODUCTION TO

DEFENDANT, THE UNITED STATES OF AMERICA ETL

TO: The United States of America, et al,

Defendant

State of Texas et al,
Co-Defendant(s)

        And

Harris County Texas et al,
Co-Defendant(s)

Plaintiffs, pursuant to Rules 33, 34, 36, and 37 of the Federal Rules of Civil Procedure, hereby propounds the following:

 Interrogatories, Requests for Admissions and Request for Production to Defendant which are to be read and interpreted in accordance with the instructions and definitions set forth below. The answers to these Interrogatories must be signed and verified by the Defendant and a copy of the answers to Interrogatories and Responses to Admissions and Production must be served on the undersigned within thirty-five days after service of these Interrogatories and Requests.

INSTRUCTIONS

            1.  If any information called for by these Interrogatories or Requests is withheld on the ground that the information is privileged, constitutes attorney work-product or trial preparation materials by or for any other reason is exempt from discover, set forth the grounds or grounds for withholding the information, explain what type of information is being withheld, and furnish such other information as may be required to enable the court to adjudicate the propriety of the refusal to furnish the information.

       2.  These Interrogatories, Requests for Admissions and Requests for Production are intended to be continuing and you are requested to supplement or amend your answers if you obtain additional information responsive to any of the requests.

       3.  The singular includes the plural number, and vice versa.  The masculine includes the feminine and neuter genders. Past tense includes the present tense unless the clear meaning is distorted by change of tense.

DEFINITIONS

       1.  The term “document” shall mean all writings and means of communication of any kind, including the original and non-identical copies (whether different from the originals by reason of notations made on such copies or otherwise) of any written, recorded, or graphic matter of any nature whatsoever, regardless of how recorded, including but not limited to the following:  Letters, correspondence, memoranda, notes, diaries, statistics, telegrams, payments, and certificates for payment, statements/invoices, medical records and police reports, notices, confirmations, telegrams,receipts, pamphlets, magazines, newspapers; notations of any sort of conversation, telephone call, meeting or other communication; bulletins, printed matter, computer printouts, teletypes, invoices, checks (front and back), check stubs, transcripts, diaries, summaries, financial statements, expert opinions, studies and investigations, questionnaires and surveys, and work sheets (and all drafts, preliminary versions, alterations, modifications, revisions, changes, and amendments of any of the foregoing as well as any attachments or appendices thereto); and graphic or oral records or representations of any kind (including, without limitation, photographs, charts, graphs, microfiche, microfilm, videotape, recordings, and motions pictures); and electronic, mechanical and electric records or representations of any kind (including without limitation tapes, cassettes, disks and recordings); and other written, printed, typed, or other graphic or recorded matter of any kind or nature, whoever produced or reproduced, and whether preserved in writing, phone or record, film, tape, disk, or videotape.

       2.  The term “document” includes all documents by whomever prepared withing the care, custody, or control of the Plaintiff as well as documents that they have a legal right to obtain, documents that they have a right to copy or have access to, documents that they have placed in the temporary possession, custody, or control of any third party including any attorney.

3.  The term “identify” when used with respect to documents means: (a) for those documents introduced as deposition exhibits, give the number of the exhibit; (b) for those documents produced by parties to this litigation, a stamp with a document identification number, give that number; (c) for other documents, give sufficient information including date, subject matter, author, addressee or in the alternative produce the document.

4.  The term “identify” when used with respect to a person means to state his or her full name and present and last known business or residential address and phone number.  When referring to a public or private corporation, partnership, association or other organization or to a governmental agency means to state its full name and present and last known pertinent business address and and phone number.

5.  The term “identify” when referring to a statement means to identify who made it, who took or recorded it, and all persons, if any, present during the making thereof; to state when, where and how it was taken or recorded, and identify who has present or last known possession, custody or control thereof.

6.  The terms “and” and “or” shall be construed either conjunctively or disjunctively to bring within the scope of  these interrogatories any information which might otherwise be construed to be outside their scope.

Admit (1)

That defendant herein (The United States of America) State of Texas (Co-Defendant), Harris County 215 District Judge “Steven Kirkland” stated and accused in “open court records”

The Plaintiff herein (Hamilton II) being the “Direct Cause of Action” (Harry C. Arthur et al) dismiss civil actions against “Christ Church Cathedral” in Houston Texas  while “Christ Church Cathedral” during said  time frame

  Being under full representation by: Attorney Andy Vickery a partner in Vickery, Waldner & Mallia.

Admit (2)

Plaintiff herein (Hamilton II) filed in The United States "Bob Casey Federal Court in Houston Texas “exhibit records” and “Physical Proof” of

(Harry C. Arthur Esq.) building Rent Receipts showing to wit: During the month of November 2009 when (Arthur et al) file suit against (Christ Church Cathedral et al)

(Arthur et al) had possession in excess of $166,500.00 per 1 month = in building L.L.C and Harry C. Arthur Law firm  “Account receivable” with a grand total $330,001.00 for (2) months in the Month of November 2009 and the month of December 2009.

(Admit 3)

Canon 1, DR 1-102(A),(4) which states that "[a] lawyer shall not: (4) engage in conduct involving dishonesty", fraud, deceit, or misrepresentation."

(Admit4)

Canon 7, DR 7-101(A),(2) provides that `a lawyer shall not intentionally fail to carry out a contract of employment entered into with a client for professional services, . . .'