In The United States District Court
For the District of Texas
Beaumont Division
Louis Charles Hamilton II
Plaintiff Motion for
Vs. Disclosure
Antoine L. Freeman, J.D. Civil No. 1:2010-CV-00055
Defendant
And
Edward McCray
Joyce M. Guy
Co-Defendant(s)
Comes Now the Pro Se Plaintiff, Louis Charles Hamilton II, in this Cause Civil No. 1:2010-CV-00055 at this time hereby request Defendant(s) Antoine L. Freeman, J.D. Defendant;
To disclose the following information:
1. The Name and, if Known, the Address and telephone number of each individual likely to have discoverable information relevant to dispute facts alleged with particularity In the Pleadings” and the subject of the information each person has;
2. Copies of “ or a description by category and location of all documents, data compilations, and tangible things in possession, custody and or control of the party that are relevant to dispute facts with particularity in the pleadings;”that the disclosing party may use to support its claims or defenses, unless solely for impeachment;
3. A Computations of any category of damages claimed by the disclosing party, making available for inspection and copying the documents or other evidentiary materials, not privileged or protected from disclosure, on which such computation is based, including materials bearing on the nature and extent of injuries suffered; and
4. For inspection and copying any legal malpractice insurance agreements that may cover all or part of a Judgment in this action or to indemnify or reimburse for payments made to satisfy the Judgment;
5. The Correct Party Names;
6. Potential Parties;
7. Testifying experts;
8. In addition, Responsible Third Party Names Address and daytime phone Numbers.
Plaintiff hereby gives notice that all documents produced by any Plaintiff or Defendant in the past, will be used at pretrial proceeding or at the Trial of this matter.
Dated this ______ Day of _________________, 2010
Respectfully submitted
By, ____________________________
Louis Charles Hamilton II
Pro Se Plaintiff
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