In The District Court
215th Judicial District
Harris County, Texas
Cause No. 2009-80663
Louis Charles Hamilton II Plaintiff Second Set of
Plaintiff Request for
Vs. Admission
Harry C. Arthur (Esq.)
Marine Building, L.L.C.
Defendant(s),
Comes Now the Plaintiff, Louis Charles Hamilton II, hereby files a Motion to Defendant(s) Harry C. Arthur and The Marine Building L.L.C. hereafter name (Arthur et al);
Pursuant to the Rule 198 of the Texas Rules of Civil Procedure, (Defendants) (Arthur et al) to respond to the following requests for admission propounded by the above described Plaintiff as described above;
Request for Admission Question(s)
I. Admit that the Defendant herein this civil action as described above (Arthur et al) engaged in discovery devise of the following with the Defendant(s) in Cause No. 2009-756693: (Arthur et al Plaintiff vs. Christ Church Cathedral et al Defendants):
1. Initial Disclosure Discovery phases.
2. Request For Admissions Questions
3. Interrogatories Questions.
4. Deposition being conducted upon the (Arthur et al ) under “Oath” by direct examination by (Attorney or record) (Andy) Vickery with the Law Firm of Vickery, Waldner & Mallia, LLP
5. To include but not limited to possible Deposition collectively being conducted at the same time by direct examination second (Attorney or record) Kenny IV Esq.
II. Admit that the Defendant (Arthur et al) collectively Base his decision to file a non-suit (among other reasons) on some of the circumstantial “materials facts” surrounding defendant (Arthur et al) facing possible future cause of actions made by “Beacon Clients” singularly or in a class action against defendant (Arthur et al)
Having being brought to levy before a Honorable Court of law, and (Arthur et al) being further held accountable and made to make monetary liability in regards to defamation and discriminatory practices against the rights of the Plaintiff and (among others)
Which being issues brought out in the said deposition collectively being-conducted by Attorneys of records in Cause No. 2009-756693: (Arthur et al Plaintiff vs. Christ Church Cathedral et al Defendants):
Which (Arthur et al) defendant to this action filed a Non-Suite their after said above-mentioned Deposition..? And other combine discovery devices.
III. Admit that the Defendant (Arthur et al) collectively Base his decision “not to file suit” against all of the other “non-profit organizations evidentially similarly” providing the same services in the Houston (CBD) Central Business District as the “Christ Church Cathedral Beacon et al” dose in providing “Food” to the poor (“among other basic humanitarian needs and things”)
Because “they” the other “non-profit organizations” evidentially similarly” doing the same as the Christ Church Cathedral Beacon et al” in providing “Food” among other humanitarian services and “They” the others “non-profit humanitarian organizations” do not attract “Derelict(s)” and or cause a nuisances with their Houston homeless clients” in the (CBD) in Houston Texas.
IV. Admit that the defendant (Arthur et al) wantonly and with fully knowledge sought to cause the Plaintiff among other “Beacon Clients” to suffer retaliation of a, public ridicule, humiliation nature;
And further public fall out” of embarrassment from all of the statement(s) made in the Cause No. 2009-756693: (Arthur et al Plaintiff vs. Christ Church Cathedral et al Defendants) in regards to namely the pissing and crapping on the Defendant(s) (Arthur et al) property:
Dated this ______ Day of _________________, 2010
By, ____________________________
Louis Charles Hamilton II
Pro Se Plaintiff
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