In The United States District Court
For the Eastern District of Texas
Beaumont Division
Louis Charles Hamilton II
(Negro African American)
Plaintiff
Vs. Civil No. 4:10-CV-2709
United States of America
State of Texas
Harris County
PLAINTIFF'S (First Set) INTERROGATORIES
REQUESTS FOR ADMISSIONS AND
REQUESTS FOR PRODUCTION
TO: Third Parties:
Andy Vickery (Attorney att Law)
"Law Firm of "Vickery and Waldner, LLP." (Houston Texas)
Pro Se Plaintiffs, (Louis Charles Hamilton II)
In the above entitled matter pursuant to Rules 33, 34, 36, and 37 of the Federal Rules of Civil Procedure, hereby propound 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 within 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 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). A civil dispute arise in which (Harry C. Arthur Esq.) declare in a “civil tort” of being in a monetary losses in rental revenue at Marine Building L.L.C. in Houston Texas against “Christ Church Cathedral” in Houston Texas being filed in Harris County Courthouse
because the (Plaintiff) herein (Hamilton II) among other are declare “Derelict” to cause such monetary losses in rental revenue at Marine Building L.L.C.
Admit (2). (Harry C. Arthur Esq.) Declare in a “civil tort” of also having “property value losses” and or “depreciation” of the Commercial Value of “The Marine Building L.L.C. in Houston Texas against “Christ Church Cathedral” in Houston Texas also being filed in Harris County Courthouse.
Admit (3) (Harry C. Arthur Esq.) “property value losses” and or “depreciation” of the Commercial Value of “The Marine Building L.L.C. in Houston Texas
because the (Plaintiff) herein (Hamilton II) among other are declare “Derelict” to cause such “property value losses” and or “depreciation” in the Commercial Value of “ The Marine Building L.L.C. in Houston Texas.
Admit (4) Andy Vickery (Attorney at Law) represented “Christ Church Cathedral” in Harris County Courthouse against (Harry C. Arthur Esq.) and (The Marine Building L.L.C.) and further admittances this was done for Pro Bono “Legal Fee’s J
Admit (5) (Harry C. Arthur Esq.) sought permanent injunction against the Beacon operation in feeding “Homeless Citizens and Children in Houston Texas.
Admit (6) (Harry C. Arthur Esq.) sought in addition to the permanent injunction against the Beacon operation in feeding
“Homeless Citizens and Children in Houston Texas. Monetary awards of in excess of $250,000 in damages
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