Sherlock Holmes Case of The Dead Man who Paid Taxes 58th District Judge Bob Wortham Request for Admission

      In The United States District Court

                  For the District of Texas

                   Beaumont Division

Louis Charles Hamilton II

Plaintiff                    Civil No. 1:2010-CV-00055

                 

            Vs.                                    

 Antoine L. Freeman, J.D. et al     

                  Defendant

PLAINTIFF'S (First Set) INTERROGATORIES

REQUESTS FOR ADMISSIONS AND

REQUESTS FOR PRODUCTION

      TO:  Third Parties:

      Honorable 58^th District Judicial Judge Bob Wortham,

Jefferson County Texas Courthouse 1149 Pearl Street Beaumont Texas 77701

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 Pro Se Plaintiff (Louis Charles Hamilton II) herein this Discovery request fully legally declare in a

 “Civil tort” of being in a monetary losses in breach of construction contract against (Joyce Guy and Edward McCray) of Port Arthur Texas 448 Dequeen Blvd 77640

Admit (2). ( Antoine L. Freeman, J.D) “Attorney at Law” filed a notice of counsel for the legal behalf of (Joyce Guy and Edward McCray) Civil No.180805 also being filed in Jefferson County Texas Courthouse records.

Admit (3) Plaintiff (Hamilton II) appeared before the 58^th District Honorable Court on 9/11/2009 to compel discovery request and initial Disclosure request of the Pro Se Plaintiff Louis Charles Hamilton II herein.

Admit (4) The Honorable 58^th District Court described here “Judge Bob Wortham” adjudged and Decreed Defendant (Guy and McCray)

Through their retain Attorney of Record (Antoine L. Freeman J.D. Attorney at Law) to fully produce all Pro Se (Hamilton II) describe discovery request sought to the Plaintiff by November 6^th 2009

If admitted;

1. State fully in great detail under what set of complete legal Judicial Judge circumstances end result and exactly happen to Attorney of Record (Antoine L. Freeman J.D. Attorney at Law) producing all Pro Se (Hamilton II) describe discovery request sought to the Plaintiff by November 6^th 2009 per the “Honorable Bob Wortham” Judicial Orders.

2. Did the Honorable 58^th Judge Bob Wortham provide (Antoine L. Freeman J.D. Attorney at Law) a legal chance to comply with said 58^th District Honorable Court Orders.

3. State fully in great Judicial “Judge Bob Wortham” details under what complete legal Judicial Judge circumstances the ending result in a legal chance (Antoine L. Freeman J.D. Attorney at Law) to comply to required Honorable and state fully exactly what happen and all events and end result of the Honorable 58^th Judge Bob Wortham issued orders

4. Did the Pro Se Plaintiff (Hamilton II) ever received said discovery request after order by Judge Bob Wortham.