Tuesday, December 30, 2014

MOTION TO FREEZE DOCUMENTS, ASSETS, OF DEFENDANT ANTOINE L. FREEMAN J.D., "Attorney at Law" et al U.S. CAUSE No.1:14-CV-592

To: Thee “United States of America”

“Happy 2015” You Crooked “F-c-k-ing Bastards”

To: My Favorite “Commander in Chief” (Barack Obama)

My Gasoline price hitting @ a low $1.95 (WTF) ha, ha

I am taking relaxing “High Boost Octane” baths in it. (Good Job)

(Appears) that good old USDA (IRAQ) “Halliburton Dessert Oil” slant rig drilling system

officially being a cool “American Government” Kick Back hand out…

it is now paying off ($$$)….xoxoxoxo! Ha ha 

“Happy 2015 “Mr. President (Obama) & Family” 

To: U.S. Congress ya so “sloooooow-n-crooked” better wakes ya dead asses up

and check out them gasoline prices as ya eating my greenly lime peanuts filled crap turds

To: Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 a/k/a “Scank Thong Rat Puss Face”


“Hey” (RICO) Sauvé, here is your “inner active” tracking No. 9505511124414363503185 (USPS)

The very second that (TRO) and application to freeze, all ya fu-king corrupted court documents,

crooked sketchy book keeping records, files, assets,

and all evidence (I) wanting in support thereof hit the official “Custody”, “Possession” and “legal control” of the

Honorable U.S. Federal Court House In The United States District Court For The Eastern Division of Texas,

Beaumont Division and it is scan into Cause No. 1:14-CV-592,

Before that “Mean Old USDA” Federal Magistrate Judge” it going to go a little likes this:

“You’re Honor”

That Chicken Thievery “Scank Thong Rat Puss Face” “Attorney at Law” Texas Bar No. 24058299

Antoine L. Freeman J. D. “Black Ass “N-I-G-G-E-R” did it

“You’re Honor”

“First and Foremost” we have “Live Surveillance Video-Taping” of him In the Jefferson County Texas

“Old Folks Nursing Home” with his DNA and finger prints all over a “large quantity” of maybe

“50-60” empty pill bottles he made a Valiums Crush Up Glass mix in the old Lady(s) “Apple Sauce”,

He proceed next with the “Cordless” Dewalt Saw all (18 Inches) Double Headed Vibrators,

“Vaginal and Rectal” cavity “examinations”

While having his “mutable senior female victims” heavy sedated induced under the influence of 25 cc of “Heroin and Coke Mix”

Speed Ball Chaser per each victims, being strapped to their beds

As he happy about “Pimp slapping” each and every 52 of them Seniors to their “brutal deaths”

with the “Ying and Yang” Gold Plated “Brass Knuckles

Secondly “You’re Honor”

He further preceded his “Chicken Thievery Greasy Black Ass”

to the City of Port Arthur Texas” towns “Bowling alley”,

“Library”, “City Hall”, “Two Child Care Centers”,

and “City Community College Center” with what seems like a endless supply of bullets and the “Gatlin Gun” 

And is presently on a “Nation Wide Attorney at Law Amber Alert”… 

That exactly what “Your” f-c-king evidences is looking like right about now “Scank Thong Rat Puss Face” “Attorney at Law”. Da” 

Now let me clue you in on a little extra legal “Attorney at Law”

“inside scoop” four eyes extra special read all about it court room drama details….. It’s called……. “Justia” ha, ha 

Ya See Him “Attorney at Law” whom ya think me to be weak, slow, stupid, and uneducated like

“Your” heavy Law degree ass

Me actually having an “Encrypt Cmdr. Bluefin Naval Message”…..

This read (Nice Cut Throat Job)….. “Commander”….

“Another Funky Crooked “Attorney at Law” Negro Scank Thong Rat Puss Face Skrimp on the grill,

(Smooches and Happy 2015 U.S. Navy)

And ya see further (A-Hole) “Scank Thong Rat Puss Face” “Attorney at Law”

(Now) them extra four-eye Split Pea Soup “No Crackers” eating

flat foot “Motherf-ckers” @ the “U.S. Justice Department”

Just simply sitting around the “Wire” high on “popcorn” waiting on the scan to be uploaded into the official

“custody”, “possession” and “legal control” of the Honorable U.S. Federal Court House “Clerk of Court” office

In The United States District Court For The Eastern Division of Texas,

Beaumont Division and it is scan into Cause No. 1:14-CV-592,

As they “always watching” a particular “VAMC Sick Brother”

They going to be Like “O God Dam”

“You see this Case of the “Dead Man Who Paid Taxes “Sherlock Holmes” “Internet Special”

That old “Cmdr. Bluefin” Ninja Navy

(Extra Special Crazy Retard Negro S-H-I-T”” that Cajun burn up cooking and He done filed in here….!!!!

“Meat and Potatoes” 

“Scramble” the “Fighter Jets”

Notwithstanding the official “Oval Office” “Military Briefing Report”

into my Favorite “Commander in Chief” (Obama)

always is waiting for the official Ninja Naval “Damage Report”….xoxoxoox!

Mr. President “Sir”

“Cmdr. Bluefin” has cause damages as follows:

“Both Engine rooms flooded, Aft Steering Rudder and Both engine screws completely “Blown off”,

The “Main Bridge” took a direct hit with a “Tomahawk Missile”

And it appears

Mr. President “Sir”

“Scank Thong Rat Puss Face” “Attorney at Law” is (DIW) “Dead in The Water”

Seriously Leaking A-1 Jet Fuel from all storage holding tanks, “including main Ships “fuel oil”,

“While rolling slowly over” onto his “Port Side” as all hands attempting a swim for safety”….!!!

And that just 1/3 of the real physical “Pirate Loot” “Scank Thong Rat Puss Face” Chicken Thievery

“Attorney at Law” evidence you been greedily (RICO) Sauvé,

gorging upon” for the last past 7 years concealing, hiding and destroying.

“Happy Fu-ked up 2015 New Years to “You and Your Family”

Smell ya Later “Mr. Scank Thong Rat Puss Face Attorney at Law”

“Cmdr. Bluefin” Going off “Wire Line”……..(Dial Tones)……” 

Monday, December 29, 2014

Pro Se Plaintiff “Louis Charles Hamilton II” REQUESTS FOR ADMISSION, Cause No. 1:14-CV-592 To Defendant “Antoine L. Freeman

Request Number 172.

Admit: You” Attorney at Law that “You” Drafted the Court Order Judge Bob Wortham gave his approval on, placed his signature upon said

“Court Order” issued in “Your” favor on December 11th 2009 which said 58th Judicial District Court Order of Jefferson County Texas was

electronically computer filed in Document # 8 herein 58th Judicial District Court of Jefferson County Texas “Case Ledger” and all Court Records thereof

For “Your” Withdrawal as “Attorney of Record”

Cause No. A-180805 as described in attached Document # 12 herein 58th Judicial District Court of Jefferson County Texas “Docket Report”

Request Number 173.

Admit: You” Attorney at Law that these “Chain of Events” are “True” of “Your” attend a hearing held on the date of December 11th 2009 for

“Your” Withdrawal as acting “Attorney of Record” as “Your” being Acting Attorney of Record since December 18th 2007 – December 11th 2009

1 year, 11 months and 11 days your officially active attorney of record in

Cause No. A-180805 as described in attached Document # 12 herein 58th Judicial District Court of Jefferson County Texas “Docket Report”

With a “Court Order” on file of approval of “Your withdrawal from Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively from cause No. A-180805

And as described in attached Document # 8 herein 58th Judicial District Court of Jefferson County Texas “Case Ledger”

And “Your” Affidavit in support of “Your” reply to Pro Se Plaintiff “Motion for Sanctions” against “You” Document #9 herein

contain with false statement made by “You” of “Your” having only knowledge of “Required Pro Se Plaintiff discovery request for

admissions, interrogatories and Disclosure on or about the dates of April 2nd 2008 and April 11, 2008

Which “You” already had Placed in the United States Mail and Publically Mailed to The Jefferson County Texas Court House “Clerk of District Court” for cause No. A-180805

And this document was electronically computer filed in Document # 8 herein 58th Judicial District Court of Jefferson County Texas “Case Ledger” and The Court Records for cause No. A-180805

During this same time frame “Your” being acting Attorney of record for cause No. A-180805 filed in the Jefferson County Texas Courthouse

The said “Property Deeds” a issue” for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas of the Co-Defendant(s) “Joyce M. Guy and Edward McCray herein

Was already legally Completely Transfer to the Texas Department of Housing & Community Affairs

on the date of June 18th 2009 as described by “Jefferson County Real Estate Index” in attached document #7 herein for a $76,000.00 U. S. Dollars Housing Grant

And “You” then after said dwelling being a party to this civil suit A-180805 was transfer for said $76,000.00 U. S. Dollars Housing Grant and the old one completely destroyed

“You” there after then attend a Hearing dated on December 11th 2009 after “Your” already done supplying “false information” as

“You” made in “Your” Response to Motion for Sanctions Document dated September 11th 2009, being Document # 1 attached herein

of “Your” having only knowledge of “Required” Pro Se Plaintiff discovery request for admissions, interrogatories and Disclosure

on or about the dates of April 2nd 2008 and April 11, 2008

In comparison to attached Document # 12 herein 58th Judicial District Court of Jefferson County Texas “Docket Report” showing

“You” officially having said Discovery request clearly back in March 14th 2009 as described in attached Document # 12 herein

58th Judicial District Court of Jefferson County Texas “Docket Report”

And ”You” then later used this “false information” for “Your” Withdrawal as acting “Attorney of Record” as described in attached Document # 2 herein

“Your Motion for withdrawal” from Cause No. A-180805

As “You” further stated “You” were only retain to file a “General Denial” (Only) which “You” did on December 18th 2007,

But “Your” legal representation in the capacity of an acting “Attorney at Law” in and for the State of Texas

did not officially end for the Co-Defendant “Joyce M. Guy and Edward McCray” herein collectively until “December 11th 2009

Which “You” completely refused throughout this entire time frame to simply turnover “among other things”

Production of copies the “Property deeds” for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas

which was request “You” and The Co-Defendant(s) collectively to do so in Pro Se Plaintiff Motion for Document(s) dated August 12th 2009

As described in attached Document # 12 herein 58th Judicial District Court of Jefferson County Texas “Docket Report”

But “Your” still officially makes “False Claims” in Court Records “Your” only being official retain as

“Attorney at Law” duties from the Time frame of December 18th 2007 – December 11th 2009 was to file a “General Denial” (only)

As “Your” in real life time “factual events and legal circumstances” claiming before the 58th Judicial District Court of Jefferson County Texas

these facts as such described in Document #1 in “Your” response to Motion for sanctions against “You”

and as Co-Defendant “Joyce M. Guy” herein also claiming in Document # 10 Co-Defendant “Joyce M. Guy” “Affidavit” in support of “Your” false claims

Which Her Fraudulent statement “Affidavit” no less is in fact in support of “You” so no sanction being imposed again “You”

which Co-Defendant “Joyce M. Guy” herein “Affidavit” in cause No. A-180805

Contains the same “false material information” as “Your” Supplying in knowledge of having possession, custody and legal control of

Pro Se Plaintiff Discovery request as Described in Pro Se Plaintiff attached Document # 1 herein “Your” response to Motion for sanctions against “You”

but “However” at the same time frame chain of events

“Your” being officially present at two Court hearing on August 12th 2009 and on September 11th 2009

in the capacity of acting “Attorney of Record” but not retain to be there at all and no motion for youe withdrawal as acting Attorney of Record

being official on file with the Jefferson County Civil Clerk of Court office until the date of November 13th 2009 for “Your” official withdrawal

But however no less “Your” in “factual events and legal circumstances” “physically officially present”

in “human life form of some sorts” breathing and quite in fact officially alive and present at

“two required Court hearing being held on August 12th 2009 and on September 11th 2009 and

“Your” acting in the capacity of acting “Attorney of Record” during these said “Two Live Court Hearings”

which “You” claim “Your” not even retain for at all but as Described in attached Document # 8 herein the 58th Judicial District Court of Jefferson County Texas

“Case Ledger” that “Your” acting “Attorney of Record”

But meanwhile “Your” 100% officially claiming “Your” not retain to be there and this never even happen as

“Your” making this false claim in attached Document # 1 herein “Your” response to Motion for sanctions against “You”

that the only understanding “Your” having is filed a “General Denial” (Only) as this was “Your” only Duties

Which “Your” still making such claims in December 11th 2009 at the hearing “Your” request to be now removal as acting “Attorney of Record” while

“Your” stating to the 58th Judicial District Court of Jefferson County Texas of a state of physically only legally being in a state of retain duties which is completed after December 18th 2007

for the sole purpose of “Your” filing a simple “General Denial” (Only) for Co-Defendant “Joyce M. Guy” and Edward McCray legal behalf collectively

as “Your” Official claim to this is so official stated in this attached Document # 1 herein

“Your” response to Motion for sanctions against “You” and as described and colloberated in Co-Defendant “Joyce M. Guy” herein

“Sworn” statement no less also claiming in Document # 10 her “Affidavit” in support of “You”

While attached Document No. # 8 herein the 58th Judicial District Court of Jefferson County Texas “Case Ledger”

showing “You” being in possession of numerous Discovery Documents and Legal Motions for the Co-Defendant(s) collectively behalf starting on March 14th 2008

While attached Document No. # 8 herein the 58th Judicial District Court of Jefferson County Texas “Case Ledger”

also showing “Required Pro Se Plaintiff discovery request for admissions, interrogatories and Disclosure being in “Your” claiming was in

“Your” legal possession, custody and legal control on or about the dates of April 2nd 2008 and April 11, 2008 that

“Your” making continue false claims to about these dates of “factual events and legal circumstances”

which do not officially exist at all as described in Pro Se Plaintiff attached Document No. # 8 herein

the 58th Judicial District Court of Jefferson County Texas “Case Ledger”

With the “Chain of continual “factual events and legal circumstances” showing also Co-Defendant Joyce M. Guy” herein supplies the following

“false and fraudulent” Answer to Pro Se Plaintiff Interrogatories Document # 11 attached herein at question number 14

14. How is the State of Texas Involved?

Answer: Not Involved

In comparison to Pro Se Plaintiff attached Document # 7 here in showing during this same time frame

“Your” being acting Attorney of record cause No. A-180805

Said “Property Deeds” for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas of the

Co-Defendant(s) “Joyce M. Guy and Edward McCray herein collectively custody, control and legal possession

Was legally in all “factual events and legal circumstances” Transfer to the “Texas Department of Housing & Community Affairs” on the date of June 18th 2009

As described by “Jefferson County Real Estate Index” Instrument # 2009022762.

And The Federal Government not being described as a Party

In attached document #7 herein for a $76,000.00 U. S. Dollars Housing Grant that Co Defendant “Joyce M. Guy”

thus making conflicting false claims that in all “factual events and legal circumstances” that the Federal Government provided provision of $76,000.00 U. S. Dollars Housing Grant

never happen as Co-Defendant “Joyce M. Guy” herein making such a legal claim in Pro Se Plaintiff attached Document # 11

“Interrogatories” of Co-Defendant “Joyce M. Guy” claims of Funding

For the Property located at 448 DeQueen Blvd. in Port Arthur Texas

which said Property being a party to a “Breach of Construction Contract” since the dates of November 17th 2007

as this is to be the “True Chain of “factual events and legal circumstances” involving “You”

Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299

whom “Your” in a retain “Attorney at Law” refusal state of some sort to supply a legal response during the months of April of 2008, May of 2008, June of 2008, July of 2008, August of 2008,

September of 2008, October of 2008, November of 2008, December of 2008, January of 2009,

February of 2009, March of 2009, April of 2009, May of 2009, June of 2009, July of 2009, August of 2009, September of 2009

In a timely manner to said Discovery request “Your” having in “Your” Legal possession, custody and control over since

March 14th 2008 as legally described in Pro Se Plaintiff Document No. # 8 attached herein being the official

58th Judicial District Court of Jefferson County Texas “Case Ledger” for Civil Cause No. A-180805.

And this is not in “Violations of Rule 193.1 of the Texas Rules of Civil Procedure of “Your”

responds to discovery in a timely manner for cause of action against Co-Defendant(s) Joyce M. Guy and Edward McCray collectively herein.

Sunday, December 28, 2014

Pro Se Plaintiff “Louis Charles Hamilton II” REQUESTS FOR ADMISSION, Cause No. 1:14-CV-592 To Defendant “Antoine L. Freeman

Request Number 164.

Admit: You” Attorney at Law that Co- Defendant Joyce M. Guy” herein supply the following Answer to Pro Se Plaintiff Interrogatories

Document # 11 attached herein pursuant to Rule 197 of the Texas Rules of Civil Procedures at Question: 10, 11, 12, 13, 14, 15, and 16.

10. Where is the Funding for the New Home?

Answer: Federal Grant

11. What are the terms and conditions of any contract in regards to the new home?

Answer: Federal Government built home free of charge Defendant must remain in home for at least 3 years.

12. What is the entire cost of the construction for the new home?

Answer: $76,000.00 U.S. Dollars

13. How is the city of Port Arthur Involved?

Answer: Not involved

14. How is the State of Texas Involved?

Answer: Not Involved

15. How is the Federal Government involved?

Answer: Federal Grant

16. How much money did the Co-Defendant actually paid for the new home construction?

Answer: No money paid by Co-Defendant

Request Number 165.

Admit: You” Attorney at Law that Co- Defendant Joyce M. Guy” herein supply the following “false and fraudulent” Answer to

Pro Se Plaintiff Interrogatories Document # 11 attached herein at

question number 14

14. How is the State of Texas Involved?

Answer: Not Involved

In comparison to Pro Se Plaintiff attached Document # 7 here in showing during this same time frame

“Your” being acting Attorney of record cause No. A-180805

said “Property Deeds” for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas of the

Co-Defendant(s) “Joyce M. Guy and Edward McCray herein collectively custody, control and legal possession

Was Legally Transfer to the Texas Department of Housing & Community Affairs on June 18th 2009

as described by “Jefferson County Real Estate Index in attached document #7 herein for a $76,000.00 U. S. Dollars Housing Grant. Instrument # 2009022762.

Request Number 166.

And further Admit that Documents #11 that Co- Defendant Joyce M. Guy” herein supply the following “false and fraudulent” Answer to

Pro Se Plaintiff Interrogatories was Placed in the United States Mail and

Publically Mailed to the Jefferson County Texas Court House “Clerk of District Court” for cause No. A-180805

And was electronically computer filed in Document # 8 herein 58th Judicial District Court of Jefferson County Texas “Case Ledger” and Court Records for cause No. A-180805


Request Number 167.

And further Admit that Documents #11 that Co- Defendant Joyce M. Guy” herein supply the following “false and fraudulent” Answer to

Pro Se Plaintiff Interrogatories was Placed in the United States Mail and

Publically Mailed to the Jefferson County Texas Court House “Clerk of District Court” for cause No. A-180805

And was electronically computer filed in Document # 8 herein 58th Judicial District Court of Jefferson County Texas “Case Ledger” and Court Records for cause No. A-180805

And was Placed in the United States Mail and publically mailed to the Pro Se Plaintiff herein.

Request Number 168.

And further Admit that Documents #11 that Co- Defendant Joyce M. Guy” herein supply the following “false and fraudulent” Answer to

Pro Se Plaintiff Interrogatories was Placed in the United States Mail and

Publically Mailed to the Jefferson County Texas Court House “Clerk of District Court” for cause No. A-180805

And was electronically computer filed in Document # 8 herein 58th Judicial District Court of Jefferson County Texas “Case Ledger” and Court Records for cause No. A-180805

And was Placed in the United States Mail and publically mailed to the Pro Se Plaintiff herein.

During this same time frame “Your” being acting Attorney of record cause No. A-180805 filed in the Jefferson County Texas Courthouse said

“Property Deeds” ” for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas of the Co-Defendant(s) “Joyce M. Guy and Edward McCray herein

Was Legally Transfer to the Texas Department of Housing & Community Affairs on June 18th 2009 as described by

“Jefferson County Real Estate Index in attached document #7 herein for a $76,000.00 U. S. Dollars Housing Grant

Request Number 169.

Admit: You” Attorney at Law that “You” and Co-Defendant “Joyce M. Guy” herein supply

“Your” response to the following Answer to Pro Se Plaintiff Interrogatories Document # 11 attached herein

pursuant to Rule 197 of the Texas Rules of Civil Procedures at Question: 10, 11, 12, 13, 14, 15, and 16. In October 14th 2009

During this same time frame “Your” being acting Attorney of record cause No. A-180805 filed in the Jefferson County Texas Courthouse

said “Property Deeds” ” for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas of the Co-Defendant(s) “Joyce M. Guy and Edward McCray herein

being a Party to a $10,800.00 U.S. Dollars “Breach of Construction Contract dispute said dwelling

Was “Already Completely Legally Transfer” to the Texas Department of Housing & Community Affairs on June 18th 2009

As described by “Jefferson County Real Estate Index in attached document #7 herein for a $76,000.00 U. S. Dollars Housing Grant

Request Number 170.

And further Admit that Documents #11 attached herein that Co- Defendant Joyce M. Guy” herein supply “false and fraudulent” Answer to

Pro Se Plaintiff Interrogatories at question # 14 was legally requested by Pro Se Plaintiff herein on March 14th 2008 but

“You” did not submit Co- Defendant Joyce M. Guy” herein supplied “false and fraudulent” Answer until

October 14th 2009 against Rule 197 of the Texas Rules of Civil Procedures (30) days limit in filing a timely response to Pro Se Plaintiff herein.

Being an actual year later “Your” finally forward actual “false and fraudulent” answers of Co- Defendant Joyce M. Guy”

Interrogatories at question # 14 herein attached Document # 11 herein

Legally “You” placed in the United States Mail and Publically Mailed to The Jefferson County Texas Court House “Clerk of District Court” for cause No. A-180805

And was electronically computer filed in Document # 8 herein 58th Judicial District Court of Jefferson County Texas “Case Ledger”

Request Number 171.

And further Admit that Documents #11 attached herein that Co- Defendant Joyce M. Guy” herein supply “false and fraudulent” Answer to

Pro Se Plaintiff Interrogatories at question # 14 which was legally requested by Pro Se Plaintiff herein on March 14th 2008 but

“You” did not submit Co- Defendant Joyce M. Guy” herein supplied “false and fraudulent” Answer until October 14th 2009

against Rule 197 of the Texas Rules of Civil Procedures (30) days limit in filing a timely response to Pro Se Plaintiff herein.

Being an actual year later “You’re” finally forward actual “false and fraudulent” answers of Co- Defendant Joyce M. Guy” Interrogatories at question # 14 herein attached Documents # 11 herein

Legally “You” placed said Interrogatories response in the United States Mail and Publically Mailed to The Jefferson County Texas Court House “Clerk of District Court” for cause No. A-180805

And this Document # 11 was electronically computer filed in Document # 8 herein 58th Judicial District Court of Jefferson County Texas “Case Ledger” and Court Records thereof

And Copies of such “false and fraudulent” Answer to Pro Se Plaintiff Interrogatories being actual “false and fraudulent” answers of

Co- Defendant Joyce M. Guy” Interrogatories at question # 14 herein attached Document # 11 herein Legally

“You” placed this legal Document in the United States Mail and publically mailed also to the Pro Se Plaintiff mailing address at P.O. Box 342 in Port Arthur Texas 77640

Pro Se Plaintiff “Louis Charles Hamilton II” REQUESTS FOR ADMISSION, Cause No. 1:14-CV-592 To Defendant “Antoine L. Freeman

Request Number 148.

Admit: You” Attorney at Law that “Your” Affidavit in support of your reply to Pro Se Plaintiff “Motion for Sanctions” against you Document #9 herein with

false statement made by “You” was Placed in the United States Mail and Publically Mailed to Co -Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein Cause No. A-180805

During this same time frame “Your” being acting Attorney of record cause No. A-180805 filed in the Jefferson County Texas Courthouse said

“Property Deeds” ” for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas of the Co-Defendant(s) “Joyce M. Guy and Edward McCray herein

Was Legally Transfer to the Texas Department of Housing & Community Affairs on June 18th 2009 as described by

“Jefferson County Real Estate Index in attached document #7 herein for a $76,000.00 U. S. Dollars Housing Grant

Request Number 149.

Admit: You” Attorney at Law that “Your” Affidavit in support of your reply to Pro Se Plaintiff “Motion for Sanctions” against you Document #9 herein

with false statement made by “You” was Placed in the United States Mail and Publically Mailed to The Jefferson County Texas Court House “Clerk of District Court” for cause No. A-180805

During this same time frame “Your” being acting Attorney of record cause No. A-180805 filed in the Jefferson County Texas Courthouse said

“Property Deeds” ” for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas of the Co-Defendant(s) “Joyce M. Guy and Edward McCray herein

Was Legally Transfer to the Texas Department of Housing & Community Affairs on June 18th 2009 as described by

“Jefferson County Real Estate Index in attached document #7 herein for a $76,000.00 U. S. Dollars Housing Grant

Request Number 150.

Admit: You” Attorney at Law that “Your” Affidavit in support of your reply to Pro Se Plaintiff “Motion for Sanctions” against you Document #9 herein

with false statement made by “You” was Placed in the United States Mail and Publically Mailed to

The Jefferson County Texas Court House “Clerk of District Court” for cause No. A-180805

And was electronically computer filed in Document # 8 herein 58th Judicial District Court of Jefferson County Texas “Case Ledger” and Court Records for cause No. A-180805

During this same time frame “Your” being acting Attorney of record cause No. A-180805 filed in the Jefferson County Texas Courthouse said

“Property Deeds” ” for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas of the Co-Defendant(s) “Joyce M. Guy and Edward McCray herein

Was Legally Transfer to the Texas Department of Housing & Community Affairs on June 18th 2009 as described by

“Jefferson County Real Estate Index in attached document #7 herein for a $76,000.00 U. S. Dollars Housing Grant

Request Number 151.

Admit: “You” Attorney at Law that “Your” reply/respond to Pro Se Plaintiff “Motion for Sanctions” against you Document #1 herein

with false statement made by “You” was Placed in the United States Mail and Publically Mailed to the Pro Se Plaintiff herein at P.O. Box 342 Port Arthur Texas 77640

During this same time frame “Your” being acting Attorney of record cause No. A-180805 filed in the Jefferson County Texas Courthouse said

“Property Deeds” ” for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas of the Co-Defendant(s) “Joyce M. Guy and Edward McCray herein

Was Legally Transfer to the Texas Department of Housing & Community Affairs on June 18th 2009 as described by

“Jefferson County Real Estate Index in attached document #7 herein for a $76,000.00 U. S. Dollars Housing Grant

Request Number 152.

Admit: “You” Attorney at Law that “Your” reply/respond to Pro Se Plaintiff “Motion for Sanctions” against you Document #1 herein with false statement made by

“You” was Placed in the United States Mail and Publically Mailed to Co -Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein Cause No. A-180805

During this same time frame “Your” being acting Attorney of record cause No. A-180805 filed in the Jefferson County Texas Courthouse said

“Property Deeds” ” for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas of the Co-Defendant(s) “Joyce M. Guy and Edward McCray herein

Was Legally Transfer to the Texas Department of Housing & Community Affairs on June 18th 2009 as described by

“Jefferson County Real Estate Index in attached document #7 herein for a $76,000.00 U. S. Dollars Housing Grant

Request Number 153.

Admit: “You” Attorney at Law that “Your” reply/respond to Pro Se Plaintiff “Motion for Sanctions” against you Document #1 herein with false statement made by

“You” was Placed in the United States Mail and Publically Mailed to The Jefferson County Texas Court House “Clerk of District Court” for cause No. A-180805

During this same time frame “Your” being acting Attorney of record cause No. A-180805 filed in the Jefferson County Texas Courthouse said

“Property Deeds” ” for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas of the Co-Defendant(s) “Joyce M. Guy and Edward McCray herein

Was Legally Transfer to the Texas Department of Housing & Community Affairs on June 18th 2009 as described by

“Jefferson County Real Estate Index in attached document #7 herein for a $76,000.00 U. S. Dollars Housing Grant

Request Number 154.

Admit: “You” Attorney at Law that “Your” reply/respond to Pro Se Plaintiff “Motion for Sanctions” against you Document #1 herein

with false statement made by “You” was Placed in the United States Mail and Publically Mailed to

The Jefferson County Texas Court House “Clerk of District Court” for cause No. A-180805 by “You”

And was electronically computer filed in Document # 8 herein 58th Judicial District Court of Jefferson County Texas “Case Ledger”

During this same time frame “Your” being acting Attorney of record cause No. A-180805 filed in the Jefferson County Texas Courthouse said

“Property Deeds” ” for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas of the Co-Defendant(s) “Joyce M. Guy and Edward McCray herein

Was Legally Transfer to the Texas Department of Housing & Community Affairs on June 18th 2009 as described by

“Jefferson County Real Estate Index in attached document #7 herein for a $76,000.00 U. S. Dollars Housing Grant

Request Number 155.

Admit: “You” Attorney at Law that “You” filed Co-Defendant “Joyce M. Guy “ herein “Affidavit in Support” of

“Your” response reply to Pro Se Plaintiff Motion for Sanctions against you Dated September 11th 2009 attached document # 10 herein

Request Number 156.

Admit: “You” Attorney at Law that on Document # 10 herein Co-Defendant “Joyce M. Guy” herein

“Sworn Affidavit Statement States among other things “being personally acquainted with the facts alleged”, Retained Defendant (You)

to draft and file a general denial on Co-Defendant Behalf.

Co-Defendant did not retain (You) to represent (Co-Defendant) beyond drafting and filing a general denial on my behalf

until sometime in August of 2009 when (You) informed me that Pro Se Plaintiff secured a hearing with regards to this lawsuit (A-180805)

(You) informed (Co-Defendant) between April 2nd 2008 and April 11th 2008 about Pro Se Plaintiff discovery request

It was (Co-Defendant) decision and not (You) not to respond to the discovery request of Pro Se Plaintiff.

Request Number 157.

Admit: You having full legal “Attorney at Law” knowledge of Required Pro Se Plaintiff discovery request for

admissions, interrogatories and Disclosure for cause No. A-180805

as Co-Defendant “Joyce M. Guy” and “You” corroborate the same facts in refusal to respond to discovery for over

a full year in document #1 and document # 10 attached herein

Request Number 158.

Admit: “You” Attorney at Law that “You” drafted Co-Defendant “Joyce M. Guy” herein “Affidavit” dated September 11th 2009 for

“Your” own Defense response reply to Pro Se Plaintiff Motion for Sanctions against “You” dated September 11th 2009 attached

In “Your” response to Pro Se Plaintiff motion for sanctions dated the 11th day of September 2009 Document # 1 herein

You state of having any knowledge of “Required Pro Se Plaintiff discovery request for admissions, interrogatories and Disclosure on or about the dates of

April 2nd 2008 and April 11, 2008 as described in Document # 1 attached herein

having any knowledge of “Required Pro Se Plaintiff discovery request for admissions, interrogatories and Disclosure on or about the dates of April 2nd 2008

and April 11, 2008 and as described in Document # 10 attached herein

And further Admit this is not-correct and completely a false statement made by “you”

“Attorney at Law” and made by your client being Co-Defendant “Joyce M. Guy” herein in regards to the correct dates of

“Your” both legally having knowledge of Pro Se Plaintiff discovery request for admissions, interrogatories and Disclosure

And the correct date is March 14th 2008 “Your” having actual knowledge of “Required Pro Se Plaintiff discovery request for

admissions, interrogatories and Disclosure as described in Document # 8 herein 58th Judicial District Court of Jefferson County Texas “Case Ledger”

Request Number 159.

Admit: “You” Attorney at Law that “Your” Affidavit in support of your reply to Pro Se Plaintiff “Motion for Sanctions” against you

Document #9 herein and your response to Pro Se Plaintiff Motion for sanctions against “You” Document # 1 herein and

Co-Defendant “Joyce M. Guy” “Affidavit in support of “You” document # 10 herein

Contain false statement made by “You” and Co-Defendant “Joyce M. Guy having any knowledge of

“Required Pro Se Plaintiff discovery request for admissions, interrogatories and Disclosure on or about the dates of April 2nd 2008 and April 11, 2008

and as described in Document #1 and #10 attached herein

And further Admit all three documents #1, #9 and #10 was Placed in the United States Mail and

Publically Mailed to the Pro Se Plaintiff herein at P.O. Box 342 Port Arthur Texas 77640 by “You”

Request Number 160.

Admit: “You” Attorney at Law that “Your” Affidavit in support of your reply to Pro Se Plaintiff “Motion for Sanctions” against you

Document #9 herein and your response to Pro Se Plaintiff Motion for sanctions against “You” Document # 1 herein and

Co-Defendant “Joyce M. Guy” “Affidavit in support of “You” document # 10 herein

Contain false statement made by “You” and Co-Defendant “Joyce M. Guy having any knowledge of

“Required Pro Se Plaintiff discovery request for admissions, interrogatories and Disclosure on or about the dates of

April 2nd 2008 and April 11, 2008 and as described in Document #1 and #10 attached herein

And further admit all three documents #1, #9 and #10 was Placed in the United States Mail and Publically Mailed to

Co -Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein Cause No. A-180805

Request Number 161.

Admit: “You” Attorney at Law that “Your” Affidavit in support of your reply to Pro Se Plaintiff “Motion for Sanctions” against you Document #9 herein

and your response to Pro Se Plaintiff Motion for sanctions against “You” Document # 1 herein and Co-Defendant “Joyce M. Guy” “Affidavit in support of “You” document # 10 herein

Contain false statement made by “You” and Co-Defendant “Joyce M. Guy having any knowledge of

“Required Pro Se Plaintiff discovery request for admissions, interrogatories and Disclosure on or about the dates of April 2nd 2008 and April 11, 2008 and as described in

Document #1 and #10 attached herein

And further Admit all three documents #1, #9 and #10 was Placed in the United States Mail and Publically Mailed to

The Jefferson County Texas Court House “Clerk of District Court” for cause No. A-180805

Request Number 162.

Admit: “You” Attorney at Law that “Your” Affidavit in support of your reply to Pro Se Plaintiff “Motion for Sanctions” against you Document #9 herein

and your response to Pro Se Plaintiff Motion for sanctions against “You” Document # 1 herein and Co-Defendant “Joyce M. Guy” “Affidavit in support of “You” document # 10 herein

Contain false statement made by “You” and Co-Defendant “Joyce M. Guy having any knowledge of

“Required Pro Se Plaintiff discovery request for admissions, interrogatories and Disclosure on or about the dates of

April 2nd 2008 and April 11, 2008 and as described in Document #1 and #10 attached herein

And further Admit all three documents #1, #9 and #10 was Placed in the United States Mail and

Publically Mailed to The Jefferson County Texas Court House “Clerk of District Court” for cause No. A-180805

And was electronically computer filed in Document # 8 herein 58th Judicial District Court of Jefferson County Texas “Case Ledger” and Court Records for cause No. A-180805

Request Number 163.

“You” Attorney at Law that “Your” Affidavit in support of your reply to Pro Se Plaintiff “Motion for Sanctions” against you Document #9 herein

and your response to Pro Se Plaintiff Motion for sanctions against “You” Document # 1 herein and

Co-Defendant “Joyce M. Guy” “Affidavit in support of “You” document # 10 herein

Contain false statement made by “You” and Co-Defendant “Joyce M. Guy having any knowledge of

“Required Pro Se Plaintiff discovery request for admissions, interrogatories and Disclosure on or about the dates of

April 2nd 2008 and April 11, 2008 and as described in Document #1 and #10 attached herein

And further Admit all three documents #1, #9 and #10 was Placed in the United States Mail and

Publically Mailed to The Jefferson County Texas Court House “Clerk of District Court” for cause No. A-180805

And was electronically computer filed in Document # 8 herein 58th Judicial District Court of Jefferson County Texas

“Case Ledger” and Court Records for cause No. A-180805

During this same time frame “Your” being acting Attorney of record cause No. A-180805 filed in the Jefferson County Texas Courthouse said

“Property Deeds” for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas of the Co-Defendant(s) “Joyce M. Guy and Edward McCray herein

Was Legally Transfer to the Texas Department of Housing & Community Affairs on June 18th 2009 as described by

“Jefferson County Real Estate Index in attached document #7 herein for a $76,000.00 U. S. Dollars Housing Grant.

Saturday, December 27, 2014

Pro Se Plaintiff “Louis Charles Hamilton II” REQUESTS FOR ADMISSION, Cause No. 1:14-CV-592 To Defendant “Antoine L. Freeman

Request Number 147.

Admit: “You” Attorney at Law that “Your” Affidavit in support of your reply to Pro Se Plaintiff “Motion for Sanctions” against you

Document #9 herein with false statement made by “You” was Placed in the United States Mail and Publically Mailed to the

Pro Se Plaintiff herein at P.O. Box 342 Port Arthur Texas 77640

During this same time frame “Your” being acting Attorney of record cause No. A-180805 filed in the

Jefferson County Texas Courthouse said “Property Deeds” for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas of the

Co-Defendant(s) “Joyce M. Guy and Edward McCray herein

Was Legally Transfer to the Texas Department of Housing & Community Affairs on June 18th 2009 as described by

“Jefferson County Real Estate Index in attached document #7 herein for a $76,000.00 U. S. Dollars Housing Grant

Request Number 140.

Admit: You” Attorney at Law that “Your” Affidavit in support of your reply to Pro Se Plaintiff “Motion for Sanctions” against you

Document #9 herein with false statement made by “You” was Placed in the United States Mail and Publically Mailed to

Co -Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein Cause No. A-180805

During this same time frame “Your” being acting Attorney of record cause No. A-180805 filed in the

Jefferson County Texas Courthouse said “Property Deeds” ” for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas of the

Co-Defendant(s) “Joyce M. Guy and Edward McCray herein

Was Legally Transfer to the Texas Department of Housing & Community Affairs on June 18th 2009 as described by

“Jefferson County Real Estate Index in attached document #7 herein for a $76,000.00 U. S. Dollars Housing Grant

Request Number 141.

Admit: You” Attorney at Law that “Your” Affidavit in support of your reply to Pro Se Plaintiff “Motion for Sanctions” against you

Document #9 herein with false statement made by “You” was Placed in the United States Mail and Publically Mailed to

The Jefferson County Texas Court House “Clerk of District Court” for cause No. A-180805

During this same time frame “Your” being acting Attorney of record cause No. A-180805 filed in the Jefferson County Texas Courthouse said

“Property Deeds” ” for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas of the Co-Defendant(s) “Joyce M. Guy and Edward McCray herein

Was Legally Transfer to the Texas Department of Housing & Community Affairs on June 18th 2009 as described by

“Jefferson County Real Estate Index in attached document #7 herein for a $76,000.00 U. S. Dollars Housing Grant

Request Number 142.

Admit: You” Attorney at Law that “Your” Affidavit in support of your reply to Pro Se Plaintiff “Motion for Sanctions” against you

Document #9 herein with false statement made by “You” was Placed in the United States Mail and Publically Mailed to

The Jefferson County Texas Court House “Clerk of District Court” for cause No. A-180805

And was electronically computer filed in Document # 8 herein 58th Judicial District Court of Jefferson County Texas “Case Ledger”

During this same time frame “Your” being acting Attorney of record cause No. A-180805 filed in the Jefferson County Texas Courthouse said

“Property Deeds” ” for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas of the Co-Defendant(s) “Joyce M. Guy and Edward McCray herein

Was Legally Transfer to the Texas Department of Housing & Community Affairs on June 18th 2009 as described by

“Jefferson County Real Estate Index in attached document #7 herein for a $76,000.00 U. S. Dollars Housing Grant

Request Number 143.

Admit: “You” Attorney at Law that “Your” reply/respond to Pro Se Plaintiff “Motion for Sanctions” against you

Document #1 herein with false statement made by “You” was Placed in the United States Mail and Publically Mailed to the Pro Se Plaintiff herein at P.O. Box 342 Port Arthur Texas 77640

During this same time frame “Your” being acting Attorney of record cause No. A-180805 filed in the Jefferson County Texas Courthouse said

“Property Deeds” ” for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas of the Co-Defendant(s) “Joyce M. Guy and Edward McCray herein

Was Legally Transfer to the Texas Department of Housing & Community Affairs on June 18th 2009 as described by

“Jefferson County Real Estate Index in attached document #7 herein for a $76,000.00 U. S. Dollars Housing Grant

Request Number 144.

Admit: “You” Attorney at Law that “Your” reply/respond to Pro Se Plaintiff “Motion for Sanctions” against you

Document #1 herein with false statement made by “You” was Placed in the United States Mail and Publically Mailed to

Co -Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein Cause No. A-180805

During this same time frame “Your” being acting Attorney of record cause No. A-180805 filed in the Jefferson County Texas Courthouse said

“Property Deeds” ” for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas of the Co-Defendant(s) “Joyce M. Guy and Edward McCray herein

Was Legally Transfer to the Texas Department of Housing & Community Affairs on June 18th 2009 as described by

“Jefferson County Real Estate Index in attached document #7 herein for a $76,000.00 U. S. Dollars Housing Grant

Request Number 145.

Admit: “You” Attorney at Law that “Your” reply/respond to Pro Se Plaintiff “Motion for Sanctions” against you

Document #1 herein with false statement made by “You” was Placed in the United States Mail and Publically Mailed to

The Jefferson County Texas Court House “Clerk of District Court” for cause No. A-180805

During this same time frame “Your” being acting Attorney of record cause No. A-180805 filed in the Jefferson County Texas Courthouse said

“Property Deeds” ” for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas of the Co-Defendant(s) “Joyce M. Guy and Edward McCray herein

Was Legally Transfer to the Texas Department of Housing & Community Affairs on June 18th 2009 as described by

“Jefferson County Real Estate Index in attached document #7 herein for a $76,000.00 U. S. Dollars Housing Grant

Request Number 146.

Admit: “You” Attorney at Law that “Your” reply/respond to Pro Se Plaintiff “Motion for Sanctions” against you

Document #1 herein with false statement made by “You” was Placed in the United States Mail and Publically Mailed to

The Jefferson County Texas Court House “Clerk of District Court” for cause No. A-180805

And was electronically computer filed in Document # 8 herein 58th Judicial District Court of Jefferson County Texas “Case Ledger”

During this same time frame “Your” being acting Attorney of record cause No. A-180805 filed in the Jefferson County Texas Courthouse said

“Property Deeds” ” for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas of the Co-Defendant(s) “Joyce M. Guy and Edward McCray herein

Was Legally Transfer to the Texas Department of Housing & Community Affairs on June 18th 2009 as described by

“Jefferson County Real Estate Index in attached document #7 herein for a $76,000.00 U. S. Dollars Housing Grant

Pro Se Plaintiff “Louis Charles Hamilton II” REQUESTS FOR ADMISSION, Cause No. 1:14-CV-592 To Defendant “Antoine L. Freeman

Request Number 139.

Admit: “You” Attorney at Law that “Your” Affidavit in support of your reply to Pro Se Plaintiff “Motion for Sanctions” against you

Document #9 herein with false statement made by “You” was Placed in the United States Mail and Publically Mailed to the

Pro Se Plaintiff herein at P.O. Box 342 Port Arthur Texas 77640

Request Number 140.

Admit: You” Attorney at Law that “Your” Affidavit in support of your reply to Pro Se Plaintiff “Motion for Sanctions” against you

Document #9 herein with false statement made by “You” was Placed in the United States Mail and Publically Mailed to

Co -Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein Cause No. A-180805

Request Number 141.

Admit: You” Attorney at Law that “Your” Affidavit in support of your reply to Pro Se Plaintiff “Motion for Sanctions” against you

Document #9 herein with false statement made by “You” was Placed in the United States Mail and Publically Mailed to

The Jefferson County Texas Court House “Clerk of District Court” for cause No. A-180805

Request Number 142.

Admit: You” Attorney at Law that “Your” Affidavit in support of your reply to Pro Se Plaintiff “Motion for Sanctions” against you

Document #9 herein with false statement made by “You” was Placed in the United States Mail and Publically Mailed to

The Jefferson County Texas Court House “Clerk of District Court” for cause No. A-180805

And was electronically computer filed in Document # 8 herein 58th Judicial District Court of Jefferson County Texas “Case Ledger”

Request Number 143.

Admit: “You” Attorney at Law that “Your” reply/respond to Pro Se Plaintiff “Motion for Sanctions” against you

Document #1 herein with false statement made by “You” was Placed in the United States Mail and Publically Mailed to the

Pro Se Plaintiff herein at P.O. Box 342 Port Arthur Texas 77640

Request Number 144.

Admit: “You” Attorney at Law that “Your” reply/respond to Pro Se Plaintiff “Motion for Sanctions” against you

Document #1 herein with false statement made by “You” was Placed in the United States Mail and Publically Mailed to

Co -Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein Cause No. A-180805

Request Number 145.

Admit: “You” Attorney at Law that “Your” reply/respond to Pro Se Plaintiff “Motion for Sanctions” against you

Document #1 herein with false statement made by “You” was Placed in the United States Mail and Publically Mailed to

The Jefferson County Texas Court House “Clerk of District Court” for cause No. A-180805

Request Number 146.

Admit: “You” Attorney at Law that “Your” reply/respond to Pro Se Plaintiff “Motion for Sanctions” against you

Document #1 herein with false statement made by “You” was Placed in the United States Mail and Publically Mailed to

The Jefferson County Texas Court House “Clerk of District Court” for cause No. A-180805

And was electronically computer filed in Document # 8 herein 58th Judicial District Court of Jefferson County Texas “Case Ledger”

Pro Se Plaintiff “Louis Charles Hamilton II” REQUESTS FOR ADMISSION, Cause No. 1:14-CV-592 To Defendant “Antoine L. Freeman

Request Number 134.

Admit: “You” Attorney at Law that “Your” reply in your response to Pro Se Plaintiff motion for sanctions dated the 11th day of September 2009

You state of having any knowledge of “Required Pro Se Plaintiff discovery request for admissions, interrogatories and Disclosure

On or about the dates of April 2nd 2008 and April 11, 2008 as described in Document # 1 attached herein.

Request Number 135.

Admit: “You” Attorney at Law that on Document # 1 containing your correct Texas Bar No. 24058299

Request Number 136.

Admit: “You” Attorney at Law that on Document # 8 58th Judicial District Court of Jefferson County Texas “Case Ledger”

That on March 14th 2008 is the correct “actual date” your having full knowledge of Required Pro Se Plaintiff discovery request for

Admissions, interrogatories and Disclosure for cause No. A-180805

Request Number 137.

Admit: “You” Attorney at Law that “Your” reply in your response to Pro Se Plaintiff motion for sanctions dated the 11th day of September 2009 Document # 1 herein

You state of having any knowledge of “Required Pro Se Plaintiff discovery request for admissions, interrogatories and

Disclosure on or about the dates of April 2nd 2008 and April 11th, 2008 as described in Document # 1 attached herein

And this is not-correct and completely a false statement made by “you” “Attorney at Law” in regards to the correct dates of

“Your” having knowledge of Pro Se Plaintiff discovery request for admissions, interrogatories and Disclosure

And the correct date is March 14th 2008 “Your” having actual knowledge of

“Required Pro Se Plaintiff discovery request for admissions, interrogatories and Disclosure

As described in Document # 8 herein 58th Judicial District Court of Jefferson County Texas “Case Ledger”

Request Number 138.

Admit: “You” Attorney at Law that is “Your” signature on Document # 9 attached herein

“Your” Affidavit in Support of your reply to Pro Se Plaintiff Motion for sanctions dated 11th day of September 2009 and

Document # 9 contain a false verification on oath of “Your” sworn statement made by “You”

And “Your” having actual knowledge of “Required Pro Se Plaintiff discovery request for admissions, interrogatories and Disclosure as described in

Document # 8 herein 58th Judicial District Court of Jefferson County Texas “Case Ledger”

Friday, December 26, 2014

MOTION TO FREEZE DOCUMENTS, ASSETS, OF DEFENDANT ANTOINE L. FREEMAN J.D., "Attorney at Law" et al U.S. CAUSE No.1:14-CV-592

Federal Rules of Civil Procedure

Rule 26. Duty to Disclose; General Provisions Governing Discovery

(a) Required Disclosures.

(1) Initial Disclosure.

(A) In General. Except as exempted by Rule 26(a)(1)(B) or as otherwise stipulated or ordered by the court, a party must, without awaiting a discovery request, provide to the other parties:

(i) the name and, if known, the address and telephone number of each individual likely to have discoverable information—along with the subjects of that information—that the disclosing party may use to support its claims or defenses, unless the use would be solely for impeachment;

(ii) a copy—or a description by category and location—of all documents, electronically stored information, and tangible things that the disclosing party has in its possession, custody, or control and may use to support its claims or defenses, unless the use would be solely for impeachment;

(iii) a computation of each category of damages claimed by the disclosing party—who must also make available for inspection and copying as under Rule 34 the documents or other evidentiary material, unless privileged or protected from disclosure, on which each computation is based, including materials bearing on the nature and extent of injuries suffered; and

(iv) for inspection and copying as under Rule 34, any insurance agreement under which an insurance business may be liable to satisfy all or part of a possible judgment in the action or to indemnify or reimburse for payments made to satisfy the judgment.

(B) Proceedings Exempt from Initial Disclosure. The following proceedings are exempt from initial disclosure:

(i) an action for review on an administrative record;

(ii) a forfeiture action in rem arising from a federal statute;

(iii) a petition for habeas corpus or any other proceeding to challenge a criminal conviction or sentence;

(iv) an action brought without an attorney by a person in the custody of the United States, a state, or a state subdivision;

(v) an action to enforce or quash an administrative summons or subpoena;

(vi) an action by the United States to recover benefit payments;

(vii) an action by the United States to collect on a student loan guaranteed by the United States;

(viii) a proceeding ancillary to a proceeding in another court; and

(ix) an action to enforce an arbitration award.

(C) Time for Initial Disclosures—In General. A party must make the initial disclosures at or within 14 days after the parties’ Rule 26(f) conference unless a different time is set by stipulation or court order, or unless a party objects during the conference that initial disclosures are not appropriate in this action and states the objection in the proposed discovery plan. In ruling on the objection, the court must determine what disclosures, if any, are to be made and must set the time for disclosure.

(D) Time for Initial Disclosures—For Parties Served or Joined Later. A party that is first served or otherwise joined after the Rule 26(f) conference must make the initial disclosures within 30 days after being served or joined, unless a different time is set by stipulation or court order.

(E) Basis for Initial Disclosure; Unacceptable Excuses. A party must make its initial disclosures based on the information then reasonably available to it. A party is not excused from making its disclosures because it has not fully investigated the case or because it challenges the sufficiency of another party's disclosures or because another party has not made its disclosures.

(2) Disclosure of Expert Testimony.

(A) In General. In addition to the disclosures required by Rule 26(a)(1), a party must disclose to the other parties the identity of any witness it may use at trial to present evidence under Federal Rule of Evidence 702, 703, or 705.

(B) Witnesses Who Must Provide a Written Report. Unless otherwise stipulated or ordered by the court, this disclosure must be accompanied by a written report—prepared and signed by the witness—if the witness is one retained or specially employed to provide expert testimony in the case or one whose duties as the party's employee regularly involve giving expert testimony. The report must contain:

(i) a complete statement of all opinions the witness will express and the basis and reasons for them;

(ii) the facts or data considered by the witness in forming them;

(iii) any exhibits that will be used to summarize or support them;

(iv) the witness's qualifications, including a list of all publications authored in the previous 10 years;

(v) a list of all other cases in which, during the previous 4 years, the witness testified as an expert at trial or by deposition; and

(vi) a statement of the compensation to be paid for the study and testimony in the case.

(C) Witnesses Who Do Not Provide a Written Report. Unless otherwise stipulated or ordered by the court, if the witness is not required to provide a written report, this disclosure must state:

(i) the subject matter on which the witness is expected to present evidence under Federal Rule of Evidence 702, 703, or 705; and

(ii) a summary of the facts and opinions to which the witness is expected to testify.

(D) Time to Disclose Expert Testimony. A party must make these disclosures at the times and in the sequence that the court orders. Absent a stipulation or a court order, the disclosures must be made:

(i) at least 90 days before the date set for trial or for the case to be ready for trial; or

(ii) if the evidence is intended solely to contradict or rebut evidence on the same subject matter identified by another party under Rule 26(a)(2)(B) or (C), within 30 days after the other party's disclosure.

(E) Supplementing the Disclosure. The parties must supplement these disclosures when required under Rule 26(e).

(3) Pretrial Disclosures.

(A) In General. In addition to the disclosures required by Rule 26(a)(1) and (2), a party must provide to the other parties and promptly file the following information about the evidence that it may present at trial other than solely for impeachment:

(i) the name and, if not previously provided, the address and telephone number of each witness—separately identifying those the party expects to present and those it may call if the need arises;

(ii) the designation of those witnesses whose testimony the party expects to present by deposition and, if not taken stenographically, a transcript of the pertinent parts of the deposition; and

(iii) an identification of each document or other exhibit, including summaries of other evidence—separately identifying those items the party expects to offer and those it may offer if the need arises.

(B) Time for Pretrial Disclosures; Objections. Unless the court orders otherwise, these disclosures must be made at least 30 days before trial. Within 14 days after they are made, unless the court sets a different time, a party may serve and promptly file a list of the following objections: any objections to the use under Rule 32(a) of a deposition designated by another party under Rule 26(a)(3)(A)(ii); and any objection, together with the grounds for it, that may be made to the admissibility of materials identified under Rule 26(a)(3)(A)(iii). An objection not so made—except for one under Federal Rule of Evidence 402 or 403—is waived unless excused by the court for good cause.

(4) Form of Disclosures. Unless the court orders otherwise, all disclosures under Rule 26(a) must be in writing, signed, and served.

(b) Discovery Scope and Limits.

(1) Scope in General. Unless otherwise limited by court order, the scope of discovery is as follows: Parties may obtain discovery regarding any nonprivileged matter that is relevant to any party's claim or defense—including the existence, description, nature, custody, condition, and location of any documents or other tangible things and the identity and location of persons who know of any discoverable matter. For good cause, the court may order discovery of any matter relevant to the subject matter involved in the action. Relevant information need not be admissible at the trial if the discovery appears reasonably calculated to lead to the discovery of admissible evidence. All discovery is subject to the limitations imposed by Rule 26(b)(2)(C).

(2) Limitations on Frequency and Extent.

(A) When Permitted. By order, the court may alter the limits in these rules on the number of depositions and interrogatories or on the length of depositions under Rule 30. By order or local rule, the court may also limit the number of requests under Rule 36.

(B) Specific Limitations on Electronically Stored Information. A party need not provide discovery of electronically stored information from sources that the party identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the party from whom discovery is sought must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery.

(C) When Required. On motion or on its own, the court must limit the frequency or extent of discovery otherwise allowed by these rules or by local rule if it determines that:

(i) the discovery sought is unreasonably cumulative or duplicative, or can be obtained from some other source that is more convenient, less burdensome, or less expensive;

(ii) the party seeking discovery has had ample opportunity to obtain the information by discovery in the action; or

(iii) the burden or expense of the proposed discovery outweighs its likely benefit, considering the needs of the case, the amount in controversy, the parties’ resources, the importance of the issues at stake in the action, and the importance of the discovery in resolving the issues.

(3) Trial Preparation: Materials.

(A) Documents and Tangible Things. Ordinarily, a party may not discover documents and tangible things that are prepared in anticipation of litigation or for trial by or for another party or its representative (including the other party's attorney, consultant, surety, indemnitor, insurer, or agent). But, subject to Rule 26(b)(4), those materials may be discovered if:

(i) they are otherwise discoverable under Rule 26(b)(1); and

(ii) the party shows that it has substantial need for the materials to prepare its case and cannot, without undue hardship, obtain their substantial equivalent by other means.

(B) Protection Against Disclosure. If the court orders discovery of those materials, it must protect against disclosure of the mental impressions, conclusions, opinions, or legal theories of a party's attorney or other representative concerning the litigation.

(C) Previous Statement. Any party or other person may, on request and without the required showing, obtain the person's own previous statement about the action or its subject matter. If the request is refused, the person may move for a court order, and Rule 37(a)(5) applies to the award of expenses. A previous statement is either:

(i) a written statement that the person has signed or otherwise adopted or approved; or

(ii) a contemporaneous stenographic, mechanical, electrical, or other recording—or a transcription of it—that recites substantially verbatim the person's oral statement.

(4) Trial Preparation: Experts.

(A) Deposition of an Expert Who May Testify. A party may depose any person who has been identified as an expert whose opinions may be presented at trial. If Rule 26(a)(2)(B) requires a report from the expert, the deposition may be conducted only after the report is provided.

(B) Trial-Preparation Protection for Draft Reports or Disclosures. Rules 26(b)(3)(A) and (B) protect drafts of any report or disclosure required under Rule 26(a)(2), regardless of the form in which the draft is recorded.

(C) Trial-Preparation Protection for Communications Between a Party's Attorney and Expert Witnesses. Rules 26(b)(3)(A) and (B) protect communications between the party's attorney and any witness required to provide a report under Rule 26(a)(2)(B), regardless of the form of the communications, except to the extent that the communications:

(i) relate to compensation for the expert's study or testimony;

(ii) identify facts or data that the party's attorney provided and that the expert considered in forming the opinions to be expressed; or

(iii) identify assumptions that the party's attorney provided and that the expert relied on in forming the opinions to be expressed.

(D) Expert Employed Only for Trial Preparation. Ordinarily, a party may not, by interrogatories or deposition, discover facts known or opinions held by an expert who has been retained or specially employed by another party in anticipation of litigation or to prepare for trial and who is not expected to be called as a witness at trial. But a party may do so only:

(i) as provided in Rule 35(b); or

(ii) on showing exceptional circumstances under which it is impracticable for the party to obtain facts or opinions on the same subject by other means.

(E) Payment. Unless manifest injustice would result, the court must require that the party seeking discovery:

(i) pay the expert a reasonable fee for time spent in responding to discovery under Rule 26(b)(4)(A) or (D); and

(ii) for discovery under (D), also pay the other party a fair portion of the fees and expenses it reasonably incurred in obtaining the expert's facts and opinions.

(5) Claiming Privilege or Protecting Trial-Preparation Materials.

(A) Information Withheld. When a party withholds information otherwise discoverable by claiming that the information is privileged or subject to protection as trial-preparation material, the party must:

(i) expressly make the claim; and

(ii) describe the nature of the documents, communications, or tangible things not produced or disclosed—and do so in a manner that, without revealing information itself privileged or protected, will enable other parties to assess the claim.

(B) Information Produced. If information produced in discovery is subject to a claim of privilege or of protection as trial-preparation material, the party making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information to the court under seal for a determination of the claim. The producing party must preserve the information until the claim is resolved.

(c) Protective Orders.

(1) In General. A party or any person from whom discovery is sought may move for a protective order in the court where the action is pending—or as an alternative on matters relating to a deposition, in the court for the district where the deposition will be taken. The motion must include a certification that the movant has in good faith conferred or attempted to confer with other affected parties in an effort to resolve the dispute without court action. The court may, for good cause, issue an order to protect a party or person from annoyance, embarrassment, oppression, or undue burden or expense, including one or more of the following:

(A) forbidding the disclosure or discovery;

(B) specifying terms, including time and place, for the disclosure or discovery;

(C) prescribing a discovery method other than the one selected by the party seeking discovery;

(D) forbidding inquiry into certain matters, or limiting the scope of disclosure or discovery to certain matters;

(E) designating the persons who may be present while the discovery is conducted;

(F) requiring that a deposition be sealed and opened only on court order;

(G) requiring that a trade secret or other confidential research, development, or commercial information not be revealed or be revealed only in a specified way; and

(H) requiring that the parties simultaneously file specified documents or information in sealed envelopes, to be opened as the court directs.

(2) Ordering Discovery. If a motion for a protective order is wholly or partly denied, the court may, on just terms, order that any party or person provide or permit discovery.

(3) Awarding Expenses. Rule 37(a)(5) applies to the award of expenses.

(d) Timing and Sequence of Discovery.

(1) Timing. A party may not seek discovery from any source before the parties have conferred as required by Rule 26(f), except in a proceeding exempted from initial disclosure under Rule 26(a)(1)(B), or when authorized by these rules, by stipulation, or by court order.

(2) Sequence. Unless, on motion, the court orders otherwise for the parties’ and witnesses’ convenience and in the interests of justice:

(A) methods of discovery may be used in any sequence; and

(B) discovery by one party does not require any other party to delay its discovery.

(e) Supplementing Disclosures and Responses.

(1) In General. A party who has made a disclosure under Rule 26(a)—or who has responded to an interrogatory, request for production, or request for admission—must supplement or correct its disclosure or response:

(A) in a timely manner if the party learns that in some material respect the disclosure or response is incomplete or incorrect, and if the additional or corrective information has not otherwise been made known to the other parties during the discovery process or in writing; or

(B) as ordered by the court.

(2) Expert Witness. For an expert whose report must be disclosed under Rule 26(a)(2)(B), the party's duty to supplement extends both to information included in the report and to information given during the expert's deposition. Any additions or changes to this information must be disclosed by the time the party's pretrial disclosures under Rule 26(a)(3) are due.

(f) Conference of the Parties; Planning for Discovery.

(1) Conference Timing. Except in a proceeding exempted from initial disclosure under Rule 26(a)(1)(B) or when the court orders otherwise, the parties must confer as soon as practicable—and in any event at least 21 days before a scheduling conference is to be held or a scheduling order is due under Rule 16(b).

(2) Conference Content; Parties’ Responsibilities. In conferring, the parties must consider the nature and basis of their claims and defenses and the possibilities for promptly settling or resolving the case; make or arrange for the disclosures required by Rule 26(a)(1); discuss any issues about preserving discoverable information; and develop a proposed discovery plan. The attorneys of record and all unrepresented parties that have appeared in the case are jointly responsible for arranging the conference, for attempting in good faith to agree on the proposed discovery plan, and for submitting to the court within 14 days after the conference a written report outlining the plan. The court may order the parties or attorneys to attend the conference in person.

(3) Discovery Plan. A discovery plan must state the parties’ views and proposals on:

(A) what changes should be made in the timing, form, or requirement for disclosures under Rule 26(a), including a statement of when initial disclosures were made or will be made;

(B) the subjects on which discovery may be needed, when discovery should be completed, and whether discovery should be conducted in phases or be limited to or focused on particular issues;

(C) any issues about disclosure or discovery of electronically stored information, including the form or forms in which it should be produced;

(D) any issues about claims of privilege or of protection as trial-preparation materials, including—if the parties agree on a procedure to assert these claims after production—whether to ask the court to include their agreement in an order;

(E) what changes should be made in the limitations on discovery imposed under these rules or by local rule, and what other limitations should be imposed; and

(F) any other orders that the court should issue under Rule 26(c) or under Rule 16(b) and (c).

(4) Expedited Schedule. If necessary to comply with its expedited schedule for Rule 16(b) conferences, a court may by local rule:

(A) require the parties’ conference to occur less than 21 days before the scheduling conference is held or a scheduling order is due under Rule 16(b); and

(B) require the written report outlining the discovery plan to be filed less than 14 days after the parties’ conference, or excuse the parties from submitting a written report and permit them to report orally on their discovery plan at the Rule 16(b) conference.

(g) Signing Disclosures and Discovery Requests, Responses, and Objections.

(1) Signature Required; Effect of Signature. Every disclosure under Rule 26(a)(1) or (a)(3) and every discovery request, response, or objection must be signed by at least one attorney of record in the attorney's own name—or by the party personally, if unrepresented—and must state the signer's address, e-mail address, and telephone number. By signing, an attorney or party certifies that to the best of the person's knowledge, information, and belief formed after a reasonable inquiry:

(A) with respect to a disclosure, it is complete and correct as of the time it is made; and

(B) with respect to a discovery request, response, or objection, it is:

(i) consistent with these rules and warranted by existing law or by a nonfrivolous argument for extending, modifying, or reversing existing law, or for establishing new law;

(ii) not interposed for any improper purpose, such as to harass, cause unnecessary delay, or needlessly increase the cost of litigation; and

(iii) neither unreasonable nor unduly burdensome or expensive, considering the needs of the case, prior discovery in the case, the amount in controversy, and the importance of the issues at stake in the action.

(2) Failure to Sign. Other parties have no duty to act on an unsigned disclosure, request, response, or objection until it is signed, and the court must strike it unless a signature is promptly supplied after the omission is called to the attorney's or party's attention.

(3) Sanction for Improper Certification. If a certification violates this rule without substantial justification, the court, on motion or on its own, must impose an appropriate sanction on the signer, the party on whose behalf the signer was acting, or both. The sanction may include an order to pay the reasonable expenses, including attorney's fees, caused by the violation.

(Hey) (RICO) Suave

Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 a/k/a “Scank Thong Rat Puss Face”

Federal Rules of Civil Procedure Rule 26. Duty to Disclose; General Provisions Governing Discovery

Just posted for your Dumb (RICO) crooked extra sloooooooow egg head Ass".......

(I) don't want her Ass crack F-U-C-K-I-N-G S.H.I.T. from ya when (I) send you my request for discovery


Crook Just simply follow the Federal Rules of Civil Procedure this time "Ya" greasy ass (Dizzy Goony F-U-C-K S-T-A-I-N N-I-G-G-E-R")

Let me also FYI: your crooked ass,

your "Viral"

ha, ha Dumb Bitch"

Thursday, December 25, 2014

MOTION TO FREEZE DOCUMENTS, ASSETS, OF DEFENDANT ANTOINE L. FREEMAN J.D., "Attorney at Law" et al U.S. CAUSE No.1:14-CV-592

In The United States District Court
For The Eastern Division of Texas
Beaumont Division

Louis Charles Hamilton II
Pro Se Plaintiff

Vs.

Antoine L. Freeman J. D.
Defendant

Joyce M. Guy
Edward McCray
Co-Defendant(s)

Court Order Cause No. 1:14-CV-592

Came on to be Considered Pro Se Plaintiff’s Louis Charles Hamilton II

Application for a order to show cause why a (TRO) Temporary Restraining Order, and Order Freeze all assets of Defendant(s)

Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299

and Co-Defendant(s) Joyce M. Guy and Edward McCray herein collectively being enforced against all described Defendant(s).

And after review of the files, records, exhibit(s), and hearing oral arguments from all Plaintiff/Defendants parties involved on this Motion for a

(TRO) and requesting an Order to Freeze all assets standing before the “Honorable Court Justice” entertainment.

“Honorable Court Justice” Zack Hawthorn” United States Magistrate Judge being of the opinion that said Application for a order to show cause why a

(TRO) Temporary Restraining Order,

To protect all material evidence from being Destroying, concealment, alter, hide, screen, obscure, mask, disguise,

demolish, liquidate, erase, and eliminating as material evidences being subject matter before jurisdiction of This United States District Court, Eastern Division of Texas,

And requesting accompanying Order Freeze all assets of Defendant(s) Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299

And Co-Defendant(s) Joyce M. Guy and Edward McCray herein collectively” is with merit and should be granted, it is therefore

1.

Ordered that Plaintiff’s Application for a order to show cause why a (TRO) Temporary Restraining Order,

to protect all material evidence being subject matter before jurisdiction of This United States District Court, Eastern Division of Texas,

Is Granted and fully being enforced against Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299

and Co-Defendant(s) Joyce M. Guy and Edward McCray herein collectively”

2.

Ordered that Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 Freezing all records, correspondence, notes, phone records, recording,

communications, and other documents concerning or relating to any correspondence or communications

with Co-Defendant(s) Joyce M. Guy and Edward McCray from the dates of November 17th 2007 throughout December 1st 2015.

(3)

Freezing all records, correspondence, notes, communications, and other documents that concern or relate to any conversations,

discussions, requests for advice, or any matter relating to the above-captioned case.

(4)

Freezing all records, correspondence, notes, communications, and other documents concerning or relating to any correspondence or communications with any

Defendant, or Defendants or with any person or persons initially named as Defendants in this case regarding “Hamilton vs. Freeman et al filed February 2nd 2010 U.S. Cause No. 1:2010-CV-00055

(5)

Freezing all records, correspondence, notes, communications or other documents which are relevant to the allegations of this complaint,

and any and all records, correspondence, notes, communications or other documents which may lead to such relevant evidence.

(6)

Freezing all desk calendars, appointment books, journals, logs, and diaries which concern or relate to the Defendant,

in the performance of job description, duties, instructions, assignments, or evaluations of Co- Defendant(s) Joyce M. Guy and Edward McCray.

(7)

Freezing all records, correspondence, notes, communications, and other documents concerning or relating to the circumstances under which Defendant acquired employment from the Co-Defendant(s) Joyce M. Guy and Edward McCray, including, but not limited to,

Defendant job description, duties, his qualifications to perform those duties, and freezing any and all evaluations prepared by anyone about how he performed those duties for the behalf of the Co-Defendant(s) collectively herein.

(8)

Freezing all records showing the Defendant qualifications to perform those duties as an “Attorney at Law” in and for the State of Texas.

(9)

Freezing all records, correspondence, notes, communications, and other documents concerning or relating to any private hire authority working for Defendant behalf

“investigating the circumstances” under which Defendant were retain after acquired employment from the Co-Defendant(s) Joyce M. Guy and Edward McCray.

(10)

Freezing all records, and all Documents of Defendant “Attorney and Law”, contracts concerning or relating to Monetary retain

“Attorney at Law” Payments of services Defendant received from Co-Defendant(s) Joyce M. Guy and Edward McCray.

(11)

Freezing all of Defendant “Attorney and Law” Contracts with clients namely Co-Defendant(s) Joyce M. Guy and Edward McCray in cause No. A-180805.

(12)

Freezing all documents of Defendant “Attorney and Law” related to files, documents, letters, motions, certificate of mailing services, correspondence,

notes, communications, phone records, being received in cause No. A-180805 from Pro Se Plaintiff Louis Charles Hamilton II to the Defendant for the behalf of the Co-Defendant(s) Joyce M. Guy and Edward McCray.

(13)

Freezing all of Defendant “Attorney and Law” Contracts for hire of services with clients namely Co-Defendant(s) Joyce M. Guy and Edward McCray in U.S. Cause No. 1:2010-CV-00055

(14)

Freezing all Documents of Defendant “Attorney and Law” entire cause No. for each and every case load for every client Defendant office has legally represent in a civil court of law in and for the State of Texas from the exact dates of December 18th 2007 throughout December 18th 2014

(15)

Freezing all Documents Defendant “Attorney and Law” herein related to files, documents, letters, correspondence, notes, communications, phone records, Defendant contacted another Attorney at Law office to take over in cause No. A-180805 or

Defendant staff made such requested and or made such inquiry for the behalf of the Co-Defendant(s) Joyce M. Guy and Edward McCray.

(16)

Freezing all Documents Defendant “Attorney and Law” herein related to files, documents, letters, correspondence, notes, communications, phone records, Defendant contacted the 58th Judicial District Court Honorable Judge Bob Wortham,

And or his staff requesting to be removed as acting “Attorney of Record” from the cause No. A-180805 on or before the dates of November 13th 2009

or having another Attorney at Law office to take over in cause No. A-180805 as showing Defendant (Attorney at Law)

Herein made such requested and or made such inquiry for the behalf of the Co-Defendant(s) Joyce M. Guy and Edward McCray on or before the dates of November 13th 2009.

(17)

Freezing all Documents Defendant “Attorney and Law” herein related to files, documents, letters, correspondence, notes, communications, phone records,

employment for hire Attorney at Law contracts Defendant acquired employment from the Co-Defendant(s) Joyce M. Guy and Edward McCray other then in cause No. A-180805 and U.S. Cause No. 1:2010-CV-00055

(18)

Freezing all Documents Defendant “Attorney and Law” herein relating to the exact Identity of each,

and all staff member of the Defendant Law Office from the dates of November 17th 2007 throughout 2015 with each staff member day time telephone number and correct mailing address.

(19)

Freezing all Documents Defendant “Attorney and Law” herein relating to the exact monetary payment

and contract thereof the Defendant received from Co-Defendant(s) in cause No. A-180805 to file a “General Denial” to Pro Se Plaintiff Complaint.

(20)

Freezing all Documents Defendant “Attorney and Law” herein relating to the exact monetary payment and “Attorney/Client contract thereof the Defendant received from Co-Defendant(s) in cause No. A-180805

To appear at a hearing on the dates of August 28th 2009 to respond to Pro Se Plaintiff Complaint and all circumstance for the legal behalf of the Co-Defendant(s) Joyce M. Guy and Edward McCray herein on hearing dates of August 28th 2009.

(21)

Freezing all Documents Defendant “Attorney and Law” herein relating to the exact monetary payment and Attorney/client contract thereof the Defendant received from Co-Defendant(s) in cause No. A-180805 to appear at a hearing on the dates of September 11th 2009

To respond to Pro Se Plaintiff Complaint and all circumstance for the legal behalf of the Co-Defendant(s) Joyce M. Guy and Edward McCray herein on hearing dates of September 11th 2009.

(22)

Freezing all Documents Defendant “Attorney and Law” herein relating to any of Pro Se Plaintiff “Discovery Request for Interrogatories, Request for Admission, and Request for Disclosure in accordance with the Texas Rules of Civil Procedures 194.2, 197, and 198,

in Defendant possession, custody and legal control from the dates of April 2nd 2008 and April 11, 2008,

throughout the dates of October 14th 2009 which Defendant supply some sort of respond during this time frame of (1) year and (5) months and counting days Defendant not responding.

(23)

Freezing all Documents Defendant “Attorney and Law” herein relating to the exact monetary payment and Attorney/client contract thereof the Defendant represented the Co-Defendant(s) Joyce M. Guy and Edward McCray herein

legal behalf in any criminal/civil cases other then cause No. A-180805 and U.S. Cause No. 1:2010-CV-00055

(24)

Freezing all Documents Defendant “Attorney and Law” herein relating to the exact ledger of cause No. A-180805

resulting from business transactions and principal book keeping and computer filing system for all documents, records, contracts, and banking records.

(25)

Freezing all Documents Defendant “Attorney and Law” herein relating to the exact “certificate of mailing services”

Defendant received (Legal Court Documents) in cause No. A-180805 from Pro Se Plaintiff herein for the behalf of the Co-Defendant(s) Joyce M. Guy and Edward McCray herein.

(26)

Freezing all Documents Defendant “Attorney and Law” herein relating to the business transactions, dealings, and or relationship between the Defendant

“Attorney at Law” with the Co-Defendant(s) Joyce M. Guy and Edward McCray herein other than a Attorney/client relationship between the dates of 1980 throughout 2015.

(27)

Freezing all Documents Defendant “Attorney and Law” herein relating to the business transactions, dealings,

(IRS) records showing the Annually Income received for the Defendant Law Office herein from the dates of November 17th 2007 throughout December 2015.

(28)

Freezing all Documents Defendant “Attorney and Law” herein relating to the Defendant having another “Attorney/Client Relationship other then in cause No. A-180805 showing Defendant did not actually respond to discovery request for Interrogatories, Request for Admission,

And Request for Disclosure in accordance with the Texas Rules of Civil Procedures 194.2, 197, and 198, in Defendant possession, custody and legal control

for other Clients retain for Defendant “Legal Services” other than the Co-Defendant(s) Joyce M. Guy and Edward McCray herein.

(29)

Freezing all records showing the Defendant staff qualifications to perform those duties acting on behalf of Defendant “Attorney at Law” herein Law Offices in and for the State of Texas from the dates of November 17th 2007 - 2015.

(30)

Freezing all of Defendant “Attorney and Law” entire cause No. Ledger showing for each and every case load for the Defendant “Law office”

he has legally represent in a civil court in a suit in common law in and for the State of Texas from the exact dates of December 18th 2007 throughout December 18th 2014 showing each cause No.

“The exact Courthouse in Texas whereby Defendant represented, ledger showing of each documents and motions received

and filed response thereof per each cause No., with Production of Documents on all return Defendant certificate of mailing services to “opposition counsel or Pro Se (Person or Persons)”.

(31)

Freezing all Documents, Birth records, Church records, Hospital (DNA) records all of Defendant “Attorney and Law” herein

having descended from a common ancestor or constituting a people, clan, tribe, or family, relative or kinsman with the Co-Defendant(s) Joyce M. Guy and Edward McCray herein.

(32)

Freezing all of Defendant “Attorney and Law” herein entire assets in Law office located at 3629 Professional Dr. Port Arthur Texas 77642

(34)

Freezing all of Defendant “Attorney and Law” herein entire assets in Law office located at 3723 Gulfway Dr. Port Arthur Texas 77642

(35)

Freezing all of Defendant “Attorney and Law” herein entire assets in “Deed” Professional Development Block 2 Lot 3

“SBD Keith Marroquin” as being described in Pro Se Plaintiff attached exhibit (M) “Jefferson County Texas” search Index #2011035793

(36)

Freezing all of Defendant “Attorney and Law” herein entire assets in “Gulf Employee Credit Union

as being described in Pro Se Plaintiff attached exhibit (M) “Jefferson County Texas” search Index #2002005559

(37)

Freezing all of Defendant “Attorney and Law” herein entire assets in “Port Arthur Teachers Federal Credit Union

as being described in Pro Se Plaintiff attached exhibit (M) “Jefferson County Texas” search Index #2004004187

(38)

Freezing all of Defendant “Attorney and Law” herein entire assets as being described in Pro Se Plaintiff attached exhibit (M)

“Jefferson County Texas” search Index herein all such person and person(s)

(39)

As identified having (any) interests in all entities owned, in whole or in part, or controlled by, related to, or associated or

affiliated with Defendant Antoine L. Freeman J. D. (Attorney at Law) herein “Namely” “Freeman Antoine, Freeman Antoine L,

Freeman Antoine L Sr., Freeman Antoinette C & EX, Black James M and Moor Leslie M Jr.

(40)

Freezing all Assets” of Defendant (Attorney at Law) herein there after providing a “verified written described accounting” and “personal financial statement” of Defendant Antoine L. Freeman J. D. (Attorney at Law) herein as•set plural noun: assets:

“Deeds”, Banking accounts presently held, Property, Stock, Bonds, (IRA), Commercial Real estate, Companies, Investments, estates, livestock, cattle, horses, Rental Property(s), landholding, chattel,

Valuable Art collection, investment banking, (money) to use, by purchase or expenditure, in something offering potential profitable returns, as interest, income, gold investment.

(41)

Freezing all records in G and G Service Company P.O. Box 515, 416 DeQueen Blvd. in Port Arthur“ Business records”,

banking records, personal banking records, staff records, (IRS), computer records, insurance records, ledgers, tax records, from the dates of 1997-2015

(42)

Freezing all records in J Can Company 1807 East 7th Street Port Arthur Texas (Office) located at 448 DeQueen Blvd. in Port Arthur Texas 77640

“ Business records”, banking records, personal banking records, staff records, (IRS), tax records, computer records, insurance records from the dates of 2008-2015

(43)

Freezing all records in E and J Collectibles located at 448 DeQueen Blvd. in Port Arthur Texas 77640

*note this company not listed on Pro Se Plaintiff attached exhibit (C) herein records contain at “Jefferson County Texas Search Index”

However it “do exist” on the Internet as being two companies and is in “physical operation”

as Public Advertisement claims open to the public in Jefferson County Texas contact Co-Defendant “Joyce M. Guy” (409) 330-0485.

Business records”, banking records, personal banking records, staff records, (IRS), tax records, computer records, insurance records, from the dates of 1997-2015

(44)

Freezing all records in “Paragon Business Inc.” Lot 10 Block 18 (Jefferson) Chaison ADD

Business records”, banking records, personal banking records, staff records, (IRS), tax records, computer records, insurance records from the dates of 2001-2015

(45)

Freezing all records in “Cars and Pieces” office located in Beaumont Texas and all records at office located at 448 DeQueen Blvd. in Port Arthur Texas 77640
Business records”, banking records, personal banking records, staff records, (IRS), tax records, computer records, insurance records from the dates of 2001-2015

(46)

Freezing all records in DSW Homes relating to Co-Defendant(s) Joyce M. Guy and Edward McCray herein

(47)

Freezing all records in SWMJ Construction Inc. relating to Co-Defendant(s) Joyce M. Guy and Edward McCray herein

(48)

Freezing all records in “Texas Department of Housing and Community Affairs” relating to Co-Defendant(s) Joyce M. Guy and Edward McCray herein

(49)

Freezing all records in North America Popular Banco Texas relating to Co-Defendant(s) Joyce M. Guy and Edward McCray herein

(50)

Freezing all records during “Hurricane “Rita”, “Ike” and “Humberto” related Construction storm damages to the property located at 448 DeQueen Blvd in Port Arthur Texas

Business records”, banking records, personal banking records, Home owner Insurance Records, FEMA records, Contractor Construction records, and recovery repair records.

(51)

Freezing all records during “Hurricane “Rita”, “Ike” and “Humberto”

related Construction storm damages to the property located at 5050 east 7th street in Port Arthur Texas

Business records”, banking records, personal banking records, Home Owner Insurance Records, FEMA records, Contractor Construction records, recovery repair records.

(52)

Freezing all records during “Hurricane “Rita”, “Ike” and “Humberto”

related Construction storm damages to the property located at SBD “Lakeview”, Block 4 Lot 10 Jefferson County Texas

Business records”, banking records, personal banking records, Home Owner Insurance Records, FEMA records Contractor Construction records, recovery repair records.

(53)

Freezing all of Co- Defendant Joyce M. Guy and Edward McCray “collectively” herein

entire assets in G and G Service Company P.O. Box 515, 416 DeQueen Blvd. in Port Arthur“77640

(54)

Freezing all of Co- Defendant Joyce M. Guy and Edward McCray “collectively” herein

entire assets in J Can Company 1807 East 7th Street Port Arthur Texas (Office) located at 448 DeQueen Blvd. in Port Arthur Texas 77640 “

(55)

Freezing all of Co- Defendant Joyce M. Guy and Edward McCray “collectively” herein

entire assets in E and J Collectibles located at 448 DeQueen Blvd. in Port Arthur Texas 77640

(56)

Freezing all of Co- Defendant Joyce M. Guy and Edward McCray “collectively” herein

entire assets in “Paragon Business Inc.” Lot 10 Block 18 (Jefferson) Chaison ADD

(57)

Freezing all of Co- Defendant Joyce M. Guy and Edward McCray “collectively” herein entire assets in “Cars and Pieces”

Office located in Beaumont Texas and office located at 448 DeQueen Blvd. in Port Arthur Texas 77640

(58)

Freezing all of Co- Defendant Joyce M. Guy and Edward McCray “collectively” herein

entire assets in the property located at 5050 east 7th street in Port Arthur Texas

(59)

Freezing all of Co- Defendant Joyce M. Guy and Edward McCray “collectively” herein

entire assets in the property located at SBD “Lakeview”, Block 4 Lot 10 Jefferson County Texas

(60)

Freezing all of Co- Defendant Joyce M. Guy and Edward McCray “collectively” herein

entire assets in the property located at 1807 east 7th street Port Arthur Jefferson County Texas

(61)


Freezing all of Co- Defendant Joyce M. Guy and Edward McCray “collectively” herein

entire assets in the property located SBD Port Arthur City Block 210, Lot 8 Jefferson County Texas

(62)


Freezing all of Co- Defendant Joyce M. Guy and Edward McCray “collectively” herein

entire assets in the property located at SBD Port Arthur City Block 94, Lot 11 Jefferson County Texas

(63)

Freezing all of Co- Defendant Joyce M. Guy and Edward McCray “collectively” herein

entire assets in the property located at 416 DeQueen Blvd. Port Arthur Jefferson County Texas

(64)

Freezing all of Co- Defendant Joyce M. Guy and Edward McCray “collectively” herein

entire assets in the property located at 448 DeQueen Blvd. Block 172 Lot 1-2 in Port Arthur Jefferson County Texas

(65)

Freezing all of Co- Defendant Joyce M. Guy and Edward McCray “collectively” herein

entire assets in the property located at Rev Ransom Howard Street in Port Arthur Jefferson County Texas Property ID #89824 (Commercial Vacant Lot)

(66)

Freezing all of Co- Defendant Joyce M. Guy and Edward McCray “collectively” herein

entire assets as being described in Pro Se Plaintiff attached exhibit (C) “Jefferson County Texas” search Index herein all such person and person(s) to include but not limited to

As identified having (any) interests in all entities owned, in whole or in part, or controlled by, related to, or associated or affiliated with Co- Defendant Joyce M. Guy and Edward McCray “collectively” herein

“Namely” “Willie Jones, Dorothy Cooley, Norma Guy, U Guy Sr., Joyce Johnson Guy, Sarah D. West,

Gladys Carpenter, Janet L. Hart, Edward E. McCray, Edward McCray, Edward Eugene McCray Sr., Horse Grant, Allen Guy, Joyce Johnson Guy.

(67)

Freezing all Assets” of Co-Defendant “Joyce M. Guy and Edward McCray” “collectively” herein

there after providing a “verified written described accounting” and “personal financial statement” of Co-Defendant “Joyce M. Guy and Edward McCray”, “collectively” ,herein as•set plural noun: assets:

“Deeds”, Banking accounts presently held, Property, Stock, Bonds, (IRA), Commercial Real estate, Companies, Investments, estates, livestock, cattle, horses, Rental Property(s), landholding, chattel,

Valuable Art collection, investment banking, (money) to use, by purchase or expenditure, in something offering potential profitable returns, as interest, income, gold investment.

(68)

Ordered that “The United States Marshall” services shall served notice of this (TRO) Temporary Restraining Order, and Order Freeze all assets upon Co-Defendant “Joyce M. Guy and Edward McCray” collectively,

Occupants of the dwelling located at 448 DeQueen Blvd., in Port Arthur Texas that a Temporary Restraining Order,

and Order Freeze all assets is fully being enforced against them and on the Property located at 448 DeQueen Blvd. in Port Arthur Texas

(69)

Ordered that “The United States Marshall” services shall execute, secure the Temporary Restraining Order,

And “The United States Marshall” services shall execute, retrieves and secure this Order Freeze all assets upon Co-Defendant “Joyce M. Guy and Edward McCray” collectively,

Against all Personal and Business banking accounts, “Deeds”, Banking accounts presently held, Property,

Stock, Bonds, (IRA), Commercial Real estate, Companies, Investments, estates, livestock, cattle, horses, Rental Property(s), landholding, chattel,

Valuable Art collection, investment banking, (money) to use, by purchase or expenditure, in something offering potential profitable returns, as interest, income, gold investment.

(70)

Ordered that Defendant(s) Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 prohibited from any acts of

Destroying, concealment, alter, hide, screen, obscure, mask, disguise, demolish, liquidate, erase, and eliminating all material evidences supporting all subject matter herein and all assets.

(72)

Ordered that Co-Defendant(s) Joyce M. Guy and Edward McCray collectively prohibited from any acts of

Destroying, concealment, alter, hide, screen, obscure, mask, disguise, demolish, liquidate, erase, and eliminating all material evidences supporting all subject matter herein and all assets.

(73)

Ordered that Defendant(s) Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299

Immediately License “Suspended and Prohibited” from practicing law in and for the State of Texas, Until further notice of the “Honorable Justice”.

Executed on this ________ Day of ____________________ 2015


___________________________________
Honorable Justice Zack Hawthorn

United States Magistrate Judge