The Plaintiff Further State before “The Honorable Court”,
“The Defendant(s) By and through their Attorney of record Antoine L. Freeman, J.D. Texas Bar No. 24058299 was in fact served Plaintiff Request for Admissions propounded by Louis Charles Hamilton II Pro Se Plaintiff herein pursuant to rule 198 of the Texas Rules of Civil Procedure.
Filed herein as Plaintiff exhibit (K) before the “Honorable Court”.
Providing, and legally well documented additional proof with all of the court records, exhibit(s) and files herein cause No. A-180805
Thus 100% Proving the Following official legal material facts before any “Honorable Court” of Law in and for The State of Texas as follows:
1. Attorney of Record Antoine L. Freeman, J. D. Texas Bar No. 24058299 was in fact full acting Attorney of record from dates of filing a General Denial December 18th 2007 as he claim in the records and doing so further acting as Attorney of record in filing a reply to Plaintiff (Interrogatories) already filed herein and dated October 14th 2009 as Exhibit (I)
2. To now include Attorney of record was in fact full acting legal capacity in filing a reply the Plaintiff Request for Admissions exhibit (K) and dated October 14, 2009 at this point the Plaintiff point out further that Attorney of record made a illegal bogus claim before The Honorable Judge “Bob Wortham that his only legal duties as described in Plaintiff exhibit (B) paragraph III. As Stated by said Attorney of Record Antoine L. Freeman, J. D. Texas Bar No. 24058299 follows:
3. At the time of Plaintiffs discovery request Defendant’s Attorney had not been retain by Defendants to represent their interest with regard to this lawsuit, Defendant, Joyce Guy, retain the services of Antoine Freeman for the purpose of writing a general denial so as to avoid default judgment being rendered against her.
4. The Honorable Court 58th District Court Judge Bob Wortham” ruled completely erroneously in favor of said Defendant’s Attorney of record Antoine L. Freeman, J. D. Against Pro Se Plaintiff request for sanctions being level and citied against said Attorney of record Antoine L. Freeman, J. D. Texas Bar No. 24058299
In official court docket No. A-180805 records when all of Plaintiff evidence filed herein support that a legal finding that Defendant’s Attorney did violated Rule 193.1 by failing to respond to Plaintiff’s discovery request up to almost 2 years while having full legal knowledge of such a discovery request was being pursued by the Pro Se Plaintiff
A. Attorney of Record Antoine L. Freeman, J. D. Was acting with physical fiduciary capacities as an Attorney of Law for the State of Texas Bar. No. 24058299 on or about December 18th 2007 and continue doing the same legal capacities being fully intact as acting Attorney of record and filed official court records with the Plaintiff as described in Plaintiff exhibit (I) and (K) dated October 14, 2009
B. The Attorney of record Antoine L. Freeman, J. D. then at this point took his civil wrongful lie, and false presentation filing before the 58th District Jefferson County Honorable Court Judge “Bob Wortham” stating he was not the Attorney of record and only filed a general denial with the Court and this was his only legal obligations, and this ended on December 18th 2007
C. To include as further evidence to support the Plaintiff cause for sanctions against said Attorney Antoine L. Freeman, J. D. the Plaintiff exhibit (A) Affidavit of Defendant “Joyce M. Guy” dated September 11, 2009 to support another bogus Defendant claim too, on behalf of her own Attorney of record Antoine L. Freeman, J. D. rouge acts to “avoid sanctions” in favor of the Plaintiff when both Defendant(s) collectively and Attorney of record Antoine L. Freeman, J. D. having full legal knowledge of such a discovery request being in place, and pursued from December 18th 2007 throughout October 14, 2009
D. Attorney of Records Antoine L. Freeman, J. D. maintain his only duties was Just filing a “General Denial” before the Honorable 58th District Court Judge “Bob Wortham” as his Attorney of record signature and Bar No. 24058299 is materially present on both Plaintiff exhibit (I) and (K) dated October 14, 2009 well beyond the filing of said General Denial on December 18th 2007
E. Namely official Court discovery documents devise in the form of “Request for Admissions” pursuant to Rule 198 of the Texas Rules of Civil Procedure and Plaintiff First set of Interrogatories” pursuant to 197 of the Texas Rules of Civil Procedure both being dated on October 14, 2009 proving the Pro Se Plaintiff was in pursuit of civil discovery well up to 2 years through Defendant(s) Attorney of Record, Antoine L. Freeman, J. D. with his signature and Bar No. 24058299 being materially present against said Attorney Claims he was only acting in December 18th 2007
F. As this Rouge Attorney did aid in criminally stalling against the Rules of Civil Procedures tactics with full payment to doing such actions by said defendant(s) to achieve this lawless civil act against the Pro Se Plaintiff rights to a Just cause of action before any court of Law within the State of Texas in Docket No. A-180805
G. Yet” Attorney of Record Antoine L. Freeman, J. D. right after October 14, 2009 was granted in addition to sanctions ruling in his favor his additional Motion to be removed as acting Attorney from this case dated November 13th 2009, after 2 years being the official acting Attorney of record but claiming, and representing before the Honorable 58th District Court Judge “Bob Wortham” that this was not the legal case at hand in court records after December 18th 2007 general denial filing.
H. “However” elementary material legal facts containing Attorney Antoine L. Freeman, J. D. “very own signature” and Bar No. 24058299 is materially present in Plaintiff Exhibit(s) (I) and (K) proving Attorney Antoine L. Freeman, J. D. was representing the Defendant(s) “Joyce M. Guy and Edward McCray” collectively with actual payment render and received for billing hours throughout the years of 2007, 2008 and October of 2009, up to the actual date of November 13th 2009 but previously made claims before the Honorable 58th District Court Judge “Bob Wortham” in Plaintiff exhibit (B) *Response to Plaintiff’s Motion for Sanctions dated 11th of September of 2009 his only “Attorney duties” was to Draft and file a general denial on December 18th 2007 in his Attorney capacities at this time frame with payment for such as a Attorney of Law for the State of Texas Bar. No. 24058299 on or about December 18th 2007 such general denial being official filed in Court records.
I. While Pro Se Plaintiff without any law degree already being completely robbed of his profession by the actions of the Defendant(s) in the stealing namely of all of the Plaintiff Construction tools, inflicting real Hardship in this act alone
J. (Now) Plaintiff being giving a additional 100% unfair disadvantage by a “Thug Rouge” Lic# Attorney of Law in and for The State of Texas, and his Bogus counsel of law professional degree representation before the “Honorable 58th District Court Judge “Bob Wortham” in Jefferson County Texas to wit:
K. Said Attorney of record Antoine L. Freeman, J. D. did in all facts aid in hiding the Defendant(s) Collectively Material Facts of Construction Corruption of Hurricane Damages funds at 3 counts, Fraud on Insurance Monies at 3 counts, and Fraud of FEMA at 1 count, while further aiding through the Court discovery records process further theft of the Plaintiff Property namely all of Plaintiff Construction tools and further aids in all acts as described in Plaintiff Complaint filed in the records before the Honorable Court against the described Defendant(s)
L. In order that this “bogus rouge” Attorney of Law Antoine L. Freeman, J. D. “legal commitment” was to being paid in his official capacity before the “Honorable 58th District Court” and The State of Texas” to hide such “Major Grand thievery” commitment(s) of the Defendants collectively from December 18th 2007 to October 14, 2009 as described by all of the Plaintiff Exhibit(s) (I) and (K) “Request for Admissions” pursuant to Rule 198 of the Texas Rules of Civil Procedure and Plaintiff First set of Interrogatories” pursuant to 197 of the Texas Rules of Civil Procedure both being dated on October 14, 2009 and there (Now) official filing herein this undersigned date before the Honorable 58th District Court of Jefferson County Texas
M. Attorney of Record Antoine L. Freeman, J. D. being fully committed to this “actual physical constructive fraud” of The State of Texas Jefferson County Court records and actual physical constructive fraud in conspire against the Rules of Civil procedures as warrant by Pro Se Plaintiff Motion for sanctions as Attorney of record actual physical constructive fraud for this cause No. A-180805 to conspire to do the “Same Scheme of Crooked things” in his no less legal “attorney capacity” in and for the State of Texas on the full benefit package and behalf of the described Defendant(s) “Joyce M. Guy” and Edward McCray full legal behalf to achieve wrongfully civil advantages against the Plaintiff to commit continue collectively fraud of court records, while producing many bald face lie’s before a Honorable Court Judge Namely “Judge Bob Wortham”
N. And all of Court records for docket No. A-180805 with intent of sleight of hand document deception and derailment of the Plaintiff civil claim completely at that time frame described now again before the 58th District Court in Jefferson County Texas while defendant(s) doing such thievery in the past and now continue doing the same by through their acting “legal capacity status” of Professional “Attorney of Record” Namely Antoine L. Freeman, J. D. Texas Bar No. 24058299. As this Civil Action being fully investigated and prosecuted by Pro Se Plaintiff herein and now all evidence of support are official exhibit(s) and filed within the “Jefferson County Texas” court records.
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