Thursday, December 11, 2014

Defendant “Antoine L. Freeman J.D. (Attorney at Law)” Cause No. 1:14-CV-592 “First Set of Interrogatories”

Interrogatories

(1)

Explain in full expert Attorney at Law details, and Supply in full details also any and all legal court documents, letters, faxes, text, memos, emails, in support from the date of December 18th 2007 throughout the dates of October 14th 2009 you

Defendant “Antoine L. Freeman, J.D. Texas Bar No. 24058299 herein was (Only) acting in the “legal capacitates” as a Attorney at Law to file a General Denial (Only)

to reply in the Complaint made against Co-Defendant(s) Joyce M. Guy and Edward McCray( herein )

In a civil suit in the 58th Judicial District Court of Jefferson County Texas filed in Cause No. A-180805 that you were retain to for such services from said time frame of December 18th 2007

and still remaining (Acting) Attorney of record throughout the dates of October 14th 2009, up till the dates November 13th 2009 10:22 AM when you file a “Motion for Withdrawal” in cause No. A-180805

a. Explain in full detail just what was all of your legal duties as a Attorney of Law” you performed for the full behalf of the Co-Defendant(s) Joyce M. Guy and Edward McCray (herein)

between the dates and time frame from December 18th 2007 when you filed your general denial and all of your legal duties you performed their after December 18th 2007 throughout the dates November 13th 2009 10:22 AM time frame when you file a

“Motion for Withdrawal” in cause No. A-180805, describing all meeting, events, hearings you attended, Motions you filed, phone records and communications made thereof

with Co-Defendant(s) Joyce M. Guy and Edward McCray in response to any court discovery documents Pro Se Plaintiff herein filed and mail you copies thereof.

b. Stating and explaining in full legally at what point in date and precise time in month and exact year was you legal services in the capacity of a Attorney of Law in and For The State of Texas did your fudicary employment and responsibility to the

58th Judicial Court of Jefferson County Texas in all facts legally ended and your being legally discharged by the Co-Defendant(s) Joyce M. Guy and Edward McCray herein from acting as Attorney of record for a civil suit in the 58th Judicial District Court of Jefferson County Texas filed in Cause No. A-180805 between the dates of December 18th 2007 throughout the dates November 13th 2009

c. Provide a detail Month to Month account of each of your duties and billing hours you performed, to include your staff performed for the legal behalf of Co-Defendant(s) Joyce M. Guy and Edward McCray herein between the dates of December 18th 2007 throughout the dates November 13th 2009

And Supply in support of any and all legal court documents, letters, faxes, text, memos, emails, from the date of December 18th 2007 throughout the dates of November 13th 2009 providing proof in date and time of month and year your Attorney at Law Services ended for the Co-Defendant(s) Joyce M. Guy and Edward McCray herein.

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