FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO DEFENDANT ANTOINE L. FREEMAN J.D. (Attorney at Law) U.S. Cause No. 1:14-CV-592

In The United States District Court

For The Eastern Division of Texas

Beaumont Division

Cause No. 1:14-CV-592

Louis Charles Hamilton II

Pro Se Plaintiff

Vs.

Antoine L. Freeman J. D.

Defendant

Joyce M. Guy
Edward McCray

Co-Defendant(s)

PLAINTIFF'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO DEFENDANT ANTOINE L. FREEMAN J.D. (ATTORNEY AT LAW)

Plaintiff “Louis Charles Hamilton II by “Pro Se Counsel” herein and pursuant to Rule 34 of the Federal Rules of Civil Procedure,

hereby request that Defendant

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

Produce the originals of documents described below within thirty (30) days of service of this notice in the Pro Se Plaintiff P.O. Box 17524 Sugar Land Texas 77496

INSTRUCTIONS

1. In producing documents requested herein, you shall produce documents in full, without abridgment, abbreviation or expurgation of any sort.

2. All documents shall be segregated in accordance with the numbered and lettered paragraphs and subparagraphs herein.

3. All documents requested herein as to which you withhold production on the basis of a claim of privilege or statutory authority shall be listed in accordance with the procedure described in instruction 2 above

and shall be identified by: a) author(s); b) addressee(s); c) date; d) type of document; e)

subject matter; f) number of pages; g) number of attachments or appendices; h) indicated or blind copies; ) all persons to whom shown or explained;

j) present custodian; and k) factual or legal basis for claimed privilege, or specific statutory authority which provides the claimed base for non-production.

4. All documents requested herein which have been destroyed, placed beyond your control, or otherwise disposed of shall be identified by:

a) author(s); b) addressee(s); c) date; d) type of document; e) subject matter; f) number of pages; g) number of attachments or appendices; h) indicated or blind copies; i)

all persons to whom distributed, shown or explained; j) date of destruction or other disposition; k) reason for destruction or other disposition;

l) person authorizing destruction or other disposition; m) person destroying or otherwise disposing of document; and n) if not destroyed, person in possession of document otherwise disposed of.

DEFINITIONS

For purposes of this Request for Production of Documents, the following definitions shall apply unless otherwise specifically indicated:

1. The word "document" shall mean any written or graphic matter or other means of preserving thought or expression,

and all tangible things from which information can be processed or transcribed, including, but not limited to, correspondence, memoranda, notes, messages, letters, telegrams,

teletype messages, bulletins, diaries, chronological data, minutes, books, reports, charts, ledgers, invoices, worksheets, receipts, computer printouts,

schedules, affidavits, contracts, transcripts, surveys, graphic representations of any kind, photographs, graphs, microfilm, video tapes, tape recordings, motion pictures or other film.

2. "Person" means any natural person or any legal entity, including, but not limited to, a corporation, partnership and unincorporated association,

and any officer, director, employee, agent or other person acting or purporting to act on its behalf.

3. "And" and "or" shall be construed disjunctively or conjunctively as necessary in order to bring within the scope of each request all documents which might otherwise be construed to be outside its scope.

4. The term "and/or" is to be read in both the conjunctive and disjunctive and shall serve as a request for information which would be responsive under a conjunctive reading

in addition to all information which would be responsive under a disjunctive reading.

5. "Each" includes both "each" and "every."

6. The singular and masculine gender shall, respectively, include the plural and feminine gender, and vice versa.

7. "You" and "your" shall mean yourself and all other persons acting or purporting to act on your behalf.

8. "Relating to" and "relates to" mean, without limitation, relating to, concerning, constituting, mentioning, referring to, describing, summarizing,

evidencing, listing, relevant to, demonstrating, tending to prove or disprove, or explain.

9. "Communication" or "communications" includes, without limitation, in-person or telephone conversations, facsimiles, letters, electronic mail,

telegrams, telexes, tapes or other sound recordings, or other means of transmitting information from one source to another.

10. "Plaintiff"- The term "Plaintiff"" in the context of this case refers to “Louis Charles Hamilton II”.

11. "Defendants" - The term "Defendants" in the context of this case refers to Antoine L. Freeman J. D. (Attorney at Law), Joyce M. Guy and Edward McCray.

12. "Dwelling" means both the residence of the Co-Defendant(s) Joyce M. Guy and Edward McCray 448 DeQueen Blvd. in Port Arthur Texas 77640

and 5050 East 7th street in Port Arthur Texas 77642

13. These document requests cover the period of time from November 17th 2007 up to the date of your response to them and are continuing, to the extent Rule 26(e) requires.

In the event that any information or any documents come to your attention, possession, custody, or control subsequent to the filing of your responses to these document requests,

Which materials or information are responsive to any document request, but which were not included in your initial response thereto, please furnish said additional information materials to attorneys for plaintiffs as soon as possible.