Wednesday, December 17, 2014

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

23. Production of 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 or computer filing system for all documents, records, contracts, and banking records.

24. Production of all Documents Defendant “Attorney and Law” herein relating to the exact certificate of mailing services Defendant received 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.

 25. Production of 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 2014.

26. Production of 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 of 2007 throughout December 2014.

27. Production of 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.

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