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

SCHEDULE OF DOCUMENTS

1. Any and 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.

2. Any and 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.

3. Any and 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

4. Any and all records, correspondence, notes, communications or other documents which are relevant to the allegations of the complaint,

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

5. Any and 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.

6. Any and 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 any evaluations prepared by anyone about how he performed those duties.

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