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

16. Production of all Documents Defendant “Attorney and Law” herein related to files, documents, letters, correspondence, notes, communications, phone records,

employment for hire Attorney at Law contracts Defendant acquired employment from the Co-Defendant(s)

Joyce M. Guy and Edward McCray other then in cause No. A-180805 and U.S. Cause No. 1:2010-CV-00055

17. Production of all Documents Defendant “Attorney and Law” herein relating to the exact Identity of each, and all staff member

of the Defendant Law Office from the dates of November 17th 2007 throughout November 13th 2009 with each staff member day time telephone number and correct mailing address.

18. Production of all Documents Defendant “Attorney and Law” herein relating to the exact monetary payment and contract thereof the Defendant received

from Co-Defendant(s) in cause No. A-180805 to file a “General Denial” to Pro Se Plaintiff Complaint.

19. Production of all Documents Defendant “Attorney and Law” herein relating to the exact monetary payment and “Attorney/Client contract thereof the Defendant received from

Co-Defendant(s) in cause No. A-180805 to appear at a hearing on the dates of August 28th 2009 to respond to Pro Se Plaintiff

Complaint and all circumstance for the legal behalf of the Co-Defendant(s) Joyce M. Guy and Edward McCray herein McCray herein on hearing dates of August 28th 2009.

20. Production of all Documents Defendant “Attorney and Law” herein relating to the exact monetary payment and Attorney/client contract thereof the Defendant received from

Co-Defendant(s) in cause No. A-180805 to appear at a hearing on the dates of September 11th 2009 to respond to Pro Se Plaintiff

Complaint and all circumstance for the legal behalf of the Co-Defendant(s) Joyce M. Guy and Edward McCray herein on hearing dates of September 11th 2009.

21. Production of all Documents Defendant “Attorney and Law” herein relating to the exact Texas Rules of Civil Procedure allowing Defendant “Attorney at Law” herein to not respond or reply at all to any of Pro Se Plaintiff

“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 from the dates of April 2nd 2008 and April 11, 2008,

throughout the dates of October 14th 2009 which Defendant supply some sort of respond during this time frame of (1) year and (5) months and counting days Defendant not responding

22. Production of all Documents Defendant “Attorney and Law” herein relating to the exact monetary payment and Attorney/client contract thereof the Defendant represented the

Co-Defendant(s) Joyce M. Guy and Edward McCray herein McCray herein legal behalf in any criminal/civil cases other then cause No. A-180805 and U.S. Cause No. 1:2010-CV-00055