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

8. Any and all records, correspondence, notes, communications, and other documents concerning or relating to any private hire authority for Defendant behalf

“investigating the circumstances” under which you were retain after acquired employment from the Co-Defendant(s) Joyce M. Guy and Edward McCray.

9. Any and all records, correspondence, notes, communications, and other documents, contracts concerning or relating to Monetary retain

“Attorney at Law” Payments of services Defendant received from Co-Defendant(s) Joyce M. Guy and Edward McCray.

10. Production of all of Defendant “Attorney and Law” Contracts with clients namely Co-Defendant(s) Joyce M. Guy and Edward McCray in cause No. A-180805.

11. Production of documents of all of Defendant “Attorney and Law” related to files, documents, letters, motions, certificate of mailing services, correspondence, notes, communications, phone records,

being received in cause No. A-180805 from Pro Se Plaintiff Louis Charles Hamilton II to the Defendant for the behalf of the Co-Defendant(s) Joyce M. Guy and Edward McCray.

12. Production of all of Defendant “Attorney and Law” Contracts with clients namely Co-Defendant(s) Joyce M. Guy and Edward McCray in U.S. Cause No. 1:2010-CV-00055 as described in paragraph 3 above.

13. Production of all of Defendant “Attorney and Law” entire cause No. for each and every case load for every client

Defendant office has legally represent in a civil court of law in and for the State of Texas from the exact dates of December 18th 2007 throughout December 18th 2014

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

Defendant contacted another Attorney at Law office to take over in cause No. A-180805 Defendant made such requested and or made such inquiry for the behalf of the Co-Defendant(s) Joyce M. Guy and Edward McCray.

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

Defendant contacted the 58th Judicial District Court Honorable Judge Bob Wortham, and or his staff requesting to be removed as acting “Attorney of Record” from the cause No. A-180805 on or before the dates of November 13th 2009 or having another Attorney at Law office to take over in cause No. A-180805

as Defendant herein made such requested and or made such inquiry for the behalf of the Co-Defendant(s) Joyce M. Guy and Edward McCray on or before the dates of November 13th 2009.

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