Request Number 124.
Admit: “You” Attorney at Law that “You” knew from the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein
That the “Property Deed of the dwelling of 448 DeQueen Blvd. in Port Arthur Texas. Pro Se Plaintiff sent “You” herein a “Motion for Production of Document(s) dated August 12th 2009 for said “Property Deeds that’s being in the possession, custody and legal control of the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein
During this same time frame “Your” being acting Attorney of record cause No. A-180805 filed in the Jefferson County Texas Courthouse said “Property Deeds” was Legally Transfer to the Texas Department of Housing & Community Affairs on June 18th 2009 as described by “Jefferson County Real Estate Index in attached document #7 herein
Request Number 125.
Admit: “You” Attorney at Law that “You” refused to respond to any of Pro Se Plaintiff “Motion for Production of Document(s) dated August 12th 2009” on the certificate of mailing services for the same cause No. A-180805 filed in the Jefferson County Texas Courthouse (30) days thereafter service upon
“You” for the behalf of the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein and “You” did not file a Motion for withdrawal on September 9th 2009 while being in the possession, custody and legal control Pro Se Plaintiff “Motion for Production of Document(s) dated August 12th 2009”
Request Number 126.
Admit: “You” Attorney at Law that “You” refused to respond to any of Pro Se Plaintiff “Motion for Production of Document(s) dated August 12th 2009” on the certificate of mailing services for the same cause No. A-180805 filed in the Jefferson County Texas Courthouse (30) days thereafter service upon
“You” for the behalf of the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein
And “You” however in facts was retain to attend a hearing on the date of August 28th 2009 services for the same cause No. A-180805 in the capacity as Attorney of Record some (16) days after services of
“Motion for Production of Document(s) dated August 12th 2009” on the certificate of mailing services being in “Your” Possession, custody, and Control
Which “You” during this same “Time Frame” However were personally present for on the dates of August 28th 2009 hearing thereafter
While “You” already 100% being in full refusal to respond to any Pro Se Plaintiff herein discovery request in “Your” full possession, custody and legal control, discovery request of Interrogatories, Request of Admission, and Request for Disclosure Pro Se Plaintiff mailed to
“You” on the dates of April 2nd 2008 and April 11, 2008 the past year.
Request Number 127.
Admit: “You” Attorney at Law that “You” refused to respond to any of Pro Se Plaintiff “Motion for Production of Document(s) dated August 12th 2009” on the certificate of mailing services for the same cause No. A-180805 filed in the Jefferson County Texas Courthouse (30) days thereafter service upon
“You” for the behalf of the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein
And “You” however in facts was retain to attend a hearing on the date of September 11th 2009 services for the same cause No. A-180805 in the capacity as Attorney of Record some (16) days after services of “Motion for Production of Document(s) dated August 12th 2009” on the certificate of mailing services being in “Your” Possession, custody, and Control
Which “You” were during this “same time frame” personally present for one said hearing on the dates of September 11th 2009 hearing thereafter
While “You” already being in 100% full refusal to respond to any Pro Se Plaintiff herein discovery request in “Your” full possession, custody and legal control, discovery request of Interrogatories, Request of Admission, and Request for Disclosure Pro Se Plaintiff mailed to
“You” on the dates of April 2nd 2008 and April 11, 2008 the past year.
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