“Louis Charles Hamilton II” REQUESTS FOR ADMISSION, Cause No. 1:14-CV-592 To Defendant “Antoine L. Freeman

Request Number 128.

Admit: “You” Attorney at Law that “Jefferson County Real Estate Index” Instrument #2009022762 in Attached document #7 herein shown the Legal Transfer of the property deed of the Co-Defendant(s) herein

Joyce M. Guy and Edward McCray” dwelling located at 448 DeQueen Blvd. in Port Arthur Texas herein on the dates of June 18th 2009 to “The Texas Department of Housing & Community Affairs

While Which “Your” in full refusal to respond to 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 copies of such “Property Deeds” ”

For the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas being already complained of in a among other cause of action “Breach of Contract dispute” in a civil suit in common law before the 58th Judicial District Court of Jefferson County Texas cause No. A-180805.

Request Number 129.

Admit: “You” Attorney at Law that “You” having in “Your” full possession, custody and legal control, over Pro Se Plaintiff herein “Motion to Compel” Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein with mailing service date executed on September 9th 2009 same cause No. A-180805

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 same cause No. A-180805,

While “You” were already during this “same time frame” personally present for one said hearing on the dates of September 11th 2009 hearing thereafter same cause No. A-180805

While “You” were already during this “same time frame” personally present for one said hearing on the dates of August 28th 2009 hearing thereafter not filing a “Motion for withdrawal” same cause No. A-180805

While “You” were already during this “same time frame” ” 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 to Produce among other things copies of Property deed for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas (Lot) 1-2 blk. 172 (Port Arthur Texas) same cause No. A-180805

While “You” Attorney at Law refusal to file “Your” “Motion for “Your” withdrawal on or before next 58th Judicial District Court in Jefferson County Texas hearing on the dates set for September 11th 2009 same cause No. A-180805.

While “You” did personally appeared as acting Attorney of Record for same cause No. A-180805 on the dates of September 11th 2009.

But “Your” never replying to or responding to any such discovery request sought by the Pro Se Plaintiff herein as described herein “Request for Admission” # 129.