Sunday, December 21, 2014

MOTION TO FREEZE DOCUMENTS, ASSETS, OF DEFENDANT ANTOINE L. FREEMAN J.D., "Attorney at Law" et al U.S. CAUSE No.1:14-CV-592

(63)

Freezing all of Defendant Antoine L. Freeman J. D. (Attorney at Law) herein and all Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein

Business records, banking records, personal banking records, property deeds, court records, phone records, computer records, notes, ledgers, diaries,

(IRS) records, Insurance companies(s) records, FEMA records, Hurricanes “Rita”, “Humberto” and “Ike” records thereof,

And all assets for all of the above listed Defendant and Co-Defendant(s) collectively in the United States of America described as follows:

(64)

Freezing enforced against Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 240582999 herein as Follows:

Freezing 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 from the dates of November 17th 2007 throughout December 1st 2015.

(65)

Freezing 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.

(66)

Freezing 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

(67)

Freezing all records, correspondence, notes, communications or other documents which are relevant to the allegations of this complaint,

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

(68)

Freezing 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.

(69)

Freezing 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 freezing any

and all evaluations prepared by anyone about how he performed those duties for the behalf of the Co-Defendant(s) collectively herein.

(70)

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

(71)

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

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

(72)

Freezing all records, and all Documents of Defendant “Attorney and Law”, 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.

(73)

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

(74)

Freezing all documents 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.

(75)

Freezing all of Defendant “Attorney and Law” Contracts for hire of services with clients namely Co-Defendant(s) Joyce M. Guy and Edward McCray in U.S. Cause No. 1:2010-CV-00055

(76)

Freezing all Documents 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

(77)

Freezing 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

or Defendant staff made such requested and or made such inquiry for the behalf of the Co-Defendant(s) Joyce M. Guy and Edward McCray.

(78)

Freezing 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 showing 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.

(79)

Freezing 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

(80)

Freezing 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 2015 with each staff member day time telephone number and correct mailing address.

(81)

Freezing 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.

(82)

Freezing 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 on hearing dates of August 28th 2009.

(83)

Freezing 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.

(84)

Freezing all Documents Defendant “Attorney and Law” herein relating 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.

(85)

Freezing 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
(86)

Freezing all Documents Defendant “Attorney and Law” herein relating to the exact ledger of cause No. A-180805

resulting from business transactions and principal book keeping and computer filing system for all documents, records, contracts, and banking records.

(87)

Freezing all Documents Defendant “Attorney and Law” herein relating to the exact “certificate of mailing services”

Defendant received (Legal Court Documents) in cause No. A-180805 from Pro Se Plaintiff herein for the behalf of the Co-Defendant(s) Joyce M. Guy and Edward McCray herein.

(88)

Freezing all Documents Defendant “Attorney and Law” herein relating to the business transactions, dealings,

and or relationship between the Defendant “Attorney at Law” with the Co-Defendant(s) Joyce M. Guy and Edward McCray herein other than a Attorney/client relationship between the dates of 1980 throughout 2015.
(89)

Freezing all Documents Defendant “Attorney and Law” herein relating to the business transactions,

dealings, (IRS) records showing the Annually Income received for the Defendant Law Office herein from the dates of November 17th 2007 throughout December 2015.

(90)

Freezing all Documents Defendant “Attorney and Law” herein relating to the Defendant having another

“Attorney/Client Relationship other then in cause No. A-180805 showing Defendant did not actually respond to 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 for other Clients retain for Defendant “Legal Services” other than the Co-Defendant(s) Joyce M. Guy and Edward McCray herein.

(91)

Freezing all records showing the Defendant staff qualifications to perform those duties acting on behalf of Defendant

“Attorney at Law” herein Law Offices in and for the State of Texas from the dates of November 17th 2007 - 2015.

(92)

Freezing all of Defendant “Attorney and Law” entire cause No. Ledger showing for each and every case load for the Defendant “Law office”

he has legally represent in a civil court in a suit in common law in and for the State of Texas from the exact dates of December 18th 2007

throughout December 18th 2014 showing each cause No.

“The exact Courthouse in Texas whereby Defendant represented,

ledger showing of each documents and motions received and filed response thereof per each cause No.,

with Production of Documents on all return Defendant certificate of mailing services to “opposition counsel or Pro Se (Person or Persons)”.

(93)

Freezing all Documents, Birth records, Church records, Hospital (DNA) records all of Defendant “Attorney and Law” herein

having descended from a common ancestor or constituting a people, clan, tribe, or family,

relative or kinsman with the Co-Defendant(s) Joyce M. Guy and Edward McCray herein.

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