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

In The United States District Court

For The Eastern Division of Texas

Beaumont Division

Louis Charles Hamilton II

Pro Se Plaintiff

Vs.                                                                                      Cause No. 1:14-CV-592

Antoine L. Freeman J. D.

Defendant

Joyce M. Guy

Edward McCray

Co-Defendant(s)

To Defendant “Antoine L. Freeman J.D. (Attorney at Law), Pro Se Plaintiff “Louis Charles Hamilton II” herein propounding party

REQUESTS FOR ADMISSION, SET ONE

To: Antoine L. Freeman J. D. Attorney at Law AND HIS COUNSEL OF RECORD:

Pursuant to the provisions of Federal Rule of Civil Procedure 36, it is hereby requested and demanded of Defendant

Antoine L. Freeman J. D. (hereinafter “YOU” or “YOUR”),

that YOU make admissions of the following statements of fact which are materially pertinent to Plaintiff claims hereto in accordance with Rule 36,

Under which rule of procedure this request for admissions is made, thereby answering the following facts in the above-entitled and number cause,

and that such answers be sworn to and filed promptly in the office of the District Clerk

Where this cause is pending and a copy delivered to the writer within thirty (30) days from the serving of this request upon you.

Otherwise, each of the matter of which an admission is requested

and demanded shall be deemed admitted by you in accordance with Rule 36 of the Federal Rules of Civil Procedure.


Request for Admission


Truth of Facts


Admit that the following facts are true:

Request Number 1.

Admit: that you made legal claim Co-Defendant(s) Joyce M. Guy and Edward McCray herein (Only) retain the legal services of Antoine L. Freeman J.D. (Attorney at Law) for the purpose of

(Only) writing a general denial so as to avoid a default judgment being rendered against (Them)

in a civil suit in the 58th Judicial District Court of Jefferson County Texas filed in Cause No. A-180805 by Pro Se Plaintiff herein.

Request Number 2.

Admit: That You on December 18th 2007 filed for Co-Defendant(s) Joyce M. Guy and Edward McCray herein your “legal General Denial” to Complaint made by Pro Se Plaintiff herein to Cause No. A-180805

In a civil suit in the 58th Judicial District Court of Jefferson County Texas.

Request Number 3.

Admit: That you on November 13th 2009 10:22 am filed with “Lolita Ramos”, Clerk, District Court of Jefferson County, Texas

A Motion for to Withdrawal of Counsel from Co-Defendant(s) Joyce M. Guy and Edward McCray herein exactly 1 year, 10 months and 13 days of simply being “financially retain” to file a simple

“Legal General Denial” to Cause No. A-180805 on December 18th 2007

and this was you’re only “Legal Duties” and “Fiduciary Obligations” as acting retain” Counsel of Record “for the Co-Defendant(s) Joyce M. Guy and Edward McCray herein
in the entire

“Legal ongoing civil suit in common law” time frame of 1 year, 10 months and 13 days filed in the 58th Judicial District Court of Jefferson County Texas before the Honorable Bob Wortham.