Request Number 4.
Admit: That you on or about April 2nd 2008 and April 11, 2008 you were in possession, custody, and control of Pro Se Plaintiff Discovery request for Interrogatories, Request of Admission, and Request for Disclosure in accordance with the Texas Rules of Civil Procedures 194.2, 197, and 198,
to Cause No. A-180805 in a civil suit in the 58th Judicial District Court of Jefferson County Texas.
Request Number 5.
Admit: that you did not file a “Motion for withdrawal of Counsel” from the Co-Defendant(s) Joyce M. Guy and Edward McCray herein “Between” the dates of December 18th 2007 your claim of filing your “General Denial”(Only) to cause No. A-180805 to the date of April 2nd 2008 and April 11, 2008, after being in possession, custody, and control of
Pro Se Plaintiff Discovery request for Interrogatories, Request of Admission, and Request for Disclosure in accordance with the Texas Rules of Civil Procedures 194.2, 197, and 198, during this time frame “You” did not file a “Motion for withdrawal of Counsel to cause No. A-180805
Request Number 6.
Admit: that you after being in possession, custody, and control of Pro Se Plaintiff Discovery request for Interrogatories, Request of Admission, and Request for Disclosure in accordance with the Texas Rules of Civil Procedures 194.2, 197, and 198, from the dates of April 2nd 2008 and April 11, 2008,
throughout October 14th 2009 during this time frame of (1) year and (5) months “You” did not file a “Motion for withdrawal of Counsel to cause No. A-180805
Request Number 7.
Admit: that “You” being in full possession, custody, and legal control over 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,
“Between” the dates of April 2nd 2008 and April 11, 2008, throughout the dates of October 14th 2009 during this time frame of (1) year and (5) months and counting days
“You” finally filed a “Certificate of Mailing Service” on or about October 14th 2009 to cause No. A-180805 to reply to said Discovery request of Interrogatories, Request for Admission, and Request for Disclosure that the Pro Se Plaintiff herein Mail to “You”
between the dates of April 2nd 2008 and April 11th , of 2008 in a Civil Suit in Common Law within the State of Texas.
Request Number 8.
Admit: That “You” being in full possession, custody, and legal control over 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,
“Between” the dates of April 2nd 2008 and April 11, 2008, throughout the dates of April 2nd 2009 and April 11th 2009 “You” for a time frame of (1) exact year during this said time frame
of being in full possession, custody, and legal control over said Pro Se Plaintiff Discovery request for Interrogatories, Request for Admission, and Request for Disclosure
“You” did not even reply at all to any of the Pro Se Plaintiff Discovery legal request for Interrogatories, Request of Admission, and Request for Disclosure
that was mailed to you in accordance with the Texas Rules of Civil Procedures 194.2, 197, and 198, in cause No. A-180805 filed in the 58th Judicial District Court of Jefferson County Texas
Request Number 9.
Admit: “You” did not file a “Motion for withdrawal of Counsel” to cause No. A-180805 between the dates of April 2nd 2008 and April 11, 2008, throughout the dates of April 2nd 2009 and April 11th 2009 (1) exact year
“Your” being in full possession, custody, and legal control over Pro Se Plaintiff Discovery request for Interrogatories, Request of Admission, and Request for Disclosure in accordance with the Texas Rules of Civil Procedures 194.2, 197, and 198,.
Request Number 10.
Admit: “You” did not file a “Motion for withdrawal of Counsel” to cause No. A-180805, Between the dates of April 2nd 2009 and April 11th 2009 while
“Your” in full possession, custody, and legal control over Pro Se Plaintiff Discovery request for Interrogatories, Request of Admission,
and Request for Disclosure in accordance with the Texas Rules of Civil Procedures 194.2, 197, and 198, “Throughout” the dates of October 14th 2009 some (6) months during this additional time frame dates
“Your” in full possession, custody, and legal control over Pro Se Plaintiff Discovery request for Interrogatories, Request of Admission, and Request for Disclosure in accordance with the Texas Rules of Civil Procedures 194.2, 197, and 198, .
Request Number 11.
Admit: Between” the dates of April 2nd 2008 and April 11, 2008, “Your” in full possession, custody, and legal control over Pro Se Plaintiff Discovery request
for Interrogatories, Request of Admission, and Request for Disclosure in accordance with the Texas Rules of Civil Procedures 194.2, 197, and 198,
“You” were legally required to file a reply of some sorts (30) days thereafter Pro Se Plaintiff herein made such a Discovery request upon
“You” for a legal response and reply to Interrogatories, Request of Admission, and Request for Disclosure in accordance with the Texas Rules of Civil Procedures 194.2, 197, and 198,. On or about the dates of April 2nd 2008 and April 11th, 2008.
Request Number 11.
Admit: that “You” in cause No. A-180805 “Between” the dates of April 2nd 2008 and April 11, 2008, throughout the dates of October 14th 2009 “Your” in full possession, custody, and legal control
over Pro Se Plaintiff Discovery request for Interrogatories, Request of Admission, and Request for Disclosure in accordance with the Texas Rules of Civil Procedures 194.2, 197, and 198,
“You” never informed the Honorable Judge “Bob Wortham” of the 58th Judicial District Court of Jefferson County Texas
“Your” being in complete refusal to file a legal response and reply to any of the 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, in accordance with the Texas Rules of Civil Procedures 194.2, 197, and 198, in cause No. A-180805.
Request Number 12.
Admit: “You” never informed the Honorable Judge “Bob Wortham” of the 58th Judicial District Court of Jefferson County Texas between the time frame dates of April 2nd 2008 and April 11, 2008, throughout the dates of April 2nd 2009 and April 11th 2009 (1) exact year
“Your” being in full possession, custody, and legal control over Pro Se Plaintiff Discovery request for Interrogatories, Request of Admission, and Request for Disclosure in accordance with the Texas Rules of Civil Procedures 194.2, 197, and 198,.
“Your” being in complete refusal to file a legal response and reply to any of the 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, in accordance with the Texas Rules of Civil Procedures 194.2, 197, and 198, in cause No. A-180805 for the “Legal behalf” of Co-Defendant(s) Joyce M. Guy and Edward McCray herein.
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