Request Number 13.
Admit: “You” did not request a longer extension of time from the Pro Se Plaintiff herein and agree upon in writing to reply to said
“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, in accordance with the Texas Rules of Civil Procedures 194.2, 197, and 198, (30) Days after Service of said discovery request in
cause No. A-180805 for the “Legal behalf” of Co-Defendant(s) Joyce M. Guy and Edward McCray herein.
Request Number 14.
Admit: “You” did not request a longer extension of time from the 58th Judicial District Court Judge “Bob Wortham” in order to obtain a Court Order of “approval” of the Honorable Court in
“Your” being granted a longer extension of time to reply to all of the said 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, in accordance with the Texas Rules of Civil Procedures 194.2, 197, and 198,
(30) Days after Service of said discovery request in cause No. A-180805 on the dates being described herein April 2nd 2008 and April 11th 2008
for the “Legal behalf” of Co-Defendant(s) Joyce M. Guy and Edward McCray herein.
Request Number 15.
Admit: “You” did not give the 58th Judicial District Court Judge “Bob Wortham” any Written, or Verbal notice, cellular phone or office phone communication,
memo, documents or emails transmission of any type, fax, text, between the dates of April 2nd 2008 and April 11, 2008, throughout the dates of October 14th 2009
“Your” being granted a longer extension of time to reply to all of the said 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, in accordance with the Texas Rules of Civil Procedures 194.2, 197, and 198,
“Your” were being in full possession, custody, and legal control over Pro Se Plaintiff said “Discovery requests” in cause No. A-180805 on the dates being described herein
April 2nd 2008 and April 11th 2008 for the “Legal behalf” of Co-Defendant(s) Joyce M. Guy and Edward McCray herein.
Request Number 16.
Admit: “You” did not give the 58th Judicial District Court Judge “Bob Wortham” or his office clerk or any staff member of the 58th Judicial Court
any Written form, or Verbal notice of some sort, cellular phone call or office phone communication of any type,
memos, documents or emails transmission of any type, faxes, text, between the dates of December 18th 2007 throughout the dates of April 2nd 2008 and April 11, 2008
“You” wanted to file a Motion for withdrawal in cause No. A-180805 from being acting Attorney of Record on the behalf of Co-Defendant(s) Joyce M. Guy and Edward McCray herein.
Request Number 17.
Admit: “You” did not give the 58th Judicial District Court Judge “Bob Wortham” or his office clerk or any staff member of the 58th Judicial Court any Written form,
or Verbal notice of some sort, cellular phone call or office phone communication of any type,
memos, documents or emails transmission of any type, faxes, text, between the dates of April 2nd 2008 and April 11, 2008 throughout the dates of October 14th 2009
“You” wanted to file a Motion for withdrawal in cause No. A-180805 from being acting Attorney of Record on the behalf of Co-Defendant(s) Joyce M. Guy and Edward McCray herein.
Request Number 18.
Admit: “You” filed before 58th Judicial District Court Judge “Bob Wortham” A Response to Plaintiff Motion for Sanctions against you with “Your” Affidavit attached signed and dated September 11th 2009.
For not replying to any of the Pro Se Plaintiff Discovery request between the dates of April 2nd 2008 and April 11, 2008 throughout October 13th 2009 in cause No. A-180805
Request Number 19.
Admit: “You” stated before the Honorable Court in your Response Motion for Sanctions document dated September 11th 2009,
“You” being retain by Co-Defendant Joyce M. Guy herein for purpose of (Only) writing a general denial so as to avoid a default judgment being rendered against
which you filed in December of 2007 in response to the complaint cause No. A-180805
Request Number 20.
Admit: “You” did in fact legally represent Co-Defendant(s) Joyce M. Guy and Edward McCray as acting Attorney of Record in cause No. A-180805
other then just simply filing a General Denial between the dates of December 18th 2007 throughout the dates of October 14th 2009.
Request Number 21.
Admit: “You” did in fact legally represent Co-Defendant(s) Joyce M. Guy and Edward McCray as acting Attorney of Record in cause No. A-180805 during a hearing held on the 28th day of August 2009 before the Honorable Judge Bob Wortham
Request Number 22.
Admit: “You” did in fact legally represent Co-Defendant(s) Joyce M. Guy and Edward McCray as acting Attorney of Record in cause No. A-180805 other then just simply filing a General Denial between the dates of December 18th 2007
and filed your certificate of mailing service and response to said discovery request on the 14th day of October 2009 to Plaintiff said “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, in accordance with the Texas Rules of Civil Procedures 194.2, 197, and 198, for the “Legal behalf” of Co-Defendant(s) Joyce M. Guy and Edward McCray herein.
Request Number 23.
Admit: “You” fully fail and flat out refuse to reply to any of said 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,
in accordance with the Texas Rules of Civil Procedures 194.2, 197, and 198, for the “Legal behalf” of Co-Defendant(s) Joyce M. Guy and Edward McCray herein after (30) Days after Service of said discovery request in cause No. A-180805 had expired for the “Legal behalf” of Co-Defendant(s) Joyce M. Guy and Edward McCray herein.
Request Number 24.
Admit: “You” were retain by Co-Defendant(s) Joyce M. Guy and Edward McCray to not reply to any discovery request of the Pro Se Plaintiff herein cause No. A-180805
request of Interrogatories, Request of Admission, and Request for Disclosure in the time frame dates of April 2nd 2008 and April 11, 2008 throughout April 2nd 2009 and April 11, 2009
Request Number 25.
Admit: “You” were retain by Co-Defendant(s) Joyce M. Guy and Edward McCray to not reply to any discovery request of the Pro Se Plaintiff herein cause No. A-180805 request of Interrogatories, Request of Admission,
and Request for Disclosure in the time frame dates of April 2nd 2008 and April 11, 2008 throughout September 1st 2009
Request Number 26.
Admit: “You” claim were retain by Co-Defendant(s) Joyce M. Guy and Edward McCray simply to the Attorney at Law duties of filing a General Denial between the dates of December 18th 2007
but was acting Attorney of Record throughout the dates of November 13th 2009.
Request Number 27.
Admit: “You” were retained by Co-Defendant(s) Joyce M. Guy and Edward McCray to hide all of the discovery phase of this civil cause No. A-180805 from the Pro Se Plaintiff and the 58th Judicial District Court of Jefferson County Texas
and Not allowed Pro Se Plaintiff any legal access at all to said 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, in accordance with the Texas Rules of Civil Procedures 194.2, 197, and 198, for the “Legal behalf”
of Co-Defendant(s) Joyce M. Guy and Edward McCray between the dates of April 2nd 2008 and April 11, 2008 throughout the dates of September 1st 2009.
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