Sunday, December 14, 2014

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

Request Number 87.

Admit: “You” Attorney at Law was retained by Co-Defendant(s) Joyce. M. Guy and Edward McCray herein cause No. A-180805 and “You” Attorney at Law appear before a hearing at the 58th Judicial District Court of Jefferson County Texas on September 11th, 2009 before the Honorable Bob Wortham and

Your Clients Co-Defendant(s) Joyce. M. Guy and Edward McCray herein

Were through “You” were order to respond to Pro Se Plaintiff Discovery request of Interrogatories, Request of Admission, and Request for Disclosure “You” held in your possession, custody and legal control since dates of April 2nd 2008 and April 11, 2008, that

“You” refused to respond to throughout the dates of September 11th, 2009 at this hearing before the Honorable Bob Wortham

Request Number 88.

Admit: “You” Attorney at Law was retained by Co-Defendant(s) Joyce. M. Guy and Edward McCray herein cause No. A-180805 and

“You” Attorney at Law appear before a hearing at the 58th Judicial District Court of Jefferson County Texas on August 28th, 2009 before the Honorable Bob Wortham and

your Clients Co-Defendant(s) Joyce. M. Guy and Edward McCray herein was required to respond to a Motion Pro Se Plaintiff filed namely a (TRO) Temporary Restraining Order Against Co-Defendant “Joyce M. Guy” herein

Request Number 89.

Admit: “You” Attorney at Law was retained by Co-Defendant(s) Joyce. M. Guy and Edward McCray herein cause No. A-180805 and “You” Attorney at Law appear before a hearing at the 58th Judicial District Court of Jefferson County Texas on August 28th, 2009 before the Honorable Bob Wortham and

Your Clients Co-Defendant(s) Joyce. M. Guy and Edward McCray herein was required to respond to a Motion Pro Se Plaintiff filed namely a Motion for a Guardian over “Norma Guy” Natural Mother to Co-Defendant Joyce M. Guy whom had power of Attorney of said “Mother”.

Request Number 90.

Admit: “You” Attorney at Law was retained by Co-Defendant(s) Joyce. M. Guy and Edward McCray herein cause No. A-180805 and had 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, and did not respond to any of said discovery request

When “You” Attorney at Law appear before a hearing at the 58th Judicial District Court of Jefferson County Texas on August 28th, 2009 before the Honorable Bob Wortham and your Clients Co-Defendant(s) Joyce. M. Guy and Edward McCray herein was required to respond to a Motion Pro Se Plaintiff filed

namely a Motion for a Guardian over “Norma Guy” Natural Mother to Co-Defendant Joyce M. Guy whom had power of Attorney of said “Mother” and

“You” did not respond to discovery request of Interrogatories, Request for Admission, and Request for Disclosure on August 28th, 2009.

Request Number 91.

Admit: “You” Attorney at Law was retained by Co-Defendant(s) Joyce. M. Guy and Edward McCray herein cause No. A-180805 and had 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 and that “You” refused to respond to any formal legal reply of some sorts to said discovery request and

“You” attended two Hearing before the Honorable Bob Wortham 58th Judicial District Court of Jefferson County Texas on dates of August 28th, 2009 and September 11th, 2009 while still not responding 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.

Request Number 92.

Admit: “You” Attorney at Law was retained by Co-Defendant(s) Joyce. M. Guy and Edward McCray herein cause No. A-180805 at the old mailing address 448 DeQueen blvd. in Port Arthur Texas

in December of 2007 and “You” having known Co-Defendant(s) last known address to be 5050 east 7th street in Port Arthur Texas77642 in the year 2009 up to November 13th of 2009

“Your” knowing full well of this change of mailing address and Co-Defendant(s) Joyce. M. Guy and Edward McCray living at a different location other then 448 DeQueen Blvd. in Port Arthur Texas while this civil suit still ongoing in the 58th Judicial District Court of Jefferson County Texas..

 Admit: “You” Attorney at Law was retained by Co-Defendant(s) Joyce. M. Guy and Edward McCray herein cause No. A-180805 at the old mailing address 448 DeQueen blvd. in Port Arthur Texas

in December of 2007 and “You” having known Co-Defendant(s) last known address to be 5050 east 7th street in Port Arthur Texas77642 in the year 2009 up to November 13th of 2009

“Your” knowing full well of this change of mailing address and Co-Defendant(s) Joyce. M. Guy and Edward McCray living at a different location other then 448 DeQueen Blvd. in Port Arthur Texas while this civil suit still ongoing in the 58th Judicial District Court of Jefferson County Texas..

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