Request Number 122.
Admit: “You” Attorney at Law that “You” received and had in “Your” possession, custody, and legal control from Pro Se Plaintiff “Louis Charles Hamilton II” herein a “Motion for Production of Document(s) dated August 12th 2009” on the certificate of mailing services for the same cause No. A-180805 filed in the Jefferson County Texas Courthouse
Said Motion for Production of Document(s) requested “among other things” copies of the Property Deeds of the dwelling of 448 DeQueen Blvd. in Port Arthur Texas.
That’s being in the possession, custody and legal control of the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein
Request Number 123.
Admit: “You” Attorney at Law that “You” received and had in “Your” possession, custody, and legal control from Pro Se Plaintiff “Louis Charles Hamilton II” herein a “Motion for Production of Document(s) dated August 12th 2009” on the certificate of mailing services for the same cause No. A-180805 filed in the Jefferson County Texas Courthouse and
“You” Attorney at Law was retain to attended a hearing on August 28th 2009 (16) days later after “Your” receiving a “Motion for Production of Document(s) dated August 12th 2009” for the Behalf of the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein
While 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 “You” Attorney at Law refused to respond and that on the date of “August 12th 2009”
And “You” Attorney at Law did not file any Motion for withdrawal on “August 12th 2009 from cause No. A-180805 filed in the Jefferson County Texas Courthouse.
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