Request Number 148.
Admit: You” Attorney at Law that “Your” Affidavit in support of your reply to Pro Se Plaintiff “Motion for Sanctions” against you Document #9 herein with
false statement made by “You” was Placed in the United States Mail and Publically Mailed to Co -Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein Cause No. A-180805
During this same time frame “Your” being acting Attorney of record cause No. A-180805 filed in the Jefferson County Texas Courthouse said
“Property Deeds” ” for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas of the Co-Defendant(s) “Joyce M. Guy and Edward McCray herein
Was Legally Transfer to the Texas Department of Housing & Community Affairs on June 18th 2009 as described by
“Jefferson County Real Estate Index in attached document #7 herein for a $76,000.00 U. S. Dollars Housing Grant
Request Number 149.
Admit: You” Attorney at Law that “Your” Affidavit in support of your reply to Pro Se Plaintiff “Motion for Sanctions” against you Document #9 herein
with false statement made by “You” was Placed in the United States Mail and Publically Mailed to The Jefferson County Texas Court House “Clerk of District Court” for cause No. A-180805
During this same time frame “Your” being acting Attorney of record cause No. A-180805 filed in the Jefferson County Texas Courthouse said
“Property Deeds” ” for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas of the Co-Defendant(s) “Joyce M. Guy and Edward McCray herein
Was Legally Transfer to the Texas Department of Housing & Community Affairs on June 18th 2009 as described by
“Jefferson County Real Estate Index in attached document #7 herein for a $76,000.00 U. S. Dollars Housing Grant
Request Number 150.
Admit: You” Attorney at Law that “Your” Affidavit in support of your reply to Pro Se Plaintiff “Motion for Sanctions” against you Document #9 herein
with false statement made by “You” was Placed in the United States Mail and Publically Mailed to
The Jefferson County Texas Court House “Clerk of District Court” for cause No. A-180805
And was electronically computer filed in Document # 8 herein 58th Judicial District Court of Jefferson County Texas “Case Ledger” and Court Records for cause No. A-180805
During this same time frame “Your” being acting Attorney of record cause No. A-180805 filed in the Jefferson County Texas Courthouse said
“Property Deeds” ” for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas of the Co-Defendant(s) “Joyce M. Guy and Edward McCray herein
Was Legally Transfer to the Texas Department of Housing & Community Affairs on June 18th 2009 as described by
“Jefferson County Real Estate Index in attached document #7 herein for a $76,000.00 U. S. Dollars Housing Grant
Request Number 151.
Admit: “You” Attorney at Law that “Your” reply/respond to Pro Se Plaintiff “Motion for Sanctions” against you Document #1 herein
with false statement made by “You” was Placed in the United States Mail and Publically Mailed to the Pro Se Plaintiff herein at P.O. Box 342 Port Arthur Texas 77640
During this same time frame “Your” being acting Attorney of record cause No. A-180805 filed in the Jefferson County Texas Courthouse said
“Property Deeds” ” for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas of the Co-Defendant(s) “Joyce M. Guy and Edward McCray herein
Was Legally Transfer to the Texas Department of Housing & Community Affairs on June 18th 2009 as described by
“Jefferson County Real Estate Index in attached document #7 herein for a $76,000.00 U. S. Dollars Housing Grant
Request Number 152.
Admit: “You” Attorney at Law that “Your” reply/respond to Pro Se Plaintiff “Motion for Sanctions” against you Document #1 herein with false statement made by
“You” was Placed in the United States Mail and Publically Mailed to Co -Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein Cause No. A-180805
During this same time frame “Your” being acting Attorney of record cause No. A-180805 filed in the Jefferson County Texas Courthouse said
“Property Deeds” ” for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas of the Co-Defendant(s) “Joyce M. Guy and Edward McCray herein
Was Legally Transfer to the Texas Department of Housing & Community Affairs on June 18th 2009 as described by
“Jefferson County Real Estate Index in attached document #7 herein for a $76,000.00 U. S. Dollars Housing Grant
Request Number 153.
Admit: “You” Attorney at Law that “Your” reply/respond to Pro Se Plaintiff “Motion for Sanctions” against you Document #1 herein with false statement made by
“You” was Placed in the United States Mail and Publically Mailed to The Jefferson County Texas Court House “Clerk of District Court” for cause No. A-180805
During this same time frame “Your” being acting Attorney of record cause No. A-180805 filed in the Jefferson County Texas Courthouse said
“Property Deeds” ” for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas of the Co-Defendant(s) “Joyce M. Guy and Edward McCray herein
Was Legally Transfer to the Texas Department of Housing & Community Affairs on June 18th 2009 as described by
“Jefferson County Real Estate Index in attached document #7 herein for a $76,000.00 U. S. Dollars Housing Grant
Request Number 154.
Admit: “You” Attorney at Law that “Your” reply/respond to Pro Se Plaintiff “Motion for Sanctions” against you Document #1 herein
with false statement made by “You” was Placed in the United States Mail and Publically Mailed to
The Jefferson County Texas Court House “Clerk of District Court” for cause No. A-180805 by “You”
And was electronically computer filed in Document # 8 herein 58th Judicial District Court of Jefferson County Texas “Case Ledger”
During this same time frame “Your” being acting Attorney of record cause No. A-180805 filed in the Jefferson County Texas Courthouse said
“Property Deeds” ” for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas of the Co-Defendant(s) “Joyce M. Guy and Edward McCray herein
Was Legally Transfer to the Texas Department of Housing & Community Affairs on June 18th 2009 as described by
“Jefferson County Real Estate Index in attached document #7 herein for a $76,000.00 U. S. Dollars Housing Grant
Request Number 155.
Admit: “You” Attorney at Law that “You” filed Co-Defendant “Joyce M. Guy “ herein “Affidavit in Support” of
“Your” response reply to Pro Se Plaintiff Motion for Sanctions against you Dated September 11th 2009 attached document # 10 herein
Request Number 156.
Admit: “You” Attorney at Law that on Document # 10 herein Co-Defendant “Joyce M. Guy” herein
“Sworn Affidavit Statement States among other things “being personally acquainted with the facts alleged”, Retained Defendant (You)
to draft and file a general denial on Co-Defendant Behalf.
Co-Defendant did not retain (You) to represent (Co-Defendant) beyond drafting and filing a general denial on my behalf
until sometime in August of 2009 when (You) informed me that Pro Se Plaintiff secured a hearing with regards to this lawsuit (A-180805)
(You) informed (Co-Defendant) between April 2nd 2008 and April 11th 2008 about Pro Se Plaintiff discovery request
It was (Co-Defendant) decision and not (You) not to respond to the discovery request of Pro Se Plaintiff.
Request Number 157.
Admit: You having full legal “Attorney at Law” knowledge of Required Pro Se Plaintiff discovery request for
admissions, interrogatories and Disclosure for cause No. A-180805
as Co-Defendant “Joyce M. Guy” and “You” corroborate the same facts in refusal to respond to discovery for over
a full year in document #1 and document # 10 attached herein
Request Number 158.
Admit: “You” Attorney at Law that “You” drafted Co-Defendant “Joyce M. Guy” herein “Affidavit” dated September 11th 2009 for
“Your” own Defense response reply to Pro Se Plaintiff Motion for Sanctions against “You” dated September 11th 2009 attached
In “Your” response to Pro Se Plaintiff motion for sanctions dated the 11th day of September 2009 Document # 1 herein
You state of having any knowledge of “Required Pro Se Plaintiff discovery request for admissions, interrogatories and Disclosure on or about the dates of
April 2nd 2008 and April 11, 2008 as described in Document # 1 attached herein
having any knowledge of “Required Pro Se Plaintiff discovery request for admissions, interrogatories and Disclosure on or about the dates of April 2nd 2008
and April 11, 2008 and as described in Document # 10 attached herein
And further Admit this is not-correct and completely a false statement made by “you”
“Attorney at Law” and made by your client being Co-Defendant “Joyce M. Guy” herein in regards to the correct dates of
“Your” both legally having knowledge of Pro Se Plaintiff discovery request for admissions, interrogatories and Disclosure
And the correct date is March 14th 2008 “Your” having actual knowledge of “Required Pro Se Plaintiff discovery request for
admissions, interrogatories and Disclosure as described in Document # 8 herein 58th Judicial District Court of Jefferson County Texas “Case Ledger”
Request Number 159.
Admit: “You” Attorney at Law that “Your” Affidavit in support of your reply to Pro Se Plaintiff “Motion for Sanctions” against you
Document #9 herein and your response to Pro Se Plaintiff Motion for sanctions against “You” Document # 1 herein and
Co-Defendant “Joyce M. Guy” “Affidavit in support of “You” document # 10 herein
Contain false statement made by “You” and Co-Defendant “Joyce M. Guy having any knowledge of
“Required Pro Se Plaintiff discovery request for admissions, interrogatories and Disclosure on or about the dates of April 2nd 2008 and April 11, 2008
and as described in Document #1 and #10 attached herein
And further Admit all three documents #1, #9 and #10 was Placed in the United States Mail and
Publically Mailed to the Pro Se Plaintiff herein at P.O. Box 342 Port Arthur Texas 77640 by “You”
Request Number 160.
Admit: “You” Attorney at Law that “Your” Affidavit in support of your reply to Pro Se Plaintiff “Motion for Sanctions” against you
Document #9 herein and your response to Pro Se Plaintiff Motion for sanctions against “You” Document # 1 herein and
Co-Defendant “Joyce M. Guy” “Affidavit in support of “You” document # 10 herein
Contain false statement made by “You” and Co-Defendant “Joyce M. Guy having any knowledge of
“Required Pro Se Plaintiff discovery request for admissions, interrogatories and Disclosure on or about the dates of
April 2nd 2008 and April 11, 2008 and as described in Document #1 and #10 attached herein
And further admit all three documents #1, #9 and #10 was Placed in the United States Mail and Publically Mailed to
Co -Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein Cause No. A-180805
Request Number 161.
Admit: “You” Attorney at Law that “Your” Affidavit in support of your reply to Pro Se Plaintiff “Motion for Sanctions” against you Document #9 herein
and your response to Pro Se Plaintiff Motion for sanctions against “You” Document # 1 herein and Co-Defendant “Joyce M. Guy” “Affidavit in support of “You” document # 10 herein
Contain false statement made by “You” and Co-Defendant “Joyce M. Guy having any knowledge of
“Required Pro Se Plaintiff discovery request for admissions, interrogatories and Disclosure on or about the dates of April 2nd 2008 and April 11, 2008 and as described in
Document #1 and #10 attached herein
And further Admit all three documents #1, #9 and #10 was Placed in the United States Mail and Publically Mailed to
The Jefferson County Texas Court House “Clerk of District Court” for cause No. A-180805
Request Number 162.
Admit: “You” Attorney at Law that “Your” Affidavit in support of your reply to Pro Se Plaintiff “Motion for Sanctions” against you Document #9 herein
and your response to Pro Se Plaintiff Motion for sanctions against “You” Document # 1 herein and Co-Defendant “Joyce M. Guy” “Affidavit in support of “You” document # 10 herein
Contain false statement made by “You” and Co-Defendant “Joyce M. Guy having any knowledge of
“Required Pro Se Plaintiff discovery request for admissions, interrogatories and Disclosure on or about the dates of
April 2nd 2008 and April 11, 2008 and as described in Document #1 and #10 attached herein
And further Admit all three documents #1, #9 and #10 was Placed in the United States Mail and
Publically Mailed to The Jefferson County Texas Court House “Clerk of District Court” for cause No. A-180805
And was electronically computer filed in Document # 8 herein 58th Judicial District Court of Jefferson County Texas “Case Ledger” and Court Records for cause No. A-180805
Request Number 163.
“You” Attorney at Law that “Your” Affidavit in support of your reply to Pro Se Plaintiff “Motion for Sanctions” against you Document #9 herein
and your response to Pro Se Plaintiff Motion for sanctions against “You” Document # 1 herein and
Co-Defendant “Joyce M. Guy” “Affidavit in support of “You” document # 10 herein
Contain false statement made by “You” and Co-Defendant “Joyce M. Guy having any knowledge of
“Required Pro Se Plaintiff discovery request for admissions, interrogatories and Disclosure on or about the dates of
April 2nd 2008 and April 11, 2008 and as described in Document #1 and #10 attached herein
And further Admit all three documents #1, #9 and #10 was Placed in the United States Mail and
Publically Mailed to The Jefferson County Texas Court House “Clerk of District Court” for cause No. A-180805
And was electronically computer filed in Document # 8 herein 58th Judicial District Court of Jefferson County Texas
“Case Ledger” and Court Records for cause No. A-180805
During this same time frame “Your” being acting Attorney of record cause No. A-180805 filed in the Jefferson County Texas Courthouse said
“Property Deeds” for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas of the Co-Defendant(s) “Joyce M. Guy and Edward McCray herein
Was Legally Transfer to the Texas Department of Housing & Community Affairs on June 18th 2009 as described by
“Jefferson County Real Estate Index in attached document #7 herein for a $76,000.00 U. S. Dollars Housing Grant.
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