Request Number 172.
Admit: You” Attorney at Law that “You” Drafted the Court Order Judge Bob Wortham gave his approval on, placed his signature upon said
“Court Order” issued in “Your” favor on December 11th 2009 which said 58th Judicial District Court Order of Jefferson County Texas was
electronically computer filed in Document # 8 herein 58th Judicial District Court of Jefferson County Texas “Case Ledger” and all Court Records thereof
For “Your” Withdrawal as “Attorney of Record”
Cause No. A-180805 as described in attached Document # 12 herein 58th Judicial District Court of Jefferson County Texas “Docket Report”
Request Number 173.
Admit: You” Attorney at Law that these “Chain of Events” are “True” of “Your” attend a hearing held on the date of December 11th 2009 for
“Your” Withdrawal as acting “Attorney of Record” as “Your” being Acting Attorney of Record since December 18th 2007 – December 11th 2009
1 year, 11 months and 11 days your officially active attorney of record in
Cause No. A-180805 as described in attached Document # 12 herein 58th Judicial District Court of Jefferson County Texas “Docket Report”
With a “Court Order” on file of approval of “Your withdrawal from Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively from cause No. A-180805
And as described in attached Document # 8 herein 58th Judicial District Court of Jefferson County Texas “Case Ledger”
And “Your” Affidavit in support of “Your” reply to Pro Se Plaintiff “Motion for Sanctions” against “You” Document #9 herein
contain with false statement made by “You” of “Your” having only 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
Which “You” already had 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 this document was electronically computer filed in Document # 8 herein 58th Judicial District Court of Jefferson County Texas “Case Ledger” and The Court Records for cause No. A-180805
During this same time frame “Your” being acting Attorney of record for cause No. A-180805 filed in the Jefferson County Texas Courthouse
The said “Property Deeds” a issue” 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 already legally Completely Transfer to the Texas Department of Housing & Community Affairs
on the date of 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
And “You” then after said dwelling being a party to this civil suit A-180805 was transfer for said $76,000.00 U. S. Dollars Housing Grant and the old one completely destroyed
“You” there after then attend a Hearing dated on December 11th 2009 after “Your” already done supplying “false information” as
“You” made in “Your” Response to Motion for Sanctions Document dated September 11th 2009, being Document # 1 attached herein
of “Your” having only 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
In comparison to attached Document # 12 herein 58th Judicial District Court of Jefferson County Texas “Docket Report” showing
“You” officially having said Discovery request clearly back in March 14th 2009 as described in attached Document # 12 herein
58th Judicial District Court of Jefferson County Texas “Docket Report”
And ”You” then later used this “false information” for “Your” Withdrawal as acting “Attorney of Record” as described in attached Document # 2 herein
“Your Motion for withdrawal” from Cause No. A-180805
As “You” further stated “You” were only retain to file a “General Denial” (Only) which “You” did on December 18th 2007,
But “Your” legal representation in the capacity of an acting “Attorney at Law” in and for the State of Texas
did not officially end for the Co-Defendant “Joyce M. Guy and Edward McCray” herein collectively until “December 11th 2009
Which “You” completely refused throughout this entire time frame to simply turnover “among other things”
Production of copies the “Property deeds” for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas
which was request “You” and The Co-Defendant(s) collectively to do so in Pro Se Plaintiff Motion for Document(s) dated August 12th 2009
As described in attached Document # 12 herein 58th Judicial District Court of Jefferson County Texas “Docket Report”
But “Your” still officially makes “False Claims” in Court Records “Your” only being official retain as
“Attorney at Law” duties from the Time frame of December 18th 2007 – December 11th 2009 was to file a “General Denial” (only)
As “Your” in real life time “factual events and legal circumstances” claiming before the 58th Judicial District Court of Jefferson County Texas
these facts as such described in Document #1 in “Your” response to Motion for sanctions against “You”
and as Co-Defendant “Joyce M. Guy” herein also claiming in Document # 10 Co-Defendant “Joyce M. Guy” “Affidavit” in support of “Your” false claims
Which Her Fraudulent statement “Affidavit” no less is in fact in support of “You” so no sanction being imposed again “You”
which Co-Defendant “Joyce M. Guy” herein “Affidavit” in cause No. A-180805
Contains the same “false material information” as “Your” Supplying in knowledge of having possession, custody and legal control of
Pro Se Plaintiff Discovery request as Described in Pro Se Plaintiff attached Document # 1 herein “Your” response to Motion for sanctions against “You”
but “However” at the same time frame chain of events
“Your” being officially present at two Court hearing on August 12th 2009 and on September 11th 2009
in the capacity of acting “Attorney of Record” but not retain to be there at all and no motion for youe withdrawal as acting Attorney of Record
being official on file with the Jefferson County Civil Clerk of Court office until the date of November 13th 2009 for “Your” official withdrawal
But however no less “Your” in “factual events and legal circumstances” “physically officially present”
in “human life form of some sorts” breathing and quite in fact officially alive and present at
“two required Court hearing being held on August 12th 2009 and on September 11th 2009 and
“Your” acting in the capacity of acting “Attorney of Record” during these said “Two Live Court Hearings”
which “You” claim “Your” not even retain for at all but as Described in attached Document # 8 herein the 58th Judicial District Court of Jefferson County Texas
“Case Ledger” that “Your” acting “Attorney of Record”
But meanwhile “Your” 100% officially claiming “Your” not retain to be there and this never even happen as
“Your” making this false claim in attached Document # 1 herein “Your” response to Motion for sanctions against “You”
that the only understanding “Your” having is filed a “General Denial” (Only) as this was “Your” only Duties
Which “Your” still making such claims in December 11th 2009 at the hearing “Your” request to be now removal as acting “Attorney of Record” while
“Your” stating to the 58th Judicial District Court of Jefferson County Texas of a state of physically only legally being in a state of retain duties which is completed after December 18th 2007
for the sole purpose of “Your” filing a simple “General Denial” (Only) for Co-Defendant “Joyce M. Guy” and Edward McCray legal behalf collectively
as “Your” Official claim to this is so official stated in this attached Document # 1 herein
“Your” response to Motion for sanctions against “You” and as described and colloberated in Co-Defendant “Joyce M. Guy” herein
“Sworn” statement no less also claiming in Document # 10 her “Affidavit” in support of “You”
While attached Document No. # 8 herein the 58th Judicial District Court of Jefferson County Texas “Case Ledger”
showing “You” being in possession of numerous Discovery Documents and Legal Motions for the Co-Defendant(s) collectively behalf starting on March 14th 2008
While attached Document No. # 8 herein the 58th Judicial District Court of Jefferson County Texas “Case Ledger”
also showing “Required Pro Se Plaintiff discovery request for admissions, interrogatories and Disclosure being in “Your” claiming was in
“Your” legal possession, custody and legal control on or about the dates of April 2nd 2008 and April 11, 2008 that
“Your” making continue false claims to about these dates of “factual events and legal circumstances”
which do not officially exist at all as described in Pro Se Plaintiff attached Document No. # 8 herein
the 58th Judicial District Court of Jefferson County Texas “Case Ledger”
With the “Chain of continual “factual events and legal circumstances” showing also Co-Defendant Joyce M. Guy” herein supplies the following
“false and fraudulent” Answer to Pro Se Plaintiff Interrogatories Document # 11 attached herein at question number 14
14. How is the State of Texas Involved?
Answer: Not Involved
In comparison to Pro Se Plaintiff attached Document # 7 here in showing during this same time frame
“Your” being acting Attorney of record cause No. A-180805
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 collectively custody, control and legal possession
Was legally in all “factual events and legal circumstances” Transfer to the “Texas Department of Housing & Community Affairs” on the date of June 18th 2009
As described by “Jefferson County Real Estate Index” Instrument # 2009022762.
And The Federal Government not being described as a Party
In attached document #7 herein for a $76,000.00 U. S. Dollars Housing Grant that Co Defendant “Joyce M. Guy”
thus making conflicting false claims that in all “factual events and legal circumstances” that the Federal Government provided provision of $76,000.00 U. S. Dollars Housing Grant
never happen as Co-Defendant “Joyce M. Guy” herein making such a legal claim in Pro Se Plaintiff attached Document # 11
“Interrogatories” of Co-Defendant “Joyce M. Guy” claims of Funding
For the Property located at 448 DeQueen Blvd. in Port Arthur Texas
which said Property being a party to a “Breach of Construction Contract” since the dates of November 17th 2007
as this is to be the “True Chain of “factual events and legal circumstances” involving “You”
Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299
whom “Your” in a retain “Attorney at Law” refusal state of some sort to supply a legal response during the months of April of 2008, May of 2008, June of 2008, July of 2008, August of 2008,
September of 2008, October of 2008, November of 2008, December of 2008, January of 2009,
February of 2009, March of 2009, April of 2009, May of 2009, June of 2009, July of 2009, August of 2009, September of 2009
In a timely manner to said Discovery request “Your” having in “Your” Legal possession, custody and control over since
March 14th 2008 as legally described in Pro Se Plaintiff Document No. # 8 attached herein being the official
58th Judicial District Court of Jefferson County Texas “Case Ledger” for Civil Cause No. A-180805.
And this is not in “Violations of Rule 193.1 of the Texas Rules of Civil Procedure of “Your”
responds to discovery in a timely manner for cause of action against Co-Defendant(s) Joyce M. Guy and Edward McCray collectively herein.
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