Request Number 93.
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 having full knowledge that the old home was being completely disassembled down to the ground and a
“New Home” being replaced in 2009 at the old mailing address 448 DeQueen blvd. in Port Arthur Texas
And that is why “Your” having full knowledge of Co-Defendant(s) Joyce. M. Guy and Edward McCray herein cause No. A-180805 and that is why “You” are having known Co-Defendant(s) Joyce. M. Guy and Edward McCray last known address to be 5050 east 7th street in Port Arthur Texas77642 in the year 2009 up to November 13th of 2009.
Request Number 94.
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 77640 in December of 2007 and mailed to Co-Defendant(s) Joyce. M. Guy and Edward McCray herein ”Your” Motion for withdrawal “You” filed on November 13th 2009 whereby “You” mailed
“Your” Motion for withdrawal to 5050 east 7th street in Port Arthur Texas 77642 whereby your having full knowledge of Co-Defendant(s) last known address to be at 5050 east 7th street in Port Arthur Texas 77642 thereafter the knowledge of Co-Defendant(s) Joyce. M. Guy and Edward McCray herein living in the dwelling located at 448 DeQueen blvd. in Port Arthur Texas 77640.
Request Number 95.
Admit: “You” Attorney at Law was not going to mail a copy of “Your” Motion for withdrawal to the dwelling located at 448 DeQueen blvd. in Port Arthur Texas 77640 on or about November 13th of 2009 you filed in Jefferson County Clerk of Court Office knowingly that the dwelling located at 448 DeQueen blvd. in Port Arthur Texas
no longer exist, and Construction of a New Home had commence in the year of 2009 for the Co-Defendant(s) Joyce. M. Guy and Edward McCray herein.
Request Number 96.
Admit: “You” Attorney at Law was retained by Co-Defendant(s) Joyce. M. Guy and Edward McCray herein cause No. A-180805 on or about December 18th 2007 and "You" did not filed a Motion for withdrawal on or about June 18th 2009
when Co-Defendant(s) Joyce. M. Guy and Edward McCray herein transfer property dwelling located at 448 DeQueen Blvd. in Port Arthur Texas to “The Department of Housing & Community Affairs” for a “New Home”
during the same time frame “You” Attorney at Law was retained by Co-Defendant(s) Joyce. M. Guy and Edward McCray herein cause No. A-180805
And “You” 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 “You” did not respond to any of said discovery request until on or about October 14th 2009
Request Number 97.
Admit: “You” Attorney at Law was retained by Co-Defendant(s) Joyce. M. Guy and Edward McCray herein cause No. A-180805 on or about December 18th 2007 and
"You" did not filed a Motion for withdrawal on or about June 18th 2009 when Co-Defendant(s) Joyce. M. Guy and Edward McCray herein filed with The County Clerk office in Jefferson County Texas “
“Financing Statement” in connection with “The Department of Housing & Community Affairs” for a “New Home” during the same time frame
“You” Attorney at Law was retained by Co-Defendant(s) Joyce. M. Guy and Edward McCray herein cause No. A-180805
And “You” 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 “You” did not respond to any of said discovery request until on or about October 14th 2009.
Request Number 98.
Admit: “You” Attorney at Law was retained by Co-Defendant(s) Joyce. M. Guy and Edward McCray herein cause No. A-180805
on or about December 18th 2007 and did not filed a Motion for withdrawal on or about June 18th 2009 when Co-Defendant(s) Joyce. M. Guy and Edward McCray herein
had a “Mechanics Lien” filed against them by
“SWMJ Construction Inc.” filed with The County Clerk office in Jefferson County Texas “or about June 18th 2009 during the same time frame
“You” Attorney at Law was retained by Co-Defendant(s) Joyce. M. Guy and Edward McCray herein cause No. A-180805
And “You” 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 “You” did not respond to any of said discovery request until on or about October 14th 2009.
Request Number 99.
Admit: “You” Attorney at Law was retained by Co-Defendant(s) Joyce. M. Guy and Edward McCray herein cause No. A-180805
on or about December 18th 2007 as was requested to comply to Texas rules of Civil Procedures 30 days later with a response to Pro Se Plaintiff Discovery request
“You” had in your full possession, custody and legal control, 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, and
“You” did not respond to any of said discovery request (30) days later as required and demanded but until in the time frame of
on or about October 14th 2009 when your response to Discovery Request in Civil No. A-180805
Some (1) year and (6) months plus days later as “You” was requested complying with Texas rules of Civil Procedures, 194.2., 197, and 198. Request of Interrogatories, Request of Admission, and Request for Disclosure
No comments:
Post a Comment