Request Number 116.
Admit: “You” Attorney at Law that “You” were “monetary retain” to file a General Denial on December 18th 2007 and that you were legally retained once again at some point as acting Attorney of Law Texas Bar. No. 24058299
to prepare and be ready to attended (2) court hearing before the 58th Judicial District Court in Jefferson County Texas for the legal behalf of Co-Defendant(s) Joyce. M. Guy and Edward McCray herein cause No. A-180805 on the dates of “August 28th 2009 and September 11th 2009
And during this same time frame of your retain services on September 2nd of 2009 before “Your” September 11th 2009 hearing No. A-180805 that required “You” to produce Pro Se Plaintiff said discovery request on behalf of Co-Defendant(s) Joyce M. Guy and Edward McCray herein
Pro Se Plaintiff herein filed on September 2nd of 2009 “inquiry, investigation, and complaint” #21883 with the “State of Texas, Department of Aging and Disability Services” regarding GNG Service Company of Co-Defendant “Joyce M. Guy” herein in violation of Health and Safety Code Chapter 142 by
Co-Defendant “Joyce M. Guy” herein engaging in home health or personal assistance services, which includes hands-on personal care; by representing to the public that Co-Defendant “Joyce M. Guy” herein is a provider of home health, or personal assistance services which includes hands-on personal care for “Pay”
Co-Defendant “Joyce M. Guy” herein never having a HCSSA license and immediately cease providing home health services without said HCSSA licensed attached document #5 and # 6 herein dated December 1st, 2009 and January 7th 2010
Request Number 117.
Admit: “You” Attorney at Law that “You” were fully aware during the time frame of December 18th 2007 throughout “Your” being acting Attorney of record until November 13th 2009
"Your" being aware Pro Se Plaintiff was making “inquiry, investigation, and discovery requests into the past history of your “Clients” Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein.
Request Number 118.
Admit: “You” Attorney at Law that “You” signed the “Response to First Set of Interrogatories of Plaintiff Louis Charles Hamilton II on October 14th 2009 attached document #3 herein containing
“Your” signature, that “You” did not forward said discovery request back to the Pro Se Plaintiff herein their after (60) days of said discovery request being in your full legal possession, custody, and legal control on or about the dates of April 2nd 2008 and April 11, 2008.
Request Number 119.
Admit: “You” Attorney at Law that “You” signed the “Request for Admission of Plaintiff Louis Charles Hamilton II on October 14th 2009 attached document #2 herein containing
“Your” signature, That “You” did not forward said discovery request back to the Pro Se Plaintiff herein their after (60) days of said discovery request being in your full legal possession, custody, and legal control on or about the dates of April 2nd 2008 and April 11, 2008.
Request Number 120.
Admit: “You” Attorney at Law that “You” signed the “Response to First Set of Interrogatories of Plaintiff Louis Charles Hamilton II on October 14th 2009 attached document #3 herein containing “Your” signature, that
“You” did not forward all of said legal discovery request “docket No. A-180805” being in “Your” full legal possession, custody, and legal control on or about the dates of April 2nd 2008 and April 11, 2008
Being Forward (30) to (60) days thereafter to any other Law Office or Attorney(s) other then “Yourself” for the “Legal Behalf of the Co-Defendant(s) Joyce M. Guy and Edward McCray herein ongoing Civil Suit in Common Law.
Request Number 121.
Admit: “You” Attorney at Law that “You” signed the “Request for Admission of Plaintiff Louis Charles Hamilton II on October 14th 2009 attached document #2 herein containing “Your” signature,
“You” did not forward all of said legal discovery request “docket No. A-180805” being in “Your” full legal possession, custody, and legal control on or about the dates of April 2nd 2008 and April 11, 2008
Being Forward (30) to (60) days thereafter to any other Law Office or Attorney(s) other then “Yourself” for the “Legal Behalf of the Co-Defendant(s) Joyce M. Guy and Edward McCray herein ongoing Civil Suit in Common Law.
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