Request Number 112.
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” Attorney at Law had in “Your” legal possession, custody and control on the dates of April 2nd 2008 and April 11, 2008.
Request Number 113.
Admit: “You” Attorney at Law that “You” signed the “Response to Request for Admissions of Plaintiff Louis Charles Hamilton II on October 14th 2009 attached document #4 herein containing “Your” signature, that “You” Attorney at Law had in “Your” legal possession, custody and control on the dates of April 2nd 2008 and April 11, 2008.
Request Number 114.
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 as Attorney of Law Texas Bar. No. 24058299 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
But “You” was “monetary retain” to keep also all discovery request phase of request of Interrogatories, Request for Admission, and Request for Disclosure
"You" had in your possession, custody and legal control “Absolutely Secret”, Private, and not to be a part of the Pro Se Plaintiff herein ongoing civil court proceeding against Co-Defendant(s) Joyce. M. Guy and Edward McCray herein while “Your” being acting Attorney of record for cause No. A-180805 filed in the Jefferson County Texas Courthouse
Request Number 115.
Admit: “You” Attorney at Law that you were “monetary retain” to file a “General Denial” on December 18th 2007 for the Co-Defendant(s) Joyce. M. Guy and Edward McCray herein then “You” Attorney at Law
Were monetary retain as legal counsel “once again” on August 28th 2009 to attend a Court hearing same cause No. A-180805 filed in the Jefferson County Texas Courthouse
for the Co-Defendant(s) Joyce. M. Guy and Edward McCray herein then
“You” Attorney at Law were retained “another once” as legal counsel again on September 11th 2009 to attend another separate court hearing in the same cause No. A-180805 filed in the Jefferson County Texas Courthouse
But “You” Attorney at Law at no time frame between the dates of April 2nd 2008 and April 11, 2008, throughout September 14th 2009 was monetary retain by the Co-Defendant(s) Joyce. M. Guy and Edward McCray herein
To file and respond to any of the 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 11th 2008 for the same cause No. A-180805 filed in the Jefferson County Texas Courthouse.
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