Request Number 164.
Admit: You” Attorney at Law that Co- Defendant Joyce M. Guy” herein supply the following Answer to Pro Se Plaintiff Interrogatories
Document # 11 attached herein pursuant to Rule 197 of the Texas Rules of Civil Procedures at Question: 10, 11, 12, 13, 14, 15, and 16.
10. Where is the Funding for the New Home?
Answer: Federal Grant
11. What are the terms and conditions of any contract in regards to the new home?
Answer: Federal Government built home free of charge Defendant must remain in home for at least 3 years.
12. What is the entire cost of the construction for the new home?
Answer: $76,000.00 U.S. Dollars
13. How is the city of Port Arthur Involved?
Answer: Not involved
14. How is the State of Texas Involved?
Answer: Not Involved
15. How is the Federal Government involved?
Answer: Federal Grant
16. How much money did the Co-Defendant actually paid for the new home construction?
Answer: No money paid by Co-Defendant
Request Number 165.
Admit: You” Attorney at Law that Co- Defendant Joyce M. Guy” herein supply 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 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. Instrument # 2009022762.
Request Number 166.
And further Admit that Documents #11 that Co- Defendant Joyce M. Guy” herein supply the following “false and fraudulent” Answer to
Pro Se Plaintiff Interrogatories 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 167.
And further Admit that Documents #11 that Co- Defendant Joyce M. Guy” herein supply the following “false and fraudulent” Answer to
Pro Se Plaintiff Interrogatories 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
And was Placed in the United States Mail and publically mailed to the Pro Se Plaintiff herein.
Request Number 168.
And further Admit that Documents #11 that Co- Defendant Joyce M. Guy” herein supply the following “false and fraudulent” Answer to
Pro Se Plaintiff Interrogatories 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
And was Placed in the United States Mail and publically mailed to the Pro Se Plaintiff herein.
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 169.
Admit: You” Attorney at Law that “You” and Co-Defendant “Joyce M. Guy” herein supply
“Your” response to the following Answer to Pro Se Plaintiff Interrogatories Document # 11 attached herein
pursuant to Rule 197 of the Texas Rules of Civil Procedures at Question: 10, 11, 12, 13, 14, 15, and 16. In October 14th 2009
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
being a Party to a $10,800.00 U.S. Dollars “Breach of Construction Contract dispute said dwelling
Was “Already Completely 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 170.
And further Admit that Documents #11 attached herein that Co- Defendant Joyce M. Guy” herein supply “false and fraudulent” Answer to
Pro Se Plaintiff Interrogatories at question # 14 was legally requested by Pro Se Plaintiff herein on March 14th 2008 but
“You” did not submit Co- Defendant Joyce M. Guy” herein supplied “false and fraudulent” Answer until
October 14th 2009 against Rule 197 of the Texas Rules of Civil Procedures (30) days limit in filing a timely response to Pro Se Plaintiff herein.
Being an actual year later “Your” finally forward actual “false and fraudulent” answers of Co- Defendant Joyce M. Guy”
Interrogatories at question # 14 herein attached Document # 11 herein
Legally “You” 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”
Request Number 171.
And further Admit that Documents #11 attached herein that Co- Defendant Joyce M. Guy” herein supply “false and fraudulent” Answer to
Pro Se Plaintiff Interrogatories at question # 14 which was legally requested by Pro Se Plaintiff herein on March 14th 2008 but
“You” did not submit Co- Defendant Joyce M. Guy” herein supplied “false and fraudulent” Answer until October 14th 2009
against Rule 197 of the Texas Rules of Civil Procedures (30) days limit in filing a timely response to Pro Se Plaintiff herein.
Being an actual year later “You’re” finally forward actual “false and fraudulent” answers of Co- Defendant Joyce M. Guy” Interrogatories at question # 14 herein attached Documents # 11 herein
Legally “You” placed said Interrogatories response 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 # 11 was electronically computer filed in Document # 8 herein 58th Judicial District Court of Jefferson County Texas “Case Ledger” and Court Records thereof
And Copies of such “false and fraudulent” Answer to Pro Se Plaintiff Interrogatories being actual “false and fraudulent” answers of
Co- Defendant Joyce M. Guy” Interrogatories at question # 14 herein attached Document # 11 herein Legally
“You” placed this legal Document in the United States Mail and publically mailed also to the Pro Se Plaintiff mailing address at P.O. Box 342 in Port Arthur Texas 77640
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