Sunday, December 28, 2014

Pro Se Plaintiff “Louis Charles Hamilton II” REQUESTS FOR ADMISSION, Cause No. 1:14-CV-592 To Defendant “Antoine L. Freeman

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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