(4)
Explain in full expert Attorney at Law details, after you filed your “General Denial”
for the Co-Defendant(s) Joyce M. Guy and Edward McCray (herein) behalf collectively to complaint Cause No. A-180805
in Jefferson County Texas on the dates of December 18th 2007
As described by Document #1 attached herein being the official 58th Judicial District Court of Jefferson County Texas “Case Ledger” for Civil Cause No. A-180805
How is it you’re still acting live retaining “Attorney of record” …?
Until Judge Bob Wortham gave official Court approval for your motion to withdrawal from Co-Defendant(s) “Joyce M. Guy and Edward McCray collectively herein on December 11th 2009
exactly for a time frame of 1 year, 11 months and 11 days later active in civil suit in common law Docket No. A-180805 filed in Jefferson County Texas…?
(5)
Explain in full expert Attorney at Law details, after you filed your “General Denial” for the Co-Defendant(s) Joyce M. Guy and Edward McCray (herein) collectively behalf
to complaint Cause No. A-180805 in Jefferson County Texas on the dates of December 18th 2007
And your claiming in Document # 2 attached herein “Your response to Pro Se Plaintiff Motion for sanction against you for violations of Rule 193.1 by failing to respond to Plaintiff’s discovery request
In your defense in attached Document # 2 herein as you claim, sworn and stated:
Defendant, Joyce Guy, retain the services of Antoine Freeman for the purpose of writing a general denial so as to avoid a default judgment being render against her.
Why..? Are you legally in the retain capacity as an acting “Attorney of record” for docket No. A-180805
while being still in full possession, custody and legal control over Pro Se Plaintiff Discovery Request on “request for admission”, “Interrogatories”, and “Disclosure”
and at the same time frame refusing to respond to any said discovery after the months of April of 2008..?
And then the same full possession, custody and legal control over Pro Se Plaintiff Discovery Request thereafter the months of;
a. May of 2008
b. June of 2008
c. July of 2008
d. August of 2008
e. September of 2008
f. October of 2008
g. November of 2008
h. December of 2008
i. January of 2009
j. February of 2009
k. March of 2009
l. April of 2009
m. May of 2009
n. June of 2009
o. July of 2009
p. August of 2009
q. September of 2009
r. October of 2009
(6)
Explain in full expert Attorney at Law details, after you filed your “General Denial” for the Co-Defendant(s) Joyce M. Guy and Edward McCray (herein) collectively behalf
to complaint Cause No. A-180805 in Jefferson County Texas on the dates of December 18th 2007
And your claiming in Document # 2 attached herein “Your response to Pro Se Plaintiff Motion for sanction against you for violations of Rule 193.1 Texas Rules of Civil Procedure
by failing to respond to Plaintiff’s discovery request during the months of March of 2008, April of 2008, May of 2008,
June of 2008, July of 2008, August of 2008, September of 2008,
October of 2008, November of 2008, December of 2008, January of 2009, February of 2009, March of 2009,
April of 2009, May of 2009, June of 2009, July of 2009, August of 2009, and September of 2009 you did not file a “timely response”
In your defense in attached Document # 2 herein as you claim, sworn and stated:
Defendant, Joyce Guy, retain the services of Antoine Freeman for the purpose of writing a general denial so as to avoid a default judgment being render against her.
Explain Why..? Are you legally still in the “retain capacity” as an acting “Attorney of record” for docket No. A-180805
while in the time frame of being still in full possession, custody and legal control over Pro Se Plaintiff “Motion for Production of Documents dated August 12th 2009
Throughout the dates of October 12th 2009 some three months later while being still in full possession, custody and legal control, of said discovery request
With your retain “Attorney at Law” refusal to respond in a “timely fashion”
to said Production for “property deeds, and production for all construction estimates for repairs caused by damages of Hurricane Rita, Humberto, and Ike to said dwelling..?
As being described in attached Document #1 attached herein being the official 58th Judicial District Court of Jefferson County Texas “Case Ledger”
Namely Pro Se Plaintiff required Production for “Property Deeds”
to said dwelling for the property located at 448 DeQueen Blvd. in Port Arthur Texas. (Block 172, Lot 1-2)
And Production for all construction estimates for repairs caused by damages of Hurricane Rita, Humberto,
and Ike to said dwelling described herein as being described in Pro Se Plaintiff attached Document # 3 herein
58th Judicial District “Court Order” for Production for “Property Deeds” to said dwelling for the property located at 448 DeQueen Blvd. in Port Arthur Texas. (Block 172, Lot 1-2)
And “Court Order” for Production for all construction estimates for repairs caused by damages of Hurricane Rita, Humberto, and Ike to said dwelling
(7)
Explain in full expert Attorney at Law details, after you filed your “General Denial” for the Co-Defendant(s) Joyce M. Guy and Edward McCray (herein) behalf collectively
to complaint Cause No. A-180805 in Jefferson County Texas on the dates of December 18th 2007
And your claiming in Document # 2 attached herein “Your response to Pro Se Plaintiff Motion for sanction against you for
violations of Rule 193.1 Texas Rules of Civil Procedure by failing to respond to Plaintiff’s discovery request during the months of March of 2008, April of 2008, May of 2008,
June of 2008, July of 2008, August of 2008, September of 2008,
October of 2008, November of 2008, December of 2008, January of 2009, February of 2009,
March of 2009, April of 2009, May of 2009, June of 2009, July of 2009, August of 2009, and September of 2009 you did not file a “timely response”
In your defense in attached Document # 2 herein as you claim, sworn and stated:
Defendant, Joyce Guy, retain the services of Antoine Freeman for the purpose of writing a “general denial” so as to avoid a default judgment being render against her.
Explain Why..?
a. Are you legally still in the “retain capacity” as an acting “Attorney of record” for docket No. A-180805
and appearing in official “Attorney of Record” retain status before a “Live Court Hearing” on the date of August 28th 2009..?
When you’re being only retained for general denial filing for Co-Defendant(s) “Joyce M. Guy and Edward McCray collectively back on December 18th 2007..?
b. And Explain why..?
You’re still being in retained “Attorney at Law” status before a “Live Court Hearing” on the date of September 11th 2009..?
When you’re being only retained for general denial filing for Co-Defendant(s) “Joyce M. Guy and Edward McCray collectively back on December 18th 2007..?
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