(13)
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”
And “Your” only sworn duties as described in Document # 2 attached herein “Your” response to Pro Se Plaintiff Motion for sanction against you;
“You” stated “Your” said duties in the capacity as acting “Attorney of Record” cause No. A-180805 requires
“You” to only to file a “General Denial” on December 18th 2007..? As described in Document # 2 attached herein
Explain in full expert Attorney at Law details how is it physically possible, and “Why”..?
“Your” being legally “physically present” and present the performances thereof live “oral” arguments
from your mouth, thoughts, and skills as a acting “Attorney of Record”
For the legal behalf and physical public interest of the Co-Defendant(s) “Joyce M. Guy and Edward McCray”
collectively herein against the Pro Se Plaintiff “Louis Charles Hamilton II” herein
During an actual physical “Court Hearing” before Honorable Judge Bob Wortham of the 58th Judicial District Court of Jefferson County Texas
in a civil suit in common law docket No. A-180805 date of August 28th 2009
When your “physically not official in being monetary retain” for such professional legal service in the capacity as acting
“Attorney of Record” from the time frame date of December 18th 2007 to the exact date of the hearing August 28th 2009
Which “Your” stated and legally sworn to such claiming before “Judge Bob Wortham”
on December 11th 2009 hearing date and as described in attached Document # 2 attached herein
“Your” response to Pro Se Plaintiff Motion for sanction against you: To avoid “actual physical sanctions” being levy against “You”
“You’re only “legal retain duties” was to simply filing a “General Denial” back in December 18th 2007..?
But “Your” providing professional skilled legal service in the capacity as acting “Attorney of Record”…? On August 28th 2009 open Court Hearing…? Why..?
Then Further Explain in full expert “Attorney at Law” details,
How is it still humanly possible that the Defendant “Antoine L. Freeman, J.D. Texas Bar No. 24058299 herein
“Your” further physical in being legally in the same public position of providing continue “professional skilled legal service” in the same capacity as acting “Attorney of Record”…?
“Your” being legally “physically present” and present the performances thereof live “oral” arguments from your mouth, thoughts, and skills as a acting “Attorney of Record”
During an actual “second” physical “Court Hearing” before “Honorable Judge Bob Wortham”
of the 58th Judicial District Court of Jefferson County Texas in a civil suit in common law docket No. A-180805 on September 11th 2009…?
When you’re claiming “Your only legal retain duties” was to simply filing a “General Denial” back in December 18th 2007..?
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”.
While at the same time frame “Your” withholding out on all discovery to include the
physical Production of said Property Deeds for said dwelling located at 448 DeQueen Blvd. in Port Arthur Texas (Block 172, Lot 1-2)
(A). subpart
Explaining continually completely & fully in the same patter and practices of “Your”
quite professional skill “Attorney at Law” expert precise details how is it Defendant “Antoine L. Freeman, J.D. Texas Bar No. 24058299
herein in this Interrogatories question # 13 herein
“Your” still being quite further having official involvement in the legal public position of providing continue
“professional skilled legal service” in the capacity as acting “Attorney of Record”…?
And actually appearing in (person) before “Honorable Judge Bob Wortham” of the 58th Judicial District Court of Jefferson County Texas
once again in a civil suit in common law docket No. A-180805 on the hearing date of September 11th 2009…?
When your legal professional skilled “Attorney at Law” duties ended and expire back in
December 18th 2007 after filing the said “General Denial”…” as claimed by “You”…?
While “mysteriously fraudulently” during this same “legal time frame”
Throughout the time frame dates now of December 18th 2007 of your filing a “General Denial” throughout September 11th 2009
“Your” official second “Attorney at Law” appearance for that hearing date …?
Said “Property”, dwelling, and deeds thereof “for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas (Block 172, Lot 1-2)
Already being a physical issue of “material evidence” subject matter and actual party thereof in a civil suit in Common law in the State of Texas
Since November 26th of 2007 for a “Breach of Construction Contract in excess of $10,800.00 U.S. Dollars
while you’re still acting in the official legal capacity as acting “Attorney of Record” for cause No A-180805
Property Deeds now physically being entertained as subject matter conflicting issue before the “Court”
in a Motion for Production of Document(s) in “Your” possession since the date of August 12th 2009
Said “Property Deeds” now legally end up in the hand of the “Texas Department of Housing & Community Affairs”
being 100% legally in full possession, custody, control, and legal affairs surround the actual transfer on June 18th 2009
Then “deeds” release on July 22nd 2013 and then “deeds’ terminated on July 22nd 2013 said possession, custody and
control of “Property Deeds, back into the possession, custody and legal control to the
Co-Defendant(s) “Joyce M. Guy and “Edward McCray” herein collectively
On April 14th 2014 as described in Pro Se Plaintiff attached Document # 7 attached herein
“Jefferson County Texas Property search Index” Instrument # 2014012455.
And “Your” failing to fully disclosed this “material facts” said “property and deeds thereof was transfer in the full physical custody,
possession, and legal control of the “Texas Department of Housing & Community Affairs” for a $76,000.00 U.S. Dollars Housing Grant since June 6th 2009
As described in Pro Se Plaintiff attached Document # 7 attached herein “Jefferson County Texas Property search Index” Instrument # 2009022762
While you’re still acting Attorney of Record in this ongoing civil suit A-180805 58th Judicial District Court of Jefferson County Texas dated November 26th 2007…..?
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