Tuesday, January 6, 2015

Defendant “Antoine L. Freeman J.D. (Attorney at Law)” Cause No. 1:14-CV-592 “First Set of Interrogatories”

(20)

The Constitution of the State of Texas

Article 16: "General Provisions"

Contains miscellaneous provisions, including limits on interest rates, civil penalties for murder, and the punishment for bribery.

Section 37 provides for the constitutional protection of the mechanic's lien.

Section 50 provides for protection of a homestead against forced sale to pay debts, except for foreclosure on debts related to the homestead

(mortgage, taxes, mechanic's liens, and home equity loans).

Explain why in detail…? Are you Chief Defendant “Antoine L. Freeman, J.D.” Texas Bar No. 24058299 herein

providing Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein full protection,

and concealment of said “property deeds” from the Pro Se Plaintiff herein from December 18th 2007 – December 11th 2009 when you was removed as acting Attorney of Record…?

Providing the full “Attorney at Law” skilled protection, and concealment thereof said “property deeds”

against the Pro Se Plaintiff “Louis Charles Hamilton II” herein opportunity in filing a “Mechanic’s lien”

for said dwelling and the property located at 448 DeQueen Blvd. in Port Arthur Texas. (Block 172, Lot 1-2)

During the time exact time frame of “August 12th 2009 in the “actual concealment” of said “property deed”

you engaged from that day well into 2015 Attorney at Law skilled protection,

and concealment in the required Pro Se Plaintiff “Production of Document” for said “property deeds”

You 100% refused to respond to in a timely manner (30) days thereafter possession of said “Production of Document for said

“property deeds” as claiming legally before the 58th Judicial District

Court of Jefferson county Texas “Your” not retain at all on August 12th 2009 to response to said Production of Property Deeds..?

But Defendant herein still acting as “Attorney of record” until December 11th 2009…?

While into the time frame of June 18th 2009- April 22nd 2014 when “Texas Department of Housing and Community affairs”

ended having full possession, custody and legal control of said “Property Deeds”

As being described “legally” in Pro Se Plaintiff attached Document # 5 herein “Jefferson County Texas Search Index”

While “You” Defendant (Attorney at Law) did not “come forth” before the 58th Judicial District Court of Jefferson County Texas

“Honorable Judge Bob Wortham” in Docket No. A-180805

And honestly “first and foremost” file a legal written notice to the “Honorable Court” being ex-parte, or with notice served upon

said Pro Se Plaintiff “Louis Charles Hamilton II herein also

Saying in “precise legal details” your “Clients” a/k/a said Co-Defendant(s) “Joyce M. Guy and Edward McCray”

herein collectively during the course of your representation illegally Transfer the property deed”

for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas (Block 172, Lot 1-2)herein

On the exact dates of June 18th 2009 to “The Texas Department of Housing & Community Affairs”

as being described in Pro Se Plaintiff attached Document # 9“ herein Jefferson County Real Estate Index” Instrument #2009022762

And “You” are filing “You’re” immediately “Motion for withdrawal of Counsel”,

So you’re Chief Defendant “Antoine L. Freeman, J.D.” Texas Bar No. 24058299 herein not in any “shape or physical form” associated,

and being a misused party to the ongoing current June 18th 2009 dishonesty, fraud,

and deceit standing before the 58th Judicial District Court of Jefferson County Texas surrounding the said property deeds…?

In an ongoing “civil suit” in common law since 2007…? Involving “You” Chief Defendant (Attorney at Law)

and the Co-Defendant(s) herein “Joyce M. Guy and Edward McCray” collectively and the legal issues of subject matter surround said “Property Deeds”…?

Being against “among other things” the Pro Se Plaintiff herein Constitutional rights of the State of Texas Article 16: Section 37 and Section 50

When “The Texas Disciplinary Rules of Professional Conduct” particularly relating to

8.04 Misconduct paragraph (2) and (3) clearly stating that you active “Attorney at Law” within the State of Texas prohibited from:

(2) Commit a serious crime or commit any other criminal act that reflects adversely on the lawyer's honesty,

trustworthiness or fitness as a lawyer in other respects;

(3) engage in conduct involving dishonesty, fraud, deceit or misrepresentation;

Which said “property deeds” for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein being in there possession,

custody and legal control at the start of this civil suit in common law

On November 26th 2007 for dwelling and the property located at 448 DeQueen Blvd. in Port Arthur Texas. (Block 172, Lot 1-2) – June 17th 2009

As said “property deeds is a party of and subject matter to a civil suit in common law since November 26th 2007 Docket No. A-180805 throughout January 21st 2015

Notwithstanding at the “same time frame” quite fraudulently the “Texas Department of Housing and Community affairs”

end up having full possession, custody and legal control over said “Property Deeds” from June 18th 2009 – July 22nd 2013…?

And as your acting “Attorney of record” since December 18th 2007 – December 11th 2009

Having full legal possession, custody and control since 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

over all discovery request of interrogatories, request for admission, and disclosure and your 100% in refusing to

file a “timely response” thereof (30) days later claiming “Your” not acting “Attorney of record” between the time frame of December 18th 2007- November 13th 2009

As being described in Pro Se Plaintiff attached Document # 2 “Your” fraudulent response to Pro Se Plaintiff motion for sanctions against you.

When Pro Se Plaintiff attached Documents # 11 herein namely the official 58th Judicial District Court of Jefferson County Texas

“Civil Docket Report” for cause A-180805 fully describing “among other things” you “legally”

acting as “Attorney of record” from December 18th 2007- December 11th 2009

With additionally Pro Se Plaintiff Document #1 attached herein being the official 58th Judicial District Court of Jefferson County Texas “Case Ledger”

for Civil Cause No. A-180805 also showing your acting retained “Attorney of record” between the time frame of December 18th 2007- December 11th 2009…?

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