(18)
Explain in full expert “Attorney at Law” precise legal details, legal service in the capacity as acting “Attorney of Record”
for Civil Suit in Common Law 58th Judicial District Court of Jefferson County in and for the State of Texas Docket No. A-180805
Defendant “Antoine L. Freeman, J.D. Texas Bar No. 24058299 herein
As “Your” claiming in attached Document # 8 herein “Namely”; Your Motion for Withdrawal of Counsel, filed stamp dated November 13th 2009,
With “Your” attached “Certificate of Mailing Service in attached Document # 9 herein
And also with “Your” attached “Notice of Hearing” legally set for December 11th 2009 at 9:00 am hour
Before the 58th Judicial District Court of Jefferson County in and for the State of Texas
Docket No. A-180805 in attached Document # 10 herein
To discuss “among other official 58th court business things”
Your finally official filed “Motion for Withdrawal of Counsel”, filed stamp dated November 13th 2009 10:22 am hour stated as follows:
To The Honorable Judge of Said Court:
Now Comes Movant, Antoine L. Freeman J.D., Attorney for Defendants, Joyce Guy and Edward McCray, (hereinafter Defendants),
and brings this Motion for withdrawal of Counsel, and in support thereof, shows the court the following:
I.
Good cause exists for withdrawal of Movant as counsel because Defendants have not complied with the terms of employment agreement
with this attorney. Plaintiffs refuse to adhere to the terms of the employment agreement with this attorney.
II.
The setting and deadlines in this case are as follows: Motion for Sanction & Contempt on December 11th, 2009 @ 9:00 am (With Your Initials)
III.
This Motion is not sought for the purposes of delay.
IV.
A copy of this motion bearing the enclosed notice has been delivered to the last known addresses of the Defendants.
“Joyce Guy” 5050 7th street Port Arthur, Texas 77642
“Edward McCray” 5050 7th street Port Arthur, Texas 77642
V.
Defendants are hereby notified in writing of the right to object to this motion.
NOTICE
You are hereby notified that this motion for withdrawal of Counsel is set for hearing at the time and place set out below.
You do not agree to this motion. If you wish to contest the withdrawal of Antoine L. Freeman, J.D. as your attorney, you should appear at the hearing.
If you do not oppose Antoine L. Freeman, J.D.’s withdrawal as your attorney, you may notify Antoine L. Freeman, J.D. in writing of your consent to this motion.
Wherefore, Premises Considered, Movant prays that the Court enters as order
discharging Movant as attorney of record for Defendants, “Joyce Guy” and “Edward McCray”, and for such other and
further relief that may be awarded at law or in equity.
Respectfully submitted, by “Antoine L. Freeman, J.D., Texas Bar No. 24058299, 3723 Gulfway Dr. Ste #104, Port Arthur, Texas 77642 (409) 293-1627, Fax (409) 983-7405
“Attorney for Defendants” Joyce Guy and Edward McCray
“First” and primary Chief Defendant “Antoine L. Freeman, J.D., Texas Bar No. 24058299 herein carefully, legally, in precise exact details explains…?
As described by you in paragraph (1) in Pro Se Plaintiff attached Document #8 attached herein stating:
“Good cause exists for withdrawal of Movant as counsel because Defendants have not complied with the terms of employment agreement with this attorney.
Plaintiffs refuse to adhere to the terms of the employment agreement with this attorney.”
Explaining in precise legal details fully how is it “physically possible” that the Pro Se Plaintiff namely (Louis Charles Hamilton II) herein being the
Plaintiffs whom refuse to adhere to the terms of the employment agreement..?
With this attorney? Namely (You)..?
When in all factual circumstances of “real life civil legal events” said Pro Se Plaintiff (Louis Charles Hamilton II) herein
Is the “complainant” bring forth the “civil action” docket No. A-180805 against the Co-Defendant “Joyce M. Guy and Edward McCray”
In an “Independent” Pro Se Plaintiff “legal” style format without “Your” retained”Attorney at Law” for hire legal services…?
And Pro Se Plaintiff Namely (Louis Charles Hamilton II) herein
Did not “Legally” in any physical monetary “shape or form” officially retain
“Your” crooked (RICO) services in the “first place”… to represent the said Pro Se Plaintiff “Louis Charles Hamilton II”
Herein in civil suit in “common law” within the 58th Judicial District Court of Jefferson County Texas Docket No. A-180805…?
And why…? Is the Pro Se Plaintiff being “further fraudulently” represented and “Identified” by “You”
Chief (RICO) Defendant Antoine L. Freeman, J.D., Texas Bar No. 24058299 in “Your”
official filed “Motion for Withdrawal of Counsel”, filed stamp dated November 13th 2009 10:22 am hour. …?
As “Your” legal filed motion for your withdrawal of counsel before the “Honorable 58th Judicial District Court quite
“among other things” completely represented and “Identified”
Very “fraudulently” the describing Pro Se Plaintiff “Louis Charles Hamilton II” herein
in a “legal status state” of “Plaintiffs refuses to adhere to the terms of the employment agreement..?
In connection with “Attorney at Law” Chief (RICO) Defendant Antoine L. Freeman, J.D., Texas Bar No. 24058299 herein…?
As foolishly, stupidly and bogusly being described in Pro Se Plaintiff attached Document # 8…?
“Your” official filed “Motion for Withdrawal of Counsel”?
Subpart (A)
Further expertly explaining in precise legal careful details Defendant “Antoine L. Freeman, J.D.” Texas Bar No. 24058299 herein fully legally precisely
how was the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein collectively…?
Exactly with supporting “physical documented” of proof and your “legally” precise details said Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein
“Not officially” complying fully with, and acting in all accordance with all specified standards and terms of the employment agreement contract for your “Attorney at Law” legal services
For said civil in “common law” within the 58th Judicial District Court of Jefferson County Texas, Docket No. A-180805…?
During the exact precise month of November of 2009…?
Subpart (B)
Further expertly explaining in precise legal careful details Defendant “Antoine L. Freeman, J.D.” Texas Bar No. 24058299 herein fully legally precisely
how was the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein collectively…?
Exactly with supporting “physical documented” of proof and your “legally” precise details said Co-Defendant(s) collectively complying fully with,
and acting in accordance with all specified standards and terms of the employment agreement contract for your “Attorney at Law” legal services
For said civil in “common law” within the 58th Judicial District Court of Jefferson County Texas, Docket No. A-180805…?
During the exact precise month of December of 2007…?
Subpart (C)
Further expertly explaining in precise legal careful details Defendant “Antoine L. Freeman, J.D.” Texas Bar No. 24058299 herein fully legally precisely
how was the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein collectively…?
Exactly with supporting “physical documented” of proof and your “legally” precise details said Co-Defendant(s) collectively complying fully with,
and acting in accordance with all specified standards and terms of the employment agreement contract for your “Attorney at Law” legal services
For said civil in “common law” within the 58th Judicial District Court of Jefferson County Texas, Docket No. A-180805…?
During the exact precise month of January 2008.…?
Subpart (D)
Further expertly explaining in precise legal careful details Defendant “Antoine L. Freeman, J.D.” Texas Bar No. 24058299 herein fully legally precisely
how was the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein collectively…?
Exactly with supporting “physical documented” of proof and your “legally” precise details said Co-Defendant(s) collectively complying fully with,
and acting in accordance with all specified standards and terms of the employment agreement contract for your “Attorney at Law” legal services
For said civil in “common law” within the 58th Judicial District Court of Jefferson County Texas, Docket No. A-180805…?
During the exact precise month of Februarys of 2008…?
Subpart (E)
Further expertly explaining in precise legal careful details Defendant “Antoine L. Freeman, J.D.” Texas Bar No. 24058299 herein fully legally precisely
how was the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein collectively…?
Exactly with supporting “physical documented” of proof and your “legally” precise details said Co-Defendant(s) collectively complying fully with,
and acting in accordance with all specified standards and terms of the employment agreement contract for your “Attorney at Law” legal services
For said civil in “common law” within the 58th Judicial District Court of Jefferson County Texas, Docket No. A-180805…?
During the exact precise month of March of 2008…?
Subpart (F)
Further expertly explaining in precise legal careful details Defendant “Antoine L. Freeman, J.D.” Texas Bar No. 24058299 herein fully legally precisely
how was the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein collectively…?
Exactly with supporting “physical documented” of proof and your “legally” precise details said Co-Defendant(s) collectively complying fully with,
and acting in accordance with all specified standards and terms of the employment agreement contract for your “Attorney at Law” legal services
For said civil in “common law” within the 58th Judicial District Court of Jefferson County Texas, Docket No. A-180805…?
During the exact precise month of April of 2008…?
Subpart (G)
Further expertly explaining in precise legal careful details Defendant “Antoine L. Freeman, J.D.” Texas Bar No. 24058299 herein fully legally precisely
how was the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein collectively…?
Exactly with supporting “physical documented” of proof and your “legally” precise details said Co-Defendant(s) collectively complying fully with,
and acting in accordance with all specified standards and terms of the employment agreement contract for your “Attorney at Law” legal services
For said civil in “common law” within the 58th Judicial District Court of Jefferson County Texas, Docket No. A-180805…?
During the exact precise month of May of 2008…?
Subpart (H)
Further expertly explaining in precise legal careful details Defendant “Antoine L. Freeman, J.D.” Texas Bar No. 24058299 herein fully legally precisely
how was the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein collectively…?
Exactly with supporting “physical documented” of proof and your “legally” precise details said Co-Defendant(s) collectively complying fully with,
and acting in accordance with all specified standards and terms of the employment agreement contract for your “Attorney at Law” legal services
For said civil in “common law” within the 58th Judicial District Court of Jefferson County Texas, Docket No. A-180805…?
During the exact precise month of June of 2008…?
Subpart (I)
Further expertly explaining in precise legal careful details Defendant “Antoine L. Freeman, J.D.” Texas Bar No. 24058299 herein fully legally precisely
how was the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein collectively…?
Exactly with supporting “physical documented” of proof and your “legally” precise details said Co-Defendant(s) collectively complying fully with,
and acting in accordance with all specified standards and terms of the employment agreement contract for your “Attorney at Law” legal services
For said civil in “common law” within the 58th Judicial District Court of Jefferson County Texas, Docket No. A-180805…?
During the exact precise month of July of 2008…?
Subpart (J)
Further expertly explaining in precise legal careful details Defendant “Antoine L. Freeman, J.D.” Texas Bar No. 24058299 herein fully legally precisely
how was the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein collectively…?
Exactly with supporting “physical documented” of proof and your “legally” precise details said Co-Defendant(s) collectively complying fully with,
and acting in accordance with all specified standards and terms of the employment agreement contract for your “Attorney at Law” legal services
For said civil in “common law” within the 58th Judicial District Court of Jefferson County Texas, Docket No. A-180805…?
During the exact precise month of August of 2008…?
Subpart (K)
Further expertly explaining in precise legal careful details Defendant “Antoine L. Freeman, J.D.” Texas Bar No. 24058299 herein fully legally precisely
how was the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein collectively…?
Exactly with supporting “physical documented” of proof and your “legally” precise details said Co-Defendant(s) collectively complying fully with,
and acting in accordance with all specified standards and terms of the employment agreement contract for your “Attorney at Law” legal services
For said civil in “common law” within the 58th Judicial District Court of Jefferson County Texas, Docket No. A-180805…?
During the exact precise month of September of 2008…?
Subpart (L)
Further expertly explaining in precise legal careful details Defendant “Antoine L. Freeman, J.D.” Texas Bar No. 24058299 herein fully legally
precisely how was the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein collectively…?
Exactly with supporting “physical documented” of proof and your “legally” precise details said Co-Defendant(s) collectively complying fully with,
and acting in accordance with all specified standards
and terms of the employment agreement contract for your “Attorney at Law” legal services
For said civil in “common law” within the 58th Judicial District Court of Jefferson County Texas, Docket No. A-180805…?
During the exact precise month of October of 2008…?
Subpart (M)
Further expertly explaining in precise legal careful details Defendant “Antoine L. Freeman, J.D.” Texas Bar No. 24058299 herein fully legally precisely
how was the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein collectively…?
Exactly with supporting “physical documented” of proof and your “legally” precise details said Co-Defendant(s) collectively complying fully with,
and acting in accordance with all specified standards and terms of the employment agreement contract for your “Attorney at Law” legal services
For said civil in “common law” within the 58th Judicial District Court of Jefferson County Texas, Docket No. A-180805…?
During the exact precise month of November of 2008…?
Subpart (N)
Further expertly explaining in precise legal careful details Defendant “Antoine L. Freeman, J.D.” Texas Bar No. 24058299 herein fully legally precisely
how was the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein collectively…?
Exactly with supporting “physical documented” of proof and your “legally” precise details said Co-Defendant(s) collectively complying fully with,
and acting in accordance with all specified standards and terms of the employment agreement contract for your “Attorney at Law” legal services
For said civil in “common law” within the 58th Judicial District Court of Jefferson County Texas, Docket No. A-180805…?
During the exact precise month of December of 2008…?
Subpart (O)
Further expertly explaining in precise legal careful details Defendant “Antoine L. Freeman, J.D.” Texas Bar No. 24058299 herein fully legally precisely
how was the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein collectively…?
Exactly with supporting “physical documented” of proof and your “legally” precise details said Co-Defendant(s) collectively complying fully with,
and acting in accordance with all specified standards and terms of the employment agreement contract for your “Attorney at Law” legal services
For said civil in “common law” within the 58th Judicial District Court of Jefferson County Texas, Docket No. A-180805…?
During the exact precise month of January of 2009…?
Subpart (P)
Further expertly explaining in precise legal careful details Defendant “Antoine L. Freeman, J.D.” Texas Bar No. 24058299 herein fully legally precisely
how was the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein collectively…?
Exactly with supporting “physical documented” of proof and your “legally” precise details said Co-Defendant(s) collectively complying fully with,
and acting in accordance with all specified standards and terms of the employment agreement contract for your “Attorney at Law” legal services
For said civil in “common law” within the 58th Judicial District Court of Jefferson County Texas, Docket No. A-180805…?
During the exact precise month of Februarys of 2009…?
Subpart (Q)
Further expertly explaining in precise legal careful details Defendant “Antoine L. Freeman, J.D.” Texas Bar No. 24058299 herein fully legally precisely
how was the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein collectively…?
Exactly with supporting “physical documented” of proof and your “legally” precise details said Co-Defendant(s) collectively complying fully with,
and acting in accordance with all specified standards and terms of the employment agreement contract for your “Attorney at Law” legal services
For said civil in “common law” within the 58th Judicial District Court of Jefferson County Texas, Docket No. A-180805…?
During the exact precise month of March of 2009…?
Subpart (R)
Further expertly explaining in precise legal careful details Defendant “Antoine L. Freeman, J.D.” Texas Bar No. 24058299 herein fully legally precisely
how was the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein collectively…?
Exactly with supporting “physical documented” of proof and your “legally” precise details said Co-Defendant(s) collectively complying fully with,
and acting in accordance with all specified standards and terms of the employment agreement contract for your “Attorney at Law” legal services
For said civil in “common law” within the 58th Judicial District Court of Jefferson County Texas, Docket No. A-180805…?
During the exact precise month of April of 2009…?
Subpart (S)
Further expertly explaining in precise legal careful details Defendant “Antoine L. Freeman, J.D.” Texas Bar No. 24058299 herein fully legally precisely
how was the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein collectively…?
Exactly with supporting “physical documented” of proof and your “legally” precise details said Co-Defendant(s) collectively complying fully with,
and acting in accordance with all specified standards and terms of the employment agreement contract for your “Attorney at Law” legal services
For said civil in “common law” within the 58th Judicial District Court of Jefferson County Texas, Docket No. A-180805…?
During the exact precise month of May of 2009…?
Subpart (T)
Further expertly explaining in precise legal careful details Defendant “Antoine L. Freeman, J.D.” Texas Bar No. 24058299 herein fully legally precisely
how was the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein collectively…?
Exactly with supporting “physical documented” of proof and your “legally” precise details said Co-Defendant(s) collectively complying fully with,
and acting in accordance with all specified standards and terms of the employment agreement contract for your “Attorney at Law” legal services
For said civil in “common law” within the 58th Judicial District Court of Jefferson County Texas, Docket No. A-180805…?
During the exact precise month of June of 2009…?
Subpart (U)
Further expertly explaining in precise legal careful details Defendant “Antoine L. Freeman, J.D.” Texas Bar No. 24058299 herein fully legally precisely
how was the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein collectively…?
Exactly with supporting “physical documented” of proof and your “legally” precise details said Co-Defendant(s) collectively complying fully with,
and acting in accordance with all specified standards and terms of the employment agreement contract for your “Attorney at Law” legal services
For said civil in “common law” within the 58th Judicial District Court of Jefferson County Texas, Docket No. A-180805…?
During the exact precise month of July of 2009…?
Subpart (V)
Further expertly explaining in precise legal careful details Defendant “Antoine L. Freeman, J.D.” Texas Bar No. 24058299 herein fully legally precisely
how was the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein collectively…?
Exactly with supporting “physical documented” of proof and your “legally” precise details said Co-Defendant(s) collectively complying fully with,
and acting in accordance with all specified standards and terms of the employment agreement contract for your “Attorney at Law” legal services
For said civil in “common law” within the 58th Judicial District Court of Jefferson County Texas, Docket No. A-180805…?
During the exact precise month of August of 2009…?
Subpart (W)
Further expertly explaining in precise legal careful details Defendant “Antoine L. Freeman, J.D.” Texas Bar No. 24058299 herein fully legally precisely
how was the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein collectively…?
Exactly with supporting “physical documented” of proof and your “legally” precise details said Co-Defendant(s) collectively complying fully with,
and acting in accordance with all specified standards and terms of the employment agreement contract for your “Attorney at Law” legal services
For said civil in “common law” within the 58th Judicial District Court of Jefferson County Texas, Docket No. A-180805…?
During the exact precise month of September of 2009…?
Subpart (X)
Further expertly explaining in precise legal careful details Defendant “Antoine L. Freeman, J.D.” Texas Bar No. 24058299 herein fully
legally precisely how was the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein collectively…?
Exactly with supporting “physical documented” of proof and your “legally” precise details said Co-Defendant(s) collectively
complying fully with, and acting in accordance with all specified standards and terms of the employment agreement contract for your “Attorney at Law” legal services
For said civil in “common law” within the 58th Judicial District Court of Jefferson County Texas, Docket No. A-180805…?
During the exact precise month of October of 2009…?
Subpart (Y)
Further expertly explaining in precise legal quite careful avoiding “Perjury” details…?
Defendant “Antoine L. Freeman, J.D.” Texas Bar No. 24058299 herein
Fully legally precisely how is possible it that the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein collectively…?
Having a physical “legal binding contract” for your “legal services” from the time frame of December 18th 2007 when you filed “Your” General Denial…?
Throughout the time frame until “You” finally official filed a “Motion for Withdrawal of Counsel”, filed stamp dated November 13th 2009 10:22 am hour…?
Being fully quite “Legally” described in Pro Se Plaintiff attached Document # 8 “Your Motion for withdrawal of counsel”
As stated legally by you as follows:
To The Honorable Judge of Said Court:
Now Comes Movant, Antoine L. Freeman J.D., Attorney for Defendants, Joyce Guy and Edward McCray, (hereinafter Defendants),
and brings this Motion for withdrawal of Counsel, and in support thereof, shows the court the following:
I.
Good cause exists for withdrawal of Movant as counsel because Defendants have not complied with the terms of employment agreement with this attorney.
Plaintiffs refuse to adhere to the terms of the employment agreement with this attorney.
II.
The setting and deadlines in this case are as follows: Motion for Sanction & Contempt on December 11th, 2009 @ 9:00 am (With Your Initials)
III.
This Motion is not sought for the purposes of delay.
IV.
A copy of this motion bearing the enclosed notice has been delivered to the last known addresses of the Defendants.
“Joyce Guy” 5050 7th street Port Arthur, Texas 77642
“Edward McCray” 5050 7th street Port Arthur, Texas 77642
V.
Defendants are hereby notified in writing of the right to object to this motion.
NOTICE
You are hereby notified that this motion for withdrawal of Counsel is set for hearing at the time and place set out below.
You do not agree to this motion. If you wish to contest the withdrawal of Antoine L. Freeman, J.D. as your attorney, you should appear at the hearing.
If you do not oppose Antoine L. Freeman, J.D.’s withdrawal as your attorney, you may notify Antoine L. Freeman, J.D. in writing of your consent to this motion.
Wherefore, Premises Considered, Movant prays that the Court enters as order discharging Movant
as attorney of record for Defendants, “Joyce Guy” and “Edward McCray”, and for such other and
further relief that may be awarded at law or in equity.
Respectfully submitted, by “Antoine L. Freeman, J.D., Texas Bar No. 24058299, 3723 Gulfway Dr. Ste #104, Port Arthur, Texas 77642 (409) 293-1627, Fax (409) 983-7405
“Attorney for Defendants” Joyce Guy and Edward McCray
“When” oddly being described once again by “You” officially in Pro Se Plaintiff attached Document # 2
your fully legally claiming in said 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 in paragraph 1 and 2 stated as follows:
(1)
At the time of Plaintiffs discovery request Defendant’s Attorney had not been retain by Defendants to represent their interest with regards to this lawsuit.
(2)
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 legally…? Now in November of 2009 there is in factual circumstances surrounding a legal binding contract you’re claiming
do in fact exist between Attorney/client namely Defendant “Antoine L. Freeman, J.D.” Texas Bar No. 24058299 herein
and said Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein
As described in Pro Se Plaintiff attached Document # 8 herein namely “Your” Motion for withdrawal of counsel” fully stating among other things
Said Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein
“Not officially” complying fully with, and acting in all accordance with all specified standards and terms of the employment agreement contract for your “Attorney at Law” legal services
For said civil in “common law” within the 58th Judicial District Court of Jefferson County Texas, Docket No. A-180805…?
During the exact precise day of the 13th during the month of November in the year of 2009…?
Which now legally “You” are seeking the 58th Judicial District Court Judge Bob Wortham
“honest official approval” to terminate said contract… in December 11th 2009 Court Hearing…?
As you’re saying “officially” before the “Honorable Court” a contract do not exist at all between the time frame of December 18th 2007…?
Throughout the time frame you file said Response to Plaintiff’s Motion for sanctions against you on September 11th 2009…?
Between “You” Defendant (Attorney at Law) herein and said Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein…?
As you secure your official false, fraudulent bogus (RICO) Obstruction of Justice”
representation before the “Honorable 58th Judicial District Judge Bob Wortham “Honorable Court” in regards to “among other things”
Your 100% “acting Attorney of Record” violation of Rule 193.1 of the Texas Rules of Civil Procedure regarding responds to discovery in a timely manner…?
But “Your” still at the same “time frame” legally claiming before the same Honorable 58th Judicial District Court Judge “Bob Wortham”
in Pro Se Plaintiff attached Document # 2 herein “Your” response to Plaintiff’s Motion for sanctions against you
Your being 100% official stating that “no such legal binding Contract exists” at all,
“Your (only) duties were the official filing of a “General Denial” on December 18th 2007…?
And “Your” having official just legal rights to not respond to all said discovery request
of the Pro Se Plaintiff herein for this civil suit in common law being in your 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 against Texas Rules of Civil Procedures
When such a real Legal binding Contract does exist between you and The Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein collectively
From the exact time frame date of December 18th 2007 throughout December 11th 2009
when the court granted your withdrawal of counsel…?
From said “Contract” between “You” and the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein collectively
As being further precisely legally being “officially” cleverly described in Pro Se Plaintiff attached Document # 8
“Your” very own “Motion for withdrawal as counsel” stating in November 13th 2009…? “Among other things”
The said Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein collectively
“Have not complied with the “terms of employment agreement” with this attorney.”…? In the month of November of 2009…?
Subpart (Z)
Further expertly explaining in precise legal quite careful avoiding “Perjury” details…?
Chief Defendant “Antoine L. Freeman, J.D.” Texas Bar No. 24058299 herein
Fully legally precisely how is “legally 100% possible” it that the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein collectively…?
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,
Actually physically complied fully with all of the “terms and conditions of employment agreement” with this attorney.”…?
Namely “You” Defendant Antoine L. Freeman, J.D.” Texas Bar No. 24058299 herein …?
When while “Your” representing said Co-Defendant(s) herein collectively at the same time
“You” (Attorney at Law) never ever produce an “actual physical copy(s)” of said Property deeds for dwelling and the property located
at 448 DeQueen Blvd. in Port Arthur Texas. (Block 172, Lot 1-2) as request and required in Pro Se Plaintiff Motion for Production of Document dated August 12th 2008…?
As being described such a motion exist for the production of said “Property deeds in Pro Se Plaintiff attached Document #10
The 58th Judicial District Court of Jefferson County Texas “Court Order”
dated the 10th day of May 2010 in Compelling the physical Production of said “Property Deeds”…?
While fraudulently (RICO) also at this same “precise legal time frame”
same property deeds for dwelling and the property located at 448 DeQueen Blvd. in Port Arthur Texas. (Block 172, Lot 1-2)
Being in the “Active physical” possession, custody and legal control of the “Texas Department of Housing & Community Affairs”
During the same time frame of “June 18th 2009 throughout July 22nd 2013 as being described in Pro Se Plaintiff attached Document # 9 herein
The “Jefferson County Texas Property search Index” (Public Record).
While these same said “Property Deeds” for dwelling and the property located at 448 DeQueen Blvd. in Port Arthur Texas. (Block 172, Lot 1-2) of Co-Defendant(s) “Joyce M. Guy and Edward McCray herein collectively
Being official “subject matter” in a civil suit in common law since November 26th 2007 while you’re still acting “Attorney of Record…?
Throughout December 11th 2009…?
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