Tuesday, January 6, 2015

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

(19)

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

“The Texas Disciplinary Rules of Professional Conduct” particularly relating to 8.04 Misconduct described as follows:

a) A lawyer shall not:

(1) Violate these rules, knowingly assist or induce another to do so, or do so through the acts of another,

whether or not such violation occurred in the course of a client-lawyer relationship;

(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;

(4) Engage in conduct constituting obstruction of justice;

“Explain…..? “Chief” Defendant “Antoine L. Freeman, J.D.” Attorney at Law Texas Bar No. 24058299 herein precisely why…?

When (I) Pro Se Plaintiff “Louis Charles Hamilton II” herein on the exact day of August 12th 2009 request for the Production of Document

“namely” in the exact physical proof of “ownership” in the production of said property deeds for dwelling

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

and your fully aware at that exact moment in time of said Production of document request..?

“You” Defendant (Attorney at Law) did not come forth before the 58th Judicial District Court of Jefferson County Texas “Honorable Bob Wortham” in docket No. A-180805

And honestly first and foremost file a legal written notice “Honorable Court” ex-parte, or with notice served upon said Pro Se Plaintiff herein

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

collectively illegally 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“Jefferson County Real Estate Index” Instrument #2009022762 in Attached document #7 herein shown

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

So you’re 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

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 Property Deeds…?

When “The Texas Disciplinary Rules of Professional Conduct” particularly relating to 8.04 Misconduct described as follows:

a) A lawyer shall not:

(1) Violate these rules, knowingly assist or induce another to do so, or do so through the acts of another, whether or not such violation occurred in the course of a client-lawyer relationship;

(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;

And “Your” being directly legally, documented proof engaging in the conduct involving dishonesty,

fraud, deceit and concealment of said property deeds since August 12th 2009…?

And failing to disclosed this “material facts” said “property and deeds thereof was in the custody,

possession and legal control of the “Texas Department of Housing & Community Affairs”

as described in Pro Se Plaintiff attached Document # 9 attached herein “Jefferson County Texas Property search Index” Instrument # 2014012455

While you’re still acting Attorney of Record in ongoing civil suit A-180805 before the 58th Judicial District Court of Jefferson County Texas…..?

When “The Texas Disciplinary Rules of Professional Conduct” particularly relating to 8.04 Misconduct paragraph (2) and (3) clearly stating:

(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;

Subpart (A)

Further expertly explaining in precise legal careful details Defendant “Antoine L. Freeman, J.D.” Texas Bar No. 24058299 herein for the exact month of April of 2008…?

Your having full possession, custody and legal control over said discovery request,

of Request for admission, Interrogatories, and Disclosure Request Pursuant to Rule 194 of the Texas rules of Civil Procedure,

As you stated in Pro Se Plaintiff attached Document # 2 herein “Your response to Plaintiff Motion for sanctions against you

for violation of Rule 193.1 of the Texas Rules of Civil Procedure regarding responding to discovery in a timely manner…?

Fully explaining why did you Defendant (Attorney at Law) come forth before the 58th Judicial District Court of Jefferson County Texas

appearing in person no less before the “Honorable Bob Wortham” in docket No. A-180805 on the 11th day of September 2009 and completely

“lie” and further supply false fabricated affidavits of Co-Defendant “Joyce M. Guy” herein filed as attached Document # 6

and further supply false fabricated “Motion for withdrawal” filed as attached Document #2 attached herein

And stated “You” are Not the “retain acting attorney of record” to defend the legal interest of the Co-Defendant(s) described collectively herein

and there is no such binding contract for your legal services there after the 18th day of December 2007 when you was under contract to file said “General Denial”

And “Your” having official just legal rights standing to not respond to any and 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

But you’re filing a “Motion for withdrawal of counsel” on November 13th 2009 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 during the month of November 2009...?

When “The Texas Disciplinary Rules of Professional Conduct” particularly relating to 8.04 Misconduct paragraph (2) and (3) clearly stating you’re not to be:

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

But you’re physically chief Defendant “Antoine L. Freeman, J.D.” Texas Bar No. 24058299 herein bring forth false misrepresentation

before the “Honorable Bob Wortham” in docket No. A-180805

On the 11th day of September 2009 regarding “Your” actual retain for hire status throughout 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 you’re physically being discharge as acting Attorney of record on December 11th 2009…?

From said “Attorney for hire contract" in connection with the Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein.

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