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

Subpart (B)

Further expertly continue explaining in precise legal careful details Defendant “Antoine L. Freeman, J.D.” Texas Bar No. 24058299 herein

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” among other things 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..

And you’re claiming in attached Document # 2 herein Your Response to Plaintiff motion for sanctions against “You” in paragraph 1 and 2

In your defense in attached Document # 2 herein as you claim, sworn and stated as follows:

“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.”

“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 on the exact dates of August 28th 2009 “physically present” before the “Honorable Bob Wortham”

in same Docket No. A-180805 in the physical breathing acting “Attorney of Record” legal capacity presenting

“Oral Arguments” no less against the Pro Se Plaintiff (TRO) ‘Temporary Restraining Order, order to show cause, motion for Guardian AD LITEM being described in

Pro Se Plaintiff attached Documents # 11 herein namely the 58th Judicial District Court of Jefferson County Texas “Civil Docket Report”

for cause A-180805 fully describing “among other things you “legally physically there” as acting retain

“Attorney of record” for the Co-Defendant(s) “Joyce M. Guy” and Edward McCray” collectively behalf…?

And you having no official “Motion for withdrawal of counsel” as being described in Pro Se Plaintiff attached Document # 8 herein filed on November 13th 2009

When as already stated by “You” in attached Document # 2 herein Your Response to Plaintiff motion for sanctions against “You” in paragraph 1 and 2 as you legally claim, sworn and stated as

follows:

“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.”

“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”

Which “You” directly “sworn” to these “material facts” on “December 11th 2009 being 100% adamantly

“However” at the same time frame your actually acting attorney of record until “December 11th 2009 in the AM hour…?

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

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

But your being at the same time frame physically dishonest, providing fraudulent documents to support the facts,

as described in attached Documents #2, your response to motion for sanctions against you

And Document #6 herein “Affidavit” of Co-Defendant “Joyce M. Guy”

And Defendant (Attorney at Law) 100% directly misrepresentation “Live” actual deceit before the

“Honorable Judge Bob Wortham” of the 58th Judicial District Court in Jefferson County Texas in same Docket No. A-180805

Stating “You” are not acting retain “attorney of record” after the filing of the “General Denial” on December 18th 2007 as your physically saying all of this on December 11th 2009…?

But Pro Se Plaintiff attached Document # 11 herein namely the 58th Judicial District Court of Jefferson County Texas

“Civil Docket Report” for cause A-180805 having you acting Attorney of record

Fully 100% describing “among other things you “legally physically there”

as acting retain “Attorney of record” for the Co-Defendant(s) “Joyce M. Guy” and Edward McCray” collectively behalf… on August 28th 2009 “Live Hearing” date…?

As you’re deceiving the “Honorable Court” from August 28th 2009 “Live Hearing” dates throughout the hearing date of December 11th 2009…?

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

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

As acting retain “Attorney of record” for the Co-Defendant(s) “Joyce M. Guy” and Edward McCray” collectively behalf

Is this not in direct violation…? Of The Texas Disciplinary Rules of Professional Conduct” particularly relating to

8.04 Misconduct paragraphs (3) clearly stating you’re not to be a Attorney:

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