Request Number 174.
Admit: You” Attorney at Law that “You” filed document # 1 herein “Your response to Motion for sanctions against you in
the Jefferson County Texas “Clerk of Court” office using the “United States Mailing System”.
And you further forward such document #1 herein to the Pro Se Plaintiff while still using the “United States mailing system”.
Request Number 175.
Admit: You” Attorney at Law that “You” filed document # 1 herein “Your response to Motion for sanctions in the
Jefferson County Texas “Clerk of Court” office and obtain “Judge Bob Worthham” approval for you withdrawal
As being described on Document # 8 attached herein 58th Judicial District Court of Jefferson County Texas case ledger Docket No. A-180805
Request Number 176.
Admit: You” Attorney at Law that “You” forward such Document #1 Your response to Motion for sanctions against you herein to the
Pro Se Plaintiff while still using the “United States mailing system”.
Request Number 177.
Admit: You” Attorney at Law that “You” did in real “factual circumstances” obtain “Judge Bob Worthham”
approval for your withdrawal as acting “Attorney of Record” on Document # 2 attached herein “Your Motion for withdrawal”
While “Your” being in complete refusal to submit and reply to Pro Se Plaintiff “Discovery request” until “October 14th 2010 which
“You” had in your possession as “You” are claiming since April of 2008
As you are so order by Co-Defendant “Joyce M. Guy” herein to not submit to any such discovery request in a “timely fashion”
as required by Texas rules of Civil Procedure” to Pr Se Plaintiff discovery requests
as stated on Document # 10 attached herein Co-Defendant “Joyce M. Guy” affidavit in support of
”You” to not reply to required discovery of Pro Se Plaintiff while your being the fully legal retain “Attorney of Record” for cause no. A-180805
From the time frame dates of December 18th 2007 throughout December 11th 2009 as Document # 12 attached herein
showing “Judge Bob Wortham” approval for your motion for withdrawal as acting “Attorney of Record being granted on December 11th 2009
While Co-Defendant(s) Edward McCray and Joyce M. Guy” herein collectively in all “factual events and legal circumstances”
(Already)Transfer to the “Texas Department of Housing & Community Affairs” Said “Property Deeds”
for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas on the date of June 18th 2009
As described by “Jefferson County Real Estate Index” Instrument # 2009022762 in attached exhibit #7 herein “while
“Your” further admit that Said “Property”, dwelling, and deeds thereof “already being a material evidence and
actual Party of a Civil suit in common law since November 26th 2007 when Pro Se Plaintiff herein filed “original Complaint A-180805
against Co-Defendant(s) Edward McCray and Joyce M. Guy” herein collectively
Request Number 178.
Admit: You” Attorney at Law that “You” was so order and legally retain for you “Attorney at Law” services by Co-Defendant Joyce M. Guy” herein collectively
as described in attached Document # 10 herein Co-Defendant “Joyce M. Guy” affidavit” as this was required for
“You” in the capacity of acting “Attorney of Record in cause No. A-180805 during the months of 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, September of 2009 to not respond
In a timely manner at all to said Discovery request of Pro Se Plaintiff “Your” having in “Your” Legal possession, custody and control over
since March 14th 2008 as legally described in Pro Se Plaintiff Document No. # 8 attached herein
being the official 58th Judicial District Court of Jefferson County Texas “Case Ledger” for Civil Cause No. A-180805.
And as “Your” claiming in Document # 1 attached Herein “You”
Further admit this is not in “Violations of Rule 193.1 of the Texas Rules of Civil Procedure of
“Your” responds to filing a discovery in a “timely manner” for cause of action against Co-Defendant(s) Joyce M. Guy and Edward McCray collectively herein.
Which your acting Attorney of record and retain to not submit to any discovery request of the Pro Se Plaintiff in docket No. A-180805
until provision of $76,000.00 U. S. Dollars Housing Grant was applied for,
executed and achieved by Co-Defendant(s) “Joyce M. Guy and Edward McCray herein collectively
for the property located at 448 DeQueen Blvd. in Port Arthur Texas. (Block 172, Lot 1-2)
Request Number 179.
Admit: You” Attorney at Law that “You” always never file “Discovery requests” in a timely fashion as required by Texas Rules of Civil Procedures
to any “opposing counsel and any Pro Se Plaintiffs”.
When “Your” retain clients require you to cover up all discovery requests being made against them
as being described in Document # 8 attached herein
“Your” having possession, custody and legal control over said “Discovery Request” of the Pro Se Plaintiff
and this is your legal retain duties in the capacity of a “Attorney at Law” in and for the State of Texas “Your” Attorney at Law” Bar No. 24058299.
Request Number 180.
Admit: You” Attorney at Law that “You” was so order by Co-Defendant Joyce M. Guy” herein collectively
as described in attached Document # 10 herein Co-Defendant “Joyce M. Guy” affidavit”
As this was required for “Your” retain duties as acting “Attorney of Record” during the months of 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, September of 2009 to not respond at all
In a timely manner to said “Discovery request” of Pro Se Plaintiff “Your” having in “Your” Legal possession, custody and control over since March 14th 2008
as legally described in Pro Se Plaintiff Document No. # 8 attached herein
being the official 58th Judicial District Court of Jefferson County Texas “Case Ledger” for Civil Cause No. A-180805.
“You” was so “Order” and retain by Co-Defendant Joyce M. Guy” herein to represent all legal interest against Pro Se Plaintiff herein in cause No. A-180805
at (2) court hearing dated “August 28th 2009 and September 11th 2009
While “Your” claiming “Your” only official retain legal services obligations was to filing a “General Denial”
on December 18th 2007 as described in Document # 1”Your response to motion for sanctions against “You”
but you did attended (2) said court hearing dated “August 28th 2009 and September 11th 2009
Request Number 181.
Admit: You” Attorney at Law that the 58th Judicial District Court of Jefferson County Texas “Case Ledger” showing
“You” being in possession of numerous Discovery Documents and
Legal Motions for the Co-Defendant(s) “Joyce M. Guy and Edward McCray herein collectively behalf
starting on March 14th 2008 such a discovery process started
While attached Document No. # 8 herein the 58th Judicial District Court of Jefferson County Texas “Case Ledger”
also showing “Required Pro Se Plaintiff discovery made to “You” being request for admissions, interrogatories and Disclosure being in
“Your” legal possession, custody and legal control on or about the dates of April 2nd 2008 and April 11, 2008 that
“Your” making continue false claims to about these dates of “factual events and legal circumstances”
which do not officially exist at all as described in Pro Se Plaintiff attached Document No. # 8 herein
the 58th Judicial District Court of Jefferson County Texas “Case Ledger”
” You” was so order by Co-Defendant Joyce M. Guy” herein as described in attached Document # 10 herein Co-Defendant “Joyce M. Guy”
affidavit” as this was required for “Your” retain legal duties as acting “Attorney of Record” during the months of 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, September of 2009 to not respond at all
In a timely manner to said “Discovery request” of Pro Se Plaintiff “Your” having in “Your”
Legal possession, custody and control over since March 14th 2008 as legally described in Pro Se Plaintiff Document No. # 8 attached herein
being the official 58th Judicial District Court of Jefferson County Texas “Case Ledger” for Civil Cause No. A-180805 and
“You” refusal to withdrawal “Your” self during this same time frame.
Request Number 182.
Admit: You” Attorney at Law that “You” Was so order by Co-Defendant Joyce M. Guy” herein collectively as described in attached Document # 10 herein
Co-Defendant “Joyce M. Guy” affidavit”
As this was required for “Your” retain legal duties as acting “Attorney of Record” during the months of 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, September of 2009 to not respond at all
In a timely manner to said “Discovery request” of Pro Se Plaintiff “Your” having in
“Your” Legal possession, custody and control over since March 14th 2008 as legally described in Pro Se Plaintiff Document No. # 8
attached herein being the official 58th Judicial District Court of Jefferson County Texas “Case Ledger” for Civil Cause No. A-180805
And “Your” additional duties include for “Your” official retain “Attorney at Law” skills
to keep the Production of documents in said production of the “Property Deeds” being conceal from this “civil action”
and Pro Se Plaintiff between the dates of August 12th 2009 throughout December 11th 2009 while “Your” acting Attorney of record
While “Your” further admitting Co-Defendant(s) Edward McCray and Joyce M. Guy” herein collectively in all “factual events and legal circumstances”
commenced the legal Transfer to the “Texas Department of Housing & Community Affairs” provided provision of $76,000.00 U. S. Dollars Housing Grant
as described in Document # 7 attached herein “Jefferson County Texas Property search Index
Said “Property Deeds” for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas on the date of June 18th 2009
being legally transfer while “You’re” acting “Attorney of Record.
As described by “Jefferson County Real Estate Index” Instrument # 2009022762 in attached exhibit #7 herein “
While “Your” further admit that Said “Property”, dwelling, and deeds thereof “already being a “material evidence”
and actual party of a Civil suit in common law since for a “Breach of Construction Contract in excess of $10,800.00 U.S. Dollars since
November 26th 2007 when Pro Se Plaintiff herein filed “Original Complaint” A-180805
against Co-Defendant(s) Edward McCray and Joyce M. Guy” herein collectively.
Request Number 183.
Admit: You” Attorney at Law that “You” having always refuse to comply and submit to Texas rules of Civil Procedures.
Against all Pro Se Plaintiffs when “Your” numerous clients retain “You” to so do in the legal Profession as acting “Attorney of Record”...
Request Number 184.
Admit: You” Attorney at Law that “Your” additional legal duties include for “Your” official retain “Attorney at Law” skills
to keep the Production of documents in said production of the “Property Deeds” being conceal from this “civil action”
between the dates of August 12th 2009 throughout December 11th 2009 while “Your” acting Attorney of record
Request Number 185.
Admit: You” Attorney at Law that “Your” additional legal duties include for “Your” official retain “Attorney at Law” skills
to keep the Production of documents in said production of the “Property Deeds” being conceal from this “civil action”
between the dates of August 12th 2009 throughout the dates of November 13th 2009
and you did not file a Motion for withdrawal as acting Attorney of record between the date of December 18th 2007 throughout November 12th 2009,
While Co-Defendant(s) Joyce M. Guy and Edward McCray herein collectively in all
“factual events and legal circumstances” commenced the legal Transfer to the “Texas Department of Housing & Community Affairs”
provided provision of $76,000.00 U. S. Dollars Housing Grant as described in Document # 7 attached herein “Jefferson County Texas Property search Index
Said “Property Deeds” for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas
before the date of June 18th 2009 when deeds was being legally transfer while “You’re” acting “Attorney of Record.
As described by “Jefferson County Real Estate Index” Instrument # 2009022762 in attached exhibit #7 herein “
While “Your” further admit that Said “Property”, dwelling, and deeds thereof
“already being a material evidence and actual party of a Civil suit in Common law since 2007 for a
“Breach of Construction Contract in excess of $10,800.00 U.S. Dollars
November 26th 2007 when Pro Se Plaintiff herein filed “original Complaint A-180805
against Co-Defendant(s) Edward McCray and Joyce M. Guy” herein collectively.
Request Number 186.
Admit: You” Attorney at Law that after December 18th of 2007 when you filed said “General Denial”
as “Your” claiming this was “Your” only legal duties as described in Document # 1 attached herein
“Your” response to motion for sanctions against “You”
additionally Admit “You” could have filed a “Motion for immediately “Your” withdrawal from cause No. A-180805 at this time frame
but “Your” legal choice was to continue being acting “Attorney of record during the month of December of 2007
Request Number 187.
Admit: You” Attorney at Law that after December 18th of 2007 “You could have filed a
“Motion for “Your” immediately withdrawal from cause No. A-180805 but
“Your” legal choice was to continue being acting “Attorney of record during the month of January 2008
Request Number 188.
Admit: You” Attorney at Law that after December 18th of 2007 “You” could have filed a
“Motion for “Your” immediately withdrawal from cause No. A-180805 but
“Your” legal choice was to continue being acting “Attorney of record during the month of February 2008
Request Number 189.
Admit: You” Attorney at Law that after December 18th of 2007 you could have filed a
“Motion for “Your” immediately withdrawal from cause No. A-180805 but
“Your” legal choice was to continue being acting “Attorney of record during the month of March of 2008
Request Number 190.
Admit: You” Attorney at Law that after December 18th of 2007 you could have filed a
“Motion for “Your” immediately withdrawal from cause No. A-180805 but
“Your” legal choice was to continue being acting “Attorney of record during the month of April of 2008
Request Number 191.
Admit: You” Attorney at Law that after December 18th of 2007 you could have filed a
“Motion for “Your” immediately withdrawal from cause No. A-180805 but
“Your” legal choice was to continue being acting “Attorney of record during the month of May of 2008
Request Number 192.
Admit: You” Attorney at Law that after December 18th of 2007 you could have filed a
“Motion for “Your” immediately withdrawal from cause No. A-180805 but
“Your” legal choice was to continue being acting “Attorney of record during the month of June of 2008
Request Number 193.
Admit: You” Attorney at Law that after December 18th of 2007 you could have filed a
“Motion for “Your” immediately withdrawal from cause No. A-180805 but
“Your” legal choice was to continue being acting “Attorney of record during the month of July of 2008
Request Number 194.
Admit: You” Attorney at Law that after December 18th of 2007 you could have filed a
“Motion for “Your” immediately withdrawal from cause No. A-180805 but
“Your” legal choice was to continue being acting “Attorney of record during the month of August of 2008
Request Number 192.
Admit: You” Attorney at Law that after December 18th of 2007 you could have filed a
“Motion for “Your” immediately withdrawal from cause No. A-180805 but
“Your” legal choice was to continue being acting “Attorney of record during the month of September of 2008
Request Number 193.
Admit: You” Attorney at Law that after December 18th of 2007 you could have filed a
“Motion for “Your” immediately withdrawal from cause No. A-180805 but
“Your” legal choice was to continue being acting “Attorney of record during the month of October of 2008
Request Number 194.
Admit: You” Attorney at Law that after December 18th of 2007 you could have filed a
“Motion for “Your” immediately withdrawal from cause No. A-180805 but
“Your” legal choice was to continue being acting “Attorney of record during the month of November of 2008
Request Number 195.
Admit: You” Attorney at Law that after December 18th of 2007 you could have filed a
“Motion for “Your” immediately withdrawal from cause No. A-180805 but
“Your” legal choice was to continue being acting “Attorney of record during the month of December of 2008
Request Number 196.
Admit: You” Attorney at Law that after December 18th of 2007 you could have filed a
“Motion for “Your” immediately withdrawal from cause No. A-180805 but
“Your” legal choice was to continue being acting “Attorney of record during the month of January 2009
Request Number 197.
Admit: You” Attorney at Law that after December 18th of 2007 you could have filed a
“Motion for “Your” immediately withdrawal from cause No. A-180805 but
“Your” legal choice was to continue being acting “Attorney of record during the month of February 2009
Request Number 198.
Admit: You” Attorney at Law that after December 18th of 2007 you could have filed a
“Motion for “Your” immediately withdrawal from cause No. A-180805 but
“Your” legal choice was to continue being acting “Attorney of record during the month of March of 2009
Request Number 199.
Admit: You” Attorney at Law that after December 18th of 2007 you could have filed a
“Motion for “Your” immediately withdrawal from cause No. A-180805 but
“Your” legal choice was to continue being acting “Attorney of record during the month of April of 2009
Request Number 200.
Admit: You” Attorney at Law that after December 18th of 2007 you could have filed a
“Motion for “Your” immediately withdrawal from cause No. A-180805 but
“Your” legal choice was to continue being acting “Attorney of record during the month of May of 2009
Request Number 201.
Admit: You” Attorney at Law that after December 18th of 2007 you could have filed a
“Motion for “Your” immediately withdrawal from cause No. A-180805 but
“Your” legal choice was to continue being acting “Attorney of record during the month of June of 2009
Request Number 202.
Admit: You” Attorney at Law that after December 18th of 2007 you could have filed a
“Motion for “Your” immediately withdrawal from cause No. A-180805 but
“Your” legal choice was to continue being acting “Attorney of record during the month of July of 2009
Request Number 203.
Admit: You” Attorney at Law that after December 18th of 2007 you could have filed a
“Motion for “Your” immediately withdrawal from cause No. A-180805 but
“Your” legal choice was to continue being acting “Attorney of record during the month of August of 2009
Request Number 204.
Admit: You” Attorney at Law that after December 18th of 2007 you could have filed a
“Motion for “Your” immediately withdrawal from cause No. A-180805 but
“Your” legal choice was to continue being acting “Attorney of record during the month of September of 2009
Request Number 205.
Admit: You” Attorney at Law that after December 18th of 2007 you could have filed a
“Motion for “Your” immediately withdrawal from cause No. A-180805
but “Your” legal choice was to continue being acting “Attorney of record during the month of October of 2009
Request Number 206.
Admit: You” Attorney at Law that in cause No. A-180805 “Your” physically present at (2) court hearing dated on “August 28th 2009 and on September 11th 2009
While “Your” claiming “Your” (only) official retain legal services obligations was to filing a “General Denial” on December 18th 2007
as described in Document # 1 attached herein
Your response to motion for sanctions against “You”
and “You” was never legally retain to attend said hearing dates but was in legal factual event, circumstances and duties thereof acting Attorney of Record on
“August 28th 2009 and September 11th 2009 for the legal behalf of the Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein in cause No. A-180805.
Request Number 207.
Admit that Said “Property”, dwelling, and deeds thereof “already being a issue of “material evidence”
and actual party thereof 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
And “Your” having legal knowledge Pro Se Plaintiff herein stated in the “Original Complaint” A-180805 File November 26th 2007
Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein had already squander all of the “Insurances monies”
being paid out to fix said dwelling for the property located at 448 DeQueen Blvd. in Port Arthur Texas.
(Block 172, Lot 1-2) as a result of damages cause by Hurricanes Humberto.
While during this time frame of a Civil suit “Original Complaint” A-180805 File November 26th 2007
all “factual events and legal circumstances” Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein
Commenced the “legal Transfer” to the “Texas Department of Housing & Community Affairs” to provided provision of $76,000.00 U. S. Dollars Housing Grant
as described in Document # 7 attached herein “Jefferson County Texas Property search Index” instrument # 2009022762
Said “Property Deeds” for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas
on the date of June 18th 2009 being legally transfer to “Texas Department of Housing & Community Affairs ”while “You’re” acting “Attorney of Record.
As described by in Pro Se Plaintiff in attached Document namely “Jefferson County Real Estate Index” Instrument # 2009022762 in document #7 attached herein
“After Pro Se Plaintiff herein stated to “You” in the “Original Complaint” A-180805 File November 26th 2007
Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein had already squandered all of the “Insurances monies”
being paid out to fix said dwelling for the property located at 448 DeQueen Blvd. in Port Arthur Texas.
(Block 172, Lot 1-2) as a result of damages cause by “Hurricanes Humberto”.
Request Number 208.
Admit that Said “Property”, dwelling, and deeds thereof “already being a “material evidence”
and actual party of 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 docket NO. A-180805
And “Your” having legal knowledge Pro Se Plaintiff herein stated to “You” in the “Original Complaint” A-180805 File November 26th 2007
Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein had already squander all of the “Insurances monies”
being paid out to fix said dwelling for the property located at 448 DeQueen Blvd. in Port Arthur Texas. (Block 172, Lot 1-2)
as a result of damages cause by “Hurricanes Rita”.
While during this time frame of a Civil suit “Original Complaint” A-180805 File November 26th 2007
all “factual events and legal circumstances” Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein
Commenced the legal Transfer to the “Texas Department of Housing & Community Affairs” provided provision of $76,000.00 U. S. Dollars Housing Grant
as described in Document # 7 attached herein “Jefferson County Texas Property search Index
Said “Property Deeds” for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas
on the date of June 18th 2009 being legally transfer while “You’re” acting “Attorney of Record.
As described by “Jefferson County Real Estate Index” Instrument # 2009022762 in attached exhibit #7 herein
Request Number 209.
Admit that Said “Property”, dwelling, and deeds thereof “already being a “material evidence” and actual party of 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 docket No. A-180805
And “Your” having legal knowledge Pro Se Plaintiff herein stated to “You” in the “Original Complaint” A-180805 File November 26th 2007
Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein had already squander all of the “Insurances monies”
being paid out to fix said dwelling for the property located at 448 DeQueen Blvd. in Port Arthur Texas. (Block 172, Lot 1-2)
as a result of damages cause by “Hurricanes Ike”.
While during this time frame of a Civil suit “Original Complaint” A-180805 File November 26th 2007
all “factual events and legal circumstances” Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein
Commenced the legal Transfer to the “Texas Department of Housing & Community Affairs”
provided provision of $76,000.00 U. S. Dollars Housing Grant as described in Document # 7 attached herein “Jefferson County Texas Property search Index
Said “Property Deeds” for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas
on the date of June 18th 2009 being legally transfer while “You’re” acting “Attorney of Record.
As described by “Jefferson County Real Estate Index” Instrument # 2009022762 in attached Document exhibit #7 herein
Request Number 210
Admit that Said “Property”, dwelling, and deeds thereof “already being a “material evidence” and actual party of 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 docket No. A-180805
The Honorable 58th Judicial District Court of Jefferson County Texas ordered”
Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein to produce all records, for property damages caused by Hurricanes “Rita”, Humberto, and Ike” ,
And 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)
as being described in Pro Se Plaintiff attached Document # 13
herein namely Order of the 58th Judicial District Court of Jefferson County Texas.
Which “You” refused to produce such discovery request of property deeds said
dwelling for the property located at 448 DeQueen Blvd. in Port Arthur Texas. (Block 172, Lot 1-2) in a ”timely fashion”
And “You” refused at the same time to produce all records, for property dwelling and the property located at 448 DeQueen Blvd. in Port Arthur Texas.
(Block 172, Lot 1-2) damages caused by Hurricanes “Rita”, Humberto, and Ike” in a “timely fashion”
while your acting retain “Attorney of record” between the time frame of December 18th 2007 throughout the dates of December 10th 2009
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