Request Number 238.
Admit:
Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” Bar No. 24058299 herein was not acting;
In that term Attorney - n. an agent or someone authorized to act for another a person
who has been qualified by a state or federal court to provide legal services, including appearing in court.
In that term Attorney of Record - n. the attorney who has appeared in court and/or signed pleadings or other forms on behalf of a client.
The lawyer remains the attorney of record until some other attorney or the client substitutes for him/her,
He/she is allowed by the court to withdraw, or after the case is closed.
In that term Attorney's Fee - n. The payment for legal services, hourly charge,
and flat fee for the performance of a particular service some mixture of hourly and contingent fee or other combination.
A "retainer" is a down payment on fees, often required by the attorney in order to make sure he or she is not left holding the bag for work performed,
or at least as a good faith indication that the client is serious and can afford the services.
In the term Attorney's Work Product - n. written materials, charts, notes of conversations and investigations,
and other materials directed toward preparation of a case or other legal representation.
In the term Attorney-Client Privilege - n. the requirement that an attorney may not reveal communications,
conversations and letters between himself/ herself and his/her client, under the theory
that a person should be able to speak freely and honestly with his/her attorney without fear of future revelation.
In the term Defense - n. a general term for the effort of an attorney representing a defendant during trial and in pre-trial maneuvers
to defeat the party suing, to counter, defeat or remove all or a part of the contentions of the plaintiff.
And you were fully not in that term “Attorney of Record”, a party thereof from December 18th 2007 throughout
the exact dates in time of November 13th 2009 10:22 AM when you file a “Motion for Withdrawal” in cause No. A-180805…?
Request Number 239.
Admit:
That your clients “Joyce M. Guy and Edward McCray” herein collectively namely being “Co-Defendant(s)
Were “physically legally” acting as their own “counsel of record” for their very own collectively “legal civil interest behalf”
appearing as such in their own “Pro Se” persons excluding “Your” Attorney
at Law skilled representation and they appearing before the 58th Judicial District Court of Jefferson County Texas
in a civil suit in common law docket No A-180805 being filed November 26th 2007
Namely in that term of appearing in their own person/persons as Pro Se thereafter the date of December 18th 2007
Namely in that term of Pro Se, Pro se legal representation (/ˌproʊ ˈsiː/ or /ˌproʊ ˈseɪ/)
means advocating on one's own behalf before a court, rather than being represented by a lawyer
namely “You” Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” Bar No. 24058299 herein
As “Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein collectively “Appeared”
official Pro Se before the 58th Judicial District Court of Jefferson County Texas in a civil suit in common law docket No A-180805
As “Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein collectively “Appeared” before The “Honorable Judge Bob Wortham”
in a legal format as described now by you and contentions being
admitted herein
As such said Co-Defendant(s) collectively being said Pro Se counsel of record fully acting as such for their very own
“legal interest” against the said Pro Se Plaintiff Louis Charles Hamilton II herein
from the exact the exact “time frame dates” of December 19th 2007 throughout December 11th 2009…
Request Number 240.
Admit:
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not filing any legal court documents
for their legal behalf of said Co-Defendant(s) collectively through
the “United States Mailing System” thereafter December 18th 2007 throughout the exact dates of November 11st 2009
And forwarding such to the “Honorable Judge Bob Wortham, to the “Honorable Judge Bob Wortham” staff namely
“Ms. Sydney Moreau”, to The Jefferson County Clerk of Court “Lolita Ramos”,
And all (active) Deputy Clerks acting on behalf of said Jefferson County Clerk of Court “Lolita Ramos, involved in the records thereof,
Namely” the 58th Judicial District Court of Jefferson County Texas “Case Ledger” for Cause No. A-180805
Namely” the 58th Judicial District Court of Jefferson County Texas “Civil Docket report” for cause No. A-180805
With Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein directly not having any
physical Usage of the “United States Mailing System” surround civil court event thereafter
December 18th 2007 throughout the exact dates of November 11st 2009 for their “legal behalf”
of said Co-Defendant(s) collectively through the “United States Mailing System”
Request Number 241.
Admit:
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not physically involved with
inner actions on live “court transcripts” with the 58th Court reporters “Anita
Becker” thereafter December 18th 2007 throughout the exact dates of November 11st 2009 for the
Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805.
Namely on hearing dates of August 28th, 2009
Request Number 242.
Admit:
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not physically involved with
inner actions on live “court transcripts” with the 58th Court reporters “Anita
Becker” thereafter December 18th 2007 throughout the exact dates of November 11st 2009
for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805.
Namely on hearing date of September 11th 2009
Request Number 243.
Admit:
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not present before the
58th Judicial District Court of Jefferson County Texas bailiff’s, thereafter the time frame
of December 18th 2007 throughout the exact dates of November 11th 2009 involved in cause No. A-180805
Request Number 244.
Admit:
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation,
presentation of material facts as acting “Attorney of record” Before
the “Honorable Judge Bob Wortham”, thereafter the date of December 18th 2007 throughout the exact dates of
November 11st 2009 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray”
legal behalf” in cause No. A-180805
Request Number 245.
Admit:
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation,
presentation of material facts as acting “Attorney of record” before
The “Honorable Judge Bob Wortham” staff namely “Ms. Sydney Moreau”, thereafter the Date of December 18th 2007
throughout the exact dates of November 11st 2009 for the Co-Defendant
(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805
Request Number 246.
Admit:
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation,
presentation of material facts as acting “Attorney of record” before the
Jefferson County Clerk “Lolita Ramos”, record office of Jefferson County Texas thereafter the Date of December 18th 2007
throughout the exact dates of November 11st 2009 for the Co-Defendant
(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805
Request Number 247.
Admit:
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not involved in any
“attorney/client”, work product thereof, and making such a presentations and
representations of “material facts” as acting physically in the professional capacity of acting “Attorney of record”
Before the “Honorable Judge Bob Wortham”, against said Pro Se Plaintiff “Louis Charles Hamilton II” herein
subject matter in complaint against the Co-Defendant(s) “Joyce M. Guy and Edward
McCray” legal behalf” thereafter of December 18th 2007 throughout the exact dates of November 11st 2009 in cause No. A-180805
“Meaning” in that Chief Defendant “Antoine L. Freeman, J.D. “Attorney at Law” Texas Bar No240582299
was not in any shape or form involved in any “attorney/client”, work product
thereof, “attorney/client” communications thereof,
And making such a physical presentations and representations of “material facts”
as acting physically in the professional capacity of acting “Attorney of record”.
Request Number 248.
Admit:
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was (Only) acting in the “legal capacitates”
as a Attorney at Law to file a General Denial (Only) on December 18th
2007
To “simply” reply in the Complaint A-180805 made against Co-Defendant(s) “Joyce M. Guy and Edward McCray” (Herein) collectively
and such “legal attorney at law retain services” ended
thereafter the exact date of December 18th 2007 and Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein collectively
there after December 18th 2007 was acting fully “Pro Se” in all legal
matters, and hearing before the court, and all records derive thereof
In a civil suit in the 58th Judicial District Court of Jefferson County Texas filed in Cause No. A-180805
admitting that you “Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein
were legally retain for such legal services to file a General Denial (Only)
Regarding a “Breach of Construction Contract” in excess of $10,800.00 U.S. Dollars
“Your” only being retain for such services, as describe by a contract between
“You” and Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein
For all legal services simply thereof required for such professional legal services to file a simple “General Denial” (Only) on December 18th 2007
Request Number 249.
Admit:
In that Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein collectively was acting as Pro Se (Counsel of record)
and physically involved with inner actions on live “court transcripts” with the
58th Court reporters “Anita Becker” thereafter December 18th 2007 throughout the exact dates of
November 11st 2009 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” own “legal
behalf” in cause No. A-180805.
Namely that Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein was acting Pro Se (Counsel of record)
on hearing dates of August 28th, 2009 before “58th Court Reporter” Anita Becker”
other than “Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein
Request Number 250.
Admit:
In that Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein was acting as Pro Se (Counsel of record)
and physically involved with inner actions on live “court transcripts” with the 58th Court
reporters “Anita Becker” thereafter December 18th 2007 throughout the exact dates of November 11st 2009 for the
Co-Defendant(s) “Joyce M. Guy and Edward McCray” own “legal behalf” in cause
No. A-180805.
Namely that Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein was acting Pro Se (Counsel of record)
on hearing date of September 11th 2009 before “58th Court Reporter” Anita Becker”
other than “Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein
Request Number 251.
Admit:
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” Texas Bar No. 24058299 herein
“Your” absolute 100% solid “set” in concrete, stone, chisel ink “You” being named “Chief
Defendant” (Attorney at Law) herein “legally entertaining” such that your “contentions” before a
“Honorable Federal Court of Law” is that one Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein collectively
“Appeared” active before the 58th Judicial District Court of Jefferson County
Texas
In a civil suit in common law in docket No A-180805 and appearing as such before The “Honorable Judge Bob Wortham”
in a legal format as acting “Live” Pro Se Defendant(s) being one “Joyce M.
Guy and Edward McCray” collectively herein fully engage as such under the term as
Pro Se counsel for their very own “legal civil courtroom interest”
In a “Breach of Construction Contract” Complaint filed in connection with the
dwelling and the property located at 448 DeQueen Blvd. in Port Arthur Texas. (Block 172, Lot 1-2)
Your absolute contentions as saying such legal terms of a legal Pro Se Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein collectively
acting physically in a “court of law” within Texas State
Court
Appearing as such against the same said Pro Se Plaintiff Louis Charles Hamilton II herein from the exact time frame dates of
“December 19th 2007 throughout to the exact date of December 11th
2009” being fully 100% Pro Se for their own legal interest.
Request Number 252.
Admit:
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was (Only) acting in the “legal capacitates”
as a Attorney at Law to file a General Denial (Only) on December 18th 2007
To “simply” reply in the Complaint A-180805 made against Co-Defendant(s) “Joyce M. Guy and Edward McCray”
(Herein) collectively and such “legal attorney at law retain services” ended
thereafter the exact date of December 18th 2007
And “You” filed “You're” immediately “Motion for withdrawal of counsel” of record between the exact dates of
December 18th 2007 throughout the exact dates of November 11st 2009 from
cause No. A-180805 filed in Jefferson County Texas Courthouse.
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