Monday, January 12, 2015

Pro Se Plaintiff “Louis Charles Hamilton II” REQUESTS FOR ADMISSION, Cause No. 1:14-CV-592 To Defendant “Antoine L. Freeman

Request Number 253.

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 that said Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” Texas Bar No. 24058299 herein

was not on any “court transcript recording” of “Anita Becker” on the hearing date of

exactly August 28th 2009 before the 58th Judicial District Court of Jefferson County Texas Docket No. A-180805

In which “You” Defendant (Attorney at law) herein admit “You” did not “cross examine” a “Subpoena Witness” herein

namely one “Allen T. Guy” natural brother to the Co-Defendant “Joyce M. Guy” herein.

In the term Subpena - (subpoena): (suh-pea-nah) n. an order of the court for a witness to appear at a particular time

and place to testify and/or produce documents in the control of the witness (if

a "subpena duces tecum").

A subpena is used to obtain testimony from a witness at both depositions (testimony under oath taken outside of court) and at trial.

Subpenas are usually issued automatically by the court clerk but must be served personally on the party being summoned.

Failure to appear as required by the subpena can be punished as contempt of court if it appears the absence was intentional or without cause.

In the term Cross-Examination - n. the opportunity for the attorney (or an unrepresented party)

to ask questions in court of a witness who has testified in a trial on behalf of the opposing party.

The questions on cross-examination are limited to the subjects covered in the direct examination of the witness,

but importantly, the attorney may ask leading questions, in which he/she is allowed

to suggest answers or put words in the witness's mouth.

(For example, "Isn't it true that you told Mrs. Jones she had done nothing wrong?"

which is leading, as compared to "Did you say anything to Mrs. Jones?") A strong cross-examination (often called just "cross" by lawyers and judges)

can force contradictions, expressions of doubts or even complete obliteration of a witness's prior carefully rehearsed testimony.

On the other hand, repetition of a witness’s story, vehemently defended, can strengthen his/her credibility.

In the term Testimony - n. oral evidence given under oath by a witness in answer to questions posed by attorneys at trial

or at a deposition (questioning under oath outside of court).

In the term Testify - v. to give oral evidence under oath in answer to questions posed by attorneys either at trial or at a deposition

(testimony under oath outside of court), with the opportunity for

opposing attorneys to cross-examine the witness in regard to answers given.

In the term Transcript - n. the written record of all proceedings, including testimony, in a trial,

hearing or deposition (out-of-court testimony under oath). Jurisdictions vary as to whether the

attorneys' final arguments are recorded, with the Federal Court Reporter Act, but not all states, requiring inclusion.

A copy of the transcript may be ordered from the court reporter and a fee paid for the transcription and first copy;

if the opposing party also wants a copy, the cost will not include the transcription fee.

In most appeals a copy of the transcript is required so that the court of appeals can review the entire proceedings in the trial court.

Copies of depositions may be ordered for a fee from the court

reporter who took down the testimony. Transcripts are not printed from the record unless transcription is requested

And that said Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” Texas Bar No. 24058299 herein

the term Testimony, In the term Testify, In the term Cross-Examination, In the term Transcript,

In the term Subpena being fully not involved thereof, or making any legal representation, presentation,

as acting “Attorney of record” on any “court transcript recording” of “Anita Becker” on the

hearing date of exactly August 28th 2009 appearing before “Judge Bob Wortham” of the 58th Judicial District Court of Jefferson County Texas.

Request Number 254.

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 that said Co-Defendant(s) “Joyce M. Guy and Edward McCray” (Herein) collectively

was acting “Pro Se” on “court transcript recording” of “Anita Becker” on the hearing date of exactly August 28

th 2009 before the 58th Judicial District Court of Jefferson County Texas Docket No. A-180805

In which “You” Chief Defendant (Attorney at law) herein admit that said Co-Defendant(s) “Joyce M. Guy and Edward McCray” (Herein) collectively

was acting “Pro Se” and physically “cross examine”

a “Subpoena Witness” herein namely one “Allen T. Guy” natural brother to the Co-Defendant “Joyce M. Guy” herein.

In the term Subpena - (subpoena): (suh-pea-nah) n. an order of the court for a witness to appear at a particular time

and place to testify and/or produce documents in the control of the witness (if

a "subpena duces tecum").

A subpena is used to obtain testimony from a witness at both depositions (testimony under oath taken outside of court) and at trial.

Subpenas are usually issued automatically by the court clerk but

must be served personally on the party being summoned.

Failure to appear as required by the subpena can be punished as contempt of court if it appears the absence was intentional or without cause.

In the term Cross-Examination - n. the opportunity for the attorney (or an unrepresented party)

to ask questions in court of a witness who has testified in a trial on behalf of the opposing party.

The questions on cross-examination are limited to the subjects covered in the direct examination of the witness,

but importantly, the attorney may ask leading questions, in which he/she is allowed

to suggest answers or put words in the witness's mouth.

(For example, "Isn't it true that you told Mrs. Jones she had done nothing wrong?" which is leading, as compared to

"Did you say anything to Mrs. Jones?") A strong cross-examination (often called

just "cross" by lawyers and judges) can force contradictions, expressions of doubts

or even complete obliteration of a witness's prior carefully rehearsed testimony.

On the other hand, repetition of a witness’s story, vehemently defended, can strengthen his/her credibility.

In the term Testimony - n. oral evidence given under oath by a witness in answer to questions

posed by attorneys at trial or at a deposition (questioning under oath outside of court).

In the term Testify - v. to give oral evidence under oath in answer to questions posed by attorneys either at trial or at a deposition

(testimony under oath outside of court), with the opportunity for

opposing attorneys to cross-examine the witness in regard to answers given.

In the term Transcript - n. the written record of all proceedings, including testimony, in a trial,

hearing or deposition (out-of-court testimony under oath). Jurisdictions vary as to whether the

attorneys' final arguments are recorded, with the Federal Court Reporter Act, but not all states, requiring inclusion.

A copy of the transcript may be ordered from the court reporter and a fee paid for the transcription and first copy;

if the opposing party also wants a copy, the cost will not include the transcription fee.

In most appeals a copy of the transcript is required so that the court of appeals can review the entire proceedings in the trial court.

Copies of depositions may be ordered for a fee from the court

reporter who took down the testimony. Transcripts are not printed from the record unless transcription is requested

And that said Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” Texas Bar No. 24058299 herein

In the term Testimony, in the term Testify, in the term Cross-Examination, in the term Transcript, in the term Subpoena

“You” being fully not involved thereof, or making any legal representation, presentation, as acting “Attorney of record” on any “court transcript recording” of “Anita Becker” on the hearing date of

exactly August 28th 2009 appearing before “Judge Bob Wortham” of the 58th Judicial District Court of Jefferson County Texas

And it was in fact said Co-Defendant(s) “Joyce M. Guy and Edward McCray” (Herein) collectively was acting

“Pro Se” and fully involved In the term Testimony, In the term Testify, In the term Cross-

Examination, In the term Transcript, In the term Subpoena of witness “Allen T. Guy” named herein.


By, _______________________________

Louis Charles Hamilton II
Pro Se Plaintiff
P.O. Box 17524
Sugar Land Texas 77496

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