Request Number 224.
Admit: You” Attorney at Law that in U.S. Cause 1:2010-CV-00055 Pro Se Plaintiff filed Complaint against “You”
and Co-Defendant(s) “Joyce M. Guy and “Edward McCray” herein collectively charging among other things
(RICO) “Obstruction of Justice” Fraud from events and circumstances surrounding
civil suit in common law filed in Jefferson county Texas cause No. A-180805
as being also described in U. S. Cause 1:2014-CV-592 herein now.
Request Number 225.
Admit: You” Attorney at Law that “You” also in U.S. Cause 1:2010-CV-00055 Pro Se Plaintiff filed Complaint against “You”
and Co-Defendant(s) “Joyce M. Guy and “Edward McCray” herein collectively
That once again the Co-Defendant(s) “Joyce M. Guy and “Edward McCray” herein collectively physically ‘retain”
your legal services and representation for their legal interest for the First Federal Complaint”,
U.S. Cause 1:2010-CV-00055
Request Number 226.
Admit: You” Attorney at Law that “You” also in U.S. Cause 1:2010-CV-00055 also retain your legal services
to cover up all of your combine criminal (RICO) activities,
Fraud of the 58th Judicial District Court, against the Pro Se Plaintiff “Louis Charles Hamilton II” herein
as described in U.S. Cause 1:2010-CV-00055 and U. S. Cause 1:2014-CV-592 herein now.
Request Number 227.
Admit: You” Attorney at Law that there after Pro Se Plaintiff filed Complaint against “You”
and Co-Defendant(s) “Joyce M. Guy and “Edward McCray” herein collectively
in U.S. Cause 1:2010-CV-00055 on February 2nd 2010
That Said “Property”, dwelling, and deeds thereof “already being a issue of “material evidence”
and actual party thereof in 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
The “Texas Department of Housing & Community Affairs” release and terminated said possession,
custody and control of “Property Deeds, back into the possession, custody and legal control to the Co-Defendant(s)
“Joyce M. Guy and “Edward McCray” herein collectively
on April 14th 2014 as described in Pro Se Plaintiff attached Document # 7 attached herein “Jefferson County Texas Property search Index
Request Number 228.
Admit: You” Attorney at Law that That Said “Property”, dwelling, and deeds thereof “already being a issue of “material evidence”
and actual party thereof in 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
for dwelling and the property located at 448 DeQueen Blvd. in Port Arthur Texas. (Block 172, Lot 1-2)
The same ”deeds” for dwelling and the property located at 448 DeQueen Blvd. in Port Arthur Texas. (Block 172, Lot 1-2)
is also being in the active possession, custody and legal control of “Texas Department of Housing & Community Affairs”
During the same time frame of “June 18th 2009 throughout July 22nd 2013 as described in Pro Se Plaintiff attached Document # 7 attached herein
“Jefferson County Texas Property search Index” while “Your” acting “Attorney of Record” in Cause No. A-180805
Request Number 229.
Admit: You” Attorney at Law that Said “Property”, dwelling, and deeds thereof “already being a issue of
“material evidence” and actual party thereof in 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
Said Property Deeds is also being in the active possession, custody and legal control of “Texas Department of Housing & Community Affairs”
During the time frame of “June 18th 2009 throughout the dates of November 10th 2009
while “Your” acting “Attorney of Record” being request to Produce said Property deeds on the August 12th 2009 and
“You” on behalf of your client never respond to said motion for Production in a timely fashion.
Request Number 230.
Admit: while “Your” representing said Co-Defendant(s) herein collectively “You”
never ever produce an actual physical copy(s) of said Property deeds for dwelling
and the property located at 448 DeQueen Blvd. in Port Arthur Texas. (Block 172, Lot 1-2)
also same property deeds being in the
Active physical possession, custody and legal control of “Texas Department of Housing & Community Affairs”
During the same time frame of “June 18th 2009 throughout July 22nd 2013 as being described in Pro Se Plaintiff attached Document # 7 herein
the “Jefferson County Texas Property search Index” (Public Record).
Request Number 231.
Admit: You” Attorney at Law that Said “Property”, dwelling, and deeds thereof “already being a issue of “material evidence”
and actual party thereof in a Civil suit in Common law in the State of Texas cause No. A-180805
During the actual time frame dates between November 26th of 2007 for a “Breach of Construction Contract in excess of $10,800.00 U.S. Dollars
Throughout July 22nd 2013 of actual Active physical possession, custody and legal control in connection with the
“Texas Department of Housing & Community Affairs” as being described in Pro Se Plaintiff attached Document # 7 herein
the “Jefferson County Texas Property search Index” (Public Record).
Request Number 232.
Admit: You” Attorney at Law that “You” also in U.S. Cause 1:2010-CV-00055 that in
“Your” defense of U.S. Cause 1:2010-CV-00055 “You” commenced in the actual cover up, destruction, concealment of your (RICO),
Fraud, Obstruction of Justice” activities involved thereof and all records, documents, and material evidence derive thereof.
Request Number 233.
Admit: You” Attorney at Law that “You” refuse to disclosed material facts and
evidences supporting Pro Se Plaintiff claims made of numerous crimes, fraud, fraudulent business collectively perpetrating during past
Hurricanes “Rita, Humberto, and Ike”. As being fully described in this U. S. Cause 1:2014-CV-592 herein now.
And the actual Fraudulent activities of the Co-Defendant(s) “Joyce M. Guy and “Edward McCray” herein collectively
Surrounding the now physical possession, custody and legal control of said “Property Deeds” in connection with the
“Texas Department of Housing & Community Affairs” $76,000.00 U.S. Dollars housing Grant as being described in
Pro Se Plaintiff attached Document # 7 herein the “Jefferson County Texas Property search Index” (Public Record).
When Said “Property”, dwelling, and deeds thereof “already being a issue of “material evidence”
and actual party thereof in a Civil suit in Common law in the State of Texas cause No. A-180805
Since November 26th of 2007 for a “Breach of Construction Contract in excess of $10,800.00 U.S. Dollars.
Request Number 234.
Admit: You” Attorney at Law that “You” monetary retain for your legal services to not disclosed all material facts
and evidences supporting Pro Se Plaintiff claims made of numerous crimes, fraud,
fraudulent business collectively perpetrating during past Hurricanes “Rita, Humberto, and Ike”.
As being fully described in this U. S. Cause 1:2014-CV-592 herein now.
Request Number 235.
Admit: “You” were “monetary retain” for your legal services to not disclose all material facts and evidences surrounding
the actual ongoing during a civil suit Fraudulent activities of the Co-Defendant(s) “Joyce M. Guy and “Edward McCray” herein collectively
Surrounding the now physical possession, custody and legal control of said “Property Deeds” in connection with the
“Texas Department of Housing & Community Affairs” $76,000.00 U.S. Dollars housing Grant as being described in
Pro Se Plaintiff attached Document # 7 herein the “Jefferson County Texas Property search Index” (Public Record).
When Said “Property”, dwelling, and deeds thereof “already being a issue of “material evidence” and actual party thereof in a
Civil suit in Common law in the State of Texas cause No. A-180805
Since November 26th of 2007 for a “Breach of Construction Contract in excess of $10,800.00 U.S. Dollars.
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