84.
Chief
Defendant Attorney at Law herein and the Co- Defendant Joyce M. Guy” herein
supply the following Answer to Pro Se Plaintiff Interrogatories Discovery
Document pursuant to Rule 197 of the Texas Rules of Civil Procedures at
Question: 10, 11, 12, 13, 14, 15, and 16.
10. Where is the Funding for the New Home?
Answer: Federal Grant
11. What are the terms and conditions of any contract in regards
to the new home?
Answer: Federal Government built home free of charge Defendant
must remain in home for at least 3 years.
12. What is the entire cost of the construction for the new home?
Answer: $76,000.00 U.S. Dollars
13. How is the city of Port Arthur Involved?
Answer: Not involved
14. How is the State of Texas Involved?
Answer: Not Involved
15. How is the Federal Government involved?
Answer: Federal Grant
16. How much money did the Co-Defendant actually paid for the new
home construction?
Answer: No money paid by Co-Defendant
Which
Pro Se Plaintiff being further set forth
Declares, Affirm, and State further before the “Honorable U.S. Justice”
Chief Defendant “Attorney at Law” herein and the Co- Defendant Joyce M. Guy”
and Edward McCray collectively herein supply the following “false and
fraudulent” Answer to Pro Se Plaintiff Interrogatories at question number 14
14. How is the State of Texas Involved?
Answer: Not Involved
In
comparison to said “Property Deeds” for the dwelling located at 448 DeQueen
Blvd. in Port Arthur Texas of the Co-Defendant(s) “Joyce M. Guy and Edward
McCray herein collectively custody, control and legal possession was Legally
Transfer to the
“Texas Department of Housing & Community
Affairs” on June 18th 2009 for a $72,500.00 U. S. Dollars Housing
Grant.
. And further that Documents along with
the fraudulent Affidavit of Co- Defendant Joyce M. Guy” herein supply the
following “false and fraudulent” Answer to in regards to possession, custody
and control knowledge during the fraudulent dates in cover up this discovery
obstruction scheme of things was Placed in the United States Mail and
Publically
Mailed to the Jefferson County Texas Court House “Clerk of District Court” for
cause No. A-180805 and was electronically computer filed in Document # 8 herein
58th Judicial District Court of Jefferson County Texas “Case Ledger”
and Court Records for cause No. A-180805
85.
Which
Pro Se Plaintiff being further set forth
Declares, Affirm, and State further before the “Honorable U.S. Justice”
Chief Defendant “Antoine L. Freeman, J.D.” Texas Bar No. 24058299 herein
Fully
legally precisely having legal interest with the Co-Defendant(s) “Joyce M. Guy
and Edward McCray” herein collectively
Having
a physical “legal binding contract” of some hidden sorts for such (RICO)
enterprise “legal services” of thee’ described Chief Defendant “Antoine L.
Freeman, J.D.” Texas Bar No. 24058299 herein from the time exact time frame of
December 18th 2007 when you filed “Your” General Denial…
Throughout
the time frame until “You” finally official filed a “Motion for Withdrawal of
Counsel”, filed stamp dated November 13th 2009 10:22 am hour
Being
fully quite “Legally” described in Chief Defendant “Antoine L. Freeman, J.D.”
Texas Bar No. 24058299 herein “Motion for withdrawal of counsel”
As
stated legally by Chief Defendant “Antoine L. Freeman, J.D.” Texas Bar No.
24058299 herein as follows:
To
The Honorable Judge of Said Court:
Now Comes Movant, Antoine L. Freeman
J.D., Attorney for Defendants, Joyce Guy and Edward McCray, (hereinafter
Defendants), and brings this Motion for withdrawal of Counsel, and in support
thereof, shows the court the following:
I.
Good
cause exists for withdrawal of Movant as counsel because Defendants have not
complied with the terms of employment agreement with this attorney. Plaintiffs
refuse to adhere to the terms of the employment agreement with this attorney.
II.
The
setting and deadlines in this case are as follows: Motion for Sanction &
Contempt on December 11th, 2009 @ 9:00 am (With Your Initials)
III.
This
Motion is not sought for the purposes of delay.
IV.
A
copy of this motion bearing the enclosed notice has been delivered to the last known
addresses of the Defendants.
“Joyce Guy” 5050 7th street Port
Arthur, Texas 77642
“Edward
McCray” 5050 7th street Port Arthur, Texas 77642
V.
Defendants
are hereby notified in writing of the right to object to this motion.
NOTICE
You
are hereby notified that this motion for withdrawal of Counsel is set for
hearing at the time and place set out below. You do not agree to this motion.
If you wish to contest the withdrawal of Antoine L. Freeman, J.D. as your
attorney, you should appear at the hearing.
If
you do not oppose Antoine L. Freeman, J.D.’s withdrawal as your attorney, you
may notify Antoine L. Freeman, J.D. in writing of your consent to this motion.
Wherefore,
Premises Considered, Movant prays that the Court enters as order discharging
Movant as attorney of record for Defendants, “Joyce Guy” and “Edward McCray”,
and for such other and further relief that may be awarded at law or in equity.
Respectfully
submitted, by “Antoine L. Freeman, J.D., Texas Bar No. 24058299, 3723 Gulfway Dr.
Ste #104, Port Arthur, Texas 77642 (409) 293-1627, Fax (409) 983-7405
“Attorney
for Defendants” Joyce Guy and Edward McCray
86.
Now legally Chief Defendant “Antoine
L. Freeman, J.D., Texas Bar No. 24058299 seeking the 58th Judicial
District Court Judge Bob Wortham “honest official approval” to terminate said
contract… in December 11th 2009 Court Hearing after all of this
past, present “Grand (RICO) enterprise scheme of things, executed with a skilled
attorney real-estate eyes toward future 2015 financial gains of racket maturity
on
$54,839.31 U.S. Housing Grant to free
and clear property deeds on the dwelling located at 5050 east 7th
street in Port Arthur Texas, Co-Defendant “Joyce M. Guy”
enjoy such control and said “Mother”
now being (Dead) providing legally said Co-Defendant(s) “Joyce M. Guy and
Edward McCray” herein collectively in direct legal, possession, custody and
control over (2) Fraudulent (RICO) enterprise “scheme of things”
Namely “Federal Housing Grants” on the
behalf of “Texas Department of Housing & Community Affairs” in excess of
$72,500.00 U.S. Dollars
And $54,839.31 U.S. Dollars for a
combine total additional (RICO) enterprise sham of in excess of $127,339.31
involving the Pro Se Plaintiff as a unwilling party and victim thereof
87.
With
the direct (RICO) enterprise “Leadership”, “Director”, CEO, CFO, Chief
Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299
herein since March of 2008, 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, and September of 2009 against Texas Rules of Civil
Procedures
Kidnap, pimp slap, spoil, mar, impair,
desecrate, and plain old back woods “Negro Brother Esq.” corrupted in the hood
with a random “casino buffet law degree” of some sorts “savagely sodomising”
repeatedly “Lustita”
The
Roman Goddess of “Justice” or as in commonly known in U.S. of America” namely “Lady
Justice”
88.
In
this shameful extra slooooow chicken thievery quarter-back, skilled “Legal
Directional” choice of Chief Defendant “Antoine L. Freeman, J.D.” Texas Bar No.
24058299 herein
Super half bake mixture of “fermented
formaldehyde-n-meth” soaking to formulate a toxic crack cocaine freebase cooking
(RICO)
enterprise endeavor cocktail to display an obviously being quite the handsome “smoked
out” broken old stove legal professional Esq. of some sorts magically
appearing/disappearing “poof “ here and there legally” before a “Honorable 58th
Judicial District Court of Law”
With
such deployment, and actions of slipping in and out of this “legal self induce
“smoked out” coma” of some sorts” as “acting attorney of record” vs. “not
acting attorney of record” between the exact time frame of December 18th
2007 – throughout the “Motion for Withdrawal of Counsel”, filed stamp and dated
November 13th 2009 10:22 am hour
Being
fully quite “Legally” described in Chief Defendant “Antoine L. Freeman, J.D.”
Texas Bar No. 24058299 herein, “Motion for withdrawal of counsel” in his bogus,
fraudulent “representation and presentation” in obstruction of Justice, Fraud
upon the 58th Judicial District Court of Jefferson County Texas in a
collective
Co-Defendant(s)
“Joyce M. Guy and Edward McCray” herein secrete, conspire, collusion (RICO)
enterprise scheme/sham in crafty hostile complex skilled attorney at law design
directed wrongfully now at the
(Sucker) namely Pro Se Plaintiff Louis Charles
Hamilton herein “civil rights” in a suit in common law expensive on now time to
depart, abandon, flee from such (RICO) enterprise scheme/sham endeavors of Chief
Defendant “Antoine L. Freeman, J.D.” Texas Bar No. 24058299 herein on November
13th 2009 10:22 am hour.
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