REQUESTS FOR ADMISSION, SET TWO, To: Antoine L. Freeman J. D. Attorney at Law AND HIS COUNSEL OF RECORD U.S. Cause No. 1:14-CV-592

In The United States District Court

For The Eastern Division of Texas

Beaumont Division

Louis Charles Hamilton II

         Pro Se Plaintiff

            Vs.                                                            Cause No. 1:14-CV-592

Antoine L. Freeman J. D.

           Defendant

Joyce M. Guy

Edward McCray

            Co-Defendant(s)

            To Defendant “Antoine L. Freeman J.D. (Attorney at Law), Pro Se Plaintiff “Louis Charles Hamilton II” herein propounding party

REQUESTS FOR ADMISSION, SET  TWO

To: Antoine L. Freeman J. D. Attorney at Law AND HIS COUNSEL OF RECORD:

Pursuant to the provisions of Federal Rule of Civil Procedure 36, it is hereby requested and demanded of Defendant

Antoine L. Freeman J. D. (hereinafter “YOU” or “YOUR”), that YOU make admissions of the following statements of fact which are materially pertinent to Plaintiff claims hereto in accordance with Rule 36,

Under which rule of procedure this request for admissions is made, thereby answering the following facts in the above-entitled and number cause, and that such answers be sworn to and filed promptly in the office of the District Clerk

Where this cause is pending and a copy delivered to the writer within thirty (30) days from the serving of this request upon you.

Otherwise, each of the matter of which an admission is requested and demanded shall be deemed admitted by you in accordance with Rule 36 of the Federal Rules of Civil Procedure.

 

                                    Request for Admission

                                         Truth of Facts 

Admit that the following facts are true:

Request Number 1.

            Admit that you Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, was acting “Attorney of record” between the exact date of December 18^th 2007- June 9^th 2009  when document #1 attached herein was filed with the Jefferson County Texas Clerk office

namely “Mechanic’s LIEN Contract filed on June 9^th 2009 SWMJ Construction Inc., 525 N. Sam Houston Pkwy East, Suite 600, Houston, Texas 77060 in connection with a Housing Grant in excess of $72,500.00 U.S Dollars

“Texas Department of Housing and Community affairs” Loan No. 2727 File No. 1219-2102152 CFDA 14.228 Community Development Block Grant Program (“CDBG”) Hurricanes Katrina, Rita and Wilma in the Gulf of Mexico 2005

 

Federally Declared Disaster Funding under Department of Defense Appropriations Act, 2006 CDBG Disaster Recovery Program (Homeowner Assistance Program “HAP”)

Or (Sabine Pass Restoration Program “SPRP”) Awarding Federal Agency: United States Department of Housing and Urban Development TDHCA Federal Award Number: B-06-DG-48-0002 Federal Award Year (Year of Award from HUD to TDHCA): 2006 TDHCA Award Year: 2007

            For the property located at 448Dequeen Blvd. in Port Arthur Texas 77640 which you was acting counsel for Co-Defendant(s) Joyce M. Guy and Edward McCray in a civil suit in the

 

           58^th Judicial District Court of Jefferson County Texas docket No. A-180805 involving a breach of a $10,800 U.S. Dollars construction contract with the described Pro Se Plaintiff herein.