Request Number 2.
Admit
that you Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein was acting in
the monetary retain capacity as “Attorney of record” on the exact date of August
28th 2009 as described in document #2 attached herein Jefferson
County Texas “Civil Docket” for A-180805 in which
Pro
Se Plaintiff filed a (TRO) for the full legal protection of the Co-Defendant “Joyce
M. Guy”, “Mother”
Namely
Norma M. Guy and the property located at5050east 7th Street in Port
Arthur Texas Lot Number (10) in Block Number (4) of Lakeview addition, to the
City of Port Arthur, Jefferson County, Texas
As
Pro Se Plaintiff filed legal document and made claims before the Honorable Jude”
Bob Wortham” of the 58 Judicial District Court of Jefferson County Texas for
primary allegations of monetary fraud and scheme advantages during “Hurricane
“Rita”, “Ike” and “Humberto ”
Scheme of things related to Construction storm
damages, derive thereof in connection, with Co-Defendant “Joyce M. Guy” and the
Pro Se Plaintiff herein and the property at 5050 east 7th street Repair
for Hurricane Storm Roofing damages.
Request Number 3.
Admit
that you Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein was (Not) monetary
retain “Attorney of record” on the exact date of August 28th 2009 as
described in document #2 attached herein Jefferson County Texas “Civil Docket”
for A-180805 in which
Pro
Se Plaintiff filed a (TRO) for the full legal protection of the Co-Defendant “Joyce
M. Guy”, “Mother”
Namely
Norma M. Guy and the property located at5050east 7th Street in Port
Arthur Texas Lot Number (10) in Block Number (4) of Lakeview addition, to the
City of Port Arthur, Jefferson County, Texas
As
Pro Se Plaintiff filed legal document and made claims before the Honorable Jude”
Bob Wortham” of the 58 Judicial District Court of Jefferson County Texas for
primary allegations of monetary fraud and scheme advantages during “Hurricane
“Rita”, “Ike” and “Humberto ”
Scheme of things related to Construction storm
damages; derive thereof in connection, with Co-Defendant “Joyce M. Guy” and the
Pro Se Plaintiff herein and the property at 5050 east 7th street needing
Repair for Hurricane Storm Roofing damages. Which a Court hearing was held on
the 28th day of August 2009
Request Number 4.
Admit
that Pro Se Plaintiff Louis Charles Hamilton II herein Subpoena Witness namely Allen
Guy”, Brother to Co-Defendant “Joyce M. Guy” before the Honorable Jude” Bob
Wortham” of the 58 Judicial District Court of Jefferson County Texas as duly
under oath said witness was under “direct examination” of the Pro Se Plaintiff “Louis
Charles Hamilton II”
For
primary allegations and subject matter of monetary fraud and scheme advantages
during “Hurricane “Rita”, “Ike” and “Humberto”
Scheme of things related to Construction storm
damages derive thereof in connection, with Co-Defendant “Joyce M. Guy” and the
Pro Se Plaintiff herein and the property at 5050 east 7th street needing
Repair for Hurricane Storm Roofing damages.
Which
a Court hearing was held on the 28th day of August 2009.
Request Number 5.
Admit
that you Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein did in a
capacity of a Attorney cross-examination said Subpoena Witness namely Allen Guy”,
Brother to Co-Defendant “Joyce M. Guy” appearing before the Honorable Jude” Bob
Wortham” of the 58 Judicial District Court of Jefferson County Texas after duly
under oath said witness was under “direct examination” of the Pro Se Plaintiff “Louis
Charles Hamilton II”
For
primary allegations and subject matter of monetary fraud and scheme advantages
during “Hurricane “Rita”, “Ike” and “Humberto”
Scheme of things related to Construction storm
damages derive thereof in connection, with Co-Defendant “Joyce M. Guy” and the
Pro Se Plaintiff herein and the property at 5050 east 7th street needing
Repair for Hurricane Storm Roofing damages.
Which
a Court hearing was held on the 28th day of August 2009.
Request Number 6.
Admit
that you Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein did
physically make the representation and presentation of cross-examination said Subpoena
Witness namely Allen Guy”, Brother to Co-Defendant “Joyce M. Guy” before the
Honorable Jude” Bob Wortham” of the 58
Judicial District Court of Jefferson County Texas as duly under oath said
witness …
But
your were not monetary legally retain for such legal services of a Court
hearing which was held on the 28th day of August 2009
As described by you in attached document #3 “Response
to Motion for Sanctions” in which your claiming your retain legal service was
filing a “General Denial” on December 18th 2007 (only) in Civil
Docket No. A-180805.
Request Number 7.
Admit
that you Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein having
elicited an agreement in which Co-Defendant “Joyce M. Guy” and said Subpoena
Witness namely Allen Guy”, Brother to Co-Defendant “Joyce M. Guy” appearing before
the
Honorable Jude” Bob Wortham” of the 58
Judicial District Court of Jefferson County Texas as duly under oath said
witness …agree with Co-Defendant “Joyce M. Guy” to out of their own financial pockets
fix said home roofing damages
Located
at 5050 east 7th street after the “private home owner insurance
moneys” for the interest of Norma M. Guy” home having already being spent/squander
up by Co-Defendant “Joyce M. Guy”.
Request Number 8.
Admit
Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein provided
cover up legal services before the 58th Judicial District of
Jefferson County Texas for conspire in “Falsification of “Material facts” that Co-Defendant
“Joyce M. Guy” and said Subpoena Witness namely Allen Guy”, Brother to
Co-Defendant “Joyce M. Guy” Was to out of their own financial pockets fix said
home roofing damages
Located
at 5050 east 7th street after the “private home owner insurance
moneys” for the interest of Norma M. Guy” (Mother) home having already being
spent/squander up by Co-Defendant “Joyce M. Guy” thereafter your cover up legal
services before the 58th Judicial District Court on August 28th
2009 hearing date Co-Defendant “Joyce M. Guy” legally transfer once again
another property to
“Texas
Department of Housing and Community affairs” Loan No. 5866 file No.
1219-2355082 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
To
obtain on May 28th 2010 in excess of $54,839.31 U.S. Dollars
“Construction Grant” for the property located at 5050 east 7th
street in Port Arthur Texas
As
described herein Pro Se Plaintiff attached document #4 Mechanic’s Lien,
Contract Loan No. 5866, File # 1219-2355082
Request Number 9.
Admit
that you Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein was never physically
present and not monetary legally retain for such legal services of a Court
hearing which was held on the 28th day of August 2009 before the
Honorable
Bob Wortham, in 58th Judicial District Court of Jefferson County
Texas for the legal behalf of the Co-Defendant(s) Joyce M. Guy and Edward
McCray as described by you in attached herein document # 3“Response to Motion
for Sanctions” in which your claiming your retain legal service was filing a “General
Denial” only on December 18th 2007 in Civil Docket No. A-180805.
Request Number 10.
Admit
that you Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein refusal to
respond to all of the Pro Se Plaintiff discovery request your having in your
legal, possession, custody and control mailed to you since the exact time date
of March 14th 2008 –
And
such Pro Se Plaintiff discovery request in
your legal, possession, custody and control throughout August 28th
2009 hearing date as your in continual refusal to reply/response to said
discovery request
And
further admitting “You” were not monetary legally retain for such legal services
of a Court appearance at a hearing which was held on the 28th day of
August 2009 before the
Honorable
Bob Wortham, in 58th Judicial District Court of Jefferson County
Texas for the legal behalf of the Co-Defendant(s) Joyce M. Guy and Edward
McCray
As described by you in attached herein document
# 3“Response to Motion for Sanctions” in which your claiming your retain legal
service was filing a “General Denial” only on December 18th 2007 in Civil
Docket No. A-180805 and all such legal services of you Chief Defendant
Antoine L. Freeman J. D. “Attorney
at Law” fully retain ended there after December 18th 2007
While
you Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein admit
continual refusal to respond to all of the Pro Se Plaintiff discovery request
your having in your legal, possession, custody, and control being legally mailed
to you in the exact time frame of March 14th 2008
As
your continual admit in same “Attorney at Law” refusal to reply/response to
said discovery request throughout the 58th Judicial District Court
of Jefferson County Texas hearing date on the 28th day of August
2009 which you was in fact present before the Honorable Court.
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