Monday, March 2, 2015

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


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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