Request
Number 23.
Admit
Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein between the
actual dates of November 13th 2009 10:22 am hour you physically filed
“Motion for Withdrawal of Counsel” namely Pro Se Plaintiff “Louis Charles
Hamilton II” attached Document # 8 as stated by “you”
Chief
Defendant” herein in paragraph IV: A copy of this motion bearing the enclosed
notice has been delivered to the last known addresses of Defendants. Joyce Guy
5050 7th street Port Arthur. Texas 77642, and Edward McCray 5050 7th
street Port Arthur, Texas 77642
While
you furtherance Admitting Chief Defendant Antoine L.
Freeman J. D. “Attorney
at Law”, herein between the actual dates of December 18th 2007
throughout at some point date of November 13th 2009 10:22 am hour
Co-Defendant(s)
“Joyce M. Guy and Edward McCray” was in fact living on Lots Numbered One and
Two (1&2) in Block Number One Hundred Seventy Two (172) of City of Port
Arthur in Jefferson County, Texas namely 448 DeQueen Blvd. in Port Arthur Texas
77640 which is the primary address of said Co-Defendant(s) collectively herein when
you
“Chief
Defendant” herein was retaining for your “Attorney at law” legal services in
civil suit in common law docket No. A-180805 which the property 448 DeQueen
Blvd. in Port Arthur Texas 77640 is involved in a breach of Construction
Contract civil matter before the 58th Judicial District Court of
Jefferson County, Texas.
Request
Number 24.
Admit
Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein between the
actual dates of November 13th 2009 10:22 am hour you physically
filed “Motion for Withdrawal of Counsel” as stated by “you”
Chief
Defendant” herein in paragraph IV: A copy of this motion bearing the enclosed
notice has been delivered to the last known addresses of Defendants. Joyce Guy
5050 7th street Port Arthur. Texas 77642, and Edward McCray 5050 7th
street Port Arthur, Texas 77642
“Your” having full legal knowledge that Lots
Numbered One and Two (1&2) in Block Number One Hundred Seventy Two (172) of
City of Port Arthur in Jefferson County, Texas
Namely
the property located at 448 DeQueen Blvd. in Port Arthur Texas 77640 which is
the primary “physical evidence” and “physical address” of said Co-Defendant(s)
collectively herein which both “physical evidence” and “physical home” was
completely destroyed in connection with namely
“Mechanic’s
LIEN Contract filed on June 9th 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 between the exact time
frame of December 18th 2007 throughout actual date of November 13th
2009 10:22 am hour until you physically filed “Motion for Withdrawal of
Counsel” was acting counsel for Co-Defendant(s) Joyce M. Guy and Edward McCray
in a civil suit in the
58th
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.
Request
Number 25.
Admit
Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein between the
actual dates of December 18th 2007 throughout actual date of
November 13th 2009 10:22 am hour when you physically filed “Motion
for Withdrawal of Counsel” you in this said time frame was acting counsel for Co-Defendant(s)
Joyce M. Guy and Edward McCray in a civil suit in the
58th
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 admitting furtherance’s
Said
Co-Defendant(s) Joyce M. Guy and Edward McCray collectively engaged in the
destruction of physical evidence of a entire home which was completely
destroyed being on
Lots
Numbered One and Two (1&2) in Block Number One Hundred Seventy Two (172) of
City of Port Arthur in Jefferson County, Texas
Namely
the property located at 448 DeQueen Blvd. in Port Arthur Texas 77640 which is
the primary “physical evidence” and “physical address” of said Co-Defendant(s)
collectively herein as described in Pro Se Plaintiff attached Document # 1 namely
“Mechanic’s LIEN Contract filed on June 9th
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.
Request
Number 26.
Admit
Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein between the
actual dates of December 18th 2007 throughout actual date of
November 13th 2009 10:22 am hour you physically filed “Motion for
Withdrawal of Counsel” you was acting counsel for Co-Defendant(s) Joyce M. Guy
and Edward McCray legal behalf in a civil suit in the
58th
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.
Request
Number 27.
Admit
Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein between the
actual dates of March 14th 2008 – throughout actual date of November
13th 2009 10:22 am hour 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 – on behalf of said
Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein while “you”
Chief
Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein furtherance’s
admitting said Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively
herein engaged in the destruction of “physical evidence” of an entire home
which was completely destroyed being on
Lots
Numbered One and Two (1&2) in Block Number One Hundred Seventy Two (172) of
City of Port Arthur in Jefferson County, Texas
Namely
the property located at 448 DeQueen Blvd. in Port Arthur Texas 77640 which is
the primary “physical evidence” and “physical address” of said Co-Defendant(s)
collectively herein and furtherance’s admitting said
Co-Defendant(s)
“Joyce M. Guy and Edward McCray” collectively herein refusal to produce to the
Pro Se Plaintiff copies of said property deeds for Lots Numbered One and Two
(1&2) in Block Number One Hundred Seventy Two (172) of City of Port Arthur
in Jefferson County, Texas
Namely
the property located at 448 DeQueen Blvd. in Port Arthur Texas 77640 while you’re
still acting “attorney of record” between the actual dates of December 18th
2007- November 13th 2009 10:22 am
With “you” Chief Defendant Antoine
L. Freeman J. D. “Attorney
at Law”, herein in full possession, custody and legal control over of said Pro Se Plaintiff herein “request
for production of property deeds” for Lots Numbered One and Two (1&2) in
Block Number One Hundred Seventy Two (172) of City of Port Arthur in Jefferson
County, Texas
Namely
the property located at 448 DeQueen Blvd. in Port Arthur Texas 77640 in Your” Chief
Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein physical
custody, possession and legal control between the actual dates of March 14th
2008 – November 13th 2009 10:22 am hour.
Request
Number 28.
Admit
Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein between the
actual dates of December 18th 2007 throughout actual date of April
30th 2010 when you filed Defendant’s Original Answer again in U.S.
District Court for the District of Texas, Beaumont Division Jefferson County,
Texas U.S. Docket No. 1:10-CV-00055 against the Pro Se Plaintiff Louis Charles
Hamilton II herein
Before
the Honorable U.S. Judge Marcia A. Crone and Honorable U.S. Magistrate Keith F.
Giblin your Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein “your” having
full knowledge that between the actual dates of November 13th 2009
10:22 am hour you physically filed “Motion for Withdrawal of Counsel” as stated
by “you”
Chief
Defendant” herein in paragraph IV: A copy of this motion bearing the enclosed
notice has been delivered to the last known addresses of Defendants. Joyce Guy
5050 7th street Port Arthur. Texas 77642, and Edward McCray 5050 7th
street Port Arthur, Texas 77642
“Your” having full legal knowledge that on Lots
Numbered One and Two (1&2) in Block Number One Hundred Seventy Two (172) of
City of Port Arthur in Jefferson County, Texas
Namely
the property located at 448 DeQueen Blvd. in Port Arthur Texas 77640 which is
the primary “physical evidence” and “physical address” of said Co-Defendant(s)
collectively herein which is both “physical evidence” and “physical home” was
completely destroyed in connection with namely
“Mechanic’s
LIEN Contract filed on June 9th 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.
Request
Number 29.
Admit
Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein between the
actual dates of December 18th 2007 throughout actual date of April
30th 2010 when you filed Defendant’s Original Answer again in U.S.
District Court for the District of Texas, Beaumont Division Jefferson County,
Texas U.S. Docket No. 1:10-CV-00055 against the Pro Se Plaintiff Louis Charles
Hamilton II herein
Before
the Honorable U.S. Judge Marcia A. Crone and Honorable U.S. Magistrate Keith F.
Giblin
Admitting
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 – on behalf of said
Co-Defendant(s)
“Joyce M. Guy and Edward McCray” collectively herein until you Chief Defendant Antoine
L. Freeman J. D. “Attorney
at Law”, herein responded to all said discovery request on October 14th,
2009 at which during this time frame of March 14th 2008 October 14th,
2009
“Your” having full legal knowledge that on Lots
Numbered One and Two (1&2) in Block Number One Hundred Seventy Two (172) of
City of Port Arthur in Jefferson County, Texas
Namely
the property located at 448 DeQueen Blvd. in Port Arthur Texas 77640 which is
the primary “physical evidence” and “physical address” of said Co-Defendant(s)
collectively herein which is both “physical evidence” and “physical home” was
completely destroyed in connection with namely
“Mechanic’s
LIEN Contract filed on June 9th 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.
As
physically described by you Chief Defendant Antoine L.
Freeman J. D. “Attorney
at Law”, herein in Pro Se Plaintiff attached Document # 9 Defendant(s) response
to “Interrogatories” dated October 14th, 2009 said property being under
a Federal Grant namely Interrogatories herein pursuant to Rule 197 of the Texas
Rules of Civil Procedures at Question: 10, 11, 12, 13, 14, 15, and 16.
Request
Number 30.
Admit
Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein being in
full possession, custody and legal control over said Pro Se Plaintiff herein “request for
production of property deeds” for Lots Numbered One and Two (1&2) in Block
Number One Hundred Seventy Two (172) of City of Port Arthur in Jefferson
County, Texas
Namely
the property located at 448 DeQueen Blvd. in Port Arthur Texas 77640 in Your” Chief
Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein physical
custody, possession and legal control between the actual dates of March 14th
2008 and such “request for production of property deeds” for Lots Numbered One
and Two (1&2) in Block Number One Hundred Seventy Two (172) of City of Port
Arthur in Jefferson County, Texas
Namely
the property located at 448 DeQueen Blvd. in Port Arthur Texas 77640 having not
been produced to the Pro Se Plaintiff or the 58th Judicial District
Court of Jefferson County Texas throughout actual date of April 30th
2010 when you filed Defendant’s Original Answer again in U.S. District Court
for the District of Texas, Beaumont Division Jefferson County, Texas U.S.
Docket No. 1:10-CV-00055 against the Pro Se Plaintiff Louis Charles Hamilton II
herein
Before
the Honorable U.S. Judge Marcia A. Crone and Honorable U.S. Magistrate Keith F.
Giblin Namely the property located at 448 DeQueen Blvd. in Port Arthur Texas
77640 which is the primary “physical evidence” and “physical address” of said
Co-Defendant(s) collectively herein which is both “physical evidence” and
“physical home” your furtherance’s admitting
Chief
Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein the primary “physical
evidence” and “physical home on said address” of said Co-Defendant(s)
collectively herein was completely destroyed in connection with namely
“Mechanic’s
LIEN Contract filed on June 9th 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.
As
your furtherance’s admitting physically being described by you Chief Defendant Antoine
L. Freeman J. D. “Attorney
at Law”, herein in Pro Se Plaintiff attached Document # 9 Defendant(s) response
to “Interrogatories” dated October 14th, 2009
Stating said property being under a Federal
Grant namely Interrogatories questions herein pursuant to Rule 197 of the Texas
Rules of Civil Procedures at Question: 10, 11, 12, 13, 14, 15, and 16.
No comments:
Post a Comment