Request
Number 46.
Admit
Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein Pursuant
to the provisions of Federal Rule of Civil Procedure 36, YOU making same admissions
of the following statements of fact’s in the (year) of 2015 in your defense of this current Complaint filed in U.S. Cause
No. 1:14-CV-592 U.S. District Court for the District of Texas, Beaumont
Division Jefferson County, Texas 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 on your behalf Chief Defendant Antoine L.
Freeman J. D. “Attorney
at Law”, herein and the Co-Defendant(s) “Joyce M. Guy and Edward McCray
collective legal behalf Admitting you are continual making the same
“representation and presentation”
Before the Honorable U.S. Judge Marcia A.
Crone and Honorable U.S. Magistrate Keith F. Giblin, in 2010 (April) 30th
to be exact and all defense derive thereafter That you stating that on or about
April 2nd 2008 and April 11, 2008 the continual false claims you
were in possession, custody, and control of Pro Se Plaintiff Discovery request
for Production of Documents and Request for Disclosure in accordance with the
Texas
Rules of Civil Procedures to Cause No. A-180805 in a civil suit in the 58th
Judicial District Court of Jefferson County Texas and the official date your
claiming of such knowledge to be that on or about April 2nd 2008 and
April 11, 2008, to be material factual, 100% the truth against Federal Penalty
of perjury in comparison to Pro Se Plaintiff attached Document # 10 “The
Official 58th Judicial District Court of Jefferson County Texas”,
Case Ledger showing said discovery of Pro Se Plaintiff Louis Charles Hamilton
II herein Discovery request for Production of Documents and Request for Disclosure
in accordance with the
Texas Rules of Civil Procedures to Cause No.
A-180805 in a civil suit in the 58th Judicial District Court of
Jefferson County Texas was in your Chief Defendant Antoine
L. Freeman J. D. “Attorney
at Law”, herein legal possession Custody and Control since March 14th
2008 and not the dates of April 2nd 2008 and April 11, 2008 as you’re
falsely claiming.
Request
Number 47.
Admit
Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein Pursuant
to the provisions of Federal Rule of Civil Procedure 36, YOU making same admissions
of the following statements of fact’s in the (year) of 2015 in your defense of this current Complaint filed in U.S. Cause
No. 1:14-CV-592 U.S. District Court for the District of Texas, Beaumont
Division Jefferson County, Texas 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 on your behalf Chief Defendant Antoine L.
Freeman J. D. “Attorney
at Law”, herein and the Co-Defendant(s) “Joyce M. Guy and Edward McCray
collective legal behalf Admitting you are continual making the same
“representation and presentation”
Before the Honorable U.S. Judge Marcia A.
Crone and Honorable U.S. Magistrate Keith F. Giblin, in 2010 (April) 30th
to be exact and all defense derive thereafter in 2010 (April) 30th after
viewing
Pro
Se Plaintiff attached document # 10 namely Chief Defendant Antoine
L. Freeman J. D. “Attorney
at Law”, herein Subscribed and Sworn “Verification” dated the 11th
day of September 2009 to be statements under oath to be true and correct the
official date your claiming , in 2010 (April) 30th to be exact and
all defense derive thereafter 2010 (April)
30th
In
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 on your behalf Chief Defendant Antoine L.
Freeman J. D. “Attorney
at Law”, herein and the Co-Defendant(s) “Joyce M. Guy and Edward McCray
collective legal behalf
Admitting
you are continual making the same “representation and presentation” in defense of
such knowledge to be that on or about April 2nd 2008 and April 11,
2008, to be material factual, 100% the truth against Federal Penalty of perjury
in comparison to Pro Se Plaintiff attached Document # 11
“The Official 58th Judicial
District Court of Jefferson County Texas”, Case Ledger showing said discovery of
Pro Se Plaintiff Louis Charles Hamilton II herein Discovery request for Production
of Documents, and Request for Disclosure in accordance with the
Texas Rules of Civil Procedures to Cause No.
A-180805 in a civil suit in the 58th Judicial District Court of
Jefferson County Texas was in your Chief Defendant Antoine
L. Freeman J. D. “Attorney
at Law”, herein legal possession Custody and Control since March 14th
2008 and not the dates of April 2nd 2008 and April 11, 2008 as you’re
falsely claiming...
Request
Number 48.
Admit
Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein Pursuant
to the provisions of Federal Rule of Civil Procedure 36, YOU making same admissions
of the following statements of fact’s in the (year) of 2015 in your defense of this current Complaint filed in U.S. Cause
No. 1:14-CV-592 U.S. District Court for the District of Texas, Beaumont
Division Jefferson County, Texas before the
Honorable U.S. Magistrate Judge Zack
Hawthorn against
the Pro Se Plaintiff Louis Charles Hamilton II herein
on your behalf
Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein and the
Co-Defendant(s) “Joyce M. Guy and Edward McCray collective legal behalf
Admitting you are continual making the same “representation and presentation” in
2015 to be exact and all defense derive thereafter in this current Complaint
filed in U.S. Cause No. 1:14-CV-592 that you Chief Defendant Antoine
L. Freeman J. D. “Attorney
at Law”, herein
Continual
stating that on or about April 2nd 2008 and April 11, 2008 the continual
false claims you were in possession, custody, and control of Pro Se Plaintiff
Discovery request for Production of Documents and Request for Disclosure in accordance
with the
Texas
Rules of Civil Procedures to Cause No. A-180805 in a civil suit in the 58th
Judicial District Court of Jefferson County Texas and the official date your
claiming of such knowledge to be that on or about April 2nd 2008 and
April 11, 2008, to be material factual, 100% the truth against Federal Penalty
of perjury in comparison to Pro Se Plaintiff attached Document # 11
“The
Official 58th Judicial District Court of Jefferson County Texas”,
Case Ledger showing said discovery of Pro Se Plaintiff Louis Charles Hamilton
II herein Discovery request for Production of Documents and Request for Disclosure
in accordance with the
Texas Rules of Civil Procedures 194.2, 197, and
198, to Cause No. A-180805 in a civil suit in the 58th Judicial
District Court of Jefferson County Texas was in your Chief Defendant Antoine
L. Freeman J. D. “Attorney
at Law”, herein legal possession Custody and Control since March 14th
2008 and not the dates of April 2nd 2008 and April 11, 2008 as you’re
falsely claiming.
Request
Number 49.
Admit
Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein
Pursuant to the provisions of Federal Rule of Civil Procedure 36, YOU making same
admissions of the following statements of fact’s in the (year) of 2015 in your
defense of
this current Complaint filed in U.S. Cause No. 1:14-CV-592 U.S. District Court
for the District of Texas, Beaumont Division Jefferson County, Texas
before the
Honorable U.S. Magistrate Judge Zack
Hawthorn against
the Pro Se Plaintiff Louis Charles Hamilton II herein
on your behalf
Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein defense
after the date of December 3rd 2014 to be exact and all defense
derive thereafter in this current Complaint filed in U.S. Cause No. 1:14-CV-592
that you
Chief
Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein after
viewing Pro Se Plaintiff attached document # 10 namely Chief Defendant Antoine
L. Freeman J. D. “Attorney
at Law”, herein Subscribed and Sworn “Verification” dated the 11th
day of September 2009 to be statements under oath to be true and correct the
official date your claiming before the
Honorable U.S. Magistrate Judge Zack
Hawthorn against
the Pro Se Plaintiff Louis Charles Hamilton II herein
Continual
stating that on or about April 2nd 2008 and April 11, 2008 the continual
false claims you were in possession, custody, and control of Pro Se Plaintiff
Discovery request for Production of Documents and Request for Disclosure in accordance
with the
Texas
Rules of Civil Procedures to Cause No. A-180805 in a civil suit in the 58th
Judicial District Court of Jefferson County Texas and the official date your
claiming of such knowledge to be that on or about April 2nd 2008 and
April 11, 2008, to be material factual, 100% the truth against Federal Penalty
of perjury in comparison to Pro Se Plaintiff attached Document # 11
“The
Official 58th Judicial District Court of Jefferson County Texas”,
Case Ledger showing said discovery of Pro Se Plaintiff Louis Charles Hamilton
II herein Discovery request for Production of Documents and Request for Disclosure
in accordance with the
Texas Rules of Civil Procedures to Cause No.
A-180805 in a civil suit in the 58th Judicial District Court of
Jefferson County Texas was in your Chief Defendant Antoine
L. Freeman J. D. “Attorney
at Law”, herein legal possession Custody and Control since March 14th
2008 and not the dates of April 2nd 2008 and April 11, 2008 as you’re
falsely claiming.
Request
Number 50.
Admit
Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein Pursuant
to the provisions of Federal Rule of Civil Procedure 36, YOU making same admissions
of the following statements of fact’s in the (year) of 2015 in your defense of this current Complaint filed in U.S. Cause
No. 1:14-CV-592 U.S. District Court for the District of Texas, Beaumont
Division Jefferson County, Texas before the
Honorable U.S. Magistrate Judge Zack
Hawthorn against
the Pro Se Plaintiff Louis Charles Hamilton II herein
on your behalf
Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein admit that
you did not file a “Motion for withdrawal of Counsel” from the Co-Defendant(s)
Joyce M. Guy and Edward McCray civil action herein “Between” the dates of
December 18th 2007 in your claim of filing your “General Denial” (Only)
to cause No. A-180805 throughout the date of April 2nd 2008 and
April 11, 2008, after “You” Chief Defendant Antoine L.
Freeman J. D. “Attorney
at Law”, herein being in possession, custody, and control over Pro Se Plaintiff
Discovery request for Production of Documents
and
Request for Disclosure in accordance with the Texas Rules of Civil Procedures during
this time frame “You” did not file a “Motion for withdrawal of Counsel to cause
No. A-180805.
Request
Number 51.
Admit
Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein 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 on your behalf Chief Defendant Antoine L.
Freeman J. D. “Attorney
at Law”, herein and the Co-Defendant(s) “Joyce M. Guy and Edward McCray
collective legal behalf Admitting you are continual making the same
“representation and presentation”
Before the Honorable U.S. Judge Marcia A.
Crone and Honorable U.S. Magistrate Keith F. Giblin, in 2010 (April) 30th
to be exact and all defense derive thereafter in 2010 (April) 30th
“Between”
the dates of March 14th 2008, throughout the dates of October 14th
2009 “Your” in full possession, custody, and legal control over Pro Se
Plaintiff Motion for Production of Documents, and Request for Disclosure in
accordance with the Texas Rules of Civil Procedures
“You” admitting in your defense in
2010 (April) 30th to be exact and all defense derive thereafter in
2010 (April) 30th in U.S. Docket No. 1:10-CV-00055 against the Pro
Se Plaintiff Louis Charles Hamilton II herein
You Chief Defendant Antoine L. Freeman J. D. “Attorney at
Law”, herein admitting you did in facts and circumstances fully informed the
Honorable Judge “Bob Wortham” of the 58th Judicial District Court of
Jefferson County Texas
“Your” being in complete refusal per
your Co-Defendant(s)/ (Clients) “Joyce M. Guy and Edward McCray collective request
and directions to not file any legal response and reply to any of the Production
of Documents, and Request for Disclosure Pro Se Plaintiff mailed to “You” on
the dates of March 14th 2008 in accordance with the Texas Rules of
Civil Procedures in cause No. A-180805 throughout October 14th 2009 and
You Chief Defendant Antoine L.
Freeman J. D. “Attorney at Law”, herein furtherance’s admitting
you did in facts and circumstances fully informed the Honorable Judge “Bob
Wortham” of the 58th Judicial District Court of Jefferson County
Texas you’re not acting Attorney of
Record between the dates of March 14th 2008 .
Request
Number 52.
Admit
Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein
Pursuant to the provisions of Federal Rule of Civil Procedure 36, YOU making same
admissions of the following statements of fact’s in the (year) of 2015 in your
defense of
this current Complaint filed in U.S. Cause No. 1:14-CV-592 U.S. District Court
for the District of Texas, Beaumont Division Jefferson County, Texas
before the
Honorable U.S. Magistrate Judge Zack
Hawthorn against
the Pro Se Plaintiff Louis Charles Hamilton II herein
on your behalf
Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein defense
after the date of December 3rd 2014 to be exact and all defense
derive thereafter in this current Complaint filed in U.S. Cause No. 1:14-CV-592
that you
Chief
Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein after
viewing Pro Se Plaintiff attached document # 11“The Official 58th
Judicial District Court of Jefferson County Texas”, Case Ledger showing said
discovery of Pro Se Plaintiff Louis Charles Hamilton II herein Discovery
request for Production of Documents and Request for Disclosure in accordance
with the
Texas Rules of Civil Procedures to Cause No.
A-180805 in a civil suit in the 58th Judicial District Court of
Jefferson County Texas was in your Chief Defendant Antoine
L. Freeman J. D. “Attorney
at Law”, herein legal possession Custody and Control since March 14th
2008 and not the dates of April 2nd 2008 and April 11, 2008 as you’re
falsely claiming.
Request
Number 53.
Admit
Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein
Pursuant to the provisions of Federal Rule of Civil Procedure 36, YOU making same
admissions of the following statements of fact’s in the (year) of 2015 in your
defense of
this current Complaint filed in U.S. Cause No. 1:14-CV-592 U.S. District Court
for the District of Texas, Beaumont Division Jefferson County, Texas
before the
Honorable U.S. Magistrate Judge Zack
Hawthorn against
the Pro Se Plaintiff Louis Charles Hamilton II herein
on your behalf
Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein defense
after the date of December 3rd 2014 to be exact and all defense
derive thereafter in this current Complaint filed in U.S. Cause No. 1:14-CV-592
that you
Chief
Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein after
viewing Pro Se Plaintiff attached document # 11“The Official 58th
Judicial District Court of Jefferson County Texas”, Case Ledger showing said
discovery of Pro Se Plaintiff Louis Charles Hamilton II herein Discovery
request for Production of Documents and Request for Disclosure in accordance
with the
Texas Rules of Civil Procedures to Cause No.
A-180805 in a civil suit in the 58th Judicial District Court of
Jefferson County Texas was in your Chief Defendant Antoine
L. Freeman J. D. “Attorney
at Law”, herein legal possession Custody and Control since March 14th
2008 and not the dates of April 2nd 2008 and April 11, 2008 as you’re
falsely claiming.
Request
Number 54.
Admit
Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein
Pursuant to the provisions of Federal Rule of Civil Procedure 36, YOU making same
admissions of the following statements of fact’s in the (year) of 2015 in your
defense of
this current Complaint filed in U.S. Cause No. 1:14-CV-592 U.S. District Court
for the District of Texas, Beaumont Division Jefferson County, Texas
before the
Honorable U.S. Magistrate Judge Zack
Hawthorn against
the Pro Se Plaintiff Louis Charles Hamilton II herein
on your behalf
Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein defense
after the date of
December
3rd 2014 to be exact and all defense derive thereafter in this
current Complaint filed in U.S. Cause No. 1:14-CV-592 that you 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 on your behalf Chief Defendant Antoine L.
Freeman J. D. “Attorney
at Law”, herein and the Co-Defendant(s) “Joyce M. Guy and Edward McCray
collective legal behalf Admitting you are continual making the same
“representation and presentation”
Before the Honorable U.S. Judge Marcia A.
Crone and Honorable U.S. Magistrate Keith F. Giblin, in 2010 (April) 30th
to be exact and all continual defense derive thereafter in 2010 (April) 30th
Chief
Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein after
viewing Pro Se Plaintiff attached document # 11“The Official 58th
Judicial District Court of Jefferson County Texas”, Case Ledger showing said
discovery of Pro Se Plaintiff Louis Charles Hamilton II herein Discovery
request for Production of Documents and Request for Disclosure in accordance
with the
Texas Rules of Civil Procedures to Cause No.
A-180805 in a civil suit in the 58th Judicial District Court of
Jefferson County Texas was in your Chief Defendant Antoine
L. Freeman J. D. “Attorney
at Law”, herein legal possession Custody and Control since March 14th
2008 and your furtherance’s admitting not the dates of April 2nd
2008 and April 11, 2008 as your falsely claiming in Pro Se Plaintiff attached
Document # 3 “Your Chief Defendant Antoine L.
Freeman J. D. “Attorney
at Law”, herein response to motion for sanctions against you dated September 11th
2009
Request
Number 55.
Admit
Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein
Pursuant to the provisions of Federal Rule of Civil Procedure 36, YOU making same
admissions of the following statements of fact’s in the (year) of 2015 in your
defense of
this current Complaint filed in U.S. Cause No. 1:14-CV-592 U.S. District Court
for the District of Texas, Beaumont Division Jefferson County, Texas
before the
Honorable U.S. Magistrate Judge Zack
Hawthorn against
the Pro Se Plaintiff Louis Charles Hamilton II herein
on your behalf
Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein defense
after the date of
December
3rd 2014 to be exact and all defense derive thereafter in this
current Complaint filed in U.S. Cause No. 1:14-CV-592 that you 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 on your behalf Chief Defendant Antoine L.
Freeman J. D. “Attorney
at Law”, herein and the Co-Defendant(s) “Joyce M. Guy and Edward McCray
collective legal behalf Admitting you are continual making the same
“representation and presentation”
Before the Honorable U.S. Judge Marcia A.
Crone and Honorable U.S. Magistrate Keith F. Giblin, in 2010 (April) 30th
to be exact and all continual defense derive thereafter in 2010 (April) 30th
Chief
Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein “You” did
file a request for a longer extension of time herein furtherance’s admitting
you did in facts and circumstances fully informed the Honorable Judge “Bob
Wortham” of the 58th Judicial District Court of Jefferson County
Texas you needing the extra time to reply to said “Discovery Request of
Interrogatories, Request of Admission, Motion for Production of Documents and
Request for Disclosure Pro Se Plaintiff mailed to “You” on the start dates of
March 14th 2008 and your herein furtherance’s admitting you did in
facts and circumstances fully informed the Honorable Judge “Bob Wortham”
between the actual dates of March 14th 2008 throughout October 12th
2009.
Request
Number 56.
Admit
Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein
Pursuant to the provisions of Federal Rule of Civil Procedure 36, YOU making same
admissions of the following statements of fact’s in the (year) of 2015 in your
defense of
this current Complaint filed in U.S. Cause No. 1:14-CV-592 U.S. District Court
for the District of Texas, Beaumont Division Jefferson County, Texas
before the
Honorable U.S. Magistrate Judge Zack
Hawthorn against
the Pro Se Plaintiff Louis Charles Hamilton II herein
on your behalf
Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein defense
after the date of
December
3rd 2014 to be exact and all defense derive thereafter in this
current Complaint filed in U.S. Cause No. 1:14-CV-592 that you
Chief
Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein “You” did
file a request for a longer extension of time herein furtherance’s admitting
you did in facts and circumstances fully informed the Honorable Judge “Bob
Wortham” of the 58th Judicial District Court of Jefferson County
Texas you behalf Chief Defendant Antoine L.
Freeman J. D. “Attorney
at Law”, herein needing the extra time to reply to said “Discovery Request of
Interrogatories, Request of Admission,
Motion
for Production of Documents and Request for Disclosure Pro Se Plaintiff mailed
to “You” on the start dates of March 14th 2008 and your herein furtherance’s
admitting you did in facts and circumstances fully informed the Honorable Judge
“Bob Wortham” between the actual dates of March 14th 2008 throughout
October 12th 2009.
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