Monday, March 16, 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 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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