Request
Number 69.
Admitting
Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein “you” from
the time frame of March 14th 2008 1:48 pm hour while your “acting
attorney of record” and continual being said “acting attorney of record” 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 for
the legal behalf of the Co-Defendant(s) Defendant “Joyce M. Guy and Edward
McCray” collectively herein
Continual
Admitting Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein that you
were fully aware on or after March 14th 2008, Pro Se Plaintiff herein
request Pursuant to Texas rule of civil procedure 196, within thirty (30) days
of Service of this request your are requested to disclosed the information or material
described in Rule 196
As
being legally described in Pro Se Plaintiff attached document # 12 herein
Namely Plaintiff “Motion for Production of Document” filed in the District
Court of Jefferson County Texas “time stamp” March 14th 2008 1:48 pm
hour for
Co-Defendant(s) Joyce M. Guy and Edward McCray
shall produce copies of deeds, property deeds or any other such physical
document in Co-Defendants’ possession, custody or control that shows actual
ownership of the property of the dwelling located at 448 DeQueen Blvd., Port
Arthur, Texas.
And
Co-Defendant(s) Joyce M. Guy and Edward McCray shall produce copies of any and
all construction estimates for repairs in Defendants’ possession, custody or
control in relationship to the damage caused by Hurricanes Rita, Humberto and
Ike to the property located at 448 DeQueen Blvd. in Port Arthur, Texas
And
you Chief Defendant Antoine L. Freeman J. D. “Attorney at Law” herein have not
produced such requested to disclose between the dates of March 14th
2008 1:48 pm hour throughout October 14th 2009.
And
you Chief Defendant Antoine L. Freeman J. D. “Attorney at Law” herein furtherance’s
admitting on September 11th 2009 between the time frame “time stamp”
March 14th 2008 1:48 pm hour throughout October 14th 2009
you withheld said discovery request being all such as described in “Request for
Admission” (67) herein
Admitting
in that on September 11th 2009 Chief Defendant Antoine
L. Freeman J. D. “Attorney
at Law” herein used the “United States Postal System” on the exact date the 11th
day of September 2009 as described in Pro Se Plaintiff attached document # 3
herein Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein
“Response
to Motion for sanctions” and Pro Se Plaintiff attached document # 10 herein Chief
Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein “Sworn
statement under oath” to target Pro Se Plaintiff “Louis Charles Hamilton II”
herein in a
“Mail
and Wire Fraud” scheme of things on the exact date the 11th day of
September 2009 involving a civil suit in common law in the 58th
Judicial District Court of Jefferson County Texas Docket No. A-180805
In
that Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein admit after
viewing Pro Se Plaintiff attached document # 10 namely Chief Defendant Antoine
L. Freeman J. D. “Attorney
at Law”, herein “Subscribed and Sworn” legal documented “Verification” dated
the 11th day of September 2009 to be statements under oath to be
true and correct
All
said fraudulent, false material facts, as described by Pro Se Plaintiff in document
# 3 attached herein Chief Defendant Antoine L.
Freeman J. D. “Attorney
at Law”, herein “Response to Motion for sanctions”
Namely
the official date your falsely claiming of such “firsthand knowledge” of any of
the Pro Se Plaintiff herein required discovery request for copies of deeds,
property deeds or any other such physical document in Co-Defendants’
possession, custody or control that shows actual ownership of the property of
the dwelling located at 448 DeQueen Blvd., Port Arthur, Texas.
And
Co-Defendant(s) Joyce M. Guy and Edward McCray herein through counsel of record
namely Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein shall
produce copies of any and all construction estimates for repairs in Defendants’
possession, custody or control in relationship to the damage caused by
Hurricanes
Rita, Humberto and Ike to the property located at 448 DeQueen Blvd. in Port
Arthur, Texas to be that on or about April 2nd 2008 and April 11,
2008, your falsely claiming of such “firsthand knowledge” of any of the Pro Se
Plaintiff herein required discovery request 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 70.
Admitting
Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein “you” from
the time frame of March 14th 2008 1:48 pm hour while your acting
attorney of record and continual being said acting attorney of record 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 for
the legal behalf of the Co-Defendant(s) Defendant “Joyce M. Guy and Edward
McCray” collectively herein
Continual
Admitting Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein that you
were fully aware on or after March 14th 2008, Pro Se Plaintiff
herein request Pursuant to Texas rule of civil procedure Pro Se Plaintiff
Discovery request for Interrogatories, Request of Admission, and Request for
Disclosure in accordance with the
Texas
Rules of Civil Procedures 194.2, 197, and 198, Being required to be produced
within thirty (30) days of Service of this request your are requested to
disclosed the information or material
And
you Chief Defendant Antoine L. Freeman J. D. “Attorney at Law” herein admitting “you”
have not produced such requested to disclose between the dates of March 14th
2008 1:48 pm hour throughout October 12th 2009
And
you Chief Defendant Antoine L. Freeman J. D. “Attorney at Law” herein withheld all said
“discovery request” to fully “target” Pro Se Plaintiff “Louis Charles Hamilton
II” herein in a
“Mail
and Wire Fraud” scheme of things on the exact date the March 14th
2008 1:48 pm hour throughout October 12th 2009 involving a civil
suit in common law in the 58th Judicial District Court of Jefferson
County Texas Docket No. A-180805
In
that Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein admit “you”,
used the “United States Postal System” “Mail
and Wire Fraud” scheme of things to concealed, obstructed, kept secret, tuck
away, hidden, scuttle for the legal behalf of the Co-Defendant(s) “Joyce M. Guy
and Edward McCray” collectively herein all said “subject matter” contain in the
described Discovery request for Interrogatories, Request of Admission, and
Request for Disclosure in accordance with the Texas Rules of Civil Procedures
194.2, 197, and 198,.
And
admitting this such “obstruction of justice” of the 58th Judicial
District Court of Jefferson County to continual concealed, obstructed, kept secret,
tuck away, hidden, scuttle for the legal behalf of the Co-Defendant(s) “Joyce
M. Guy and Edward McCray” collectively herein all said “subject matter” contain
in the described Discovery request for Interrogatories, Request of Admission,
and Request for Disclosure in accordance with the Texas Rules of Civil
Procedures 194.2, 197, and 198,. Was facilitated in the Chief Defendant Antoine
L. Freeman J. D. “Attorney
at Law”, herein full legal usage of the “United States Postal System” Between
the exact dates of March 14th 2008 1:48 pm hour throughout October
14th 2009.
Request
Number 71.
Admitting
Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein “you” from
the time exact time frame of November 13th 2009 Chief Defendant Antoine
L. Freeman J. D. “Attorney
at Law”, herein fully legally usage of the “United States Postal System” to
serve on Pro Se Plaintiff by execution of certified mail, return receipt
requested on (Pro Se) Plaintiff at P.O. Box 342, Port Arthur, Texas 77640
“Your”
Motion for Withdrawal of Counsel of Chief Defendant Antoine
L. Freeman J. D. “Attorney
at Law” herein while Chief Defendant Antoine L.
Freeman J. D. “Attorney
at Law”, herein continual admitting to having not produced such requested to
disclose between the dates of
March
14th 2008 1:48 pm hour throughout October 14th 2009 in
that you withheld said all “discovery request” to “target” Pro Se Plaintiff
“Louis Charles Hamilton II” herein in a “Mail and Wire Fraud” scheme of things
on the exact date the March 14th 2008 1:48 pm hour throughout
October 14th 2009 involving a civil suit in common law in the 58th
Judicial District Court of Jefferson County Texas Docket No. A-180805”
To concealed, obstructed, kept secret, tuck
away, hidden, scuttle for the legal behalf of the Co-Defendant(s) “Joyce M. Guy
and Edward McCray” collectively herein all said “subject matter” contain in the
described Discovery request for Interrogatories, Request of Admission, and Request
for Disclosure in accordance with the Texas Rules of Civil Procedures 194.2,
197, and 198,.
Request
Number 72.
Admitting
Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein “you” from
the time exact time frame of April 30th 2010 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
To
continual herein fully legally usage of the “United States Postal System” “Mail
and Wire Fraud” scheme of things to continual concealed, obstructed, kept secret,
tuck away, hidden, scuttle for the legal behalf of the Co-Defendant(s) “Joyce
M. Guy and Edward McCray” collectively herein all said “subject matter” contain
in the described Discovery request for Interrogatories, Request of Admission,
and Request for Disclosure in accordance with the Texas Rules of Civil
Procedures 194.2, 197, and 198,.
That
Co-Defendant(s) Joyce M. Guy and Edward McCray shall produce copies of deeds,
property deeds or any other such physical document in Co-Defendants’
possession, custody or control that shows actual ownership of the property of
the dwelling located at 448 DeQueen Blvd., Port Arthur, Texas.
And
that Co-Defendant(s) Joyce M. Guy and Edward McCray shall produce copies of any
and all construction estimates for repairs in Defendants’ possession, custody
or control in relationship to the damage caused by Hurricanes Rita, Humberto
and Ike to the property located at 448 DeQueen Blvd. in Port Arthur, Texas
While
Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein continual
having not produced such requested to disclose between the dates of
March
14th 2008 1:48 pm hour throughout October 14th 2009 in
that you withheld said all “discovery request” to “target” Pro Se Plaintiff
“Louis Charles Hamilton II” herein in a “Mail and Wire Fraud” scheme of things
in the usage of the United States Postal system on the exact time frame dates
of March 14th 2008 1:48 pm hour throughout October 14th
2009 involving a civil suit in common law in the 58th Judicial
District Court of Jefferson County Texas Docket No. A-180805”
Request
Number 73.
Admit
Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein fully
legally intend to continual usage of the “United States Postal System” in a
“Mail and Wire Fraud” scheme of things against “The United States District
Court For The Eastern Division of Texas, Beaumont Division” from the time exact
time frame of April 30th 2010 and all defense derive thereafter
In that you Chief Defendant Antoine
L. Freeman J. D. “Attorney
at Law”, herein are continual making the same fraudulent, false, fictitious
“Representation and Presentation” Before the Honorable U.S. Judge Marcia A.
Crone and Honorable U.S. Magistrate Keith F. Giblin U.S. Docket No.
1:10-CV-00055 against the Pro Se Plaintiff Louis Charles Hamilton II herein
All
said fraudulent, false material facts, as described by Pro Se Plaintiff in
document # 3 attached herein Chief Defendant Antoine L.
Freeman J. D. “Attorney
at Law”, herein “Response to Motion for sanctions” in that “You” was only
retain to file a
“General
Denial” only on December 18th 2007 and from the time frame of March
14th 2008 1:48 pm hour throughout November 13th 2009
10:22 am hour “You” herein Chief Defendant Antoine L.
Freeman J. D. “Attorney
at Law”, herein was not the acting ‘attorney of record”, did not attend any
hearing on August 28th, 2009 and September 11th 2009.
Request
Number 74.
Admit
Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein fully
legally intend to “continual usage” of the “United States Postal System” in a
“Mail and Wire Fraud” scheme of things against “The United States District
Court For The Eastern Division of Texas, Beaumont Division” from the time exact
time frame of December 3rd 2014 and all defense derive thereafter
In that you Chief Defendant Antoine
L. Freeman J. D. “Attorney
at Law”, herein are continual making the same fraudulent, false, fictitious
“Representation and Presentation” Before the
Honorable
U.S. Magistrate Judge Zack Hawthorn U.S. Docket No. 1:14-CV-00592 against the
Pro Se Plaintiff Louis Charles Hamilton II herein
All
said fraudulent, false material facts, as described by Pro Se Plaintiff in
document # 3 attached herein Chief Defendant Antoine L.
Freeman J. D. “Attorney
at Law”, herein “Response to Motion for sanctions” in that “You” was only
retain to file a
“General
Denial” only on December 18th 2007 and from the time frame of March
14th 2008 1:48 pm hour throughout November 13th 2009
10:22 am hour “You” herein Chief Defendant Antoine L.
Freeman J. D. “Attorney
at Law”, herein was not in any legal capacity the acting ‘attorney of record”,
did not attend any hearing on August 28th, 2009 and September 11th
2009. In a civil suit in common law in the Jefferson County Texas 58th
Judicial District Court Docket No. A-180805
Request
Number 75.
Admit
Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein fully
legally intend to “continual usage” of the “United States Postal System” in a
“Mail and Wire Fraud” scheme of things against “The United States District
Court For The Eastern Division of Texas, Beaumont Division” from the time exact
time frame of December 3rd 2014 and all defense derive thereafter
Before the
Honorable
U.S. Magistrate Judge Zack Hawthorn U.S. Docket No. 1:14-CV-00592 against the
Pro Se Plaintiff Louis Charles Hamilton II herein
In that you Chief Defendant Antoine
L. Freeman J. D. “Attorney
at Law”, herein are continual fully legally usage of the “United States Postal
System” in a “Mail and Wire Fraud” scheme of things to continual concealed,
obstructed, kept secret, tuck away, hidden, scuttle for the legal behalf of the
Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein all said
“subject matter” contain in the described Discovery request for
Interrogatories, Request of Admission, and Request for Disclosure in accordance
with the Texas Rules of Civil Procedures 194.2, 197, and 198,.
In
That Co-Defendant(s) Joyce M. Guy and Edward McCray shall produce copies of
deeds, property deeds or any other such physical document in Co-Defendants’
possession, custody or control that shows actual ownership of the property of
the dwelling located at 448 DeQueen Blvd., Port Arthur, Texas.
And
in that Co-Defendant(s) Joyce M. Guy and Edward McCray shall produce copies of
any and all construction estimates for repairs in Defendants’ possession,
custody or control in relationship to the damage caused by Hurricanes Rita,
Humberto and Ike to the property located at 448 DeQueen Blvd. in Port Arthur,
Texas
Request
Number 76.
Admit
Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein fully
legally intend to “continual usage” of the “United States Postal System” in a
“Mail and Wire Fraud” scheme of things against “The United States District
Court For The Eastern Division of Texas, Beaumont Division” from the time exact
time frame of December 3rd 2014 and all defense derive thereafter
Before the
Honorable
U.S. Magistrate Judge Zack Hawthorn U.S. Docket No. 1:14-CV-00592 against the
Pro Se Plaintiff Louis Charles Hamilton II herein
In that you Chief Defendant Antoine
L. Freeman J. D. “Attorney
at Law”, herein are continual fully legally usage of the “United States Postal
System” in a “Mail and Wire Fraud” scheme of things to continual concealed,
obstructed, kept secret, tuck away, hidden, scuttle for the legal behalf of the
Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein copies of
said required “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 as
described in Pro Se Plaintiff attached document # 14 “General Warranty Deed” of
the Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein
Request
Number 77.
Admit
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 In
that you Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein did usage of
the “United States Postal System” to forward Subscribed and Sworn
“Verification” dated the 11th day of September 2009 to the 58th
Judicial District Court of Jefferson County Texas,
And
in that you Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein did usage of
the “United States Postal System” to forward said Subscribed and Sworn
“Verification” dated the 11th day of September 2009 to the Pro Se
Plaintiff by execution of certified mail, return receipt requested on (Pro Se)
Plaintiff at P.O. Box 342, Port Arthur, Texas 77640
Request
Number 78.
Admit
Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein In that you fully
legally usage of the “United States Postal System” in a “Mail and Wire Fraud”
scheme of things to continual concealed, obstructed, kept secret, tuck away,
hidden, scuttle for the legal behalf of the Co-Defendant(s) “Joyce M. Guy and
Edward McCray” collectively herein all said “subject matter” contain in the
described Discovery request for Interrogatories, Request of Admission, from the
time frame dates of March 14th 2008 1:48 pm hour throughout October 14th
2009
In
which on October 14th 2009 Chief Defendant Antoine
L. Freeman J. D. “Attorney
at Law”, herein while in legal possession, custody and control of Discovery
request for Interrogatories, Request of Admission, since March 14th
2008 1:48 pm hour finally did make effort to Response/reply to the Pro Se
Plaintiff by execution of certified mail, return receipt requested on (Pro Se)
Plaintiff at P.O. Box 342, Port Arthur, Texas 77640 as this was legally usage
of the “United States Postal System” on the exact date of October 14th
2009
Request
Number 79.
Admitting
Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein “you” from
the time frame of March 14th 2008 1:48 pm hour while your acting
attorney of record and 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 said acting attorney of record and all defense derive thereafter in
2010 (April) 30th for the legal behalf of the Co-Defendant(s) Defendant
“Joyce M. Guy and Edward McCray” collectively herein
U.S.
Docket No. 1:10-CV-00055 against the Pro Se Plaintiff Louis Charles Hamilton II
herein You fully legally continual in the usage of the “United States Postal
System” in a “Mail and Wire Fraud” scheme of things defense against “The United
States District Court For The Eastern Division of Texas Beaumont Division” to
continual concealed, obstructed, kept secret, tuck away, hidden, scuttle for
the legal behalf of the Co-Defendant(s) “Joyce M. Guy and Edward McCray”
collectively herein said “property deeds” Namely “General Warranty Deed” 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 deeds” for dwelling and Property located at 448 DeQueen Blvd. in
Port Arthur Texas.
Request
Number 80.
Admitting
Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein “you” from
the time frame of March 14th 2008 1:48 pm hour while your acting
attorney of record and 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 said acting attorney of record and all defense derive thereafter in
2010 (April) 30th for the legal behalf of the Co-Defendant(s) Defendant
“Joyce M. Guy and Edward McCray” collectively herein
U.S.
Docket No. 1:10-CV-00055 against the Pro Se Plaintiff Louis Charles Hamilton II
herein You fully legally continual in the usage of the “United States Postal
System” in a “Mail and Wire Fraud” scheme of things defense against “The United
States District Court For The Eastern Division of Texas Beaumont Division” to
continual concealed, obstructed, kept secret, tuck away, hidden, scuttle for
the legal behalf of the Co-Defendant(s) “Joyce M. Guy and Edward McCray”
collectively herein said “property deeds” Namely “General Warranty Deed” 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 deeds” for dwelling and Property located at 448 DeQueen Blvd. in
Port Arthur Texas
In order that the Co- Defendant “Joyce M. Guy
and Edward McCray” collectively herein fully comply under all the terms and
conditions of any contract in regards to the new home being said
Federal Government built home “free of charge”
Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein must
remain in home for at least 3 years.
Request
Number 81.
Admitting
Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein “you” from
the time frame of March 14th 2008 1:48 pm hour while your acting
attorney of record and 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 said acting attorney of record and all defense derive thereafter in
2010 (April) 30th for the legal behalf of the Co-Defendant(s) Defendant
“Joyce M. Guy and Edward McCray” collectively herein
U.S.
Docket No. 1:10-CV-00055 against the Pro Se Plaintiff Louis Charles Hamilton II
herein You fully legally continual in the usage of the “United States Postal
System” in a “Mail and Wire Fraud” scheme of things defense against “The United
States District Court For The Eastern Division of Texas Beaumont Division” in December
3rd 2014 and all defense derive thereafter December 3rd
2014 Before the
Honorable
U.S. Magistrate Judge Zack Hawthorn U.S. Docket No. 1:14-CV-00592 against the
Pro Se Plaintiff Louis Charles Hamilton II herein
In that you Chief Defendant Antoine
L. Freeman J. D. “Attorney
at Law”, herein are continual fully legally intent to the usage of the “United
States Postal System” in a “Mail and Wire Fraud” scheme of things to continual
concealed, obstructed, kept secret, tuck away, hidden, scuttle for the legal
behalf of the Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively
herein copies of said required “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 as
described in Pro Se Plaintiff attached document # 14 “General Warranty Deed” of
the Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein to furtherance’s
continual concealed, obstructed, kept secret, tuck away, hidden, scuttle for
the legal behalf of the Co-Defendant(s) “Joyce M. Guy and Edward McCray”
collectively herein said “property deeds” Namely “General Warranty Deed” 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 deeds” for dwelling and Property located at 448 DeQueen Blvd. in
Port Arthur Texas in order that the Co- Defendant “Joyce M. Guy and Edward
McCray” collectively herein fully comply under all the terms and conditions of
any contract in regards to the new home being said
Federal Government built home “free of charge”
Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein must
remain in home for at least 3 years.
Request
Number 82.
Admitting
Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein “you” from
the time frame of March 14th 2008 1:48 pm hour while your acting
attorney of record and 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 said acting attorney of record and all defense derive thereafter in
2010 (April) 30th for the legal behalf of the Co-Defendant(s) Defendant
“Joyce M. Guy and Edward McCray” collectively herein
U.S.
Docket No. 1:10-CV-00055 against the Pro Se Plaintiff Louis Charles Hamilton II
herein You fully legally intent continual in the usage of the “United States
Postal System” in a “Mail and Wire Fraud” scheme of things defense against “The
United States District Court For The Eastern Division of Texas Beaumont
Division” in December 3rd 2014 and all defense derive thereafter December
3rd 2014 Before the
Honorable
U.S. Magistrate Judge Zack Hawthorn U.S.
Docket No. 1:14-CV-00592 against the Pro Se Plaintiff Louis Charles Hamilton II
herein withholding “subject matter” the
old home being “physical material evidence” in said suit in common law in the
58th Judicial District Court of
Jefferson County Texas docket No. A-180805 since November 26th 2007
with Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein is said
old home; dwelling is fully legally forever destroyed by
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 83.
Admit
Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein that you
were fully aware on or after March 14th 2008, Pro Se Plaintiff
herein request Pursuant to Texas rule of civil procedure 196 Pro Se Plaintiff
Discovery request for Production of Documents, Namely “Property Deeds”
You
Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein fully
legally intent continual in the usage of the “United States Postal System” in a
“Mail and Wire Fraud” scheme of things defense against “The United States
District Court For The Eastern Division of Texas, Beaumont Division” in December
3rd 2014 and all defense derive thereafter December 3rd
2014 Before the
Honorable
U.S. Magistrate Judge Zack Hawthorn U.S. Docket No. 1:14-CV-00592 against the
Pro Se Plaintiff Louis Charles Hamilton II herein in withholding same “subject
matter” of the production of said Co-Defendant(s) Joyce M. Guy and Edward
McCray herein collective “Property Deeds” ” in a continual time frame dates of
now year of 2015
“Mail
and Wire Fraud” scheme of things to continual concealed, obstructed, kept secret,
tuck away, hidden, scuttle for the legal behalf of the Co-Defendant(s) “Joyce
M. Guy and Edward McCray” collectively herein produced copies of said required
“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 as
described in Pro Se Plaintiff attached document # 14 “General Warranty Deed” of
the Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein well beyond
things to continual concealed, obstructed, kept secret, tuck away, hidden,
scuttle for the legal behalf of the Co-Defendant(s) “Joyce M. Guy and Edward
McCray” collectively herein into future dates of June 30th of 2015 in
this U.S. Docket No. 1:14-CV-00592 ” in a “Mail and Wire Fraud” scheme of
things to continual concealed, obstructed, kept secret, tuck away, hidden,
scuttle for the legal behalf of the
Co-Defendant(s)
“Joyce M. Guy and Edward McCray” collectively herein hidden copies of said
required “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 as
described in Pro Se Plaintiff attached document # 14 “General Warranty Deed” of
the Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein this
continual
“Mail and Wire Fraud” scheme of things defense
against “The United States District Court For The Eastern Division of Texas, Beaumont
Division” in December 3rd 2014 and all defense derive thereafter December
3rd 2014 Before the Honorable U.S. Magistrate Judge Zack Hawthorn.
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