Tuesday, March 17, 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 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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