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 57.

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

Admitting Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein that Co- Defendant Joyce M. Guy” herein supply the following Answer to Pro Se Plaintiff Interrogatories Document # 9 attached herein pursuant to Rule 197 of the Texas Rules of Civil Procedures at Question: 10, 11, 12, 13, 14, 15, and 16.

10. Where is the Funding for the New Home?

Answer: Federal Grant

11. What are the terms and conditions of any contract in regards to the new home?

Answer: Federal Government built home free of charge Defendant must remain in home for at least 3 years.

12. What is the entire cost of the construction for the new home?

Answer: $76,000.00 U.S. Dollars

13. How is the city of Port Arthur Involved?

Answer: Not involved

14. How is the State of Texas Involved?

Answer: Not Involved

15. How is the Federal Government involved?

Answer: Federal Grant

16. How much money did the Co-Defendant actually paid for the new home construction?

Answer: No money paid by Co-Defendant

And furtherance admitting Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, you never even took the “simple time” to legally factually discovery and obtain from the Co-Defendant(s) “Joyce M. Guy and Edward McCray correct material facts as described by

Pro Se Plaintiff attached document #1 herein which was filed with the Jefferson County Texas Clerk office

namely “Mechanic’s LIEN Contract filed on June 9^th 2009 SWMJ Construction Inc., 525 N. Sam Houston Pkwy East, Suite 600, Houston, Texas 77060 in connection with a Housing Grant in excess of $72,500.00 U.S Dollars

“Texas Department of Housing and Community affairs” Loan No. 2727 File No. 1219-2102152 CFDA 14.228 Community Development Block Grant Program (“CDBG”) Hurricanes Katrina, Rita and Wilma in the Gulf of Mexico 2005

Federally Declared Disaster Funding under Department of Defense Appropriations Act, 2006 CDBG Disaster Recovery Program (Homeowner Assistance Program “HAP”)

Or (Sabine Pass Restoration Program “SPRP”) Awarding Federal Agency: United States Department of Housing and Urban Development TDHCA Federal Award Number: B-06-DG-48-0002 Federal Award Year (Year of Award from HUD to TDHCA): 2006 TDHCA Award Year: 2007

For the property located at 448Dequeen Blvd. in Port Arthur Texas 77640 which you was acting counsel for Co-Defendant(s) Joyce M. Guy and Edward McCray in a civil suit in the

58^th Judicial District Court of Jefferson County Texas docket No. A-180805 involving a breach of a $10,800 U.S. Dollars construction contract with the described Pro Se Plaintiff herein before Chief Defendant Antoine L. Freeman J. D. “Attorney at Law” herein filing false and fraudulent material facts concerning

Interrogatories pursuant to Rule 197 of the Texas Rules of Civil Procedures at Question:  12,

What is the entire cost of the construction for the new home?

Answer: $76,000.00 U.S. Dollars

Which the correct answer is $72,500.00 U.S Dollars as described in Pro Se Plaintiff attached document # 1 herein namely

“Mechanic’s LIEN Contract filed on June 9^th 2009 SWMJ Construction Inc., 525 N. Sam Houston Pkwy East, Suite 600, Houston, Texas 77060 in connection with a Housing Grant in excess of $72,500.00 U.S Dollars

“Texas Department of Housing and Community affairs” Loan No. 2727 File No. 1219-2102152 CFDA 14.228 Community Development Block Grant Program (“CDBG”) Hurricanes Katrina, Rita and Wilma in the Gulf of Mexico 2005

Furtherance Before you Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, furtherance filing additional “false and fraudulent material facts” concerning Interrogatories pursuant to Rule 197 of the Texas Rules of Civil Procedures at Question:  14.

How is the State of Texas Involved?

Answer: Not Involved

Which the correct answer is

 “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 is involved

 As described “legally” in Pro Se Plaintiff attached document # 1 herein namely

“Mechanic’s LIEN Contract filed on June 9^th 2009 SWMJ Construction Inc., 525 N. Sam Houston Pkwy East, Suite 600, Houston, Texas 77060 in connection with a Housing Grant in excess of $72,500.00 U.S Dollars

“Texas Department of Housing and Community affairs” Loan No. 2727 File No. 1219-2102152 CFDA 14.228 Community Development Block Grant Program (“CDBG”) Hurricanes Katrina, Rita and Wilma in the Gulf of Mexico 2005.