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 104.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein “All Subcontractors and material suppliers must serve the “property owner and the General Contractor with a Pre0Lien Notice by no later than the 15^th day of the second month from each and every month that you namely “Subcontractors” provide labor and /or materials to the property and have not been paid.

Request Number 105.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein “All Subcontractors” must serve the notice contractual retainage, if your contract with the Contractor who hire you allows them to withhold a percentage of monthly progress payments as contractual retainage

 (Typically 5% to 10 % of the overall Contract amount, then you “All Subcontractors” must serve the property owner and the General Contractor with the notice of contractual retainage by the earlier of: (1) 30 days from completion of your work; or (2) with 30 days from completion of the entire project, whichever comes first.

Request Number 106.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein this is a Mandatory Pre Lien Notice which must be served before you “All Subcontractors” can file a Lien for withheld unpaid retainage.

Request Number 107.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein “Further affiant” “Joyce M. Guy” your retain client at some point in time and namely Co-Defendant “Joyce M. Guy” herein clearly enter into a contract with Pro Se “Louis Charles Hamilton II” herein for a amount of $10,800.00 collectively with Co-Defendant “Edward McCray” 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 which said dwelling, property located at 448 DeQueen Blvd. in Port Arthur Texas 77640 and you having view said contract since December 18^th 2007 throughout March 30^th 2015 as also being attached herein as Pro Se Plaintiff document # 16 “Construction Contract” dated November 5^th 2007

Request Number 108.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein Pro Se Plaintiff “Louis Charles Hamilton II” herein was not a Subcontractors as described in paragraph 104, 105, and 106 above.

Request Number 109.

 

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein Pro Se “Louis Charles Hamilton II” herein was the “General Contractor” “Further affiant” “Joyce M. Guy” your retain client at some point in time and namely Co-Defendant “Joyce M. Guy” herein clearly enter into a contract with Pro Se for a amount of $10,800.00 collectively with Co-Defendant “Edward McCray” 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 which said dwelling, property located at 448 DeQueen Blvd. in Port Arthur Texas 77640 and you having view said contract since December 18^th 2007 throughout March 30^th 2015 as also being attached herein as Pro Se Plaintiff document # 16 “Construction Contract” dated November 5^th 2007 with “Further affiant” “Joyce M. Guy” your retain client at some point in time and namely Co-Defendant “Joyce M. Guy” herein signature on said contract.

Request Number 110.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein Pro Se “Louis Charles Hamilton II” herein was the “General Contractor” and arrange building material from suppliers to namely Co-Defendant “Joyce M. Guy” and “Edward McCray” herein 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 which said dwelling, property located at 448 DeQueen Blvd. in Port Arthur Texas 77640.

Request Number 111.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein Parker Lumber-Port Arthur Texas 2948 Gulfway Drive 77642 (409) 983-2745 was the “material suppliers” in connection with  Pro Se “Louis Charles Hamilton II” herein the “General Contractor” whom arrange building material from said suppliers on the behalf of namely Co-Defendant “Joyce M. Guy” and “Edward McCray” herein 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 which said dwelling, property located at 448 DeQueen Blvd. in Port Arthur Texas 77640

After your expert legal Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein viewing of Pro Se Plaintiff attached Document # 17 “Namely” Parker Lumber “Estimates and Invoice for $2869.08 from said “material suppliers” dated on the 22^nd day of October 2007

Request Number 112.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein all monetary funding as being, depicted, described and set forth in paragraphs 104 throughout 111 herein 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 which said dwelling, property located at 448 DeQueen Blvd. in Port Arthur Texas 77640 was paid out from private homeowner insurance company in connection with “Hurricane Humberto” causing damages to the dwelling of Co-Defendant “Joyce M. Guy” and “Edward McCray” herein 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 which said dwelling, property located at 448 DeQueen Blvd. in Port Arthur Texas 77640

Request Number 113.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein under the terms and condition of said construction contract of Co-Defendant “Joyce M. Guy” agreed to put an advance of $3616 down on all materials as Pro Se Plaintiff document # 16 “Construction Contract” dated November 5^th 2007 fully describing such.

Request Number 114.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein Co-Defendant “Joyce M. Guy” only put down $2869.08 on all materials as Pro Se Plaintiff document # 17 “Namely” Parker Lumber “Estimates and Invoice for $2869.08 from said “material suppliers” dated on the 22^nd day of October 2007.

Request Number 115.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein “Further affiant” “Joyce M. Guy” became your retain client at some point in time and namely Co-Defendant “Joyce M. Guy” herein clearly enter into a contract with Pro Se “Louis Charles Hamilton II” herein for a amount of $10,800.00 collectively with Co-Defendant “Edward McCray” 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 which said dwelling, property located at 448 DeQueen Blvd. in Port Arthur Texas 77640 and you having view said contract since December 18^th 2007 throughout March 30^th 2015

As also being attached herein as Pro Se Plaintiff document # 16 “Construction Contract” dated November 5^th 2007 and Pro Se Plaintiff alleges a Breach of said contract in the 58^th Judicial District Court of Jefferson County Texas, you Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein became attorney of record from the time frame of December 18^th 2007 when you file a

 “General Denial” (only) as claimed by you, further you, conspire, hidden, scuttled, obstructed, conceal, keep secrete, tuck away, between the dates of March 14^th 2008 1:48 pm hour throughout March 30^th 2015 among other discovery document primary “hidden, scuttled, obstructed, conceal, keep secrete, tuck away” namely the “property deeds” ” 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 which said dwelling, property located at 448 DeQueen Blvd. in Port Arthur Texas 77640 which is a party to this civil suit in common law in the 58^th Judicial District Court of Jefferson County Texas Docket No. A-180805 while from the time frame of March 14^th 2008 1:48 pm hour throughout December 11^th 2009 when finally the

 58^th Judicial District Court of Jefferson County Texas Judge Bob Wortham granted Your Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein “Motion for with Drawl of Counsel on December 11^th 2009 as described in Pro Se Plaintiff attached document # 2 herein 58^th Judicial District Court of Jefferson County Texas “Docket” A-180805 “You”

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 , Production of Documents, Interrogatories, Request of Admission, and Request for Disclosure in accordance with the Texas Rules of Civil Procedures 194.2, 196, 197, and 198,.

After “Your” claim Knowledge “Further affiant” “Joyce M. Guy” your retain client at some point in time and namely Co-Defendant “Joyce M. Guy” herein clearly will not be responding from the time frame of April 2^nd 2008 and April 11^th 2008 throughout October 13^th 2009 to Pro Se Plaintiff (Many) discovery requests to include the production of property deeds for the dwelling located at

 448 DeQueen Blvd. in Port Arthur Texas before the 58^th Judicial District Court of Jefferson County Texas in Civil Suit in Common Law Docket No. A-180805 while during this “Further affiant” “Joyce M. Guy” your retain client at some point in time and namely Co-Defendant “Joyce M. Guy” herein clearly will not be responding from the time frame of April 2^nd 2008 and April 11^th 2008 throughout October 13^th 2009 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 and

“You” Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein did not between the exact time frame of April 2^nd 2008 and April 11^th 2008 throughout November 12^th 2009 file an immediate

Motion for with Drawl as Acting attorney of record in before the 58^th Judicial District Court of Jefferson County Texas in Civil Suit in Common Law Docket No. A-180805 for the behalf of the Co-Defendant(s) “Joyce M. Guy and Edward McCray” as you’re Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein falsely claiming with fully legally intent continual in the usage of the

 “United States Postal System” in a “Mail and Wire Fraud” scheme of things defense herein in the continual usage of Co-Defendant(s) “Joyce M. Guy” “Subscribed and Sworn”, fraudulent, fictitious Affidavit in Support of Motion for Sanctions against “You” Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein as described in Pro Se Plaintiff attached Document # 15 “Affidavit of Joyce M. Guy” dated September 11^th 2009 in a continual time frame dates of now in the year of 2015 March 30^th to be exact in a continual

“Mail and Wire Fraud” scheme of things defense against “The United States District Court for the Eastern Division of Texas, Beaumont Division”

Before the Honorable U.S. Judge Marcia A. Crone and Honorable U.S. Magistrate Keith F. Giblin, in 2010 (April) 30^th in this continual (RICO) enterprise “Mail and Wire Fraud” scheme of things defense against the Pro Se Plaintiff personal property namely Construction Company Tools Listed as follows:

a.     Brand New Hitachi Air Compressor #2700009 $680.00

b.     Bosch Drill M# Brute S# NV $345.00

c.      “Portacable Skill saw $137.00

d.     Dewalt Sawall $97

e.     “Hitachi Nail Gun (Framing) $327.00

f.       “Hitachi Roofing Nailer $315.00

g.     Gas Power Generator $300.00

h.     Extension ladder $127.00

i.       100 ft. of air hose $95.

j.       50ft. of air hose $42.

k.     100ft. electric cord $70

l.       50ft. electric cord $38

m.  (4) Framing hammers $37. (each)

n.     “Pro Se Plaintiff “Personal Hammer” $48.

o.     “Leather tool belt” $50.

p.     Kobalt Razor Knife $17.

q.     Swanson pencil set & refills $22.

r.      “Black tool box & Respiratory $138.00

s.      “Extreme Safety Face Shield” $30

t.      Ear plugs (2) pack $16.

u.     (4) Normal face respirators with strap $12.

v.     Small assortment pliers set $35.

w.   (2) Tuck pointers $24.

x.     (1) Square mouth shovels $18.

y.     (1) set of blueprints $1200.00

z.      Gas container 15.

aa. Masonry trowel $18.

bb.            “Fatmax 35ft. tape measure $30.

cc.  Catspaw nail puller $12.

dd.            Speed square $8.

ee.             Contractor Calculator $34.

ff.    Crowbar $17.

gg. Utility knife (3) $9.  (Each)

hh.            Nail Punch $8.

ii.     Maxx Gloves $34.

jj.     Canvas Tarp 95ft. X 180ft. $100.00

kk. Roofing shovels (2) $48. (Each)

ll.     Saw blades with drill bits $24.

mm.       (2) Speed square (Plastic) $5.  (Each)

nn.            25ft. “Fatmaxx tape measure $19.00

oo.            3-way air hose fitting set $38.

pp.            Case of Gatorade $12.

qq.            Residential framing book $21.

rr.   (2) Paint brushes $14. (Each)

ss.  (1) Paint scraper $14.

tt.   (1) Paint scraper wire handle $10.

To include Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein continual engaging in a “Mail and Wire Fraud” scheme of things defense to deprive Pro Se Plaintiff in “Actual damages” of namely $336,000.00 U.S. Dollars in “loss wages” and “Loss Earning capacity” from date of injury December 17^th 2007 – 2014 to include figure this computation well into 2015 this (RICO) enterprise scheme of things continue causing such loss of wages and loss of earning capacity at a loss rate of $48,000.00 per year with 6% interest incurred

 And further deprive Pro Se Plaintiff herein in “actual damages” in excess of $3800.00 U.S. dollars for Chief Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 herein conspire (RICO) enterprise in a continual “Mail and Wire Fraud” scheme of things defense in full conspiracy, plotting, collaboration, scheming, conspire, collusion, with Co-Defendant(s) “Joyce M. Guy and Edward McCray” and the actual theft of Pro Se Plaintiff personal property namely construction company tools, with 6% interest incurred

 To include but not limited to Chief Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 herein 100% foolishly admitting furtherance’s (Ready) to continual making the same 3 strikes (RICO) “representation and presentation” in a continual 2015 “Mail and Wire Fraud” scheme of things defense in full conspiracy, plotting, collaboration, scheming, conspire, collusion, with Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein collectively all (3) Defendants standing proudly now Before the

 United States Magistrate Honorable Judge Zack Hawthorn notwithstanding the outrageous fictitious, fraudulent response to Pro Se Plaintiff “Interrogatories” as described in document # 9 attached herein Chief Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 fully “admitting and saying” he namely Antoine L. Freeman J. D. Attorney at Law was never even acting “Attorney of record” from December 18^th 2007 throughout December 11^th 2009 only filed a simple “General Denial” (Only) in Texas State Court Docket No A-180805 …?