Sunday, March 22, 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 115.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein and his counsel of record  before responding to each and every request for admission having fully examine the 58th Judicial District Court of Jefferson County Texas Civil Action for Docket No. A-180805

Namely all records, court documents, and exhibit(s) in its entirety before respond to Pro Se Plaintiff Louis Charles Hamilton II herein propounding party 2015 Request for Admission, Set (1)

Request Number 116.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein and his counsel of record  before responding to each and every “Request for Admission” having fully examine the 58th Judicial District Court of Jefferson County Texas Civil Action for Docket No. A-180805

Namely all records, court documents, and exhibit(s) in its entirety before respond to Pro Se Plaintiff Louis Charles Hamilton II herein propounding party 2015 Request for Admission, Set (2)

Request Number 117.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein and his counsel of record before responding to each and every “Request for Admission” having fully examine each and every attached records, court documents, and exhibit(s) filed by Pro Se Plaintiff Louis Charles Hamilton II herein propounding party 2015 Request for Admission, set (1) in its entirety.

Request Number 118.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein and his counsel of record before responding to each and every “Request for Admission”

Having fully examine each and every attached records, court documents, and exhibit(s) filed by Pro Se Plaintiff Louis Charles Hamilton II herein propounding party 2015 Request for Admission, set (2) in its entirety.

Request Number 119.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein and his counsel of record before responding to each and every “Request for Admission”

Having fully examine Chapter 96 of Title 18, United State Code: (RICO) Racketeering Influences Corruption Organization, Title 18 U.S.C. § 1341, 1343

 And 1349 “Mail and Wire Fraud”, section 1028(relating to fraud and related activity in connection with identification documents),

Section 1503(relating to obstruction of justice) as it relate in connection with the Pro Se Plaintiff “Louis Charles Hamilton II, Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, and Co-Defendant(s) Joyce M. Guy and Edward McCray herein all Complaints, records, affidavits, court records, transcripts, files and documents, described legally fully herein Request for Admission, set (1) and Request for Admission set (2) in its entirety.

Request Number 120.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein and his counsel of record before responding to each and every “Request for Admission” Having fully examine Computer Fraud and Abuse Act (CFAA) 18 U.S.C. § 1030

As it relate in connection with the Pro Se Plaintiff “Louis Charles Hamilton II, Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, and Co-Defendant(s) Joyce M. Guy and Edward McCray herein all Complaints, records, affidavits, court records, transcripts, files and documents, described legally fully herein Request for Admission, set (1) and Request for Admission set (2) in its entirety.

Request Number 121.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein and his counsel of record before responding to each and every “Request for Admission”

Having fully examine Amendment VII of the United States of America as it relate in connection with the Pro Se Plaintiff “Louis Charles Hamilton II, Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, and Co-Defendant(s) Joyce M. Guy and Edward McCray herein

 All Complaints, records, affidavits, court records, transcripts, files and documents,  described legally fully herein Request for Admission, set (1) and Request for Admission set (2) in its entirety.

Request Number 122.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein and his counsel of record before responding to each and every “Request for Admission” Having fully examine The Constitution of the State of Texas,

Article 16: "General Provisions" Section 37 provides for the constitutional protection of the mechanic's lien.

Section 50 provides for protection of a homestead against forced sale to pay debts, except for foreclosure on debts related to the homestead (mortgage, taxes, mechanic's liens, and home equity loans).

As it relate in connection with the Pro Se Plaintiff “Louis Charles Hamilton II, Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, and Co-Defendant(s) Joyce M. Guy and Edward McCray herein

 All Complaints, records, affidavits, court records, transcripts, files and documents,  described legally fully herein Request for Admission, set (1) and Request for Admission set (2) in its entirety.

Request Number 123.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein and his counsel of record before responding to each and every “Request for Admission” Having fully examine  18 U.S.C. § 1001 : US Code - Section 1001: Statements or entries generally

(a) Except as otherwise provided in this section, whoever, in any matter within the jurisdiction of the executive, legislative, or judicial branch of the Government of the United States,

Knowingly and willfully - (1) falsifies, conceals, or covers up by any trick, scheme, or device a material fact;

        (2) Makes any materially false, fictitious, or fraudulent statement or representation; or

       (3) Makes or uses any false writing or document knowing the same to contain any materially false, fictitious, or fraudulent statement or entry;

As it relate in connection with the Pro Se Plaintiff “Louis Charles Hamilton II, Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, and Co-Defendant(s) Joyce M. Guy and Edward McCray herein

 All Complaints, records, affidavits, court records, transcripts, files and documents,  described legally fully herein Request for Admission, set (1) and Request for Admission set (2) in its entirety.

Request Number 124.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein and his counsel of record before responding to each and every “Request for Admission” Having fully examine U.S. Code: Title 28:1343

As it relate in connection with the Pro Se Plaintiff “Louis Charles Hamilton II, Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, and Co-Defendant(s) Joyce M. Guy and Edward McCray herein

 All Complaints, records, affidavits, court records, transcripts, files and documents,  described legally fully herein Request for Admission, set (1) and Request for Admission set (2) in its entirety.

Request Number 125.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein and his counsel of record before responding to each and every “Request for Admission” Having fully examined Texas Rules of Civil Procedures 194.2, 196, 197, and 198,

As it relate in connection with the Pro Se Plaintiff “Louis Charles Hamilton II, Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, and Co-Defendant(s) Joyce M. Guy and Edward McCray herein

 All Complaints, records, affidavits, court records, transcripts, files and documents,  described legally fully herein Request for Admission, set (1) and Request for Admission set (2) in its entirety.

Request Number 126.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein and his counsel of record before responding to each and every “Request for Admission” Having fully examined Texas Rules of Civil Procedures “Subpoena”

As it relate in connection with the Pro Se Plaintiff “Louis Charles Hamilton II, Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, and Co-Defendant(s) Joyce M. Guy and Edward McCray herein

 All Complaints, records, affidavits, court records, transcripts, files and documents,  described legally fully herein Request for Admission, set (1) and Request for Admission set (2) in its entirety.

Request Number 127.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein and his counsel of record before responding to each and every “Request for Admission” Having fully examined Texas Rules of Civil Procedures 10 “Withdrawal of Attorney”

As it relate in connection with the Pro Se Plaintiff “Louis Charles Hamilton II, Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, and Co-Defendant(s) Joyce M. Guy and Edward McCray herein

 All Complaints, records, affidavits, court records, transcripts, files and documents,  described legally fully herein Request for Admission, set (1) and Request for Admission set (2) in its entirety.

Request Number 128.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein and his counsel of record before responding to each and every “Request for Admission” Having fully examined Texas Disciplinary Rules of Professional Conduct, Particularly 8.04

As it relate in connection with the Pro Se Plaintiff “Louis Charles Hamilton II, Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, and Co-Defendant(s) Joyce M. Guy and Edward McCray herein

 All Complaints, records, affidavits, court records, transcripts, files and documents,  described legally fully herein Request for Admission, set (1) and Request for Admission set (2) in its entirety.

Request Number 129.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein and his counsel of record that “Antoine L. Freeman J.D. is an active “Attorney” in and for the State of Texas and this is his correct “Attorney at Law” Bar No. 24058299 in that further admitting “Antoine L. Freeman J.D. is described as a Defendant in U.S. Cause No. 1:14-CV-592

Request Number 130.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein and his counsel of record that said Request for Admission, set (1) and Request for Admission set (2) in its entirety fully free from, fraudulent, fictitious, false, misleading material facts, in all “Subject Matter” described legally therein which are materially pertinent to Pro Plaintiff “Louis Charles Hamilton II” herein claims hereto in accordance with Rule 36,


Under which rule of federal procedure this request for admissions is made, thereby answering all of the described legally fully herein Request for Admission, set (1) and Request for Admission set (2) in its entirety facts in the above-entitled and number cause, and that such answers be sworn to and filed promptly in the office of the District Clerk .

Request Number 131.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein and his counsel of record that “Antoine L. Freeman J.D. is an active “Attorney” in and for the State of Texas and this is his correct “Attorney at Law” Bar No. 24058299 in that further admitting

 “Antoine L. Freeman J.D. is described as a Defendant in U.S. Cause No. 1:14-CV-592 and pursuant to Request for Admission set (two) at Request Number (127)

Said Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein after having fully examined Texas Rules of Civil Procedures 10 “Withdrawal of Attorney”

Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein furtherance’s admitting he was in fact “attorney of record” for Co-Defendant(s) Joyce M. Guy and Edward McCray” collectively from the exact time frame of December 18th 2007 throughout December 11th 2009 when

 “Honorable Judge Bob Wortham” of the 58th Judicial District Court of Jefferson County Texas fully granted said Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein “Motion for “Withdrawal of Attorney” in Docket No. A-180805 on December 11th 2009

 


Dated on this ______ Day of ________________ 2015

 

By, _______________________________

     Louis Charles Hamilton II

     Pro Se Plaintiff

      P.O. Box 17524

     Sugar Land Texas 77496

 

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