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 11.

Admit that you Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein refusal to respond to all of the Pro Se Plaintiff discovery request your having in your legal, possession, custody and control mailed to you since the exact time date of March 14^th 2008 –

And such Pro Se Plaintiff discovery request in your legal, possession, custody and control throughout September 11^th 2009 hearing date as your in continual refusal to reply/response to said discovery request

To provided actual “obstruction of justice” cover up legal services before the 58^th Judicial District of Jefferson County Texas “Honorable Bob Wortham” for conspire in “Falsification of all “Material facts” and Subject matter that Co-Defendant “Joyce M. Guy” and Edward McCray” collectively on June 9^th 2009  when document #1 attached herein 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 which you Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein furtherance admitting “Your” legally having Pro Se Plaintiff request for said production of document for “property deeds” for the For the property located at 448Dequeen Blvd. in Port Arthur Texas 77640

 Which you Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein was acting legal counsel on behalf of for Co-Defendant(s) Joyce M. Guy and Edward McCray in your (3) combine continual refusal to produce said “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

From the exact date of March 14^th 2008 throughout March 30^th 2015

On or before an upcoming evidentiary hearing held on March 30^th at 10:00 a.m. before

“Honorable Justice” United States Magistrate Judge Zack Hawthorn at the Jack Brooks Federal Building, Beaumont Texas

 In which said “Property Deeds” still outstanding in said production having never been having been produce, and filed in Civil Suit in Common Law in the 58^th Judicial District Court of Jefferson County Texas. Even after “Court Orders” being obtain in such a production.

Request Number 12.

Admit that you Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein was acting legal counsel on behalf of for Co-Defendant(s) Joyce M. Guy and Edward McCray in your

 (3) Combine continual refusal to produce said “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

From the exact date of March 14^th 2008 throughout November 13^th 2009

 Request Number 13.

Admit that you Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein Admit that you Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein was acting legal counsel on behalf of for Co-Defendant(s) Joyce M. Guy and Edward McCray in your

(3) Combine continual refusal to produce said “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

From the exact date of March 14^th 2008 throughout February 19^th 2015 9:00 am which a hearing was held for “Contempt of Court” of the 58^th Judicial District Court of Jefferson County Texas for said production of

 “Property deeds”, among other documents being refusal in this continual obstruction of justice and hiding, obscuring, and failing to produce said “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 which is subject matter in civil suit in common law A-180805

 Request Number 14.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein that request for admission question (7) and (11) above combine having a monetary value in Connection with

United States Department of Housing and Urban Development TDHCA Federal Award

Federally Declared Disaster Funding in further connection directly with the “Texas Department of Housing and Community affairs” in excess of $127,339.31 U.S. Dollars.