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 95.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein Pro Se Plaintiff attached Document # 15 herein is that legally being “Affidavit” of Co-Defendant “Joyce M. Guy” herein this U.S. Docket No. 1:14-CV-00592

Request Number 96.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein Pro Se Plaintiff attached Document # 15 herein is that legally being “Affidavit” of Co-Defendant “Joyce M. Guy” herein was “Subscribed and Sworn on the 11^th Day of September 2009 before a Notary Public.

Request Number 97.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein Pro Se Plaintiff attached Document # 15 herein is that legally being “Affidavit” of Co-Defendant “Joyce M. Guy” herein Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein fully legally engaged in the usage of the

 “United States Postal System” a true and correct copy of Pro Se Plaintiff attached Document # 15 herein is that legally being “Affidavit” of Co-Defendant “Joyce M. Guy” was served by certified mail, return receipt requested on Louis Charles Hamilton II at P.O. Box 342, Port Arthur, Texas 77640 on the 11^th Day of September 2009.

Request Number 98.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein Pro Se Plaintiff attached Document # 15 herein is that legally being “Affidavit” of Co-Defendant “Joyce M. Guy” herein states: Mr. Freeman informed me between April 2^nd 2008 and April 11^th 2008 about Mr. Hamilton discovery request.

 It was my decision and not Mr. Freeman’s decision not to respond to the discovery request of Mr. Hamilton. “Further affiant sayeth not.”

Request Number 99.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein Pro Se Plaintiff attached Document # 15 herein states between April 2^nd 2008 and April 11^th 2008 “you” Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein fully aware and in agreement with Co-Defendant “Joyce M. Guy” herein from the time frame of April 2^nd 2008 and April 11^th 2008 throughout October 13^th 2009 not to respond to the discovery request of Pro Se Plaintiff “Louis Charles Hamilton II”, herein “you” Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein having such “firsthand “ knowledge,  acceptances, possession, custody and control of said discovery request on

March 14^th 2008 1:48 pm hour while your acting attorney of record in civil suit in common law Docket No. A-180805 58^th Judicial District Court of Jefferson County Texas and Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein 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) 30^th to be exact said acting “attorney of record” and all defense derive thereafter in 2010 (April) 30^th 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.

Request Number 100.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein Pro Se Plaintiff attached Document # 15 herein states between April 2^nd 2008 and April 11^th 2008 “you” Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein fully aware and in agreement with Co-Defendant “Joyce M. Guy” herein from the time frame of April 2^nd 2008 and April 11^th 2008 throughout October 13^th 2009 not to respond to the discovery request of Pro Se Plaintiff “Louis Charles Hamilton II”, herein “you”

Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein refused to inform the Honorable Bob Wortham, of the 58^th Judicial District Court of Jefferson County Texas in Civil Suit in Common Law Docket No. A-180805

“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 any and all of the required discovery request of Pro Se Plaintiff “Louis Charles Hamilton II”, herein.

Request Number 101.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein Pro Se Plaintiff attached Document # 15 herein states between April 2^nd 2008 and April 11^th 2008 “you” Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein fully aware and in agreement with Co-Defendant “Joyce M. Guy” herein from the time frame of April 2^nd 2008 and April 11^th 2008 throughout October 13^th 2009 not to respond to the discovery request of Pro Se Plaintiff “Louis Charles Hamilton II”, herein “you”

Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein refused to inform the Pro Se Plaintiff “Louis Charles Hamilton II herein in Civil Suit in Common Law Docket No. A-180805

“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 any and all of the required discovery request of Pro Se Plaintiff “Louis Charles Hamilton II”, herein.

 And you Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein made such Knowledge being legally know in fully legally engaged in the usage of the “United States Postal System” on the 11^th day of September 2009 to the Pro Se Plaintiff, and the Honorable Bob Wortham, of the 58^th Judicial District Court of Jefferson County Texas in Civil Suit in Common Law Docket No. A-180805  “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.

Request Number 102.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein 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 “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 April 2^nd 2009 and April 11^th 2009 being one exact year file an immediate Motion for with Drawl as Acting attorney of record for the behalf of the Co-Defendant(s) “Joyce M. Guy and Edward McCray”

Request Number 102.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein 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

“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 for the behalf of the Co-Defendant(s) “Joyce M. Guy and Edward McCray” after “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.

Request Number 103.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein 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” herein while “you” Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein having such “firsthand “ knowledge, acceptances, possession, custody and control of said discovery request on

March 14^th 2008 1:48 pm hour while your acting attorney of record in civil suit in common law Docket No. A-180805 58^th Judicial District Court of Jefferson County Texas 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 “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 files an immediate Motion for with Drawl as acting attorney of record for the behalf of the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein

Said Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively on June 9^th 2009 as showing  document #1 attached herein having already engaged in the transfer of said 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 is also involved in a civil suit in common law in the

 58^th Judicial District Court of Jefferson County Texas docket No. A-180805 since November 26^th 2007 with Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein connection 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” after “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 ever responding in any “fashion or form” from the time frame of April 2^nd 2008 and April 11^th 2008 throughout November 12^th 2009