Monday, March 16, 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 61.

Admitting Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein that you were fully aware on March 14th 2008, Pro Se Plaintiff herein request production of copies of property deeds 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 is also involved in a civil suit in common law in the 58th Judicial District Court of Jefferson County Texas docket No. A-180805 since

 November 26th 2007 as such request production of copies of property deeds as being legally described in Pro Se Plaintiff attached document # 12 Namely Plaintiff Motion for Production of Document(s) filed in the District Court of Jefferson County Texas “time stamp” March 14th 2008 1:48 pm hour.

And Co- Defendant “Joyce M. Guy” and “Edward McCray” herein collectively having not filed Pro Se Plaintiff attached document # 14

Namely “General Warranty Deed” 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 deeds for dwelling and Property located at 448 DeQueen Blvd. in Port Arthur Texas

Request Number 62.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein filed Pro Se Plaintiff attached document # 14

Namely “General Warranty Deed” 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 deeds” for dwelling and Property located at 448 DeQueen Blvd. in Port Arthur Texas that you were fully aware on March 14th 2008, Pro Se Plaintiff herein request production of copies of said “property deeds” 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 is also involved in a civil suit in common law in the

 58th Judicial District Court of Jefferson County Texas docket No. A-180805 since

 November 26th 2007 as such request production of copies of property deeds as being legally described in Pro Se Plaintiff attached document # 12 Namely Plaintiff Motion for Production of Document(s) filed in the District Court of Jefferson County Texas “time stamp” March 14th 2008 1:48 pm hour.

And you have not produce such copies of said “property deeds” between the dates of March 14th 2008 throughout October 14th 2009 as being described in Pro Se Plaintiff attached document # 14 Namely “General Warranty Deed” 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 deeds” for dwelling and Property located at 448 DeQueen Blvd. in Port Arthur Texas.

Request Number 63.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein filed Pro Se Plaintiff attached document # 14

Namely “General Warranty Deed” 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 deeds” for dwelling and Property located at 448 DeQueen Blvd. in Port Arthur Texas that you were fully aware on March 14th 2008, throughout June 9th 2009 when document #1 attached herein was filed with the Jefferson County Texas Clerk office

namely “Mechanic’s LIEN Contract filed on June 9th 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 58th 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.

Request Number 64.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein filed Pro Se Plaintiff attached document # 14

Namely “General Warranty Deed” 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 deeds” for dwelling and Property located at 448 DeQueen Blvd. in Port Arthur Texas was kept secret, concealed, hidden, tuck away, put out of sight, throughout June 9th 2009 by “you” Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, for the legal collective behalf of the Co-Defendant(s) “Joyce M. Guy and Edward McCray” providing “General Warranty Deed” protection against the Pro Se Plaintiff civil suit in common law “civil rights” of “Texas Constitution Article 16 Section 37 “Protection of Mechanic’s Lien” and Section 50 therein

Admitting furtherance’s when document #1 attached herein was transfer and legally filed with the Jefferson County Texas Clerk office

namely “Mechanic’s LIEN Contract filed on June 9th 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 58th 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.

Request Number 65.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein is in direct Violations of 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), and

Section 1503(relating to obstruction of justice) in connection with the Pro Se Plaintiff and all records, affidavits, court records, transcripts, files and documents,  as described legally fully herein from March 14th 2008 1:48 pm hour

Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein kept secret, concealed, hidden, tuck away, fully put out of sight, throughout June 9th 2009 by “you” Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, for the legal collective behalf of the Co-Defendant(s) “Joyce M. Guy and Edward McCray” providing

“General Warranty Deed” protection against the Pro Se Plaintiff civil suit in common law “civil rights” of “Texas Constitution Article 16 Section 37 “Protection of Mechanic’s Lien” and Section 50 therein Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein have not produce such copies of said “property deeds” between the dates of March 14th 2008 throughout October 14th 2009.

Request Number 66.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein March 14th 2008 1:48 pm hour while your acting attorney of record throughout June 9th 2009 is approximately (1) year, (2) Months and (23) days Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein is in direct Violations of Chapter 96 of Title 18, United State Code: (RICO) Racketeering Influences Corruption Organization, Section 1503(relating to obstruction of justice) in connection with the Pro Se Plaintiff on March 14th 2008 1:48 pm hour, Pro Se Plaintiff Louis Charles Hamilton II herein request production of copies of said “property deeds” from

Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, 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 is also involved in a civil suit in common law in the

 58th Judicial District Court of Jefferson County Texas docket No. A-180805 since November 26th 2007 with Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein.

Request Number 66.

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:  (11)

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.

Request Number 67.

Admitting Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein “you” from the time frame of March 14th 2008 1:48 pm hour while your acting attorney of record and continual being said acting attorney of record 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) 30th to be exact and all defense derive thereafter in 2010 (April) 30th

throughout April 22nd 2014 is approximately the time frame Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein conspire in ‘obstruction of justice” with Co- Defendant “Joyce M. Guy and Edward McCray” collectively herein admitting to continual kept secret, concealed, hidden, tuck away, fully put out of sight, Pro Se Plaintiff attached document # 14

Namely “General Warranty Deed” 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 deeds” for dwelling and Property located at 448 DeQueen Blvd. in Port Arthur Texas in order that the Co- Defendant “Joyce M. Guy and Edward McCray” collectively herein fully comply under all the terms and conditions of any contract in regards to the new home being said

 Federal Government built home “free of charge” Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein must remain in home for at least 3 years while furtherance’s admitting the old home being “physical material evidence in said suit in common law in the

 58th Judicial District Court of Jefferson County Texas docket No. A-180805 since November 26th 2007 with Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein fully forever destroyed.

 

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