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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