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 41.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein that the said Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein having a “Mechanic’s LIEN Contract” filed on June 9^th 2009 with 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 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 58^th Judicial District Court of Jefferson County Texas since November 26^th 2007 before said “Mechanic’s LIEN Contract” filed on June 9^th 2009 with SWMJ Construction Inc., was established, posted, date mark, and executed against 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.

Request Number 42.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein that the said Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein having a “Mechanic’s LIEN Contract” filed on June 9^th 2009 with 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 in Connection with “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

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 58^th Judicial District Court of Jefferson County Texas since

 November 26^th 2007 before said “Mechanic’s LIEN Contract” filed on June 9^th 2009 with SWMJ Construction Inc., was established, posted, date mark, and executed against 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.

Request Number 43.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein that the said Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein having a “Mechanic’s LIEN Contract” filed on June 9^th 2009 with 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 in Connection with Federally Declared Disaster Funding under Department of Defense Appropriations Act, 2006 CDBG Disaster Recovery Program (Homeowner Assistance Program “HAP”)

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 58^th Judicial District Court of Jefferson County Texas since

 November 26^th 2007 before said “Mechanic’s LIEN Contract” filed on June 9^th 2009 with SWMJ Construction Inc., was established, posted, date mark, and executed against 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.

Request Number 44.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein that the said Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein having a “Mechanic’s LIEN Contract” filed on June 9^th 2009 with 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 in Connection with

Federally Declared Disaster Funding under Department of Defense Appropriations Act, 2006 CDBG Disaster Recovery Program (Homeowner Assistance Program “HAP”)

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 58^th Judicial District Court of Jefferson County Texas since

 November 26^th 2007 before said “Mechanic’s LIEN Contract” filed on June 9^th 2009 with SWMJ Construction Inc., was established, posted, date mark, and executed against 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.

Request Number 45.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein that the said Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein having a “Mechanic’s LIEN Contract” filed on June 9^th 2009 with 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 in Connection with (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 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 since

 November 26^th 2007 before said “Mechanic’s LIEN Contract” filed on June 9^th 2009 with SWMJ Construction Inc., was established, posted, date mark, and executed against 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.