Friday, March 13, 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 31.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein being in full possession, custody and legal control over said Pro Se Plaintiff discovery request for “interrogatories” herein filed as Pro Se Plaintiff attached Document # 9 Defendant(s) response to “Interrogatories” dated October 14th, 2009 in “Your” physical possession between the actual dates of March 14th 2008 throughout the Dates of October 14th, 2009 and your admitting furtherance

Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein in defense after your retain counsel of record  filed Defendant’s Collective Original Answer again in U.S. District Court for the District of Texas, Beaumont Division Jefferson County, Texas U.S. Docket No. 1:10-CV-00055 against the Pro Se Plaintiff Louis Charles Hamilton II herein and “you” Antoine L. Freeman J. D. “Attorney at Law”, being Defendant (also) in U.S. District Court for the District of Texas, Beaumont Division Jefferson County, Texas U.S. Docket No. 1:10-CV-00055

Before the Honorable U.S. Judge Marcia A. Crone and Honorable U.S. Magistrate Keith F. Giblin

Admitting furtherance Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein against penalty of perjury Before the Honorable U.S. Judge Marcia A. Crone and Honorable U.S. Magistrate Keith F. Giblin

Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein admitting when question (12) was asked “what is the entire cost of the construction for the new home..? And you Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein and on behalf of Co-Defendant(s) collectively supply the responded of $76,000

Admitting you are continual making the same “representation and presentation” Before the Honorable U.S. Judge Marcia A. Crone and Honorable U.S. Magistrate Keith F. Giblin of the Question under Federal Rules of Civil Procedure in Your Answer to Interrogatories herein (now) to still be that of the false and fraudulent statement response of $76,000 in comparison to Pro Se Plaintiff attached official document # 1 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 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 Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein engaged in the destruction of “physical evidence” of an entire home which was completely destroyed being on

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 is the primary “physical evidence” and “physical address” of said Co-Defendant(s) collectively herein and furtherance’s admitting said

Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein refusal to produce to the Pro Se Plaintiff copies of said required “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 while you’re still acting “attorney of record” between the actual dates of December 18th 2007- November 13th 2009 10:22 am and continual admitting Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein said Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein

Continual between the date of November 13th 2009 10:22 am throughout March 30th 2015 refusal to produce 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 into civil suit in common law files before the Jefferson County Texas 58th Judicial District Court even after the 58th Judicial District Court (Order) as described in Pro Se Plaintiff attached Document # 5 herein Order of the 58th Judicial District Court Cause No. A-180805 dated May 10th 2010

Said Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein in the production of said “property deeds” to the dwelling located at 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.

Request Number 32.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein being in full possession, custody and legal control over said Pro Se Plaintiff discovery request for “interrogatories” herein filed as Pro Se Plaintiff attached Document # 9 Defendant(s) response to “Interrogatories” dated October 14th, 2009 in “Your” physical possession between the actual dates of March 14th 2008 throughout the Dates of October 14th, 2009 and your admitting furtherance

Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein in defense after your retain counsel of record filed Defendant’s Collective Original Answer again in

 U.S. District Court for the District of Texas, Beaumont Division Jefferson County, Texas U.S. Docket No. 1:10-CV-00055 against the Pro Se Plaintiff Louis Charles Hamilton II herein and “you” Antoine L. Freeman J. D. “Attorney at Law”, being Defendant (also) in U.S. District Court for the District of Texas, Beaumont Division Jefferson County, Texas U.S. Docket No. 1:10-CV-00055

Before the Honorable U.S. Judge Marcia A. Crone and Honorable U.S. Magistrate Keith F. Giblin

Admitting furtherance Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein against penalty of perjury Before the Honorable U.S. Judge Marcia A. Crone and Honorable U.S. Magistrate Keith F. Giblin

Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein admitting when question (14) was asked

“How is the state of Texas Involved..?

And you Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein and on behalf of Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein collectively supply the responded of “Not involved

Admitting you are continual making the same “representation and presentation” Before the Honorable U.S. Judge Marcia A. Crone and Honorable U.S. Magistrate Keith F. Giblin of the Question under Federal Rules of Civil Procedure in Your Answer to Interrogatories herein (now) to still be that of the false and fraudulent statement response of (Texas) not Involved in comparison to Pro Se Plaintiff attached official document # 1 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 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 Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein engaged in the destruction of “physical evidence” of an entire home which was completely destroyed being on

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 is the primary “physical evidence” and “physical address” of said Co-Defendant(s) collectively herein and furtherance’s admitting said

Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein refusal to produce to the Pro Se Plaintiff copies of said required “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 while you’re still acting “attorney of record” between the actual dates of December 18th 2007- November 13th 2009 10:22 am and continual admitting Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein said Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein

Continual between the date of November 13th 2009 10:22 am throughout March 30th 2015 refusal to produce 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 into civil suit in common law files before the Jefferson County Texas 58th Judicial District Court even after the 58th Judicial District Court (Order) as described in Pro Se Plaintiff attached Document # 5 herein Order of the 58th Judicial District Court Cause No. A-180805 dated May 10th 2010

Said Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein in the production of said “property deeds” to the dwelling located at 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.

Request Number 33.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein said Pro Se Plaintiff discovery request for “interrogatories” herein filed as Pro Se Plaintiff attached Document # 9 Defendant(s) response to “Interrogatories” questions at number (12) and (14) are indeed “false, fictitious and fraudulent” statement of entry in said Interrogators in comparison to Pro Se Plaintiff attached official document # 1 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 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 34.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein that you, conspire, hidden, scuttled, obstructed, conceal, keep secrete, tuck away, between the dates of March 14th 2008 throughout the Dates of October 14th, 2009 Pro Se Plaintiff attached official document # 1 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 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 for the Behalf of the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein.

Request Number 35.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein that you, conspire, hidden, scuttled, obstructed, conceal, keep secrete, tuck away, between the dates of March 14th 2008 throughout the Dates of May 10th 2010 Pro Se Plaintiff attached official document # 1 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 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 for the Behalf of the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein.

Request Number 36.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein that you, conspire, hidden, scuttled, obstructed, conceal, keep secrete, tuck away, in the same “representation and presentation” Before the Honorable U.S. Judge Marcia A. Crone and Honorable U.S. Magistrate Keith F. Giblin

Herein in continual “defense” after your retain again as counsel of record in the file Defendant’s Collective Original Answer again in U.S. District Court for the District of Texas, Beaumont Division Jefferson County, Texas U.S. Docket No. 1:10-CV-00055 against the

 Pro Se Plaintiff Louis Charles Hamilton II herein and “you” Antoine L. Freeman J. D. “Attorney at Law”, being Defendant (also) in U.S. District Court for the District of Texas, Beaumont Division Jefferson County, Texas U.S. Docket No. 1:10-CV-00055 between the dates of March 14th 2008 throughout the Dates of April 30th 2010 continual in the same (RICO) enterprise “pattern and practices” conspire, hidden, scuttled, obstructed, conceal, keep secrete, tuck away, for the continual legal behalf of the of the said Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein  now federal “subject matter” before the Honorable U.S. Judge Marcia A. Crone and Honorable U.S. Magistrate Keith F. Giblin

Pro Se Plaintiff attached official document # 1 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 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 for the continual legal Behalf of the said Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein April 30th 2010 and all Federal Court Proceeding derive thereafter in the continual conspire, hidden, scuttled, obstructed, conceal, keep secrete, tuck

 Pro Se Plaintiff attached official document # 1 “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

Request Number 37.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein that you, conspire, hidden, scuttled, obstructed, conceal, keep secrete, tuck away, between the dates of March 14th 2008 throughout the Dates of May 10th 2010 Pro Se Plaintiff attached official document # 1 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 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 for the Behalf of the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein.

Request Number 38.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein that you, conspire, hidden, scuttled, obstructed, conceal, keep secrete, tuck away, between the dates of March 14th 2008 throughout the Dates of March 30th 2015 Pro Se Plaintiff attached official document # 1 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 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 for the Behalf of the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein.

Request Number 39.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein that you, conspire, hidden, scuttled, obstructed, conceal, keep secrete, tuck away, between the dates of March 14th 2008 throughout the Dates of October 14th, 2009 Pro Se Plaintiff attached official document # 1 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 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 for the Behalf of the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein and “you” Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein refused to file a “Motion for Withdrawal of Counsel” until November 13th 2009 10:22 am hour.

Request Number 40.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein that you, conspire, hidden, scuttled, obstructed, conceal, keep secrete, tuck away, between the dates of March 14th 2008 throughout the Dates of December 11th 2009 Pro Se Plaintiff attached official document # 1 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 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 for the Behalf of the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein and “you” Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein refused to file a “Motion for Withdrawal of Counsel” until November 13th 2009 10:22 am hour.

 

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