Request
Number 59.
Admit
Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein
in your defense of
this current Complaint filed in U.S. Cause No. 1:14-CV-592 U.S. District Court
for the District of Texas, Beaumont Division Jefferson County, Texas
before the
Honorable U.S. Magistrate Judge Zack
Hawthorn against
the Pro Se Plaintiff Louis Charles Hamilton II herein
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
you have not produce such copies of said “property deeds between the dates of March
14th 2008 throughout October 14th 2009.
Request
Number 60.
Admit
Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein
in your defense of
this current Complaint filed in U.S. Cause No. 1:14-CV-592 U.S. District Court
for the District of Texas, Beaumont Division Jefferson County, Texas
before the
Honorable U.S. Magistrate Judge Zack
Hawthorn against
the Pro Se Plaintiff Louis Charles Hamilton II herein
Admitting
Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein that you
were fully aware on or after March 14th 2008, Pro Se Plaintiff
herein request Pursuant to rule 194, within thirty (30) days of Service of this
request your are requested to disclosed the information or material described
in Rule 194.2
As
being legally described in Pro Se Plaintiff attached document # 13 herein Namely
Plaintiff “request for disclosure” filed in the District Court of Jefferson
County Texas “time stamp” March 14th 2008 1:48 pm hour
And
you Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein have not
produced such requested to disclosed between the dates of March 14th
2008 1:48 pm hour throughout October 14th 2009.
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