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 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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