Cmdr. Bluefin a/k/a (Sherlock Holmes) "Legal page": 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

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 23.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein between the actual dates of November 13^th 2009 10:22 am hour you physically filed “Motion for Withdrawal of Counsel” namely Pro Se Plaintiff “Louis Charles Hamilton II” attached Document # 8 as stated by “you”

Chief Defendant” herein in paragraph IV: A copy of this motion bearing the enclosed notice has been delivered to the last known addresses of Defendants. Joyce Guy 5050 7^th street Port Arthur. Texas 77642, and Edward McCray 5050 7^th street Port Arthur, Texas 77642

While you furtherance Admitting Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein between the actual dates of December 18^th 2007 throughout at some point date of November 13^th 2009 10:22 am hour

Co-Defendant(s) “Joyce M. Guy and Edward McCray” was in fact living 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 448 DeQueen Blvd. in Port Arthur Texas 77640 which is the primary address of said Co-Defendant(s) collectively herein when you

“Chief Defendant” herein was retaining for your “Attorney at law” legal services in civil suit in common law docket No. A-180805 which the property 448 DeQueen Blvd. in Port Arthur Texas 77640 is involved in a breach of Construction Contract civil matter before the 58^th Judicial District Court of Jefferson County, Texas.

Request Number 24.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein between the actual dates of November 13^th 2009 10:22 am hour you physically filed “Motion for Withdrawal of Counsel” as stated by “you”

“Your” having full legal knowledge that 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 which both “physical evidence” and “physical home” was completely destroyed in connection with namely

“Mechanic’s LIEN Contract filed on June 9^th 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 between the exact time frame of December 18^th 2007 throughout actual date of November 13^th 2009 10:22 am hour until you physically filed “Motion for Withdrawal of Counsel” was acting counsel for Co-Defendant(s) Joyce M. Guy and Edward McCray in a civil suit in the

58^th 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 25.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein between the actual dates of December 18^th 2007 throughout actual date of November 13^th 2009 10:22 am hour when you physically filed “Motion for Withdrawal of Counsel” you in this said time frame was acting counsel for Co-Defendant(s) Joyce M. Guy and Edward McCray in a civil suit in the

58^th 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 admitting furtherance’s

Said Co-Defendant(s) Joyce M. Guy and Edward McCray collectively engaged in the destruction of physical evidence of a 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 as described in Pro Se Plaintiff attached Document # 1 namely

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

For the property located at 448Dequeen Blvd. in Port Arthur Texas 77640.

Request Number 26.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein between the actual dates of December 18^th 2007 throughout actual date of November 13^th 2009 10:22 am hour you physically filed “Motion for Withdrawal of Counsel” you was acting counsel for Co-Defendant(s) Joyce M. Guy and Edward McCray legal behalf in a civil suit in the

58^th 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 27.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein between the actual dates of March 14^th 2008 – throughout actual date of November 13^th 2009 10:22 am hour Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein refusal to respond to all of the Pro Se Plaintiff discovery request your having in your legal, possession, custody and control mailed to you since the exact time date of March 14^th 2008 – on behalf of said Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein while “you”

Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein furtherance’s admitting 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

Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein refusal to produce to the Pro Se Plaintiff 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 while you’re still acting “attorney of record” between the actual dates of December 18^th 2007- November 13^th 2009 10:22 am

With “you” Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein in full possession, custody and legal control over of said Pro Se Plaintiff herein “request for production 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 in Your” Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein physical custody, possession and legal control between the actual dates of March 14^th 2008 – November 13^th 2009 10:22 am hour.

Request Number 28.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein between the actual dates of December 18^th 2007 throughout actual date of April 30^th 2010 when you filed Defendant’s 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

Before the Honorable U.S. Judge Marcia A. Crone and Honorable U.S. Magistrate Keith F. Giblin your Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein “your” having full knowledge that between the actual dates of November 13^th 2009 10:22 am hour you physically filed “Motion for Withdrawal of Counsel” as stated by “you”

“Your” having full legal knowledge that 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 which is both “physical evidence” and “physical home” was completely destroyed in connection with namely

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

Request Number 29.

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

Admitting Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein refusal to respond to all of the Pro Se Plaintiff discovery request your having in your legal, possession, custody and control mailed to you since the exact time date of March 14^th 2008 – on behalf of said

Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein until you Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein responded to all said discovery request on October 14^th, 2009 at which during this time frame of March 14^th 2008 October 14^th, 2009

“Your” having full legal knowledge that 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 which is both “physical evidence” and “physical home” was completely destroyed in connection with namely

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

As physically described by you Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein in Pro Se Plaintiff attached Document # 9 Defendant(s) response to “Interrogatories” dated October 14^th, 2009 said property being under a Federal Grant namely Interrogatories herein pursuant to Rule 197 of the Texas Rules of Civil Procedures at Question: 10, 11, 12, 13, 14, 15, and 16.

Request Number 30.

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 herein “request for production 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 in Your” Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein physical custody, possession and legal control between the actual dates of March 14^th 2008 and such “request for production 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 having not been produced to the Pro Se Plaintiff or the 58^th Judicial District Court of Jefferson County Texas throughout actual date of April 30^th 2010 when you filed Defendant’s 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

Before the Honorable U.S. Judge Marcia A. Crone and Honorable U.S. Magistrate Keith F. Giblin 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 which is both “physical evidence” and “physical home” your furtherance’s admitting

Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein the primary “physical evidence” and “physical home on said address” of said Co-Defendant(s) collectively herein was completely destroyed in connection with namely

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

As your furtherance’s admitting physically being described by you Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein in Pro Se Plaintiff attached Document # 9 Defendant(s) response to “Interrogatories” dated October 14^th, 2009

Stating said property being under a Federal Grant namely Interrogatories questions herein pursuant to Rule 197 of the Texas Rules of Civil Procedures at Question: 10, 11, 12, 13, 14, 15, and 16.