Racketeer Influenced and Corrupt Organizations Act, commonly referred to as the RICO Act or simply RICO,
is a United States federal law that provides for extended criminal penalties and a civil cause of action for acts performed as part of an ongoing criminal organization.
The RICO Act focuses specifically on racketeering, and it allows the leaders of a syndicate to be tried for the crimes which they ordered others to do or assisted them,
closing a perceived loophole that allowed someone who told a man to, for example, murder, to be exempt from the trial because he did not actually commit the crime personally.
RICO was enacted by section 901(a) of the Organized Crime Control Act of 1970 (Pub.L. 91–452, 84 Stat. 922, enacted October 15, 1970). RICO is codified as Chapter 96 of Title 18 of the United States Code, 18 U.S.C. § 1961–1968. G. Robert Blakey,
an adviser to the United States Senate Government Operations Committee, drafted the law under the close supervision of the committee's chairman, Senator John Little McClellan. It was enacted as Title IX of the Organized Crime Control Act of 1970, and signed into law by Richard M. Nixon.
While its original use in the 1970s was to prosecute the Mafia as well as others who were actively engaged in organized crime, its later application has been more widespread.
Beginning in 1972, 33 States adopted state RICO laws to be able to prosecute similar conduct.
Under RICO, a person who has committed "at least two acts of racketeering activity" drawn from a list of 35 crimes—27 federal crimes and 8 state crimes—within a 10-year period, if such acts are related in one of four specified ways to an "enterprise," can be charged with racketeering.
Those found guilty of racketeering can be fined up to $25,000 and sentenced to 20 years in prison per racketeering count. In addition, the racketeer must forfeit all ill-gotten gains and interest in any business gained through a pattern of "racketeering activity."
When the U.S. Attorney decides to indict someone under RICO, he or she has the option of seeking a pre-trial restraining order or injunction to temporarily seize a defendant's assets and prevent the transfer of potentially forfeitable property, as well as require the defendant to put up a performance bond.
This provision was placed in the law because the owners of Mafia-related shell corporations often absconded with the assets. An injunction and/or performance bond ensures that there is something to seize in the event of a guilty verdict.
In many cases, the threat of a RICO indictment can force defendants to plead guilty to lesser charges, in part because the seizure of assets would make it difficult to pay a defense attorney.
Despite its harsh provisions, a RICO-related charge is considered easy to prove in court, as it focuses on patterns of behavior as opposed to criminal acts.
RICO also permits a private individual "damaged in his business or property" by a "racketeer" to file a civil suit.
The plaintiff must prove the existence of an "enterprise". The defendant(s) are not the enterprise; in other words, the defendant(s) and the enterprise are not one and the same.
There must be one of four specified relationships between the defendant(s) and the enterprise:
either the defendant(s) invested the proceeds of the pattern of racketeering activity into the enterprise;
or the defendant(s) acquired or maintained an interest in,
or control over, the enterprise through the pattern of racketeering activity;
or the defendant(s) conducted or participated in the affairs of the enterprise "through" the pattern of racketeering activity;
or the defendant(s) conspired to do one of the above.
In essence, the enterprise is either the 'prize,' 'instrument,' 'victim,' or 'perpetrator' of the racketeers.
A civil RICO action can be filed in state or federal court.
The crime of obstruction of justice, in United States jurisdictions, refers to the crime of obstructing the work of police, investigators, regulatory agencies, prosecutors, or other (usually government) officials.
Common law jurisdictions other than the United States tend to use the wider offense of perverting the course of justice.
Generally, obstruction charges are laid when it is discovered that a person questioned in an investigation, other than a suspect, has lied to the investigating officers.
However, in most common law jurisdictions, the right to remain silent used to allow any person questioned by police merely to refuse to answer questions posed by an investigator without giving any reason for doing so.
(In such a case, the investigators may subpoena the witness to give testimony under oath in court,
though the witness may then exercise their rights, for example in the Fifth Amendment, if they believe their answer may serve to incriminate themselves.)
If the person tried to protect a suspect (such as by providing a false alibi, even if the suspect is in fact innocent) or to hide from investigation of their own activities (such as to hide their involvement in another crime),
this may leave them liable to prosecution. Obstruction charges can also be laid if a person alters, destroys, or conceals physical evidence, even if he was under no compulsion at any time to produce such evidence. Often, no actual investigation or substantiated suspicion of a specific incident need exist to support a charge of obstruction of justice.
Obstruction can include crimes committed by judges, prosecutors, attorneys general, and elected officials in general.
It is misfeasance, malfeasance or nonfeasance in the conduct of the office.
Most commonly it is prosecuted as a crime for perjury by a non governmental official primarily because of prosecutorial discretion.
Saturday, January 10, 2015
"U.S. District Court" Louis Charles Hamilton II vs. Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 et al
A lawsuit or (very rarely) "suit in law" is a civil action brought in a court of law in which a plaintiff, a party who claims to have incurred loss as a result of a defendant's actions, demands a legal or equitable remedy.
The defendant is required to respond to the plaintiff's complaint.
If the plaintiff is successful, judgment is in the plaintiff's favor, and a variety of court orders may be issued to enforce a right, award damages, or impose a temporary or permanent injunction to prevent an act or compel an act.
A declaratory judgment may be issued to prevent future legal disputes.
A lawsuit may involve dispute resolution of private law issues between individuals, business entities or non-profit organizations.
A lawsuit may also enable the state to be treated as if it were a private party in a civil case, as plaintiff, or defendant regarding an injury, or may provide the state with a civil cause of action to enforce certain laws.
The conduct of a lawsuit is called litigation. The plaintiffs and defendants are called litigants and the attorneys representing them are called litigators.The term litigation may also refer to criminal trial.
Rules of criminal or civil procedure govern the conduct of a lawsuit in the common law adversarial system of dispute resolution.
Procedural rules are additionally constrained/informed by separate statutory laws, case law, and constitutional provisions that define the rights of the parties to a lawsuit (see especially due process),
though the rules generally reflect this legal context on their face. The details of procedure differ greatly from jurisdiction to jurisdiction, and often from court to court within the same jurisdiction.
The rules are very important for litigants to know, however, because they dictate the timing and progression of the lawsuit—what may be filed and when, to obtain what result.
Failure to comply with the procedural rules may result in serious limitations upon the ability to present claims or defenses at any subsequent trial, or even dismissal of the lawsuit.
Though the majority of lawsuits are settled and never reach trial, they can be very complicated to litigate.
This is particularly true in federal systems, where a federal court may be applying state law (e.g., the Erie doctrine in the United States) or vice versa, or one state applying the law of another,
and where additionally it may not be clear which level (or location) of court actually has jurisdiction over the claim or personal jurisdiction over the defendant,
or whether the plaintiff has standing to participate in a lawsuit. About 98 percent of civil cases in the United States federal courts are resolved without a trial.
Domestic courts are also often called upon to apply foreign law, or to act upon foreign defendants, over whom they may not, as a practical matter, even have the ability to enforce a judgment if the defendant's assets are outside their reach.
Lawsuits become additionally complicated as more parties become involved (see joinder). Within a "single" lawsuit,
there can be any number of claims and defenses (all based on numerous laws) between any number of plaintiffs or defendants, each of whom can bring any number of cross-claims and counterclaims against each other,
and even bring additional parties into the suit on either side after it progresses.
However, courts typically have some power to sever claims and parties into separate actions if it is more efficient to do so, such as if there is not a sufficient overlap of factual issues between the various associates.
A lawsuit begins when a complaint is filed with the court. This complaint states that one or more plaintiffs seeks damages or equitable relief from one or more stated defendants, and identifies the legal and factual bases for doing so.
It is important that the "plaintiff selects the proper venue with the proper jurisdiction to bring his lawsuit.
" The clerk of a court signs or stamps the court seal upon a summons, which is then served by the plaintiff upon the defendant, together with a copy of the complaint.
This service notifies the defendants that they are being sued and that they have a specific time limit to file a response.
By providing a copy of the complaint, the service also notifies the defendants of the nature of the claims. Once the defendants are served with the summons and complaint,
they are subject to a time limit to file an answer stating their defenses to the plaintiff's claims, including any challenges to the court's jurisdiction, and any counterclaims they wish to assert against the plaintiff.
In a handful of jurisdictions (notably, the U.S. state of New York) a lawsuit begins when one or more plaintiffs properly serve a summons and complaint upon the defendant(s).
In such jurisdictions, nothing must be filed with the court until a dispute develops requiring actual judicial intervention.
If the defendant chooses to file an answer within the time permitted, the answer must address each of the plaintiffs' allegations by admitting the allegation, denying it, or pleading a lack of sufficient information to admit or deny the allegation.
Some jurisdictions, like California, still authorize general denials of each and every allegation in the complaint.
At the time the defendant files an answer, the defendant also raises all "affirmative" defenses.
The defendant may also assert counterclaims for damages or equitable relief against the plaintiff, and in the case of "compulsory counterclaims," must do so or risk having the counterclaim barred in any subsequent proceeding.
The defendant may also file a "third party complaint" seeking to join another party or parties in the action in the belief that those parties may be liable for some or all of the plaintiff's claimed damages.
Filing an answer "joins the cause" and moves the case into the pre-trial phase.
Instead of filing an answer within the time specified in the summons, the defendant can choose to dispute the validity of the complaint by filing a demurrer (in the handful of jurisdictions where that is still allowed) or one or more "pre-answer motions," such as a motion to dismiss.
The motion must be filed within the time period specified in the summons for an answer.
If all such motions are denied by the trial court, and the defendant loses on all appeals from such denials (if that option is available), then the defendant must file an answer.
Usually the pleadings are drafted by a lawyer, but in many courts persons can file papers and represent themselves, which is called appearing pro se. Many courts have a pro se clerk to assist people without lawyers.
The early stages of the lawsuit may involve initial disclosures of evidence by each party and discovery, which is the structured exchange of evidence and statements between the parties.
Discovery is meant to eliminate surprises and clarify what the lawsuit is about, and to make the parties realize they should settle or drop frivolous claims and defenses.
At this point the parties may also engage in pretrial motions to exclude or include particular legal or factual issues before trial.
At the close of discovery, the parties may either pick a jury and then have a trial by jury or the case may proceed as a bench trial heard only by the judge if the parties waive a jury trial or if the right to a jury trial is not guaranteed for their particular claim (such as those under equity in the U.S.) or for any lawsuits within their jurisdiction.
At trial, each person presents witnesses and enters evidence into the record, at the close of which the judge or jury renders their decision. Generally speaking, the plaintiff has the burden of proof in making his claims.
The defendant may have the burden of proof on other issues, however, such as affirmative defenses.
The attorneys will devise a trial strategy that ensures they meet the necessary elements of their case or (when the opposing party has the burden of proof) to ensure the opponent will not be able to meet his or her burden.
There are numerous motions that either party can file throughout the lawsuit to terminate it "prematurely"—before submission to the judge or jury for final consideration.
These motions attempt to persuade the judge, through legal argument and sometimes accompanying evidence, that because there is no reasonable way that the other party could legally win, there is no sense in continuing with the trial.
Motions for summary judgment, for example, can usually be brought before, after, or during the actual presentation of the case. Motions can also be brought after the close of a trial to undo a jury verdict contrary to law or against the weight of the evidence, or to convince the judge to change the decision or grant a new trial.
Also, at any time during this process from the filing of the complaint to the final judgment, the plaintiff may withdraw the complaint and end the whole matter, or the defendant may agree to a settlement.
If the case settles, the parties might choose to enter into a stipulated judgment with the settlement agreement attached, or the plaintiff may simply file a voluntary dismissal, so that the settlement agreement is never entered into the court record.
After a final decision has been made, either party or both may appeal from the judgment if they believe there had been a procedural error made by the trial court. Even the prevailing party may appeal, if, for example, they wanted a larger award than was granted.
The appellate court (which may be structured as an intermediate appellate court) and/or a higher court then affirms the judgment, declines to hear it (which effectively affirms it), reverses—or vacates and remands,
which involves sending the lawsuit back to the lower trial court to address an unresolved issue, or possibly for a whole new trial. Some lawsuits go up and down the appeals ladder repeatedly before finally resolution.
Some jurisdictions, notably the United States, prevent parties from relitigating the facts on appeal, due to a history of unscrupulous lawyers deliberately reserving such issues in order to ambush each other in the appellate courts (the "invited error" problem).
The idea is that it is more efficient to force all parties to fully litigate all relevant issues of fact before the trial court. Thus, a party who does not raise an issue of fact at the trial court level generally cannot raise it on appeal.
Furthermore, appellate courts in such jurisdictions will not question the facts as found by a judge or jury in the trial court,
as long as there was some evidence in the record to support such findings—and even if the appellate judge would not personally have believed the underlying evidence if present when it was entered into the record.
When the lawsuit is finally resolved, or the allotted time to appeal has expired, the matter is res judicata.
The plaintiff may not bring another action based on the same claim again. In addition, other parties who later attempt to re-litigate a matter already ruled on in a previous lawsuit will be estopped from doing so.
When a final judgment is entered, the plaintiff is usually barred under the doctrine of res judicata from trying to bring the same or similar claim again against that defendant, or from relitigating any of the issues, even under different legal claims or theories.
This prevents a new trial of the same case with a different result, or if the plaintiff won, a repeat trial that merely multiplies the judgment against the defendant.
If the judgment is for the plaintiff, then the defendant must comply under penalty of law with the judgment, which is usually a monetary award. If the defendant fails to pay, the court has various powers to seize any of the defendant's assets located within its jurisdiction, such as:
Writ of execution
Bank account garnishment
Liens
Wage garnishment
If all assets are located elsewhere, the plaintiff must file another suit in the appropriate court to seek enforcement of the other court's previous judgment.
This can be a difficult task when crossing from a court in one state or nation to another, though courts tend to grant each other respect when there is not a clear legal rule to the contrary.
A defendant who has no assets in any jurisdiction is said to be "judgment-proof." The term is generally a colloquialism to
describe an impecunious defendant.
Indigent judgment-proof defendants are no longer imprisoned; debtor's prisons have been outlawed by statute, constitutional amendment, or international human
rights treaties in the vast majority of common law jurisdictions.
During the 18th and 19th centuries, it was common for lawyers to speak of bringing an "action" at law and a "suit" in equity. An example of that distinction survives today in the text of the Civil Rights Act of 1871. The fusion of common law and equity in England in the Judicature Acts of 1873 and 1875 led to the
collapse of that distinction, so it became possible to speak of a "lawsuit."
In the United States, the Federal Rules of Civil Procedure (1938) abolished the distinction between actions at law and suits in equity in federal practice, in favor of a single form referred to as a "civil action."
In England and Wales the term "claim" is far more common; the person initiating proceedings is called the claimant.
American terminology is slightly different, in that the term "claim" refers only to a particular count (or cause of action) in a lawsuit.
Americans also use "claim" to describe a demand filed with an insurer or administrative agency.
If the claim is denied, then the claimant (or policyholder or applicant) files a lawsuit with the courts and becomes a plaintiff.
In medieval times, both "action" and "suit" had the approximate meaning of some kind of legal proceeding, but an action terminated when a judgment was rendered, while a suit also included the execution of the judgment
In the United States, plaintiffs and defendants who lack financial resources for litigation or other attorney's fees may be able to obtain legal financing.
Legal financing companies can provide a cash advance to litigants in return for a share of the ultimate settlement or award.
If the case ultimately loses, the litigant does not have to pay any of the money funded back. Legal financing is different from a typical bank loan. The legal financing company does not look at credit history or employment history.
Litigants do not have to repay the cash advance with monthly payments, but do have to fill out an application so that the legal financing company can review the merits of the case.
Legal financing can be a practical means for litigants to obtain financing while they wait for a monetary settlement or an award in their personal injury, workers' compensation, or civil rights lawsuit.
Often, plaintiffs who were injured or forced to leave their jobs still have mortgages, rent, medical expenses, or other bills to pay.
Other times, litigants may simply need money to pay for the costs of litigation and attorneys' fees. For this reason, many litigants turn to reputable legal financing companies to apply for a cash advance to help pay for bills.
Defendants, civil rights organizations, public interest organizations, and government public officials can set up an account to pay for litigation costs and legal expenses.
These legal defense funds can have large membership counts where the members contribute to the fund.
Unlike legal financing from legal financing companies, legal defense funds provide a separate account for litigation rather than a one-time cash advancement,
though both are used for purposes of financing litigation and legal costs.
The defendant is required to respond to the plaintiff's complaint.
If the plaintiff is successful, judgment is in the plaintiff's favor, and a variety of court orders may be issued to enforce a right, award damages, or impose a temporary or permanent injunction to prevent an act or compel an act.
A declaratory judgment may be issued to prevent future legal disputes.
A lawsuit may involve dispute resolution of private law issues between individuals, business entities or non-profit organizations.
A lawsuit may also enable the state to be treated as if it were a private party in a civil case, as plaintiff, or defendant regarding an injury, or may provide the state with a civil cause of action to enforce certain laws.
The conduct of a lawsuit is called litigation. The plaintiffs and defendants are called litigants and the attorneys representing them are called litigators.The term litigation may also refer to criminal trial.
Rules of criminal or civil procedure govern the conduct of a lawsuit in the common law adversarial system of dispute resolution.
Procedural rules are additionally constrained/informed by separate statutory laws, case law, and constitutional provisions that define the rights of the parties to a lawsuit (see especially due process),
though the rules generally reflect this legal context on their face. The details of procedure differ greatly from jurisdiction to jurisdiction, and often from court to court within the same jurisdiction.
The rules are very important for litigants to know, however, because they dictate the timing and progression of the lawsuit—what may be filed and when, to obtain what result.
Failure to comply with the procedural rules may result in serious limitations upon the ability to present claims or defenses at any subsequent trial, or even dismissal of the lawsuit.
Though the majority of lawsuits are settled and never reach trial, they can be very complicated to litigate.
This is particularly true in federal systems, where a federal court may be applying state law (e.g., the Erie doctrine in the United States) or vice versa, or one state applying the law of another,
and where additionally it may not be clear which level (or location) of court actually has jurisdiction over the claim or personal jurisdiction over the defendant,
or whether the plaintiff has standing to participate in a lawsuit. About 98 percent of civil cases in the United States federal courts are resolved without a trial.
Domestic courts are also often called upon to apply foreign law, or to act upon foreign defendants, over whom they may not, as a practical matter, even have the ability to enforce a judgment if the defendant's assets are outside their reach.
Lawsuits become additionally complicated as more parties become involved (see joinder). Within a "single" lawsuit,
there can be any number of claims and defenses (all based on numerous laws) between any number of plaintiffs or defendants, each of whom can bring any number of cross-claims and counterclaims against each other,
and even bring additional parties into the suit on either side after it progresses.
However, courts typically have some power to sever claims and parties into separate actions if it is more efficient to do so, such as if there is not a sufficient overlap of factual issues between the various associates.
A lawsuit begins when a complaint is filed with the court. This complaint states that one or more plaintiffs seeks damages or equitable relief from one or more stated defendants, and identifies the legal and factual bases for doing so.
It is important that the "plaintiff selects the proper venue with the proper jurisdiction to bring his lawsuit.
" The clerk of a court signs or stamps the court seal upon a summons, which is then served by the plaintiff upon the defendant, together with a copy of the complaint.
This service notifies the defendants that they are being sued and that they have a specific time limit to file a response.
By providing a copy of the complaint, the service also notifies the defendants of the nature of the claims. Once the defendants are served with the summons and complaint,
they are subject to a time limit to file an answer stating their defenses to the plaintiff's claims, including any challenges to the court's jurisdiction, and any counterclaims they wish to assert against the plaintiff.
In a handful of jurisdictions (notably, the U.S. state of New York) a lawsuit begins when one or more plaintiffs properly serve a summons and complaint upon the defendant(s).
In such jurisdictions, nothing must be filed with the court until a dispute develops requiring actual judicial intervention.
If the defendant chooses to file an answer within the time permitted, the answer must address each of the plaintiffs' allegations by admitting the allegation, denying it, or pleading a lack of sufficient information to admit or deny the allegation.
Some jurisdictions, like California, still authorize general denials of each and every allegation in the complaint.
At the time the defendant files an answer, the defendant also raises all "affirmative" defenses.
The defendant may also assert counterclaims for damages or equitable relief against the plaintiff, and in the case of "compulsory counterclaims," must do so or risk having the counterclaim barred in any subsequent proceeding.
The defendant may also file a "third party complaint" seeking to join another party or parties in the action in the belief that those parties may be liable for some or all of the plaintiff's claimed damages.
Filing an answer "joins the cause" and moves the case into the pre-trial phase.
Instead of filing an answer within the time specified in the summons, the defendant can choose to dispute the validity of the complaint by filing a demurrer (in the handful of jurisdictions where that is still allowed) or one or more "pre-answer motions," such as a motion to dismiss.
The motion must be filed within the time period specified in the summons for an answer.
If all such motions are denied by the trial court, and the defendant loses on all appeals from such denials (if that option is available), then the defendant must file an answer.
Usually the pleadings are drafted by a lawyer, but in many courts persons can file papers and represent themselves, which is called appearing pro se. Many courts have a pro se clerk to assist people without lawyers.
The early stages of the lawsuit may involve initial disclosures of evidence by each party and discovery, which is the structured exchange of evidence and statements between the parties.
Discovery is meant to eliminate surprises and clarify what the lawsuit is about, and to make the parties realize they should settle or drop frivolous claims and defenses.
At this point the parties may also engage in pretrial motions to exclude or include particular legal or factual issues before trial.
At the close of discovery, the parties may either pick a jury and then have a trial by jury or the case may proceed as a bench trial heard only by the judge if the parties waive a jury trial or if the right to a jury trial is not guaranteed for their particular claim (such as those under equity in the U.S.) or for any lawsuits within their jurisdiction.
At trial, each person presents witnesses and enters evidence into the record, at the close of which the judge or jury renders their decision. Generally speaking, the plaintiff has the burden of proof in making his claims.
The defendant may have the burden of proof on other issues, however, such as affirmative defenses.
The attorneys will devise a trial strategy that ensures they meet the necessary elements of their case or (when the opposing party has the burden of proof) to ensure the opponent will not be able to meet his or her burden.
There are numerous motions that either party can file throughout the lawsuit to terminate it "prematurely"—before submission to the judge or jury for final consideration.
These motions attempt to persuade the judge, through legal argument and sometimes accompanying evidence, that because there is no reasonable way that the other party could legally win, there is no sense in continuing with the trial.
Motions for summary judgment, for example, can usually be brought before, after, or during the actual presentation of the case. Motions can also be brought after the close of a trial to undo a jury verdict contrary to law or against the weight of the evidence, or to convince the judge to change the decision or grant a new trial.
Also, at any time during this process from the filing of the complaint to the final judgment, the plaintiff may withdraw the complaint and end the whole matter, or the defendant may agree to a settlement.
If the case settles, the parties might choose to enter into a stipulated judgment with the settlement agreement attached, or the plaintiff may simply file a voluntary dismissal, so that the settlement agreement is never entered into the court record.
After a final decision has been made, either party or both may appeal from the judgment if they believe there had been a procedural error made by the trial court. Even the prevailing party may appeal, if, for example, they wanted a larger award than was granted.
The appellate court (which may be structured as an intermediate appellate court) and/or a higher court then affirms the judgment, declines to hear it (which effectively affirms it), reverses—or vacates and remands,
which involves sending the lawsuit back to the lower trial court to address an unresolved issue, or possibly for a whole new trial. Some lawsuits go up and down the appeals ladder repeatedly before finally resolution.
Some jurisdictions, notably the United States, prevent parties from relitigating the facts on appeal, due to a history of unscrupulous lawyers deliberately reserving such issues in order to ambush each other in the appellate courts (the "invited error" problem).
The idea is that it is more efficient to force all parties to fully litigate all relevant issues of fact before the trial court. Thus, a party who does not raise an issue of fact at the trial court level generally cannot raise it on appeal.
Furthermore, appellate courts in such jurisdictions will not question the facts as found by a judge or jury in the trial court,
as long as there was some evidence in the record to support such findings—and even if the appellate judge would not personally have believed the underlying evidence if present when it was entered into the record.
When the lawsuit is finally resolved, or the allotted time to appeal has expired, the matter is res judicata.
The plaintiff may not bring another action based on the same claim again. In addition, other parties who later attempt to re-litigate a matter already ruled on in a previous lawsuit will be estopped from doing so.
When a final judgment is entered, the plaintiff is usually barred under the doctrine of res judicata from trying to bring the same or similar claim again against that defendant, or from relitigating any of the issues, even under different legal claims or theories.
This prevents a new trial of the same case with a different result, or if the plaintiff won, a repeat trial that merely multiplies the judgment against the defendant.
If the judgment is for the plaintiff, then the defendant must comply under penalty of law with the judgment, which is usually a monetary award. If the defendant fails to pay, the court has various powers to seize any of the defendant's assets located within its jurisdiction, such as:
Writ of execution
Bank account garnishment
Liens
Wage garnishment
If all assets are located elsewhere, the plaintiff must file another suit in the appropriate court to seek enforcement of the other court's previous judgment.
This can be a difficult task when crossing from a court in one state or nation to another, though courts tend to grant each other respect when there is not a clear legal rule to the contrary.
A defendant who has no assets in any jurisdiction is said to be "judgment-proof." The term is generally a colloquialism to
describe an impecunious defendant.
Indigent judgment-proof defendants are no longer imprisoned; debtor's prisons have been outlawed by statute, constitutional amendment, or international human
rights treaties in the vast majority of common law jurisdictions.
During the 18th and 19th centuries, it was common for lawyers to speak of bringing an "action" at law and a "suit" in equity. An example of that distinction survives today in the text of the Civil Rights Act of 1871. The fusion of common law and equity in England in the Judicature Acts of 1873 and 1875 led to the
collapse of that distinction, so it became possible to speak of a "lawsuit."
In the United States, the Federal Rules of Civil Procedure (1938) abolished the distinction between actions at law and suits in equity in federal practice, in favor of a single form referred to as a "civil action."
In England and Wales the term "claim" is far more common; the person initiating proceedings is called the claimant.
American terminology is slightly different, in that the term "claim" refers only to a particular count (or cause of action) in a lawsuit.
Americans also use "claim" to describe a demand filed with an insurer or administrative agency.
If the claim is denied, then the claimant (or policyholder or applicant) files a lawsuit with the courts and becomes a plaintiff.
In medieval times, both "action" and "suit" had the approximate meaning of some kind of legal proceeding, but an action terminated when a judgment was rendered, while a suit also included the execution of the judgment
In the United States, plaintiffs and defendants who lack financial resources for litigation or other attorney's fees may be able to obtain legal financing.
Legal financing companies can provide a cash advance to litigants in return for a share of the ultimate settlement or award.
If the case ultimately loses, the litigant does not have to pay any of the money funded back. Legal financing is different from a typical bank loan. The legal financing company does not look at credit history or employment history.
Litigants do not have to repay the cash advance with monthly payments, but do have to fill out an application so that the legal financing company can review the merits of the case.
Legal financing can be a practical means for litigants to obtain financing while they wait for a monetary settlement or an award in their personal injury, workers' compensation, or civil rights lawsuit.
Often, plaintiffs who were injured or forced to leave their jobs still have mortgages, rent, medical expenses, or other bills to pay.
Other times, litigants may simply need money to pay for the costs of litigation and attorneys' fees. For this reason, many litigants turn to reputable legal financing companies to apply for a cash advance to help pay for bills.
Defendants, civil rights organizations, public interest organizations, and government public officials can set up an account to pay for litigation costs and legal expenses.
These legal defense funds can have large membership counts where the members contribute to the fund.
Unlike legal financing from legal financing companies, legal defense funds provide a separate account for litigation rather than a one-time cash advancement,
though both are used for purposes of financing litigation and legal costs.
Friday, January 9, 2015
Defendant “Antoine L. Freeman J.D. (Attorney at Law)” Cause No. 1:14-CV-592 “First Set of Interrogatories”
Explain in full expert “Attorney at Law” details, Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” Bar No. 24058299 herein
do you contend fully even at the door steps of facing U.S. Federal penalties for “perjury” that
In a civil suit in common law in docket No A-180805, in the 58th Judicial District Court of Jefferson County Texas
your absolute solid “set” in concrete, stone, chisel ink you
“Chief Defendant” (Attorney at Law) herein “legally entertaining” such that your “contentions”
before a “Federal Court of Law” is that one Co-Defendant(s) “Joyce M. Guy and Edward McCray”
herein collectively in ongoing active civil suit before the 58th Judicial District Court of Jefferson County Texas in January of 2015
Further explaining in Affirm, Sworn, and stated legal details dates, with supporting documents, exhibits,
witnesses, and real life time fact of events and circumstances from the exact date of
December 18th 2007 throughout the exact dates of November 13th 2009 10:22 AM
Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” Bar No. 24058299 herein was not acting;
In that term Attorney - n. an agent or someone authorized to act for another a person who has been qualified by a state
or federal court to provide legal services, including appearing in court.
In that term Attorney of Record - n. the attorney who has appeared in court and/or signed pleadings or other forms on behalf of a client.
The lawyer remains the attorney of record until some other attorney or the client substitutes for him/her,
He/she is allowed by the court to withdraw, or after the case is closed.
In that term Attorney's Fee - n. The payment for legal services, hourly charge,
and or flat fee for the performance of a particular service some mixture of hourly and contingent fee or other combination.
A "retainer" is a down payment on fees, often required by the attorney in order to make sure he or she is not left holding the bag for work performed,
or at least as a good faith indication that the client is serious and can afford the services.
In the term Attorney's Work Product - n. written materials, charts, notes of conversations and investigations,
and other materials directed toward preparation of a case or other legal representation.
In the term Attorney-Client Privilege - n. the requirement that an attorney may not reveal communications,
conversations and letters between himself/ herself and his/her client, under the theory
that a person should be able to speak freely and honestly with his/her attorney without fear of future revelation.
In the term Defense - n. a general term for the effort of an attorney representing a defendant during trial and in pre-trial maneuvers
to defeat the party suing, to counter, defeat or remove all or a part of the contentions of the plaintiff.
As described in Pro Se Plaintiff attached Document # 2 herein
“Your” response to Pro Se Plaintiff Motion for Sanction against “You”
Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” Bar No. 24058299 herein
And you were fully not in that term “Attorney of Record”,
a party thereof from December 18th 2007 throughout the exact dates of
up till the exact date in time of November 13th 2009 10:22 AM
when you file a “Motion for Withdrawal” in cause No. A-180805…?
By, _______________________________
Louis Charles Hamilton II
Pro Se Plaintiff
P.O. Box 17524
Sugar Land Texas 77496
do you contend fully even at the door steps of facing U.S. Federal penalties for “perjury” that
In a civil suit in common law in docket No A-180805, in the 58th Judicial District Court of Jefferson County Texas
your absolute solid “set” in concrete, stone, chisel ink you
“Chief Defendant” (Attorney at Law) herein “legally entertaining” such that your “contentions”
before a “Federal Court of Law” is that one Co-Defendant(s) “Joyce M. Guy and Edward McCray”
herein collectively in ongoing active civil suit before the 58th Judicial District Court of Jefferson County Texas in January of 2015
Further explaining in Affirm, Sworn, and stated legal details dates, with supporting documents, exhibits,
witnesses, and real life time fact of events and circumstances from the exact date of
December 18th 2007 throughout the exact dates of November 13th 2009 10:22 AM
Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” Bar No. 24058299 herein was not acting;
In that term Attorney - n. an agent or someone authorized to act for another a person who has been qualified by a state
or federal court to provide legal services, including appearing in court.
In that term Attorney of Record - n. the attorney who has appeared in court and/or signed pleadings or other forms on behalf of a client.
The lawyer remains the attorney of record until some other attorney or the client substitutes for him/her,
He/she is allowed by the court to withdraw, or after the case is closed.
In that term Attorney's Fee - n. The payment for legal services, hourly charge,
and or flat fee for the performance of a particular service some mixture of hourly and contingent fee or other combination.
A "retainer" is a down payment on fees, often required by the attorney in order to make sure he or she is not left holding the bag for work performed,
or at least as a good faith indication that the client is serious and can afford the services.
In the term Attorney's Work Product - n. written materials, charts, notes of conversations and investigations,
and other materials directed toward preparation of a case or other legal representation.
In the term Attorney-Client Privilege - n. the requirement that an attorney may not reveal communications,
conversations and letters between himself/ herself and his/her client, under the theory
that a person should be able to speak freely and honestly with his/her attorney without fear of future revelation.
In the term Defense - n. a general term for the effort of an attorney representing a defendant during trial and in pre-trial maneuvers
to defeat the party suing, to counter, defeat or remove all or a part of the contentions of the plaintiff.
As described in Pro Se Plaintiff attached Document # 2 herein
“Your” response to Pro Se Plaintiff Motion for Sanction against “You”
Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” Bar No. 24058299 herein
And you were fully not in that term “Attorney of Record”,
a party thereof from December 18th 2007 throughout the exact dates of
up till the exact date in time of November 13th 2009 10:22 AM
when you file a “Motion for Withdrawal” in cause No. A-180805…?
By, _______________________________
Louis Charles Hamilton II
Pro Se Plaintiff
P.O. Box 17524
Sugar Land Texas 77496
Defendant “Antoine L. Freeman J.D. (Attorney at Law)” Cause No. 1:14-CV-592 “First Set of Interrogatories”
(23)
Explain in full expert “Attorney at Law” details, Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” Bar No. 24058299 herein do you contend fully even at the door steps of facing
U.S. Federal penalties for “perjury” that your clients “Joyce M. Guy and Edward McCray” herein collectively Namely being “Co-Defendant(s)
Were “physically legally” acting as their own counsel of record for their very own collectively “legal civil interest behalf” appearing as such in their own “Pro Se” persons excluding “Your” Attorney at
Law skilled representation appearing before the 58th Judicial District Court of Jefferson County Texas in a civil suit in common law docket No A-180805 being filed November 26th 2007
Namely in that term of appearing in their own person/persons as Pro Se thereafter the date of December 18th 2007
Namely in that term of Pro Se, Pro se legal representation (/ˌproʊ ˈsiː/ or /ˌproʊ ˈseɪ/) means advocating on one's own behalf before a court, rather than being represented by a lawyer
In that “You” Chief Defendant (Attorney at Law) herein as an official officer of the Court in and for the State of Texas fully, legally, honestly 100% contend and appearing now before the “Honorable
Justice Magistrate Judge ”
Namely the “Honorable Zack Hawthorn” being a U.S. Magistrate Judge of the United States District Court for the Eastern District of Texas, Beaumont Division, in U.S. Docket Cause No. 1:14-CV-592 herein
In that “You” Chief Defendant (Attorney at Law) herein affirm, state, and supplied such attached sworn affidavit statement thereof your “material facts”, circumstances, and real life time events that said
“Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein collectively represented the civil suit in common law docket No A-180805 filed November 26th 2007 thereafter the exact date of
December 18th 2007 your describing of you and your physical person legally being discharged of law duties in the capacity as acting legal counsel of record in cause No A-180805
As also described by you in Pro Se Plaintiff attached Document # 2 attached herein “namely”, “Your response” to Pro Se Plaintiff motion for sanctions against you being “Chief Defendant” (Attorney
at Law) herein with your filing a supporting “Affidavit” of Co-Defendant “Joyce M. Guy” herein in support thereof as Pro Se Plaintiff attached such Affidavit being Document # 6 herein
As “Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein collectively “Appeared” official before the 58th Judicial District Court of Jefferson County Texas in a civil suit in common law docket No A-180805
As “Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein collectively “Appeared” before The “Honorable Judge Bob Wortham” in a legal format as described now by you and contentions
herein as Pro Se counsel fully acting as such for their very own “legal interest” against the said Pro Se Plaintiff Louis Charles Hamilton II herein from the exact “time frame dates” of December 19th
2007 throughout December 11th 2009…?
(24)
If your answer is 100% yes.., to Pro Se Plaintiff “interrogatories question” at # 23 herein, then please “Chief Defendant” (Attorney at Law) Texas Bar No. 24058299 herein
Fully identify all facts, circumstances, legal events, dates, documents, and witnesses that fully legal support your
honestly 100% contention that the “Co-Defendant(s) “Joyce M. Guy and Edward
McCray” described herein collectively did in all facts and legal circumstances, events and real life person/persons physically “Appeared” acting as Pro Se
To include but not limited to “namely” “Chief Defendant” (Attorney at Law) Texas Bar No. 24058299 herein
your honestly 100% contention in that the “Co-Defendant(s) “Joyce M. Guy and Edward McCray” described herein
appearing acting as Pro Se on hearing dates of August 28th 2009, before Judge Bob Wortham, and Court Reporter,
“Anita Becker” and you’re not acting as legal counsel of record on said hearing dates of August 28th 2009
To include but not limited to “namely” “Chief Defendant” (Attorney at Law) Texas Bar No. 24058299 herein
your honestly 100% contention in that the “Co-Defendant(s) “Joyce M. Guy and Edward McCray” described herein
appearing acting as Pro Se on said hearing dates of September 11th 2009, before Judge Bob Wortham, and Court Reporter,
“Anita Becker” and you’re not acting as legal counsel of record on said hearing dates of September 11th 2009
As the Pro Se Plaintiff Louis Charles Hamilton II herein surly shall present such legal honest evidence
and findings legally supplied by you “namely” your being “Chief Defendant” (Attorney at Law)
Texas Bar No 24058299 herein appearing before the “Honorable Justice Magistrate” of the United States District Court in U.S. Docket Cause No. 1:14-CV-592
And Pro Se Plaintiff Louis Charles Hamilton II herein appearing for his own legal behalf before the
“Honorable U.S. Justice” and as such “Louis Charles Hamilton II surly shall withdraw the U.S.
Complaint made against You “Chief Defendant (Attorney at Law) Texas Bar No 24058299” herein and no longer waist
valuable Judicial Court Time in this U.S. Docket Cause No. 1:14-CV-592
*However take real legal notice to this * “Chief Defendant (Attorney at Law) Texas Bar No 24058299” herein
This is fully based in that your “contentions” is “Stated, Sworn, and Affirm, and 100% absolutely honest in all appearance being described before The U.S. “Honorable Justice” in that:
A. You fully identify all facts circumstances, dates and events that support your contention.
B. You fully identify all documents that support your facts, circumstances, dates, and events of your contention. And
C. You fully identify all witnesses that support all facts circumstances, dates and events of your honest contention.
Thereafter the exact date of December 18th 2007 your describing of legally being physically in a state of actual discharged of
“legal duties” in the capacity as acting legal counsel of record, in cause No. A-180805 between the exact dates of December 18th 2007 throughout the exact date of December 10th 2009
As described in Pro Se Plaintiff attached Document # 2 herein “Your response” to motion for sanctions against you with supporting “Affidavit” of Co-Defendant “Joyce M. Guy” in support
thereof “namely” Pro Se Plaintiff attached Document # 2 herein
Your absolute solid “set” in concrete, stone, chisel ink you “Chief Defendant” (Attorney at Law) herein “legally entertaining” such that your
“contentions” before a “Federal Court of Law” is that one Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein collectively
“Appeared” active before the 58th Judicial District Court of Jefferson County Texas
In a civil suit in common law in docket No A-180805 and appearing as such before The “Honorable Judge Bob Wortham” in a legal format as acting
“Live” Pro Se Defendant(s) being one “Joyce M. Guy and Edward McCray” collectively herein fully engage as such under the term as Pro Se counsel for their very own “legal civil courtroom interest”
In a “Breach of Construction Contract” Complaint filed in connection with the dwelling and the property located at 448 DeQueen Blvd. in Port Arthur Texas. (Block 172, Lot 1-2)
Your absolute contentions as saying such legal terms of a legal Pro Se Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein collectively acting physically in a “court of law” within Texas State Court
Appearing as such against the same said Pro Se Plaintiff Louis Charles Hamilton II herein from the exact time frame dates of
“December 19th 2007 throughout the exact date of December 11th 2009
” for there on legal interest…?
*Please see legal definition for Pro Se *
“Chief Defendant” (Attorney at Law) Texas Bar No 24058299” herein and or his own acting “Attorney or Record” for this U.S. Docket Cause No. 1:14-CV-592 herein
Before you even collectively commence, to entertain any foolish legal thoughts thereof to falsely begin to supply any
“Stated, Sworn, and Affirm, “further fraudulent answers” of facts, events, circumstances, dates and witnesses thereof to this “Interrogatories” question at # 23 and # 24 herein. 
Explain in full expert “Attorney at Law” details, Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” Bar No. 24058299 herein do you contend fully even at the door steps of facing
U.S. Federal penalties for “perjury” that your clients “Joyce M. Guy and Edward McCray” herein collectively Namely being “Co-Defendant(s)
Were “physically legally” acting as their own counsel of record for their very own collectively “legal civil interest behalf” appearing as such in their own “Pro Se” persons excluding “Your” Attorney at
Law skilled representation appearing before the 58th Judicial District Court of Jefferson County Texas in a civil suit in common law docket No A-180805 being filed November 26th 2007
Namely in that term of appearing in their own person/persons as Pro Se thereafter the date of December 18th 2007
Namely in that term of Pro Se, Pro se legal representation (/ˌproʊ ˈsiː/ or /ˌproʊ ˈseɪ/) means advocating on one's own behalf before a court, rather than being represented by a lawyer
In that “You” Chief Defendant (Attorney at Law) herein as an official officer of the Court in and for the State of Texas fully, legally, honestly 100% contend and appearing now before the “Honorable
Justice Magistrate Judge ”
Namely the “Honorable Zack Hawthorn” being a U.S. Magistrate Judge of the United States District Court for the Eastern District of Texas, Beaumont Division, in U.S. Docket Cause No. 1:14-CV-592 herein
In that “You” Chief Defendant (Attorney at Law) herein affirm, state, and supplied such attached sworn affidavit statement thereof your “material facts”, circumstances, and real life time events that said
“Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein collectively represented the civil suit in common law docket No A-180805 filed November 26th 2007 thereafter the exact date of
December 18th 2007 your describing of you and your physical person legally being discharged of law duties in the capacity as acting legal counsel of record in cause No A-180805
As also described by you in Pro Se Plaintiff attached Document # 2 attached herein “namely”, “Your response” to Pro Se Plaintiff motion for sanctions against you being “Chief Defendant” (Attorney
at Law) herein with your filing a supporting “Affidavit” of Co-Defendant “Joyce M. Guy” herein in support thereof as Pro Se Plaintiff attached such Affidavit being Document # 6 herein
As “Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein collectively “Appeared” official before the 58th Judicial District Court of Jefferson County Texas in a civil suit in common law docket No A-180805
As “Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein collectively “Appeared” before The “Honorable Judge Bob Wortham” in a legal format as described now by you and contentions
herein as Pro Se counsel fully acting as such for their very own “legal interest” against the said Pro Se Plaintiff Louis Charles Hamilton II herein from the exact “time frame dates” of December 19th
2007 throughout December 11th 2009…?
(24)
If your answer is 100% yes.., to Pro Se Plaintiff “interrogatories question” at # 23 herein, then please “Chief Defendant” (Attorney at Law) Texas Bar No. 24058299 herein
Fully identify all facts, circumstances, legal events, dates, documents, and witnesses that fully legal support your
honestly 100% contention that the “Co-Defendant(s) “Joyce M. Guy and Edward
McCray” described herein collectively did in all facts and legal circumstances, events and real life person/persons physically “Appeared” acting as Pro Se
To include but not limited to “namely” “Chief Defendant” (Attorney at Law) Texas Bar No. 24058299 herein
your honestly 100% contention in that the “Co-Defendant(s) “Joyce M. Guy and Edward McCray” described herein
appearing acting as Pro Se on hearing dates of August 28th 2009, before Judge Bob Wortham, and Court Reporter,
“Anita Becker” and you’re not acting as legal counsel of record on said hearing dates of August 28th 2009
To include but not limited to “namely” “Chief Defendant” (Attorney at Law) Texas Bar No. 24058299 herein
your honestly 100% contention in that the “Co-Defendant(s) “Joyce M. Guy and Edward McCray” described herein
appearing acting as Pro Se on said hearing dates of September 11th 2009, before Judge Bob Wortham, and Court Reporter,
“Anita Becker” and you’re not acting as legal counsel of record on said hearing dates of September 11th 2009
As the Pro Se Plaintiff Louis Charles Hamilton II herein surly shall present such legal honest evidence
and findings legally supplied by you “namely” your being “Chief Defendant” (Attorney at Law)
Texas Bar No 24058299 herein appearing before the “Honorable Justice Magistrate” of the United States District Court in U.S. Docket Cause No. 1:14-CV-592
And Pro Se Plaintiff Louis Charles Hamilton II herein appearing for his own legal behalf before the
“Honorable U.S. Justice” and as such “Louis Charles Hamilton II surly shall withdraw the U.S.
Complaint made against You “Chief Defendant (Attorney at Law) Texas Bar No 24058299” herein and no longer waist
valuable Judicial Court Time in this U.S. Docket Cause No. 1:14-CV-592
*However take real legal notice to this * “Chief Defendant (Attorney at Law) Texas Bar No 24058299” herein
This is fully based in that your “contentions” is “Stated, Sworn, and Affirm, and 100% absolutely honest in all appearance being described before The U.S. “Honorable Justice” in that:
A. You fully identify all facts circumstances, dates and events that support your contention.
B. You fully identify all documents that support your facts, circumstances, dates, and events of your contention. And
C. You fully identify all witnesses that support all facts circumstances, dates and events of your honest contention.
Thereafter the exact date of December 18th 2007 your describing of legally being physically in a state of actual discharged of
“legal duties” in the capacity as acting legal counsel of record, in cause No. A-180805 between the exact dates of December 18th 2007 throughout the exact date of December 10th 2009
As described in Pro Se Plaintiff attached Document # 2 herein “Your response” to motion for sanctions against you with supporting “Affidavit” of Co-Defendant “Joyce M. Guy” in support
thereof “namely” Pro Se Plaintiff attached Document # 2 herein
Your absolute solid “set” in concrete, stone, chisel ink you “Chief Defendant” (Attorney at Law) herein “legally entertaining” such that your
“contentions” before a “Federal Court of Law” is that one Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein collectively
“Appeared” active before the 58th Judicial District Court of Jefferson County Texas
In a civil suit in common law in docket No A-180805 and appearing as such before The “Honorable Judge Bob Wortham” in a legal format as acting
“Live” Pro Se Defendant(s) being one “Joyce M. Guy and Edward McCray” collectively herein fully engage as such under the term as Pro Se counsel for their very own “legal civil courtroom interest”
In a “Breach of Construction Contract” Complaint filed in connection with the dwelling and the property located at 448 DeQueen Blvd. in Port Arthur Texas. (Block 172, Lot 1-2)
Your absolute contentions as saying such legal terms of a legal Pro Se Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein collectively acting physically in a “court of law” within Texas State Court
Appearing as such against the same said Pro Se Plaintiff Louis Charles Hamilton II herein from the exact time frame dates of
“December 19th 2007 throughout the exact date of December 11th 2009
” for there on legal interest…?
*Please see legal definition for Pro Se *
“Chief Defendant” (Attorney at Law) Texas Bar No 24058299” herein and or his own acting “Attorney or Record” for this U.S. Docket Cause No. 1:14-CV-592 herein
Before you even collectively commence, to entertain any foolish legal thoughts thereof to falsely begin to supply any
“Stated, Sworn, and Affirm, “further fraudulent answers” of facts, events, circumstances, dates and witnesses thereof to this “Interrogatories” question at # 23 and # 24 herein.
"U.S. District Court" Louis Charles Hamilton II vs. Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 et al
Pro se legal representation (/ˌproʊ ˈsiː/ or /ˌproʊ ˈseɪ/) means advocating on one's own behalf before a court, rather than being represented by a lawyer.
This may occur in any court proceeding, whether one is the defendant or plaintiff in civil cases, and when one is a defendant in criminal cases.
Pro se is a Latin phrase meaning "for oneself" or "on one's own behalf". This status is sometimes known as propria persona (abbreviated to "pro per").
In England and Wales the comparable status is that of "litigant in person".
The right of a party to a legal action to represent his or her own cause has long been recognized in the United States, and even predates the ratification of the Constitution.
The Supreme Court noted that "[i]n the federal courts, the right of self-representation has been protected by statute since the beginnings of our Nation.
Section 35 of the Judiciary Act of 1789, 1 Stat. 73, 92, enacted by the First Congress and signed by President Washington one day before the Sixth Amendment was proposed,
provided that 'in all the courts of the United States, the parties may plead and manage their own causes personally or by the assistance of counsel.
In Faretta v. California, the Supreme Court of the United States held that criminal defendants have a constitutional right to refuse counsel
and represent themselves in state criminal proceedings.
That said, the right to represent oneself is not absolute.
It is the Court's right and duty to determine if a particular individual is capable of representing himself, and can inquire into the individual's lucidity and mental status to make that determination
Most U.S. states have a constitutional provision that either expressly or by interpretation allows individuals to represent their own causes in the courts of that state.
In many instances, state constitutional provisions regarding the right to petition the government for redress of grievances have been so interpreted.
The U.S. Judiciary Act, the Code of Conduct for United States Judges,
the Federal Rules of Civil Procedure, the Federal Rules of Criminal Procedure, the Federal Rules of Evidence and the Federal Rules of Appellate Procedure address the rights of the self-represented litigant in several places.
Section 1654 of title 28 of the United States Code provides: "In all courts of the United States the parties may plead and conduct their own cases personally or by counsel as, by the rules of such courts, respectively, are permitted to manage and conduct causes therein."
Laws and organizations charged with regulating judicial conduct may also impact pro se litigants. For example, The State of California Judicial Council has addressed through published materials the need of the Judiciary to act in the interests of fairness to self-represented litigants.
The California rules express a preference for resolution of every case on the merits, even if resolution requires excusing inadvertence by a pro se litigant that would otherwise result in a dismissal. The Judicial Council justifies this position based on the idea that "Judges are charged with ascertaining the truth, not just playing referee...
A lawsuit is not a game, where the party with the cleverest lawyer prevails regardless of the merits."
It suggests "the court should take whatever measures may be reasonable and necessary to insure a fair trial" and says "There is only one reported case in the U.S. finding a judge's specific accommodations have gone too far".The committee notes to the Federal Rules of Civil Procedure rule 56 on summary judgements notes that
"Many courts take extra care with pro se litigants, advising them of the need to respond and the risk of losing by summary judgment if an adequate response is not filed.
And the court may seek to reassure itself by some examination of the record before granting summary judgment against a pro se litigant."
Starting November 1, 2011, the Federal Court for the Central District of California permits pro se litigants to receive documents electronically by an Electronic Filing Account (ECF). As of May 16, 2013, they are still prohibited from filing their documents electronically unlike litigants represented by counsel.
The November 1, 2011 policy of the Central District of California is a cost-saving measure for the court. All they have to do is send in the form, have a PACER account, and provide a valid email address.
According to a June 2012 report from U.S. Courts, 18 of 94 federal district courts authorize use of ADR (Alternative Dispute Resolution) for pro ses and 11 authorize use of ADR by prisoner pro ses. Thirty seven of the ninety four federal districts allow pro se litigants to use ECF.
The ability of a party to proceed without an attorney in prosecuting or defending a civil action is largely a matter of state law, and may vary depending on the court and the positions of the parties.
A longstanding and widely practiced rule prohibits corporations from being represented by non-attorneys,
consistent with the existence of a corporation as a "person" separate and distinct from its shareholders, officers and employees.
The Wisconsin Supreme Court has stated: "A nonlawyer may not sign and file a notice of appeal on behalf of a corporation.
Requiring a lawyer to represent a corporation in filing the notice does not violate the guarantee that any suitor may prosecute or defend a suit personally. A corporation is not a natural person and does not fall with in the term “any suitor.”
Similarly, a pro se litigant may not act as a class representative in a class action lawsuit and therefore a pro se litigant may not bring a class action.
Furthermore, a non-attorney parent may not appear on behalf of his or her child, except to appeal the denial of social security benefits to such child.
Another situation in which appearance through counsel is often required is in a case involving the executor or personal administrator of a probate estate. Unless the executor or administrator is himself an attorney, he is not allowed to represent himself in matters other than the probate.
Some federal court of appeals allow unrepresented litigants to argue orally (even so nonargument disposition is still possible), and in all courts the percentage of cases in which argument occurs is higher for counseled cases.
The Connecticut Supreme Court narrowed criminal defendant's right to self representation, stating that "we are free to adopt for mentally ill
or mentally incapacitated defendants who wish to represent themselves at trial a competency standard that differs from the standard for determining whether such a defendant is competent to stand trial".
A Senior Assistant State’s Attorney explained that the new standard essentially allows judges to consider whether the defendants are competent enough to perform the skills needed to defend themselves, including composing questions for voir dire and witnesses.
Some courts issue orders against self representation in civil cases. A court enjoined a former attorney from suing the new lover of her former attorney.
The Superior Court of Bergen New Jersey also issued an order against pro se litigation based on a number of lawsuits that were dismissed and a failure to provide income tax returns in case sanctions might issue.
The Superior Court of New Jersey issued an order prohibiting a litigant from filing in federal court.
The Third Circuit however ruled that a restriction on pro se litigation went too far and that it could not be enforced if a litigant certified that he has new claims that were never before disposed of on the merits.
The 10th Circuit ruled that before imposing filing restrictions, a district court must set forth examples of abusive filings and that if the district court did not do so, the filing restrictions must be vacated.
The District of Columbia Court of Appeals wrote that "private individuals have 'a constitutional right of access to the courts',
that is, the 'right to sue and defend in the courts'.
In 2011, the Federal Judicial Conference surveyed federal court clerks offices regarding pro se issues.
They found that only 17 of 62 responding judges report that discovery is taken in most non prisoner pro se cases and only 13 reported that discovery is taken in most prisoner pro se cases.
In the same survey, 37% of judges found that most pro ses had problems examining witnesses, while 30% found that pro ses had no or few problems examining witnesses.
53% found that represented parties sometimes or frequently take advantage of pro se parties.
Only 5% reported problems of pro ses behaving inappropriately at hearings.
Respondents to the FJC study did not report any orders against non prisoner pro se litigation.
Some pro se litigants who are federal prisoners are subject to the Prison Litigation Reform Act. The American Civil Liberties Union (ACLU) has asserted:
"“For over thirteen years, the Prison Litigation Reform Act has denied access to the courts to countless prisoners who have become victims of abuse,
creating a system of injustice that denies redress for prisoners alleging serious abuses, barriers that don't apply to anyone else. It is time for Congress to pass legislation to restore the courts as a needed check on prisoner abuse.”
54% of judges responding to a Federal Judicial Conference survey use videoconferences for prisoner pro se hearings.
In criminal court
Pro se representation presents unique but not insurmountable challenges for claimants and the legal system. In Louisiana, for instance, the Louisiana Court of Appeals tracks the results of pro se appeals against represented appeals. In 2000, 7% of writs in civil appeals submitted to the court pro se were granted, compared to 46% of writs submitted by counsel.
In criminal cases the ratio is closer - 34% of pro se writs were granted, compared with 45% of writs submitted by counsel.
According to Erica J. Hashimoto, an assistant professor at the Georgia School of Law,:
“After conducting an empirical study of pro se felony defendants, I conclude that these defendants are not necessarily either ill-served by the decision to represent themselves or mentally ill….In state court, pro se defendants charged with felonies fared as well as,
and arguably significantly better than, their represented counterparts…of the 234 pro se defendants for whom an outcome was provided, just under 50 percent of them were convicted on any charge….
for represented state court defendants, by contrast, a total of 75 percent were convicted of some charge…. Only 26 percent of the pro se defendants ended up with felony convictions, while 63 percent of their represented counterparts were convicted of felonies…in federal court…the acquittal rate for pro se defendants is virtually identical to the acquittal rate for represented defendants.”
Since an independent evaluation of the cases is difficult, this study can by design not distinguish whether defendants without representation face a greater challenge or whether defendants are more likely to choose representation when in doubt of the merit of their case.
This may occur in any court proceeding, whether one is the defendant or plaintiff in civil cases, and when one is a defendant in criminal cases.
Pro se is a Latin phrase meaning "for oneself" or "on one's own behalf". This status is sometimes known as propria persona (abbreviated to "pro per").
In England and Wales the comparable status is that of "litigant in person".
The right of a party to a legal action to represent his or her own cause has long been recognized in the United States, and even predates the ratification of the Constitution.
The Supreme Court noted that "[i]n the federal courts, the right of self-representation has been protected by statute since the beginnings of our Nation.
Section 35 of the Judiciary Act of 1789, 1 Stat. 73, 92, enacted by the First Congress and signed by President Washington one day before the Sixth Amendment was proposed,
provided that 'in all the courts of the United States, the parties may plead and manage their own causes personally or by the assistance of counsel.
In Faretta v. California, the Supreme Court of the United States held that criminal defendants have a constitutional right to refuse counsel
and represent themselves in state criminal proceedings.
That said, the right to represent oneself is not absolute.
It is the Court's right and duty to determine if a particular individual is capable of representing himself, and can inquire into the individual's lucidity and mental status to make that determination
Most U.S. states have a constitutional provision that either expressly or by interpretation allows individuals to represent their own causes in the courts of that state.
In many instances, state constitutional provisions regarding the right to petition the government for redress of grievances have been so interpreted.
The U.S. Judiciary Act, the Code of Conduct for United States Judges,
the Federal Rules of Civil Procedure, the Federal Rules of Criminal Procedure, the Federal Rules of Evidence and the Federal Rules of Appellate Procedure address the rights of the self-represented litigant in several places.
Section 1654 of title 28 of the United States Code provides: "In all courts of the United States the parties may plead and conduct their own cases personally or by counsel as, by the rules of such courts, respectively, are permitted to manage and conduct causes therein."
Laws and organizations charged with regulating judicial conduct may also impact pro se litigants. For example, The State of California Judicial Council has addressed through published materials the need of the Judiciary to act in the interests of fairness to self-represented litigants.
The California rules express a preference for resolution of every case on the merits, even if resolution requires excusing inadvertence by a pro se litigant that would otherwise result in a dismissal. The Judicial Council justifies this position based on the idea that "Judges are charged with ascertaining the truth, not just playing referee...
A lawsuit is not a game, where the party with the cleverest lawyer prevails regardless of the merits."
It suggests "the court should take whatever measures may be reasonable and necessary to insure a fair trial" and says "There is only one reported case in the U.S. finding a judge's specific accommodations have gone too far".The committee notes to the Federal Rules of Civil Procedure rule 56 on summary judgements notes that
"Many courts take extra care with pro se litigants, advising them of the need to respond and the risk of losing by summary judgment if an adequate response is not filed.
And the court may seek to reassure itself by some examination of the record before granting summary judgment against a pro se litigant."
Starting November 1, 2011, the Federal Court for the Central District of California permits pro se litigants to receive documents electronically by an Electronic Filing Account (ECF). As of May 16, 2013, they are still prohibited from filing their documents electronically unlike litigants represented by counsel.
The November 1, 2011 policy of the Central District of California is a cost-saving measure for the court. All they have to do is send in the form, have a PACER account, and provide a valid email address.
According to a June 2012 report from U.S. Courts, 18 of 94 federal district courts authorize use of ADR (Alternative Dispute Resolution) for pro ses and 11 authorize use of ADR by prisoner pro ses. Thirty seven of the ninety four federal districts allow pro se litigants to use ECF.
The ability of a party to proceed without an attorney in prosecuting or defending a civil action is largely a matter of state law, and may vary depending on the court and the positions of the parties.
A longstanding and widely practiced rule prohibits corporations from being represented by non-attorneys,
consistent with the existence of a corporation as a "person" separate and distinct from its shareholders, officers and employees.
The Wisconsin Supreme Court has stated: "A nonlawyer may not sign and file a notice of appeal on behalf of a corporation.
Requiring a lawyer to represent a corporation in filing the notice does not violate the guarantee that any suitor may prosecute or defend a suit personally. A corporation is not a natural person and does not fall with in the term “any suitor.”
Similarly, a pro se litigant may not act as a class representative in a class action lawsuit and therefore a pro se litigant may not bring a class action.
Furthermore, a non-attorney parent may not appear on behalf of his or her child, except to appeal the denial of social security benefits to such child.
Another situation in which appearance through counsel is often required is in a case involving the executor or personal administrator of a probate estate. Unless the executor or administrator is himself an attorney, he is not allowed to represent himself in matters other than the probate.
Some federal court of appeals allow unrepresented litigants to argue orally (even so nonargument disposition is still possible), and in all courts the percentage of cases in which argument occurs is higher for counseled cases.
The Connecticut Supreme Court narrowed criminal defendant's right to self representation, stating that "we are free to adopt for mentally ill
or mentally incapacitated defendants who wish to represent themselves at trial a competency standard that differs from the standard for determining whether such a defendant is competent to stand trial".
A Senior Assistant State’s Attorney explained that the new standard essentially allows judges to consider whether the defendants are competent enough to perform the skills needed to defend themselves, including composing questions for voir dire and witnesses.
Some courts issue orders against self representation in civil cases. A court enjoined a former attorney from suing the new lover of her former attorney.
The Superior Court of Bergen New Jersey also issued an order against pro se litigation based on a number of lawsuits that were dismissed and a failure to provide income tax returns in case sanctions might issue.
The Superior Court of New Jersey issued an order prohibiting a litigant from filing in federal court.
The Third Circuit however ruled that a restriction on pro se litigation went too far and that it could not be enforced if a litigant certified that he has new claims that were never before disposed of on the merits.
The 10th Circuit ruled that before imposing filing restrictions, a district court must set forth examples of abusive filings and that if the district court did not do so, the filing restrictions must be vacated.
The District of Columbia Court of Appeals wrote that "private individuals have 'a constitutional right of access to the courts',
that is, the 'right to sue and defend in the courts'.
In 2011, the Federal Judicial Conference surveyed federal court clerks offices regarding pro se issues.
They found that only 17 of 62 responding judges report that discovery is taken in most non prisoner pro se cases and only 13 reported that discovery is taken in most prisoner pro se cases.
In the same survey, 37% of judges found that most pro ses had problems examining witnesses, while 30% found that pro ses had no or few problems examining witnesses.
53% found that represented parties sometimes or frequently take advantage of pro se parties.
Only 5% reported problems of pro ses behaving inappropriately at hearings.
Respondents to the FJC study did not report any orders against non prisoner pro se litigation.
Some pro se litigants who are federal prisoners are subject to the Prison Litigation Reform Act. The American Civil Liberties Union (ACLU) has asserted:
"“For over thirteen years, the Prison Litigation Reform Act has denied access to the courts to countless prisoners who have become victims of abuse,
creating a system of injustice that denies redress for prisoners alleging serious abuses, barriers that don't apply to anyone else. It is time for Congress to pass legislation to restore the courts as a needed check on prisoner abuse.”
54% of judges responding to a Federal Judicial Conference survey use videoconferences for prisoner pro se hearings.
In criminal court
Pro se representation presents unique but not insurmountable challenges for claimants and the legal system. In Louisiana, for instance, the Louisiana Court of Appeals tracks the results of pro se appeals against represented appeals. In 2000, 7% of writs in civil appeals submitted to the court pro se were granted, compared to 46% of writs submitted by counsel.
In criminal cases the ratio is closer - 34% of pro se writs were granted, compared with 45% of writs submitted by counsel.
According to Erica J. Hashimoto, an assistant professor at the Georgia School of Law,:
“After conducting an empirical study of pro se felony defendants, I conclude that these defendants are not necessarily either ill-served by the decision to represent themselves or mentally ill….In state court, pro se defendants charged with felonies fared as well as,
and arguably significantly better than, their represented counterparts…of the 234 pro se defendants for whom an outcome was provided, just under 50 percent of them were convicted on any charge….
for represented state court defendants, by contrast, a total of 75 percent were convicted of some charge…. Only 26 percent of the pro se defendants ended up with felony convictions, while 63 percent of their represented counterparts were convicted of felonies…in federal court…the acquittal rate for pro se defendants is virtually identical to the acquittal rate for represented defendants.”
Since an independent evaluation of the cases is difficult, this study can by design not distinguish whether defendants without representation face a greater challenge or whether defendants are more likely to choose representation when in doubt of the merit of their case.
Defendant “Antoine L. Freeman J.D. (Attorney at Law)” Cause No. 1:14-CV-592 “First Set of Interrogatories”
Subpart (U)
Explain in full expert “Attorney at Law” details, and Supply in full details also any and all legal court documents,
docket reports, court ledgers, letters, faxes, text, memos, emails, “filed motions for
withdrawal of counsel” all records in support thereof from the exact date of June 1st 2009
throughout July 1st 2009 In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” Bar
No. 24058299 herein
Was not legally representing any “material physical fact’s in the professional legal public capacity
as a acting “Attorney at Law“ In and for the “Sate of Texas” Bar No. 24058299
Before the 58th Judicial District Court of Jefferson County Texas described herein thereafter
Namely said “Honorable Judge Bob Wortham”
Herein in connection with one “Joyce M. Guy and Edward McCray” hereafter Co-Defendant(s) collectively
In a civil suit in the 58th Judicial District Court of Jefferson County Texas filed in Cause No. A-180805 in Jefferson County Texas.
In that Namely exactly “Antoine L. Freeman, J.D. “Attorney at Law” Texas Bar No. 24058299”
(active) within the “State of Texas” was not providing such any physical presentation, representation
and appearance thereof as acting “Attorney at Record Law services” for the full skilled “legal behalf” and
“retain interest” June 1st 2009 throughout July 1st 2009 In a civil suit in the 58th Judicial
District Court of Jefferson County Texas filed in Cause No. A-180805
Before an “Honorable Court of Law” in cause No. A-180805 filed in the Jefferson County Texas Courthouse November 26th 2007
For their combine legal representation of said Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein in a format regarding “among other things”
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein
explaining he was not making Public Representation, presentation in the Profession as a “skilled counsel of law”
Before the “Honorable Judge Bob Wortham, the “Honorable Judge Bob Wortham” staff namely
“Ms. Sydney Moreau”, the Court reporters, and the court bailiff’s, thereafter June 1st 2009 throughout
July 1st 2009 In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein
was not making any Public Representation, presentation in the Profession as a “skilled counsel of
law” Before The Jefferson County Clerk of Court “Lolita Ramos”,
And all (active) Deputy Clerks acting on behalf of said Jefferson County Clerk of Court “Lolita Ramos,
involved in the records thereof, filed as Pro Se Plaintiff attached Document(s) # 1 and
Documents # 11herein
Namely” the 58th Judicial District Court of Jefferson County Texas “Case Ledger” for Cause No. A-180805
Namely” the 58th Judicial District Court of Jefferson County Texas “Civil Docket report” for cause No. A-180805
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein
was not physically acting as “Attorney of Record” before the 58th Judicial District Court of Jefferson County Texas
for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf”
at no physical time frame other then retain filing services for December 18th 2007 “General Denial” paid services render
(only).
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein
was not filing any legal court documents for their legal behalf of said Co-Defendant(s) collectively through
the “United States Mailing System” thereafter June 1st 2009 throughout July 1st 2009
And forwarding such to the “Honorable Judge Bob Wortham, to the “Honorable Judge Bob Wortham” staff namely
“Ms. Sydney Moreau”, to The Jefferson County Clerk of Court “Lolita Ramos”,
And all (active) Deputy Clerks acting on behalf of said Jefferson County Clerk of Court “Lolita Ramos,
involved in the records thereof, filed as Pro Se Plaintiff attached Document(s) # 1 and
Documents # 11herein
Namely” the 58th Judicial District Court of Jefferson County Texas “Case Ledger” for Cause No. A-180805
Namely” the 58th Judicial District Court of Jefferson County Texas “Civil Docket report” for cause No. A-180805
With direct Usage of the “United States Mailing System” surround civil court event thereafter
June 1st 2009 throughout July 1st 2009 for their legal behalf of said Co-Defendant(s) collectively through the “United States Mailing System”
Namely in that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein
was not physically executing the usage of the “United States Mailing System” in the capacity of
acting “Attorney of Record” thereafter June 1st 2009 throughout July 1st 2009
For the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” at no physical time frame other then retain
filing services for December 18th 2007 “General Denial” paid services render (only).
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein
was not physically involved with inner actions on live “court transcripts” with the 58th Court reporters thereafter
June 1st 2009 throughout July 1st 2009 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not present before
the 58th Judicial District Court of Jefferson County Texas bailiff’s, thereafter the time frame
of June 1st 2009 throughout July 1st 2009
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation,
presentation of material facts as acting “Attorney of record” Before
the “Honorable Judge Bob Wortham”, thereafter the date of June 1st 2009 throughout July 1st 2009
for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation,
presentation of material facts as acting “Attorney of record” before
The “Honorable Judge Bob Wortham” staff namely “Ms. Sydney Moreau”, thereafter the Date of
June 1st 2009 throughout July 1st 2009 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray”
legal behalf” in cause No. A-180805
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation,
presentation of material facts as acting “Attorney of record” before the
Jefferson County Clerk “Lolita Ramos”, record office of Jefferson County Texas thereafter the Date of
June 1st 2009 throughout July 1st 2009 for the Co-Defendant(s) “Joyce M. Guy and Edward
McCray” legal behalf” in cause No. A-180805
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein
was not involved in any “attorney/client”, work product thereof, and making such a presentations and
representations of “material facts” as acting physically in the professional capacity of acting “Attorney of record”
Before the “Honorable Judge Bob Wortham”, against said Pro Se Plaintiff “Louis Charles Hamilton II” herein
subject matter in complaint against the Co-Defendant(s) “Joyce M. Guy and Edward
McCray” legal behalf” thereafter June 1st 2009 throughout July 1st 2009 in cause No. A-180805
“Meaning” in that Chief Defendant “Antoine L. Freeman, J.D. “Attorney at Law” Texas Bar No240582299
was not in any shape or form involved in any “attorney/client”, work product
thereof, “attorney/client” communications thereof,
And making such a physical presentations and representations of “material facts” as acting physically in the professional capacity of acting “Attorney of record”.
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was (Only)
acting in the “legal capacitates” as a Attorney at Law to file a General Denial (Only) on December 18th
2007
To “simply” reply in the Complaint A-180805 made against Co-Defendant(s) “Joyce M. Guy and Edward McCray”
( Herein ) collectively and such “legal attorney at law retain services” ended
thereafter the exact date of December 18th 2007
In a civil suit in the 58th Judicial District Court of Jefferson County Texas filed in Cause No. A-180805
that you Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” were legally
retain for such legal services to file a General Denial (Only)
Regarding a “Breach of Construction Contract” in excess of $10,800.00 U.S. Dollars as described by
“You” Defendant (Attorney at Law) your only being retain for services, and contract for all legal
services thereof required for such professional legal services to file a simple “General Denial” (Only) on December 18th 2007
As described in Pro Se Plaintiff attached Document # 2 herein
“Your” response to Pro Se Plaintiff Motion for Sanction against “You”
Chief Defendant “Antoine L. Freeman, J.D. “Attorney at Law” Texas Bar No. 24058299 herein describing your “legal attorney at
law retain services” ended thereafter the exact date of December 18th 2007
In a civil suit in the 58th Judicial District Court of Jefferson County Texas filed in Cause No. A-180805
Surrounding Pro Se Plaintiff claims of a chain of fraudulent events as a result of Hurricane Rita, Humberto and Ike
for said dwelling and the property located at 448 DeQueen Blvd. in Port Arthur
Texas. (Block 172, Lot 1-2) in connection with Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein.
Subpart (V)
Explain in full expert “Attorney at Law” details, and Supply in full details also any and all legal court documents,
docket reports, court ledgers, letters, faxes, text, memos, emails, “filed motions for
withdrawal of counsel” all records in support thereof from the exact date of July 1st 2009 throughout the exact dates of August 1st 2009
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” Bar No. 24058299 herein
Was not legally representing any “material physical fact’s in the professional legal public capacity as
a acting “Attorney at Law“ In and for the “Sate of Texas” Bar No. 24058299
Before the 58th Judicial District Court of Jefferson County Texas described herein thereafter
Namely said “Honorable Judge Bob Wortham”
Herein in connection with one “Joyce M. Guy and Edward McCray” hereafter Co-Defendant(s) collectively
In a civil suit in the 58th Judicial District Court of Jefferson County Texas filed in Cause No. A-180805 in Jefferson County Texas.
In that Namely exactly “Antoine L. Freeman, J.D. “Attorney at Law” Texas Bar No. 24058299”
(active) within the “State of Texas” was not providing such any physical presentation, representation
and appearance thereof as acting “Attorney at Record Law services” for the full skilled “legal behalf” and
“retain interest” thereafter July 1st 2009 throughout the exact dates of August 1st 2009
In a civil suit in the 58th Judicial District Court of Jefferson County Texas filed in Cause No. A-180805
Before an “Honorable Court of Law” in cause No. A-180805 filed in the Jefferson County Texas Courthouse November 26th 2007
For their combine legal representation of said Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein in a format regarding “among other things”
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law”
herein explaining he was not making Public Representation, presentation in the Profession as a “skilled counsel of law”
Before the “Honorable Judge Bob Wortham, the “Honorable Judge Bob Wortham” staff namely
“Ms. Sydney Moreau”, the Court reporters, and the court bailiff’s, thereafter July 1st 2009 throughout
the exact dates of August 1st 2009
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any Public Representation,
presentation in the Profession as a “skilled counsel of law” Before The
Jefferson County Clerk of Court “Lolita Ramos”,
And all (active) Deputy Clerks acting on behalf of said Jefferson County Clerk of Court “Lolita Ramos,
involved in the records thereof, filed as Pro Se Plaintiff attached Document(s) # 1 and
Documents # 11herein
Namely” the 58th Judicial District Court of Jefferson County Texas “Case Ledger” for Cause No. A-180805
Namely” the 58th Judicial District Court of Jefferson County Texas “Civil Docket report” for cause No. A-180805
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein
was not physically acting as “Attorney of Record” before the 58th Judicial District Court of Jefferson County Texas
for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf”
at no physical time frame other then retain filing services for December 18th 2007 “General Denial” paid services render
(only).
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein
was not filing any legal court documents for their legal behalf of said Co-Defendant(s) collectively through
the “United States Mailing System” thereafter July 1st 2009 throughout the exact dates of August 1st 2009
And forwarding such to the “Honorable Judge Bob Wortham, to the “Honorable Judge Bob Wortham” staff namely
“Ms. Sydney Moreau”, to The Jefferson County Clerk of Court “Lolita Ramos”,
And all (active) Deputy Clerks acting on behalf of said Jefferson County Clerk of Court “Lolita Ramos,
involved in the records thereof, filed as Pro Se Plaintiff attached Document(s) # 1 and
Documents # 11herein
Namely” the 58th Judicial District Court of Jefferson County Texas “Case Ledger” for Cause No. A-180805
Namely” the 58th Judicial District Court of Jefferson County Texas “Civil Docket report” for cause No. A-180805
With direct Usage of the “United States Mailing System” surround civil court event thereafter
February 1st 2009 throughout the exact dates of July 1st 2009 throughout the exact dates of August 1st
2009 for their legal behalf of said Co-Defendant(s) collectively through the “United States Mailing System”
Namely in that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein
was not physically executing the usage of the “United States Mailing System” in the capacity of
acting “Attorney of Record” thereafter July 1st 2009 throughout the exact dates of August 1st 2009
For the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” at no physical time frame other then
retain filing services for December 18th 2007 “General Denial” paid services render (only).
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein
was not physically involved with inner actions on live “court transcripts” with the 58th Court reporters thereafter
July 1st 2009 throughout the exact dates of August 1st 2009 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein
was not present before the 58th Judicial District Court of Jefferson County Texas bailiff’s, thereafter the time frame
of July 1st 2009 throughout the exact dates of August 1st 2009
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation,
presentation of material facts as acting “Attorney of record” Before
the “Honorable Judge Bob Wortham”, thereafter the date of July 1st 2009 throughout the exact dates of
August 1st 2009 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation,
presentation of material facts as acting “Attorney of record” before
The “Honorable Judge Bob Wortham” staff namely “Ms. Sydney Moreau”, thereafter the Date of July 1st 2009
throughout the exact dates of August 1st 2009 for the Co-Defendant(s) “Joyce M. Guy
and Edward McCray” legal behalf” in cause No. A-180805
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation,
presentation of material facts as acting “Attorney of record” before the
Jefferson County Clerk “Lolita Ramos”, record office of Jefferson County Texas thereafter the Date of
July 1st 2009 throughout the exact dates of August 1st 2009 for the Co-Defendant(s) “Joyce M.
Guy and Edward McCray” legal behalf” in cause No. A-180805
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein
was not involved in any “attorney/client”, work product thereof, and making such a presentations and
representations of “material facts” as acting physically in the professional capacity of acting “Attorney of record”
Before the “Honorable Judge Bob Wortham”, against said Pro Se Plaintiff “Louis Charles Hamilton II” herein
subject matter in complaint against the Co-Defendant(s) “Joyce M. Guy and Edward
McCray” legal behalf” thereafter of July 1st 2009 throughout the exact dates of August 1st 2009 in cause No. A-180805
“Meaning” in that Chief Defendant “Antoine L. Freeman, J.D. “Attorney at Law” Texas Bar No240582299
was not in any shape or form involved in any “attorney/client”, work product
thereof, “attorney/client” communications thereof,
And making such a physical presentations and representations of “material facts” as acting physically in the professional capacity of acting “Attorney of record”.
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was
(Only) acting in the “legal capacitates” as a Attorney at Law to file a General Denial (Only) on December 18th 2007
To “simply” reply in the Complaint A-180805 made against Co-Defendant(s) “Joyce M. Guy and Edward McCray”
( Herein ) collectively and such “legal attorney at law retain services” ended
thereafter the exact date of December 18th 2007
In a civil suit in the 58th Judicial District Court of Jefferson County Texas filed in Cause No. A-180805
that you Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” were legally
retain for such legal services to file a General Denial (Only)
Regarding a “Breach of Construction Contract” in excess of $10,800.00 U.S. Dollars as described by
“You” Defendant (Attorney at Law) your only being retain for services, and contract for all legal
services thereof required for such professional legal services to file a simple “General Denial” (Only) on December 18th 2007
As described in Pro Se Plaintiff attached Document # 2 herein
“Your” response to Pro Se Plaintiff Motion for Sanction against
“You” Chief Defendant “Antoine L. Freeman, J.D. “Attorney at Law” Texas Bar No. 24058299 herein describing your “legal attorney at
law retain services” ended thereafter the exact date of December 18th 2007
In a civil suit in the 58th Judicial District Court of Jefferson County Texas filed in Cause No. A-180805
Surrounding Pro Se Plaintiff claims of a chain of fraudulent events as a result of Hurricane Rita, Humberto and Ike
for said dwelling and the property located at 448 DeQueen Blvd. in Port Arthur
Texas. (Block 172, Lot 1-2) in connection with Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein.
Subpart (W)
Explain in full expert “Attorney at Law” details, and Supply in full details also any and all legal court documents,
docket reports, court ledgers, letters, faxes, text, memos, emails, “filed motions for
withdrawal of counsel” all records in support thereof from the exact date of August 1st 2009 throughout the exact dates of September 1st 2009
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” Bar No. 24058299 herein
Was not legally representing any “material physical fact’s in the professional legal public capacity as
a acting “Attorney at Law“ In and for the “Sate of Texas” Bar No. 24058299
Before the 58th Judicial District Court of Jefferson County Texas described herein thereafter
Namely said “Honorable Judge Bob Wortham”
Herein in connection with one “Joyce M. Guy and Edward McCray” hereafter Co-Defendant(s) collectively
In a civil suit in the 58th Judicial District Court of Jefferson County Texas filed in Cause No. A-180805 in Jefferson County Texas.
In that Namely exactly “Antoine L. Freeman, J.D. “Attorney at Law” Texas Bar No. 24058299”
(active) within the “State of Texas” was not providing such any physical presentation, representation
and appearance thereof as acting “Attorney at Record Law services” for the full skilled “legal behalf”
and “retain interest” thereafter August 1st 2009 throughout the exact dates of September 1st 2009
In a civil suit in the 58th Judicial District Court of Jefferson County Texas filed in Cause No. A-180805
Before an “Honorable Court of Law” in cause No. A-180805 filed in the Jefferson County Texas Courthouse November 26th 2007
For their combine legal representation of said Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein in a format regarding “among other things”
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein
explaining he was not making Public Representation, presentation in the Profession as a “skilled counsel of law”
Before the “Honorable Judge Bob Wortham, the “Honorable Judge Bob Wortham” staff namely
“Ms. Sydney Moreau”, the Court reporters, and the court bailiff’s, thereafter August 1st 2009
throughout the exact dates of September 1st 2009
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any Public Representation,
presentation in the Profession as a “skilled counsel of law” Before The
Jefferson County Clerk of Court “Lolita Ramos”,
And all (active) Deputy Clerks acting on behalf of said Jefferson County Clerk of Court “Lolita Ramos,
involved in the records thereof, filed as Pro Se Plaintiff attached Document(s) # 1 and
Documents # 11herein
Namely” the 58th Judicial District Court of Jefferson County Texas “Case Ledger” for Cause No. A-180805
Namely” the 58th Judicial District Court of Jefferson County Texas “Civil Docket report” for cause No. A-180805
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not physically acting as
“Attorney of Record” before the 58th Judicial District Court of Jefferson County Texas
for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” at no physical time frame other then
retain filing services for December 18th 2007 “General Denial” paid services render (only).
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein
was not filing any legal court documents for their legal behalf of said Co-Defendant(s) collectively through
the “United States Mailing System” thereafter August 1st 2009 throughout the exact dates of September 1st 2009
And forwarding such to the “Honorable Judge Bob Wortham, to the “Honorable Judge Bob Wortham”
staff namely “Ms. Sydney Moreau”, to The Jefferson County Clerk of Court “Lolita Ramos”,
And all (active) Deputy Clerks acting on behalf of said Jefferson County Clerk of Court “Lolita Ramos,
involved in the records thereof, filed as Pro Se Plaintiff attached Document(s) # 1 and
Documents # 11herein
Namely” the 58th Judicial District Court of Jefferson County Texas “Case Ledger” for Cause No. A-180805
Namely” the 58th Judicial District Court of Jefferson County Texas “Civil Docket report” for cause No. A-180805
With direct Usage of the “United States Mailing System” surround civil court event thereafter August 1st 2009
throughout the exact dates of September 1st 2009 for their legal behalf of said Co-
Defendant(s) collectively through the “United States Mailing System”
Namely in that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein
was not physically executing the usage of the “United States Mailing System” in the capacity of
acting “Attorney of Record” thereafter August 1st 2009 throughout the exact dates of September 1st 2009
For the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” at no physical time frame other then
retain filing services for December 18th 2007 “General Denial” paid services render (only).
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not physically involved with inner actions on live
“court transcripts” with the 58th Court reporters thereafter
August 1st 2009 throughout the exact dates of September 1st 2009 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein
was not present before the 58th Judicial District Court of Jefferson County Texas bailiff’s, thereafter the time frame
of August 1st 2009 throughout the exact dates of September 1st 2009
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation,
presentation of material facts as acting “Attorney of record” Before
the “Honorable Judge Bob Wortham”, thereafter the date of August 1st 2009 throughout the exact dates of
September 1st 2009 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal
behalf” in cause No. A-180805
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation,
presentation of material facts as acting “Attorney of record” before
The “Honorable Judge Bob Wortham” staff namely “Ms. Sydney Moreau”, thereafter the Date of August 1st 2009
throughout the exact dates of September 1st 2009 for the Co-Defendant(s) “Joyce
M. Guy and Edward McCray” legal behalf” in cause No. A-180805
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation,
presentation of material facts as acting “Attorney of record” before the
Jefferson County Clerk “Lolita Ramos”, record office of Jefferson County Texas thereafter the Date of
August 1st 2009 throughout the exact dates of September 1st 2009 for the Co-Defendant
(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein
was not involved in any “attorney/client”, work product thereof, and making such a presentations and
representations of “material facts” as acting physically in the professional capacity of acting “Attorney of record”
Before the “Honorable Judge Bob Wortham”, against said Pro Se Plaintiff “Louis Charles Hamilton II” herein
subject matter in complaint against the Co-Defendant(s) “Joyce M. Guy and Edward
McCray” legal behalf” thereafter of August 1st 2009 throughout the exact dates of September 1st 2009 in cause No. A-180805
“Meaning” in that Chief Defendant “Antoine L. Freeman, J.D. “Attorney at Law” Texas Bar No240582299
was not in any shape or form involved in any “attorney/client”, work product thereof, “attorney/client” communications thereof,
And making such a physical presentations and representations of “material facts” as acting physically in the professional capacity of acting “Attorney of record”.
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was (Only) acting in the “legal capacitates”
as a Attorney at Law to file a General Denial (Only) on December 18th 2007
To “simply” reply in the Complaint A-180805 made against Co-Defendant(s) “Joyce M. Guy and Edward McCray”
( Herein ) collectively and such “legal attorney at law retain services” ended
thereafter the exact date of December 18th 2007
In a civil suit in the 58th Judicial District Court of Jefferson County Texas filed in Cause No. A-180805
that you Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” were legally
retain for such legal services to file a General Denial (Only)
Regarding a “Breach of Construction Contract” in excess of $10,800.00 U.S. Dollars
as described by “You” Defendant (Attorney at Law) your only being retain for services, and contract for all legal
services thereof required for such professional legal services to file a simple “General Denial” (Only) on December 18th 2007
As described in Pro Se Plaintiff attached Document # 2 herein
“Your” response to Pro Se Plaintiff Motion for Sanction against “You”
Chief Defendant “Antoine L. Freeman, J.D. “Attorney at Law” Texas Bar No. 24058299 herein describing your “legal attorney at
law retain services” ended thereafter the exact date of December 18th 2007
In a civil suit in the 58th Judicial District Court of Jefferson County Texas filed in Cause No. A-180805
Surrounding Pro Se Plaintiff claims of a chain of fraudulent events as a result of Hurricane Rita, Humberto and Ike
for said dwelling and the property located at 448 DeQueen Blvd. in Port Arthur Texas. (Block 172, Lot 1-2)
in connection with Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein.
Subpart (X)
Explain in full expert “Attorney at Law” details, and Supply in full details also any and all legal court documents,
docket reports, court ledgers, letters, faxes, text, memos, emails, “filed motions for
withdrawal of counsel” all records in support thereof from the exact date of September 1st 2009 throughout the exact dates of October 1st 2009
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” Bar No. 24058299 herein
Was not legally representing any “material physical fact’s in the professional legal public capacity as
a acting “Attorney at Law“ In and for the “Sate of Texas” Bar No. 24058299
Before the 58th Judicial District Court of Jefferson County Texas described herein thereafter
Namely said “Honorable Judge Bob Wortham”
Herein in connection with one “Joyce M. Guy and Edward McCray” hereafter Co-Defendant(s) collectively
In a civil suit in the 58th Judicial District Court of Jefferson County Texas filed in Cause No. A-180805 in Jefferson County Texas.
In that Namely exactly “Antoine L. Freeman, J.D. “Attorney at Law” Texas Bar No. 24058299”
(active) within the “State of Texas” was not providing such any physical presentation, representation
and appearance thereof as acting “Attorney at Record Law services” for the full skilled “legal behalf” and
“retain interest” thereafter September 1st 2009 throughout the exact dates of October 1st 2009
In a civil suit in the 58th Judicial District Court of Jefferson County Texas filed in Cause No. A-180805
Before an “Honorable Court of Law” in cause No. A-180805 filed in the Jefferson County Texas Courthouse November 26th 2007
For their combine legal representation of said Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein in a format regarding “among other things”
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein
explaining he was not making Public Representation, presentation in the Profession as a “skilled counsel of law”
Before the “Honorable Judge Bob Wortham, the “Honorable Judge Bob Wortham” staff namely
“Ms. Sydney Moreau”, the Court reporters, and the court bailiff’s, thereafter September 1st 2009
throughout the exact dates of October 1st 2009
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any Public Representation,
presentation in the Profession as a “skilled counsel of law” Before The
Jefferson County Clerk of Court “Lolita Ramos”,
And all (active) Deputy Clerks acting on behalf of said Jefferson County Clerk of Court “Lolita Ramos,
involved in the records thereof, filed as Pro Se Plaintiff attached Document(s) # 1 and
Documents # 11herein
Namely” the 58th Judicial District Court of Jefferson County Texas “Case Ledger” for Cause No. A-180805
Namely” the 58th Judicial District Court of Jefferson County Texas “Civil Docket report” for cause No. A-180805
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein
was not physically acting as “Attorney of Record” before the 58th Judicial District Court of Jefferson County Texas
for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” at no physical time frame other then
retain filing services for December 18th 2007 “General Denial” paid services render
(only).
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein
was not filing any legal court documents for their legal behalf of said Co-Defendant(s) collectively through
the “United States Mailing System” thereafter September 1st 2009 throughout the exact dates of October 1st 2009
And forwarding such to the “Honorable Judge Bob Wortham, to the “Honorable Judge Bob Wortham” staff namely
“Ms. Sydney Moreau”, to The Jefferson County Clerk of Court “Lolita Ramos”,
And all (active) Deputy Clerks acting on behalf of said Jefferson County Clerk of Court “Lolita Ramos,
involved in the records thereof, filed as Pro Se Plaintiff attached Document(s) # 1 and
Documents # 11herein
Namely” the 58th Judicial District Court of Jefferson County Texas “Case Ledger” for Cause No. A-180805
Namely” the 58th Judicial District Court of Jefferson County Texas “Civil Docket report” for cause No. A-180805
With direct Usage of the “United States Mailing System” surround civil court event thereafter
September 1st 2009 throughout the exact dates of October 1st 2009 for their legal behalf of said Co-
Defendant(s) collectively through the “United States Mailing System”
Namely in that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein
was not physically executing the usage of the “United States Mailing System” in the capacity of
acting “Attorney of Record” thereafter September 1st 2009 throughout the exact dates of October 1st 2009
For the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” at no physical time frame other then
retain filing services for December 18th 2007 “General Denial” paid services render (only).
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not physically
involved with inner actions on live “court transcripts” with the 58th Court reporters thereafter
September 1st 2009 throughout the exact dates of October 1st 2009 for
the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not present before
the 58th Judicial District Court of Jefferson County Texas bailiff’s, thereafter the time frame
of September 1st 2009 throughout the exact dates of October 1st 2009
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation,
presentation of material facts as acting “Attorney of record” Before
the “Honorable Judge Bob Wortham”, thereafter the date of September 1st 2009 throughout the exact dates of
October 1st 2009 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal
behalf” in cause No. A-180805
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation,
presentation of material facts as acting “Attorney of record” before
The “Honorable Judge Bob Wortham” staff namely “Ms. Sydney Moreau”, thereafter the Date of
September 1st 2009 throughout the exact dates of October 1st 2009 for the Co-Defendant(s) “Joyce
M. Guy and Edward McCray” legal behalf” in cause No. A-180805
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation,
presentation of material facts as acting “Attorney of record” before the
Jefferson County Clerk “Lolita Ramos”, record office of Jefferson County Texas thereafter
the Date of September 1st 2009 throughout the exact dates of October 1st 2009 for the Co-Defendant
(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein
was not involved in any “attorney/client”, work product thereof, and making such a presentations and
representations of “material facts” as acting physically in the professional capacity of acting “Attorney of record”
Before the “Honorable Judge Bob Wortham”, against said Pro Se Plaintiff “Louis Charles Hamilton II” herein
subject matter in complaint against the Co-Defendant(s) “Joyce M. Guy and Edward
McCray” legal behalf” thereafter of September 1st 2009 throughout the exact dates of October 1st 2009 in cause No. A-180805
“Meaning” in that Chief Defendant “Antoine L. Freeman, J.D. “Attorney at Law” Texas Bar No240582299
was not in any shape or form involved in any “attorney/client”, work product
thereof, “attorney/client” communications thereof,
And making such a physical presentations and representations of “material facts” as acting physically in the professional capacity of acting “Attorney of record”.
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was (Only) acting in the “legal capacitates” as
a Attorney at Law to file a General Denial (Only) on December 18th 2007
To “simply” reply in the Complaint A-180805 made against Co-Defendant(s) “Joyce M. Guy and Edward McCray”
( Herein ) collectively and such “legal attorney at law retain services” ended
thereafter the exact date of December 18th 2007
In a civil suit in the 58th Judicial District Court of Jefferson County Texas filed in Cause No. A-180805 that you
Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” were legally
retain for such legal services to file a General Denial (Only)
Regarding a “Breach of Construction Contract” in excess of $10,800.00 U.S. Dollars as described by
“You” Defendant (Attorney at Law) your only being retain for services, and contract for all legal
services thereof required for such professional legal services to file a simple “General Denial” (Only) on December 18th 2007
As described in Pro Se Plaintiff attached Document # 2 herein
“Your” response to Pro Se Plaintiff Motion for Sanction against “You”
Chief Defendant “Antoine L. Freeman, J.D. “Attorney at Law” Texas Bar No. 24058299 herein describing your “legal attorney at
law retain services” ended thereafter the exact date of December 18th 2007
In a civil suit in the 58th Judicial District Court of Jefferson County Texas filed in Cause No. A-180805
Surrounding Pro Se Plaintiff claims of a chain of fraudulent events as a result of Hurricane Rita, Humberto and Ike
for said dwelling and the property located at 448 DeQueen Blvd. in Port Arthur Texas. (Block 172, Lot 1-2)
in connection with Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein.
Subpart (Y)
Explain in full expert “Attorney at Law” details, and Supply in full details also any and all legal court documents,
docket reports, court ledgers, letters, faxes, text, memos, emails, “filed motions for
withdrawal of counsel” all records in support thereof from the exact date of October 1st 2009 throughout the exact dates of November 11st 2009
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” Bar No. 24058299 herein
Was not legally representing any “material physical fact’s in the professional legal public capacity as
a acting “Attorney at Law“ In and for the “Sate of Texas” Bar No. 24058299
Before the 58th Judicial District Court of Jefferson County Texas described herein thereafter
Namely said “Honorable Judge Bob Wortham”
Herein in connection with one “Joyce M. Guy and Edward McCray” hereafter Co-Defendant(s) collectively
In a civil suit in the 58th Judicial District Court of Jefferson County Texas filed in Cause No. A-180805 in Jefferson County Texas.
In that Namely exactly “Antoine L. Freeman, J.D. “Attorney at Law” Texas Bar No. 24058299”
(active) within the “State of Texas” was not providing such any physical presentation, representation
and appearance thereof as acting “Attorney at Record Law services” for the full skilled “legal behalf” and
“retain interest” thereafter October 1st 2009 throughout the exact dates of November 11st
2009
In a civil suit in the 58th Judicial District Court of Jefferson County Texas filed in Cause No. A-180805
Before an “Honorable Court of Law” in cause No. A-180805 filed in the Jefferson County Texas Courthouse November 26th 2007
For their combine legal representation of said Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein in a format regarding “among other things”
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein
explaining he was not making Public Representation, presentation in the Profession as a “skilled counsel of law”
Before the “Honorable Judge Bob Wortham, the “Honorable Judge Bob Wortham” staff namely
“Ms. Sydney Moreau”, the Court reporters, and the court bailiff’s, thereafter October 1st 2009
throughout the exact dates of November 11st 2009
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein
was not making any Public Representation, presentation in the Profession as a “skilled counsel of law” Before The
Jefferson County Clerk of Court “Lolita Ramos”,
And all (active) Deputy Clerks acting on behalf of said Jefferson County Clerk of Court “Lolita Ramos,
involved in the records thereof, filed as Pro Se Plaintiff attached Document(s) # 1 and
Documents # 11herein
Namely” the 58th Judicial District Court of Jefferson County Texas “Case Ledger” for Cause No. A-180805
Namely” the 58th Judicial District Court of Jefferson County Texas “Civil Docket report” for cause No. A-180805
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not physically acting
as “Attorney of Record” before the 58th Judicial District Court of Jefferson County Texas
for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” at no physical time frame other then
retain filing services for December 18th 2007 “General Denial” paid services render
(only).
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein
was not filing any legal court documents for their legal behalf of said Co-Defendant(s) collectively through
the “United States Mailing System” thereafter October 1st 2009 throughout the exact dates of November 11st 2009
And forwarding such to the “Honorable Judge Bob Wortham, to the “Honorable Judge Bob Wortham” staff namely
“Ms. Sydney Moreau”, to The Jefferson County Clerk of Court “Lolita Ramos”,
And all (active) Deputy Clerks acting on behalf of said Jefferson County Clerk of Court “Lolita Ramos,
involved in the records thereof, filed as Pro Se Plaintiff attached Document(s) # 1 and
Documents # 11herein
Namely” the 58th Judicial District Court of Jefferson County Texas “Case Ledger” for Cause No. A-180805
Namely” the 58th Judicial District Court of Jefferson County Texas “Civil Docket report” for cause No. A-180805
With direct Usage of the “United States Mailing System” surround civil court event thereafter
October 1st 2009 throughout the exact dates of November 11st 2009
for their legal behalf of said Co-Defendant(s) collectively through the “United States Mailing System”
Namely in that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein
was not physically executing the usage of the “United States Mailing System” in the capacity of
acting “Attorney of Record” thereafter October 1st 2009 throughout the exact dates of November 11st 2009
For the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” at no physical time frame other then
retain filing services for December 18th 2007 “General Denial” paid services render
(only).
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not physically involved with inner actions on live
“court transcripts” with the 58th Court reporters thereafter
October 1st 2009 throughout the exact dates of November 11st 2009 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein
was not present before the 58th Judicial District Court of Jefferson County Texas bailiff’s, thereafter the time frame
of September 1st 2009 throughout the exact dates of October 1st 2009
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein
was not making any representation, presentation of material facts as acting “Attorney of record” Before
the “Honorable Judge Bob Wortham”, thereafter the date of October 1st 2009 throughout
the exact dates of November 11st 2009 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation,
presentation of material facts as acting “Attorney of record” before
The “Honorable Judge Bob Wortham” staff namely “Ms. Sydney Moreau”, thereafter the Date of October 1st 2009
throughout the exact dates of November 11st 2009 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law”
herein was not making any representation, presentation of material facts as acting “Attorney of record” before the
Jefferson County Clerk “Lolita Ramos”, record office of Jefferson County Texas thereafter
the Date of October 1st 2009 throughout the exact dates of November 11st 2009 for the Co-Defendant
(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein
was not involved in any “attorney/client”, work product thereof, and making such a presentations and
representations of “material facts” as acting physically in the professional capacity of acting “Attorney of record”
Before the “Honorable Judge Bob Wortham”, against said Pro Se Plaintiff “Louis Charles Hamilton II” herein
subject matter in complaint against the Co-Defendant(s) “Joyce M. Guy and Edward
McCray” legal behalf” thereafter of October 1st 2009 throughout the exact dates of November 11st 2009 in cause No. A-180805
“Meaning” in that Chief Defendant “Antoine L. Freeman, J.D. “Attorney at Law” Texas Bar No240582299
was not in any shape or form involved in any “attorney/client”, work product
thereof, “attorney/client” communications thereof,
And making such a physical presentations and representations of “material facts” as acting physically in the professional capacity of acting “Attorney of record”.
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein
was (Only) acting in the “legal capacitates” as a Attorney at Law to file a General Denial (Only) on December 18th
2007
To “simply” reply in the Complaint A-180805 made against Co-Defendant(s) “Joyce M. Guy and Edward McCray”
( Herein ) collectively and such “legal attorney at law retain services” ended
thereafter the exact date of December 18th 2007
In a civil suit in the 58th Judicial District Court of Jefferson County Texas filed in Cause No. A-180805 that
you Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” were legally
retain for such legal services to file a General Denial (Only)
Regarding a “Breach of Construction Contract” in excess of $10,800.00 U.S. Dollars as described by
“You” Defendant (Attorney at Law) your only being retain for services, and contract for all legal
services thereof required for such professional legal services to file a simple “General Denial” (Only) on December 18th 2007
As described in Pro Se Plaintiff attached Document # 2 herein
“Your” response to Pro Se Plaintiff Motion for Sanction against “You”
Chief Defendant “Antoine L. Freeman, J.D. “Attorney at Law” Texas Bar No. 24058299 herein describing your “legal attorney at
law retain services” ended thereafter the exact date of December 18th 2007
In a civil suit in the 58th Judicial District Court of Jefferson County Texas filed in Cause No. A-180805
Surrounding Pro Se Plaintiff claims of a chain of fraudulent events as a result of Hurricane Rita, Humberto and Ike
for said dwelling and the property located at 448 DeQueen Blvd. in Port Arthur Texas. (Block 172, Lot 1-2)
in connection with Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein.
Explain in full expert “Attorney at Law” details, and Supply in full details also any and all legal court documents,
docket reports, court ledgers, letters, faxes, text, memos, emails, “filed motions for
withdrawal of counsel” all records in support thereof from the exact date of June 1st 2009
throughout July 1st 2009 In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” Bar
No. 24058299 herein
Was not legally representing any “material physical fact’s in the professional legal public capacity
as a acting “Attorney at Law“ In and for the “Sate of Texas” Bar No. 24058299
Before the 58th Judicial District Court of Jefferson County Texas described herein thereafter
Namely said “Honorable Judge Bob Wortham”
Herein in connection with one “Joyce M. Guy and Edward McCray” hereafter Co-Defendant(s) collectively
In a civil suit in the 58th Judicial District Court of Jefferson County Texas filed in Cause No. A-180805 in Jefferson County Texas.
In that Namely exactly “Antoine L. Freeman, J.D. “Attorney at Law” Texas Bar No. 24058299”
(active) within the “State of Texas” was not providing such any physical presentation, representation
and appearance thereof as acting “Attorney at Record Law services” for the full skilled “legal behalf” and
“retain interest” June 1st 2009 throughout July 1st 2009 In a civil suit in the 58th Judicial
District Court of Jefferson County Texas filed in Cause No. A-180805
Before an “Honorable Court of Law” in cause No. A-180805 filed in the Jefferson County Texas Courthouse November 26th 2007
For their combine legal representation of said Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein in a format regarding “among other things”
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein
explaining he was not making Public Representation, presentation in the Profession as a “skilled counsel of law”
Before the “Honorable Judge Bob Wortham, the “Honorable Judge Bob Wortham” staff namely
“Ms. Sydney Moreau”, the Court reporters, and the court bailiff’s, thereafter June 1st 2009 throughout
July 1st 2009 In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein
was not making any Public Representation, presentation in the Profession as a “skilled counsel of
law” Before The Jefferson County Clerk of Court “Lolita Ramos”,
And all (active) Deputy Clerks acting on behalf of said Jefferson County Clerk of Court “Lolita Ramos,
involved in the records thereof, filed as Pro Se Plaintiff attached Document(s) # 1 and
Documents # 11herein
Namely” the 58th Judicial District Court of Jefferson County Texas “Case Ledger” for Cause No. A-180805
Namely” the 58th Judicial District Court of Jefferson County Texas “Civil Docket report” for cause No. A-180805
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein
was not physically acting as “Attorney of Record” before the 58th Judicial District Court of Jefferson County Texas
for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf”
at no physical time frame other then retain filing services for December 18th 2007 “General Denial” paid services render
(only).
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein
was not filing any legal court documents for their legal behalf of said Co-Defendant(s) collectively through
the “United States Mailing System” thereafter June 1st 2009 throughout July 1st 2009
And forwarding such to the “Honorable Judge Bob Wortham, to the “Honorable Judge Bob Wortham” staff namely
“Ms. Sydney Moreau”, to The Jefferson County Clerk of Court “Lolita Ramos”,
And all (active) Deputy Clerks acting on behalf of said Jefferson County Clerk of Court “Lolita Ramos,
involved in the records thereof, filed as Pro Se Plaintiff attached Document(s) # 1 and
Documents # 11herein
Namely” the 58th Judicial District Court of Jefferson County Texas “Case Ledger” for Cause No. A-180805
Namely” the 58th Judicial District Court of Jefferson County Texas “Civil Docket report” for cause No. A-180805
With direct Usage of the “United States Mailing System” surround civil court event thereafter
June 1st 2009 throughout July 1st 2009 for their legal behalf of said Co-Defendant(s) collectively through the “United States Mailing System”
Namely in that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein
was not physically executing the usage of the “United States Mailing System” in the capacity of
acting “Attorney of Record” thereafter June 1st 2009 throughout July 1st 2009
For the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” at no physical time frame other then retain
filing services for December 18th 2007 “General Denial” paid services render (only).
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein
was not physically involved with inner actions on live “court transcripts” with the 58th Court reporters thereafter
June 1st 2009 throughout July 1st 2009 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not present before
the 58th Judicial District Court of Jefferson County Texas bailiff’s, thereafter the time frame
of June 1st 2009 throughout July 1st 2009
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation,
presentation of material facts as acting “Attorney of record” Before
the “Honorable Judge Bob Wortham”, thereafter the date of June 1st 2009 throughout July 1st 2009
for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation,
presentation of material facts as acting “Attorney of record” before
The “Honorable Judge Bob Wortham” staff namely “Ms. Sydney Moreau”, thereafter the Date of
June 1st 2009 throughout July 1st 2009 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray”
legal behalf” in cause No. A-180805
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation,
presentation of material facts as acting “Attorney of record” before the
Jefferson County Clerk “Lolita Ramos”, record office of Jefferson County Texas thereafter the Date of
June 1st 2009 throughout July 1st 2009 for the Co-Defendant(s) “Joyce M. Guy and Edward
McCray” legal behalf” in cause No. A-180805
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein
was not involved in any “attorney/client”, work product thereof, and making such a presentations and
representations of “material facts” as acting physically in the professional capacity of acting “Attorney of record”
Before the “Honorable Judge Bob Wortham”, against said Pro Se Plaintiff “Louis Charles Hamilton II” herein
subject matter in complaint against the Co-Defendant(s) “Joyce M. Guy and Edward
McCray” legal behalf” thereafter June 1st 2009 throughout July 1st 2009 in cause No. A-180805
“Meaning” in that Chief Defendant “Antoine L. Freeman, J.D. “Attorney at Law” Texas Bar No240582299
was not in any shape or form involved in any “attorney/client”, work product
thereof, “attorney/client” communications thereof,
And making such a physical presentations and representations of “material facts” as acting physically in the professional capacity of acting “Attorney of record”.
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was (Only)
acting in the “legal capacitates” as a Attorney at Law to file a General Denial (Only) on December 18th
2007
To “simply” reply in the Complaint A-180805 made against Co-Defendant(s) “Joyce M. Guy and Edward McCray”
( Herein ) collectively and such “legal attorney at law retain services” ended
thereafter the exact date of December 18th 2007
In a civil suit in the 58th Judicial District Court of Jefferson County Texas filed in Cause No. A-180805
that you Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” were legally
retain for such legal services to file a General Denial (Only)
Regarding a “Breach of Construction Contract” in excess of $10,800.00 U.S. Dollars as described by
“You” Defendant (Attorney at Law) your only being retain for services, and contract for all legal
services thereof required for such professional legal services to file a simple “General Denial” (Only) on December 18th 2007
As described in Pro Se Plaintiff attached Document # 2 herein
“Your” response to Pro Se Plaintiff Motion for Sanction against “You”
Chief Defendant “Antoine L. Freeman, J.D. “Attorney at Law” Texas Bar No. 24058299 herein describing your “legal attorney at
law retain services” ended thereafter the exact date of December 18th 2007
In a civil suit in the 58th Judicial District Court of Jefferson County Texas filed in Cause No. A-180805
Surrounding Pro Se Plaintiff claims of a chain of fraudulent events as a result of Hurricane Rita, Humberto and Ike
for said dwelling and the property located at 448 DeQueen Blvd. in Port Arthur
Texas. (Block 172, Lot 1-2) in connection with Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein.
Subpart (V)
Explain in full expert “Attorney at Law” details, and Supply in full details also any and all legal court documents,
docket reports, court ledgers, letters, faxes, text, memos, emails, “filed motions for
withdrawal of counsel” all records in support thereof from the exact date of July 1st 2009 throughout the exact dates of August 1st 2009
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” Bar No. 24058299 herein
Was not legally representing any “material physical fact’s in the professional legal public capacity as
a acting “Attorney at Law“ In and for the “Sate of Texas” Bar No. 24058299
Before the 58th Judicial District Court of Jefferson County Texas described herein thereafter
Namely said “Honorable Judge Bob Wortham”
Herein in connection with one “Joyce M. Guy and Edward McCray” hereafter Co-Defendant(s) collectively
In a civil suit in the 58th Judicial District Court of Jefferson County Texas filed in Cause No. A-180805 in Jefferson County Texas.
In that Namely exactly “Antoine L. Freeman, J.D. “Attorney at Law” Texas Bar No. 24058299”
(active) within the “State of Texas” was not providing such any physical presentation, representation
and appearance thereof as acting “Attorney at Record Law services” for the full skilled “legal behalf” and
“retain interest” thereafter July 1st 2009 throughout the exact dates of August 1st 2009
In a civil suit in the 58th Judicial District Court of Jefferson County Texas filed in Cause No. A-180805
Before an “Honorable Court of Law” in cause No. A-180805 filed in the Jefferson County Texas Courthouse November 26th 2007
For their combine legal representation of said Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein in a format regarding “among other things”
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law”
herein explaining he was not making Public Representation, presentation in the Profession as a “skilled counsel of law”
Before the “Honorable Judge Bob Wortham, the “Honorable Judge Bob Wortham” staff namely
“Ms. Sydney Moreau”, the Court reporters, and the court bailiff’s, thereafter July 1st 2009 throughout
the exact dates of August 1st 2009
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any Public Representation,
presentation in the Profession as a “skilled counsel of law” Before The
Jefferson County Clerk of Court “Lolita Ramos”,
And all (active) Deputy Clerks acting on behalf of said Jefferson County Clerk of Court “Lolita Ramos,
involved in the records thereof, filed as Pro Se Plaintiff attached Document(s) # 1 and
Documents # 11herein
Namely” the 58th Judicial District Court of Jefferson County Texas “Case Ledger” for Cause No. A-180805
Namely” the 58th Judicial District Court of Jefferson County Texas “Civil Docket report” for cause No. A-180805
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein
was not physically acting as “Attorney of Record” before the 58th Judicial District Court of Jefferson County Texas
for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf”
at no physical time frame other then retain filing services for December 18th 2007 “General Denial” paid services render
(only).
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein
was not filing any legal court documents for their legal behalf of said Co-Defendant(s) collectively through
the “United States Mailing System” thereafter July 1st 2009 throughout the exact dates of August 1st 2009
And forwarding such to the “Honorable Judge Bob Wortham, to the “Honorable Judge Bob Wortham” staff namely
“Ms. Sydney Moreau”, to The Jefferson County Clerk of Court “Lolita Ramos”,
And all (active) Deputy Clerks acting on behalf of said Jefferson County Clerk of Court “Lolita Ramos,
involved in the records thereof, filed as Pro Se Plaintiff attached Document(s) # 1 and
Documents # 11herein
Namely” the 58th Judicial District Court of Jefferson County Texas “Case Ledger” for Cause No. A-180805
Namely” the 58th Judicial District Court of Jefferson County Texas “Civil Docket report” for cause No. A-180805
With direct Usage of the “United States Mailing System” surround civil court event thereafter
February 1st 2009 throughout the exact dates of July 1st 2009 throughout the exact dates of August 1st
2009 for their legal behalf of said Co-Defendant(s) collectively through the “United States Mailing System”
Namely in that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein
was not physically executing the usage of the “United States Mailing System” in the capacity of
acting “Attorney of Record” thereafter July 1st 2009 throughout the exact dates of August 1st 2009
For the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” at no physical time frame other then
retain filing services for December 18th 2007 “General Denial” paid services render (only).
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein
was not physically involved with inner actions on live “court transcripts” with the 58th Court reporters thereafter
July 1st 2009 throughout the exact dates of August 1st 2009 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein
was not present before the 58th Judicial District Court of Jefferson County Texas bailiff’s, thereafter the time frame
of July 1st 2009 throughout the exact dates of August 1st 2009
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation,
presentation of material facts as acting “Attorney of record” Before
the “Honorable Judge Bob Wortham”, thereafter the date of July 1st 2009 throughout the exact dates of
August 1st 2009 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation,
presentation of material facts as acting “Attorney of record” before
The “Honorable Judge Bob Wortham” staff namely “Ms. Sydney Moreau”, thereafter the Date of July 1st 2009
throughout the exact dates of August 1st 2009 for the Co-Defendant(s) “Joyce M. Guy
and Edward McCray” legal behalf” in cause No. A-180805
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation,
presentation of material facts as acting “Attorney of record” before the
Jefferson County Clerk “Lolita Ramos”, record office of Jefferson County Texas thereafter the Date of
July 1st 2009 throughout the exact dates of August 1st 2009 for the Co-Defendant(s) “Joyce M.
Guy and Edward McCray” legal behalf” in cause No. A-180805
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein
was not involved in any “attorney/client”, work product thereof, and making such a presentations and
representations of “material facts” as acting physically in the professional capacity of acting “Attorney of record”
Before the “Honorable Judge Bob Wortham”, against said Pro Se Plaintiff “Louis Charles Hamilton II” herein
subject matter in complaint against the Co-Defendant(s) “Joyce M. Guy and Edward
McCray” legal behalf” thereafter of July 1st 2009 throughout the exact dates of August 1st 2009 in cause No. A-180805
“Meaning” in that Chief Defendant “Antoine L. Freeman, J.D. “Attorney at Law” Texas Bar No240582299
was not in any shape or form involved in any “attorney/client”, work product
thereof, “attorney/client” communications thereof,
And making such a physical presentations and representations of “material facts” as acting physically in the professional capacity of acting “Attorney of record”.
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was
(Only) acting in the “legal capacitates” as a Attorney at Law to file a General Denial (Only) on December 18th 2007
To “simply” reply in the Complaint A-180805 made against Co-Defendant(s) “Joyce M. Guy and Edward McCray”
( Herein ) collectively and such “legal attorney at law retain services” ended
thereafter the exact date of December 18th 2007
In a civil suit in the 58th Judicial District Court of Jefferson County Texas filed in Cause No. A-180805
that you Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” were legally
retain for such legal services to file a General Denial (Only)
Regarding a “Breach of Construction Contract” in excess of $10,800.00 U.S. Dollars as described by
“You” Defendant (Attorney at Law) your only being retain for services, and contract for all legal
services thereof required for such professional legal services to file a simple “General Denial” (Only) on December 18th 2007
As described in Pro Se Plaintiff attached Document # 2 herein
“Your” response to Pro Se Plaintiff Motion for Sanction against
“You” Chief Defendant “Antoine L. Freeman, J.D. “Attorney at Law” Texas Bar No. 24058299 herein describing your “legal attorney at
law retain services” ended thereafter the exact date of December 18th 2007
In a civil suit in the 58th Judicial District Court of Jefferson County Texas filed in Cause No. A-180805
Surrounding Pro Se Plaintiff claims of a chain of fraudulent events as a result of Hurricane Rita, Humberto and Ike
for said dwelling and the property located at 448 DeQueen Blvd. in Port Arthur
Texas. (Block 172, Lot 1-2) in connection with Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein.
Subpart (W)
Explain in full expert “Attorney at Law” details, and Supply in full details also any and all legal court documents,
docket reports, court ledgers, letters, faxes, text, memos, emails, “filed motions for
withdrawal of counsel” all records in support thereof from the exact date of August 1st 2009 throughout the exact dates of September 1st 2009
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” Bar No. 24058299 herein
Was not legally representing any “material physical fact’s in the professional legal public capacity as
a acting “Attorney at Law“ In and for the “Sate of Texas” Bar No. 24058299
Before the 58th Judicial District Court of Jefferson County Texas described herein thereafter
Namely said “Honorable Judge Bob Wortham”
Herein in connection with one “Joyce M. Guy and Edward McCray” hereafter Co-Defendant(s) collectively
In a civil suit in the 58th Judicial District Court of Jefferson County Texas filed in Cause No. A-180805 in Jefferson County Texas.
In that Namely exactly “Antoine L. Freeman, J.D. “Attorney at Law” Texas Bar No. 24058299”
(active) within the “State of Texas” was not providing such any physical presentation, representation
and appearance thereof as acting “Attorney at Record Law services” for the full skilled “legal behalf”
and “retain interest” thereafter August 1st 2009 throughout the exact dates of September 1st 2009
In a civil suit in the 58th Judicial District Court of Jefferson County Texas filed in Cause No. A-180805
Before an “Honorable Court of Law” in cause No. A-180805 filed in the Jefferson County Texas Courthouse November 26th 2007
For their combine legal representation of said Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein in a format regarding “among other things”
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein
explaining he was not making Public Representation, presentation in the Profession as a “skilled counsel of law”
Before the “Honorable Judge Bob Wortham, the “Honorable Judge Bob Wortham” staff namely
“Ms. Sydney Moreau”, the Court reporters, and the court bailiff’s, thereafter August 1st 2009
throughout the exact dates of September 1st 2009
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any Public Representation,
presentation in the Profession as a “skilled counsel of law” Before The
Jefferson County Clerk of Court “Lolita Ramos”,
And all (active) Deputy Clerks acting on behalf of said Jefferson County Clerk of Court “Lolita Ramos,
involved in the records thereof, filed as Pro Se Plaintiff attached Document(s) # 1 and
Documents # 11herein
Namely” the 58th Judicial District Court of Jefferson County Texas “Case Ledger” for Cause No. A-180805
Namely” the 58th Judicial District Court of Jefferson County Texas “Civil Docket report” for cause No. A-180805
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not physically acting as
“Attorney of Record” before the 58th Judicial District Court of Jefferson County Texas
for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” at no physical time frame other then
retain filing services for December 18th 2007 “General Denial” paid services render (only).
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein
was not filing any legal court documents for their legal behalf of said Co-Defendant(s) collectively through
the “United States Mailing System” thereafter August 1st 2009 throughout the exact dates of September 1st 2009
And forwarding such to the “Honorable Judge Bob Wortham, to the “Honorable Judge Bob Wortham”
staff namely “Ms. Sydney Moreau”, to The Jefferson County Clerk of Court “Lolita Ramos”,
And all (active) Deputy Clerks acting on behalf of said Jefferson County Clerk of Court “Lolita Ramos,
involved in the records thereof, filed as Pro Se Plaintiff attached Document(s) # 1 and
Documents # 11herein
Namely” the 58th Judicial District Court of Jefferson County Texas “Case Ledger” for Cause No. A-180805
Namely” the 58th Judicial District Court of Jefferson County Texas “Civil Docket report” for cause No. A-180805
With direct Usage of the “United States Mailing System” surround civil court event thereafter August 1st 2009
throughout the exact dates of September 1st 2009 for their legal behalf of said Co-
Defendant(s) collectively through the “United States Mailing System”
Namely in that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein
was not physically executing the usage of the “United States Mailing System” in the capacity of
acting “Attorney of Record” thereafter August 1st 2009 throughout the exact dates of September 1st 2009
For the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” at no physical time frame other then
retain filing services for December 18th 2007 “General Denial” paid services render (only).
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not physically involved with inner actions on live
“court transcripts” with the 58th Court reporters thereafter
August 1st 2009 throughout the exact dates of September 1st 2009 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein
was not present before the 58th Judicial District Court of Jefferson County Texas bailiff’s, thereafter the time frame
of August 1st 2009 throughout the exact dates of September 1st 2009
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation,
presentation of material facts as acting “Attorney of record” Before
the “Honorable Judge Bob Wortham”, thereafter the date of August 1st 2009 throughout the exact dates of
September 1st 2009 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal
behalf” in cause No. A-180805
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation,
presentation of material facts as acting “Attorney of record” before
The “Honorable Judge Bob Wortham” staff namely “Ms. Sydney Moreau”, thereafter the Date of August 1st 2009
throughout the exact dates of September 1st 2009 for the Co-Defendant(s) “Joyce
M. Guy and Edward McCray” legal behalf” in cause No. A-180805
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation,
presentation of material facts as acting “Attorney of record” before the
Jefferson County Clerk “Lolita Ramos”, record office of Jefferson County Texas thereafter the Date of
August 1st 2009 throughout the exact dates of September 1st 2009 for the Co-Defendant
(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein
was not involved in any “attorney/client”, work product thereof, and making such a presentations and
representations of “material facts” as acting physically in the professional capacity of acting “Attorney of record”
Before the “Honorable Judge Bob Wortham”, against said Pro Se Plaintiff “Louis Charles Hamilton II” herein
subject matter in complaint against the Co-Defendant(s) “Joyce M. Guy and Edward
McCray” legal behalf” thereafter of August 1st 2009 throughout the exact dates of September 1st 2009 in cause No. A-180805
“Meaning” in that Chief Defendant “Antoine L. Freeman, J.D. “Attorney at Law” Texas Bar No240582299
was not in any shape or form involved in any “attorney/client”, work product thereof, “attorney/client” communications thereof,
And making such a physical presentations and representations of “material facts” as acting physically in the professional capacity of acting “Attorney of record”.
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was (Only) acting in the “legal capacitates”
as a Attorney at Law to file a General Denial (Only) on December 18th 2007
To “simply” reply in the Complaint A-180805 made against Co-Defendant(s) “Joyce M. Guy and Edward McCray”
( Herein ) collectively and such “legal attorney at law retain services” ended
thereafter the exact date of December 18th 2007
In a civil suit in the 58th Judicial District Court of Jefferson County Texas filed in Cause No. A-180805
that you Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” were legally
retain for such legal services to file a General Denial (Only)
Regarding a “Breach of Construction Contract” in excess of $10,800.00 U.S. Dollars
as described by “You” Defendant (Attorney at Law) your only being retain for services, and contract for all legal
services thereof required for such professional legal services to file a simple “General Denial” (Only) on December 18th 2007
As described in Pro Se Plaintiff attached Document # 2 herein
“Your” response to Pro Se Plaintiff Motion for Sanction against “You”
Chief Defendant “Antoine L. Freeman, J.D. “Attorney at Law” Texas Bar No. 24058299 herein describing your “legal attorney at
law retain services” ended thereafter the exact date of December 18th 2007
In a civil suit in the 58th Judicial District Court of Jefferson County Texas filed in Cause No. A-180805
Surrounding Pro Se Plaintiff claims of a chain of fraudulent events as a result of Hurricane Rita, Humberto and Ike
for said dwelling and the property located at 448 DeQueen Blvd. in Port Arthur Texas. (Block 172, Lot 1-2)
in connection with Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein.
Subpart (X)
Explain in full expert “Attorney at Law” details, and Supply in full details also any and all legal court documents,
docket reports, court ledgers, letters, faxes, text, memos, emails, “filed motions for
withdrawal of counsel” all records in support thereof from the exact date of September 1st 2009 throughout the exact dates of October 1st 2009
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” Bar No. 24058299 herein
Was not legally representing any “material physical fact’s in the professional legal public capacity as
a acting “Attorney at Law“ In and for the “Sate of Texas” Bar No. 24058299
Before the 58th Judicial District Court of Jefferson County Texas described herein thereafter
Namely said “Honorable Judge Bob Wortham”
Herein in connection with one “Joyce M. Guy and Edward McCray” hereafter Co-Defendant(s) collectively
In a civil suit in the 58th Judicial District Court of Jefferson County Texas filed in Cause No. A-180805 in Jefferson County Texas.
In that Namely exactly “Antoine L. Freeman, J.D. “Attorney at Law” Texas Bar No. 24058299”
(active) within the “State of Texas” was not providing such any physical presentation, representation
and appearance thereof as acting “Attorney at Record Law services” for the full skilled “legal behalf” and
“retain interest” thereafter September 1st 2009 throughout the exact dates of October 1st 2009
In a civil suit in the 58th Judicial District Court of Jefferson County Texas filed in Cause No. A-180805
Before an “Honorable Court of Law” in cause No. A-180805 filed in the Jefferson County Texas Courthouse November 26th 2007
For their combine legal representation of said Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein in a format regarding “among other things”
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein
explaining he was not making Public Representation, presentation in the Profession as a “skilled counsel of law”
Before the “Honorable Judge Bob Wortham, the “Honorable Judge Bob Wortham” staff namely
“Ms. Sydney Moreau”, the Court reporters, and the court bailiff’s, thereafter September 1st 2009
throughout the exact dates of October 1st 2009
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any Public Representation,
presentation in the Profession as a “skilled counsel of law” Before The
Jefferson County Clerk of Court “Lolita Ramos”,
And all (active) Deputy Clerks acting on behalf of said Jefferson County Clerk of Court “Lolita Ramos,
involved in the records thereof, filed as Pro Se Plaintiff attached Document(s) # 1 and
Documents # 11herein
Namely” the 58th Judicial District Court of Jefferson County Texas “Case Ledger” for Cause No. A-180805
Namely” the 58th Judicial District Court of Jefferson County Texas “Civil Docket report” for cause No. A-180805
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein
was not physically acting as “Attorney of Record” before the 58th Judicial District Court of Jefferson County Texas
for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” at no physical time frame other then
retain filing services for December 18th 2007 “General Denial” paid services render
(only).
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein
was not filing any legal court documents for their legal behalf of said Co-Defendant(s) collectively through
the “United States Mailing System” thereafter September 1st 2009 throughout the exact dates of October 1st 2009
And forwarding such to the “Honorable Judge Bob Wortham, to the “Honorable Judge Bob Wortham” staff namely
“Ms. Sydney Moreau”, to The Jefferson County Clerk of Court “Lolita Ramos”,
And all (active) Deputy Clerks acting on behalf of said Jefferson County Clerk of Court “Lolita Ramos,
involved in the records thereof, filed as Pro Se Plaintiff attached Document(s) # 1 and
Documents # 11herein
Namely” the 58th Judicial District Court of Jefferson County Texas “Case Ledger” for Cause No. A-180805
Namely” the 58th Judicial District Court of Jefferson County Texas “Civil Docket report” for cause No. A-180805
With direct Usage of the “United States Mailing System” surround civil court event thereafter
September 1st 2009 throughout the exact dates of October 1st 2009 for their legal behalf of said Co-
Defendant(s) collectively through the “United States Mailing System”
Namely in that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein
was not physically executing the usage of the “United States Mailing System” in the capacity of
acting “Attorney of Record” thereafter September 1st 2009 throughout the exact dates of October 1st 2009
For the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” at no physical time frame other then
retain filing services for December 18th 2007 “General Denial” paid services render (only).
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not physically
involved with inner actions on live “court transcripts” with the 58th Court reporters thereafter
September 1st 2009 throughout the exact dates of October 1st 2009 for
the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not present before
the 58th Judicial District Court of Jefferson County Texas bailiff’s, thereafter the time frame
of September 1st 2009 throughout the exact dates of October 1st 2009
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation,
presentation of material facts as acting “Attorney of record” Before
the “Honorable Judge Bob Wortham”, thereafter the date of September 1st 2009 throughout the exact dates of
October 1st 2009 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal
behalf” in cause No. A-180805
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation,
presentation of material facts as acting “Attorney of record” before
The “Honorable Judge Bob Wortham” staff namely “Ms. Sydney Moreau”, thereafter the Date of
September 1st 2009 throughout the exact dates of October 1st 2009 for the Co-Defendant(s) “Joyce
M. Guy and Edward McCray” legal behalf” in cause No. A-180805
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation,
presentation of material facts as acting “Attorney of record” before the
Jefferson County Clerk “Lolita Ramos”, record office of Jefferson County Texas thereafter
the Date of September 1st 2009 throughout the exact dates of October 1st 2009 for the Co-Defendant
(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein
was not involved in any “attorney/client”, work product thereof, and making such a presentations and
representations of “material facts” as acting physically in the professional capacity of acting “Attorney of record”
Before the “Honorable Judge Bob Wortham”, against said Pro Se Plaintiff “Louis Charles Hamilton II” herein
subject matter in complaint against the Co-Defendant(s) “Joyce M. Guy and Edward
McCray” legal behalf” thereafter of September 1st 2009 throughout the exact dates of October 1st 2009 in cause No. A-180805
“Meaning” in that Chief Defendant “Antoine L. Freeman, J.D. “Attorney at Law” Texas Bar No240582299
was not in any shape or form involved in any “attorney/client”, work product
thereof, “attorney/client” communications thereof,
And making such a physical presentations and representations of “material facts” as acting physically in the professional capacity of acting “Attorney of record”.
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was (Only) acting in the “legal capacitates” as
a Attorney at Law to file a General Denial (Only) on December 18th 2007
To “simply” reply in the Complaint A-180805 made against Co-Defendant(s) “Joyce M. Guy and Edward McCray”
( Herein ) collectively and such “legal attorney at law retain services” ended
thereafter the exact date of December 18th 2007
In a civil suit in the 58th Judicial District Court of Jefferson County Texas filed in Cause No. A-180805 that you
Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” were legally
retain for such legal services to file a General Denial (Only)
Regarding a “Breach of Construction Contract” in excess of $10,800.00 U.S. Dollars as described by
“You” Defendant (Attorney at Law) your only being retain for services, and contract for all legal
services thereof required for such professional legal services to file a simple “General Denial” (Only) on December 18th 2007
As described in Pro Se Plaintiff attached Document # 2 herein
“Your” response to Pro Se Plaintiff Motion for Sanction against “You”
Chief Defendant “Antoine L. Freeman, J.D. “Attorney at Law” Texas Bar No. 24058299 herein describing your “legal attorney at
law retain services” ended thereafter the exact date of December 18th 2007
In a civil suit in the 58th Judicial District Court of Jefferson County Texas filed in Cause No. A-180805
Surrounding Pro Se Plaintiff claims of a chain of fraudulent events as a result of Hurricane Rita, Humberto and Ike
for said dwelling and the property located at 448 DeQueen Blvd. in Port Arthur Texas. (Block 172, Lot 1-2)
in connection with Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein.
Subpart (Y)
Explain in full expert “Attorney at Law” details, and Supply in full details also any and all legal court documents,
docket reports, court ledgers, letters, faxes, text, memos, emails, “filed motions for
withdrawal of counsel” all records in support thereof from the exact date of October 1st 2009 throughout the exact dates of November 11st 2009
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” Bar No. 24058299 herein
Was not legally representing any “material physical fact’s in the professional legal public capacity as
a acting “Attorney at Law“ In and for the “Sate of Texas” Bar No. 24058299
Before the 58th Judicial District Court of Jefferson County Texas described herein thereafter
Namely said “Honorable Judge Bob Wortham”
Herein in connection with one “Joyce M. Guy and Edward McCray” hereafter Co-Defendant(s) collectively
In a civil suit in the 58th Judicial District Court of Jefferson County Texas filed in Cause No. A-180805 in Jefferson County Texas.
In that Namely exactly “Antoine L. Freeman, J.D. “Attorney at Law” Texas Bar No. 24058299”
(active) within the “State of Texas” was not providing such any physical presentation, representation
and appearance thereof as acting “Attorney at Record Law services” for the full skilled “legal behalf” and
“retain interest” thereafter October 1st 2009 throughout the exact dates of November 11st
2009
In a civil suit in the 58th Judicial District Court of Jefferson County Texas filed in Cause No. A-180805
Before an “Honorable Court of Law” in cause No. A-180805 filed in the Jefferson County Texas Courthouse November 26th 2007
For their combine legal representation of said Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein in a format regarding “among other things”
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein
explaining he was not making Public Representation, presentation in the Profession as a “skilled counsel of law”
Before the “Honorable Judge Bob Wortham, the “Honorable Judge Bob Wortham” staff namely
“Ms. Sydney Moreau”, the Court reporters, and the court bailiff’s, thereafter October 1st 2009
throughout the exact dates of November 11st 2009
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein
was not making any Public Representation, presentation in the Profession as a “skilled counsel of law” Before The
Jefferson County Clerk of Court “Lolita Ramos”,
And all (active) Deputy Clerks acting on behalf of said Jefferson County Clerk of Court “Lolita Ramos,
involved in the records thereof, filed as Pro Se Plaintiff attached Document(s) # 1 and
Documents # 11herein
Namely” the 58th Judicial District Court of Jefferson County Texas “Case Ledger” for Cause No. A-180805
Namely” the 58th Judicial District Court of Jefferson County Texas “Civil Docket report” for cause No. A-180805
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not physically acting
as “Attorney of Record” before the 58th Judicial District Court of Jefferson County Texas
for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” at no physical time frame other then
retain filing services for December 18th 2007 “General Denial” paid services render
(only).
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein
was not filing any legal court documents for their legal behalf of said Co-Defendant(s) collectively through
the “United States Mailing System” thereafter October 1st 2009 throughout the exact dates of November 11st 2009
And forwarding such to the “Honorable Judge Bob Wortham, to the “Honorable Judge Bob Wortham” staff namely
“Ms. Sydney Moreau”, to The Jefferson County Clerk of Court “Lolita Ramos”,
And all (active) Deputy Clerks acting on behalf of said Jefferson County Clerk of Court “Lolita Ramos,
involved in the records thereof, filed as Pro Se Plaintiff attached Document(s) # 1 and
Documents # 11herein
Namely” the 58th Judicial District Court of Jefferson County Texas “Case Ledger” for Cause No. A-180805
Namely” the 58th Judicial District Court of Jefferson County Texas “Civil Docket report” for cause No. A-180805
With direct Usage of the “United States Mailing System” surround civil court event thereafter
October 1st 2009 throughout the exact dates of November 11st 2009
for their legal behalf of said Co-Defendant(s) collectively through the “United States Mailing System”
Namely in that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein
was not physically executing the usage of the “United States Mailing System” in the capacity of
acting “Attorney of Record” thereafter October 1st 2009 throughout the exact dates of November 11st 2009
For the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” at no physical time frame other then
retain filing services for December 18th 2007 “General Denial” paid services render
(only).
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not physically involved with inner actions on live
“court transcripts” with the 58th Court reporters thereafter
October 1st 2009 throughout the exact dates of November 11st 2009 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein
was not present before the 58th Judicial District Court of Jefferson County Texas bailiff’s, thereafter the time frame
of September 1st 2009 throughout the exact dates of October 1st 2009
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein
was not making any representation, presentation of material facts as acting “Attorney of record” Before
the “Honorable Judge Bob Wortham”, thereafter the date of October 1st 2009 throughout
the exact dates of November 11st 2009 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation,
presentation of material facts as acting “Attorney of record” before
The “Honorable Judge Bob Wortham” staff namely “Ms. Sydney Moreau”, thereafter the Date of October 1st 2009
throughout the exact dates of November 11st 2009 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law”
herein was not making any representation, presentation of material facts as acting “Attorney of record” before the
Jefferson County Clerk “Lolita Ramos”, record office of Jefferson County Texas thereafter
the Date of October 1st 2009 throughout the exact dates of November 11st 2009 for the Co-Defendant
(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein
was not involved in any “attorney/client”, work product thereof, and making such a presentations and
representations of “material facts” as acting physically in the professional capacity of acting “Attorney of record”
Before the “Honorable Judge Bob Wortham”, against said Pro Se Plaintiff “Louis Charles Hamilton II” herein
subject matter in complaint against the Co-Defendant(s) “Joyce M. Guy and Edward
McCray” legal behalf” thereafter of October 1st 2009 throughout the exact dates of November 11st 2009 in cause No. A-180805
“Meaning” in that Chief Defendant “Antoine L. Freeman, J.D. “Attorney at Law” Texas Bar No240582299
was not in any shape or form involved in any “attorney/client”, work product
thereof, “attorney/client” communications thereof,
And making such a physical presentations and representations of “material facts” as acting physically in the professional capacity of acting “Attorney of record”.
In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein
was (Only) acting in the “legal capacitates” as a Attorney at Law to file a General Denial (Only) on December 18th
2007
To “simply” reply in the Complaint A-180805 made against Co-Defendant(s) “Joyce M. Guy and Edward McCray”
( Herein ) collectively and such “legal attorney at law retain services” ended
thereafter the exact date of December 18th 2007
In a civil suit in the 58th Judicial District Court of Jefferson County Texas filed in Cause No. A-180805 that
you Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” were legally
retain for such legal services to file a General Denial (Only)
Regarding a “Breach of Construction Contract” in excess of $10,800.00 U.S. Dollars as described by
“You” Defendant (Attorney at Law) your only being retain for services, and contract for all legal
services thereof required for such professional legal services to file a simple “General Denial” (Only) on December 18th 2007
As described in Pro Se Plaintiff attached Document # 2 herein
“Your” response to Pro Se Plaintiff Motion for Sanction against “You”
Chief Defendant “Antoine L. Freeman, J.D. “Attorney at Law” Texas Bar No. 24058299 herein describing your “legal attorney at
law retain services” ended thereafter the exact date of December 18th 2007
In a civil suit in the 58th Judicial District Court of Jefferson County Texas filed in Cause No. A-180805
Surrounding Pro Se Plaintiff claims of a chain of fraudulent events as a result of Hurricane Rita, Humberto and Ike
for said dwelling and the property located at 448 DeQueen Blvd. in Port Arthur Texas. (Block 172, Lot 1-2)
in connection with Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein.
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