In The United States District Court

For The Eastern Division of Texas

Beaumont Division

Louis Charles Hamilton II

Pro Se Plaintiff

Vs. Cause No. 1:14-CV-592

Antoine L. Freeman J. D.

Defendant

Joyce M. Guy

Edward McCray

Co-Defendant(s)

To Defendant “Antoine L. Freeman J.D. (Attorney at Law), Pro Se Plaintiff

“Louis Charles Hamilton II” herein propounding party

REQUESTS FOR ADMISSION, SET ONE To: Antoine L. Freeman J. D. Attorney at Law AND HIS COUNSEL OF RECORD:

Pursuant to the provisions of Federal Rule of Civil Procedure 36, it is hereby requested and demanded of Defendant

Antoine L. Freeman J. D. (hereinafter “YOU” or “YOUR”), that YOU make admissions of the following statements of fact which are materially pertinent to Plaintiff claims hereto in accordance with Rule 36,

Under which rule of procedure this request for admissions is made, thereby

answering the following facts in the above-entitled and number cause, and that such answers be sworn to and filed promptly in the office of the District Clerk

Where this cause is pending and a copy delivered to the writer within thirty (30) days from the serving of this request upon you.

Otherwise, each of the matter of which an admission is requested and demanded shall be deemed admitted by you in accordance with Rule 36 of the Federal Rules of Civil Procedure.

Request for Admission Truth of Facts

Admit that the following facts are true: Request Number 1.

Admit: that you made legal claim Co-Defendant(s) Joyce M. Guy and Edward McCray herein (Only) retain the legal services of Antoine L. Freeman J.D. (Attorney at Law) for the purpose of

(Only) writing a general denial so as to avoid a default judgment being

rendered against (Them) in a civil suit in the 58th Judicial District Court of Jefferson County Texas filed in Cause No. A-180805, By Pro Se Plaintiff herein. Request Number 2.

Admit: That You on December 18th 2007 filed for Co-Defendant(s) Joyce M.

Guy and Edward McCray herein your “legal General Denial” to Complaint made by

Pro Se Plaintiff herein to Cause No. A-180805

In a civil suit in the 58th Judicial District Court of Jefferson County Texas.

Request Number 3. Admit: That you on November 13th 2009 10:22 am filed with “Lolita Ramos”, Clerk, and District Court of Jefferson County, Texas

A Motion for to Withdrawal of Counsel from Co-Defendant(s) Joyce M. Guy and Edward McCray herein exactly 1 year, 10 months and 13 days of simply being “financially retain” to file a simple “Legal General Denial” to Cause No. A-180805 on December 18th 2007 and this was you’re only “Legal Duties” and “Fiduciary

Obligations” as acting retain” Counsel of Record “for the Co-Defendant(s) Joyce M. Guy and Edward McCray herein

in the entire “Legal ongoing civil suit in common law” time frame of 1 year, 10 months and 13 days filed in the 58th Judicial District Court of Jefferson County Texas before the Honorable Bob Wortham.

Request Number 4.

Admit: That you on or about April 2nd 2008 and April 11, 2008 you

were in possession, custody, and control of Pro Se Plaintiff Discovery request for

Interrogatories, Request of Admission, and Request for Disclosure in accordance

with the Texas Rules of Civil Procedures 194.2, 197, and 198, to Cause No. A-

180805 in a civil suit in the 58th Judicial District Court of Jefferson County Texas.

Request Number 5.

Admit: that you did not file a “Motion for withdrawal of Counsel” from the

Co-Defendant(s) Joyce M. Guy and Edward McCray herein “Between” the dates of

December 18th 2007 your claim of filing your “General Denial”(Only) to cause No.

A-180805 to the date of April 2nd 2008 and April 11, 2008, after being in

possession, custody, and control over Pro Se Plaintiff Discovery request for

Interrogatories, Request for Admission, and Request for Disclosure in accordance

with the Texas Rules of Civil Procedures 194.2, 197, and 198, during this time

frame “You” did not file a “Motion for withdrawal of Counsel to cause No. A-

180805

Request Number 6.

Admit: that you after being in full possession, custody, and legal control

over Pro Se Plaintiff Discovery request for Interrogatories, Request of Admission,

and Request for Disclosure in accordance with the Texas Rules of Civil Procedures

194.2, 197, and 198, from the dates of April 2nd 2008 and April 11, 2008,

throughout October 14th 2009 during this time frame of (1) year and (5) months

“You” did not file a “Motion for withdrawal of Counsel to cause No. A-180805

Request Number 7.

Admit: that “You” being in full possession, custody, and legal control over

Pro Se Plaintiff Discovery request for Interrogatories, Request for Admission, and

Request for Disclosure in accordance with the Texas Rules of Civil Procedures

194.2, 197, and 198, “Between” the dates of April 2nd 2008 and April 11, 2008,

throughout the dates of October 14th 2009 during this time frame of (1) year and

(5) months and counting days

“You” finally filed a “Certificate of Mailing Service” on or about October 14th

2009 to cause No. A-180805 to reply to said Discovery request of Interrogatories,

Request for Admission, and Request for Disclosure that the Pro Se Plaintiff herein

Mail to “You” between the dates of April 2nd 2008 and April 11th, of 2008 in a Civil

Suit in Common Law within the State of Texas.

Request Number 8.

Admit: That “You” being in full possession, custody, and legal control over

Pro Se Plaintiff Discovery Request for Interrogatories, Request for Admission, and

Request for Disclosure in accordance with the Texas Rules of Civil Procedures

194.2, 197, and 198,

“Between” the dates of April 2nd 2008 and April 11, 2008, throughout the dates of April 2nd 2009 and April 11th 2009 “You” for a time frame of (1) exact year during this said time frame of being in full possession, custody, and legal control over said Pro Se Plaintiff Discovery request for Interrogatories, Request for Admission, and Request for Disclosure

“You” did not even reply at all to any of the Pro Se Plaintiff Discovery legal

request for Interrogatories, Request of Admission, and Request for Disclosure that was mailed to you in accordance with the Texas Rules of Civil Procedures 194.2, 197, and 198, in cause No. A-180805 filed in the 58th Judicial District Court of Jefferson County Texas

Request Number 9.

Admit: “You” did not file a “Motion for withdrawal of Counsel” to cause No.

A-180805 between the dates of April 2nd 2008 and April 11, 2008, throughout the

dates of April 2nd 2009 and April 11th 2009 (1) exact year “Your” being in full

possession, custody, and legal control over Pro Se Plaintiff Discovery request for

Interrogatories, Request of Admission, and Request for Disclosure in accordance

with the Texas Rules of Civil Procedures 194.2, 197, and 198,.

Request Number 10.

Admit: “You” did not file a “Motion for withdrawal of Counsel” to cause No.

A-180805, Between the dates of April 2nd 2009 and April 11th 2009 while “Your” in

full possession, custody, and legal control over Pro Se Plaintiff Discovery request

for Interrogatories, Request of Admission, and Request for Disclosure in

accordance with the Texas Rules of Civil Procedures 194.2, 197, and 198,

“Throughout” the dates of October 14th 2009 some (6) months during this

additional time frame dates

“Your” in full possession, custody, and legal control over Pro Se Plaintiff

Discovery request for Interrogatories, Request of Admission, and Request for

Disclosure in accordance with the Texas Rules of Civil Procedures 194.2, 197, and

198, .

Request Number 11. Admit: Between” the dates of April 2nd 2008 and April 11, 2008, “Your” in

full possession, custody, and legal control over Pro Se Plaintiff Discovery request

for Interrogatories, Request of Admission, and Request for Disclosure in

accordance with the Texas Rules of Civil Procedures 194.2, 197, and 198,

“You” were legally required to file a reply of some sorts (30) days thereafter

Pro Se Plaintiff herein made such a Discovery request upon “You” for a legal

response and reply to Interrogatories, Request of Admission, and Request for

Disclosure in accordance with the Texas Rules of Civil Procedures 194.2, 197, and

198,. On or about the dates of April 2nd 2008 and April 11th, 2008.

Request Number 11.

Admit: that “You” in cause No. A-180805 “Between” the dates of April 2nd

2008 and April 11, 2008, throughout the dates of October 14 th 2009 “Your” in full

possession, custody, and legal control over Pro Se Plaintiff Discovery request for

Interrogatories, Request of Admission, and Request for Disclosure in accordance

with the Texas Rules of Civil Procedures 194.2, 197, and 198,

“You” never informed the Honorable Judge “Bob Wortham” of the 58th

Judicial District Court of Jefferson County Texas

“Your” being in complete refusal to file a legal response and reply to any

of the Interrogatories, Request of Admission, and Request for Disclosure Pro Se

Plaintiff mailed to “You” on the dates of April 2nd 2008 and April 11, 2008, in

accordance with the Texas Rules of Civil Procedures 194.2, 197, and 198, in cause

No. A-180805.

Request Number 12.

Admit: “You” never informed the Honorable Judge “Bob Wortham” of the

58th Judicial District Court of Jefferson County Texas between the time frame

dates of April 2nd 2008 and April 11, 2008, throughout the dates of April 2nd 2009

and April 11th 2009 (1) exact year

“Your” being in full possession, custody, and legal control over Pro Se

Plaintiff Discovery request for Interrogatories, Request of Admission, and Request

for Disclosure in accordance with the Texas Rules of Civil Procedures 194.2, 197,

and 198,.

“Your” being in complete refusal to file a legal response and reply to any of the Interrogatories, Request of Admission, and Request for Disclosure Pro Se Plaintiff mailed to “You” on the dates of April 2nd 2008 and April 11, 2008, in accordance with the Texas Rules of Civil Procedures 194.2, 197, and 198, in cause No. A-180805 for the “Legal behalf” of Co-Defendant(s) Joyce M. Guy and Edward McCray herein.

Request Number 13.

Admit: “You” did not request a longer extension of time from the Pro Se

Plaintiff herein and agree upon in writing to reply to said “Discovery Request of

Interrogatories, Request of Admission, and Request for Disclosure Pro Se Plaintiff

mailed to

“You” on the dates of April 2nd 2008 and April 11, 2008, in accordance with

the Texas Rules of Civil Procedures 194.2, 197, and 198, (30) Days after Service of

said discovery request in cause No. A-180805 for the “Legal behalf” of Co-

Defendant(s) Joyce M. Guy and Edward McCray herein.

Request Number 14.

Admit: “You” did not request a longer extension of time from the 58th

Judicial District Court Judge “Bob Wortham” in order to obtain a Court Order of

“approval” of the Honorable Court in “Your” being granted a longer extension of

time to reply to all of the said Discovery Request of Interrogatories, Request of

Admission, and Request for Disclosure Pro Se Plaintiff mailed to

“You” on the dates of April 2nd 2008 and April 11, 2008, in accordance with

the Texas Rules of Civil Procedures 194.2, 197, and 198,

(30) Days after Service of said discovery request in cause No. A-

180805 on the dates being described herein April 2nd 2008 and April 11th

2008 for the “Legal behalf” of Co-Defendant(s) Joyce M. Guy and Edward

McCray herein.

Request Number 15.

Admit: “You” did not give the 58th Judicial District Court Judge “Bob Wortham” any Written, or Verbal notice, cellular phone or office phone communication, memo, documents or emails transmission of any type, fax, text,

between the dates of April 2nd 2008 and April 11, 2008, throughout the dates of October 14th 2009

“Your” being granted a longer extension of time to reply to all of the said

Discovery Request of Interrogatories, Request of Admission, and Request for Disclosure Pro Se Plaintiff mailed to “You” on the dates of April 2nd 2008 and April 11, 2008, in accordance with the Texas Rules of Civil Procedures 194.2, 197, and 198,

“Your” were being in full possession, custody, and legal control over Pro Se

Plaintiff said “Discovery requests” in cause No. A-180805 on the dates being

described herein April 2nd 2008 and April 11th 2008 for the “Legal behalf” of Co-

Defendant(s) Joyce M. Guy and Edward McCray herein.

Request Number 16.

Admit: “You” did not give the 58th Judicial District Court Judge “Bob

Wortham” or his office clerk or any staff member of the 58th Judicial Court any

Written form, or Verbal notice of some sort, cellular phone call or office phone

communication of any type, memos, documents or emails transmission of any

type, faxes, text, between the dates of December 18th 2007 throughout the dates

of April 2nd 2008 and April 11, 2008

“You” wanted to file a Motion for withdrawal in cause No. A-180805 from

being acting Attorney of Record on the behalf of Co-Defendant(s) Joyce M. Guy

and Edward McCray herein.

Request Number 17.

Admit: “You” did not give the 58th Judicial District Court Judge “Bob

Wortham” or his office clerk or any staff member of the 58th Judicial Court any

Written form, or Verbal notice of some sort, cellular phone call or office phone

communication of any type, memos, documents or emails transmission of any

type, faxes, text, between the dates of April 2nd 2008 and April 11, 2008

throughout the dates of October 14th 2009

“You” wanted to file a Motion for withdrawal in cause No. A-180805 from

being acting Attorney of Record on the behalf of Co-Defendant(s) Joyce M. Guy

and Edward McCray herein.

Request Number 18.

Admit: “You” filed before 58th Judicial District Court Judge “Bob Wortham” A Response to Plaintiff Motion for Sanctions against you with “Your” Affidavit attached signed and dated September 11th 2009. For not replying to any of the Pro Se Plaintiff Discovery request between the dates of April 2nd 2008 and April 11, 2008 throughout October 13th 2009 in cause No. A-180805

Request Number 19.

Admit: “You” stated before the Honorable Court in your Response Motion for Sanctions document dated September 11th 2009, “You” being retain by Co-Defendant Joyce M. Guy herein for purpose of (Only) writing a general denial so as to avoid a default judgment being rendered against which you filed in December of 2007 in response to the complaint cause No. A-180805

Request Number 20.

Admit: “You” did in fact legally represent Co-Defendant(s) Joyce M. Guy and Edward McCray as acting Attorney of Record in cause No. A-180805 other then just simply filing a General Denial between the dates of December 18 th 2007 throughout the dates of October 14th 2009. Request Number 21.

Admit: “You” did in fact legally represent Co-Defendant(s) Joyce M. Guy and Edward McCray as acting Attorney of Record in cause No. A-180805 during a hearing held on the 28th day of August 2009 before the Honorable Judge Bob Wortham

Request Number 22.

Admit: “You” did in fact legally represent Co-Defendant(s) Joyce M. Guy and Edward McCray as acting Attorney of Record in cause No. A-180805 other then just simply filing a General Denial between the dates of December 18 th 2007 and filed your certificate of mailing service and response to said discovery request on the 14th day of October 2009 to Plaintiff said “Discovery Request of Interrogatories, Request of Admission, and Request for Disclosure Pro Se Plaintiff mailed to

“You” on the dates of April 2nd 2008 and April 11, 2008, in accordance with

the Texas Rules of Civil Procedures 194.2, 197, and 198, for the “Legal behalf” of

Co-Defendant(s) Joyce M. Guy and Edward McCray herein.

Request Number 23.

Admit: “You” fully fail and flat out refuse to reply to any of said discovery request of Interrogatories, Request of Admission, and Request for Disclosure Pro Se Plaintiff mailed to

“You” on the dates of April 2nd 2008 and April 11, 2008, in accordance with

the Texas Rules of Civil Procedures 194.2, 197, and 198, for the “Legal behalf” of

Co-Defendant(s) Joyce M. Guy and Edward McCray herein after (30) Days after

Service of said discovery request in cause No. A-180805 had expired for the “Legal

behalf” of Co-Defendant(s) Joyce M. Guy and Edward McCray herein.

Request Number 24.

Admit: “You” were retain by Co-Defendant(s) Joyce M. Guy and

Edward McCray to not reply to any discovery request of the Pro Se Plaintiff

herein cause No. A-180805 request of Interrogatories, Request of

Admission, and Request for Disclosure in the time frame dates of April 2nd

2008 and April 11, 2008 throughout April 2nd 2009 and April 11, 2009

Request Number 25.

Admit: “You” were retain by Co-Defendant(s) Joyce M. Guy and

Edward McCray to not reply to any discovery request of the Pro Se Plaintiff

herein cause No. A-180805 request of Interrogatories, Request of

Admission, and Request for Disclosure in the time frame dates of April 2nd

2008 and April 11, 2008 throughout September 1s t 2009

Request Number 26.

Admit: “You” claim were retain by Co-Defendant(s) Joyce M. Guy and

Edward McCray simply to the Attorney at Law duties of filing a General

Denial between the dates of December 18th 2007 but was acting Attorney

of Record throughout the dates of November 13th 2009.

Request Number 27.

Admit: “You” were retained by Co-Defendant(s) Joyce M. Guy and Edward McCray to hide all of the discovery phase of this civil cause No. A-180805 from the Pro Se Plaintiff and the 58th Judicial District Court of Jefferson County Texas and Not allowed Pro Se Plaintiff any legal access at all to said discovery request of Interrogatories, Request of Admission, and Request for Disclosure Pro Se Plaintiff mailed to

“You” on the dates of April 2nd 2008 and April 11, 2008, in

accordance with the Texas Rules of Civil Procedures 194.2, 197, and 198,

for the “Legal behalf” of Co-Defendant(s) Joyce M. Guy and Edward McCray

between the dates of April 2nd 2008 and April 11, 2008 throughout the

dates of September 1s t 2009.

Request Number 28.

Admit: “You” Attorney at Law were retained by Co-Defendant(s) Joyce M. Guy and Edward McCray in December of 2007 for cause No. A-180805 in the 58th Judicial District Court of Jefferson County Texas

Request Number 29.

Admit: “You” Attorney at Law were retained by Co-Defendant(s) Joyce M. Guy and Edward McCray in January of 2008 cause No. A-180805 in the 58th Judicial District Court of Jefferson County Texas

Request Number 30.

Admit: “You” Attorney at Law were retained by Co-Defendant(s) Joyce M. Guy and Edward McCray in February of 2008 cause No. A-180805 in the 58th Judicial District Court of Jefferson County Texas

Request Number 31.

Admit: “You” Attorney at Law were retained by Co-Defendant(s) Joyce M. Guy and Edward McCray in March of 2008 cause No. A-180805 in the 58th Judicial District Court of Jefferson County Texas

Request Number 32.

Admit: “You” Attorney at Law were retained by Co-Defendant(s) Joyce M. Guy and Edward McCray in April of 2008 cause No. A-180805 in the 58th Judicial District Court of Jefferson County Texas.

Request Number 33.

Admit: “You” Attorney at Law were retained by Co-Defendant(s) Joyce M. Guy and Edward McCray in May of 2008 cause No. A-180805 in the 58th Judicial District Court of Jefferson County Texas.

Request Number 34.

Admit: “You” Attorney at Law were retained by Co-Defendant(s) Joyce M. Guy and Edward McCray in June of 2008 cause No. A-180805 in the 58th Judicial District Court of Jefferson County Texas.

Request Number 35.

Admit: “You” Attorney at Law were retained by Co-Defendant(s) Joyce M. Guy and Edward McCray in July of 2008 cause No. A-180805 in the 58th Judicial District Court of Jefferson County Texas.

Request Number 36.

Admit: “You” Attorney at Law were retained by Co-Defendant(s) Joyce M. Guy and Edward McCray in August of 2008 cause No. A-180805 in the 58th Judicial District Court of Jefferson County Texas.

Request Number 37.

Admit: “You” Attorney at Law were retained by Co-Defendant(s) Joyce M. Guy and Edward McCray in September of 2008 cause No. A-180805 in the 58th Judicial District Court of Jefferson County Texas.

Request Number 38.

Admit: “You” Attorney at Law were retained by Co-Defendant(s) Joyce M. Guy and Edward McCray in October of 2008 cause No. A-180805 in the 58th Judicial District Court of Jefferson County Texas.

Request Number 39.

Admit: “You” Attorney at Law were retained by Co-Defendant(s) Joyce M. Guy and Edward McCray in November of 2008 cause No. A-180805 in the 58th Judicial District Court of Jefferson County Texas.

Request Number 40.

Admit: “You” Attorney at Law were retained by Co-Defendant(s) Joyce M. Guy and Edward McCray in December of 2008 cause No. A-180805 in the 58th Judicial District Court of Jefferson County Texas.

Request Number 41.

Admit: “You” Attorney at Law were retained by Co-Defendant(s) Joyce M. Guy and Edward McCray in January of 2009 cause No. A-180805 in the 58th Judicial District Court of Jefferson County Texas.

Request Number 42.

Admit: “You” Attorney at Law were retained by Co-Defendant(s) Joyce M. Guy and Edward McCray in February of 2009 cause No. A-180805 in the 58th Judicial District Court of Jefferson County Texas.

Request Number 43.

Admit: “You” Attorney at Law were retained by Co-Defendant(s) Joyce M. Guy and Edward McCray in March of 2009 cause No. A-180805 in the 58th Judicial District Court of Jefferson County Texas.

Request Number 44.

Admit: “You” Attorney at Law were retained by Co-Defendant(s) Joyce M. Guy and Edward McCray in April of 2009 cause No. A-180805 in the 58th Judicial District Court of Jefferson County Texas.

Request Number 45.

Admit: “You” Attorney at Law were retained by Co-Defendant(s) Joyce M. Guy and Edward McCray in May of 2009 cause No. A-180805 in the 58th Judicial District Court of Jefferson County Texas.

Request Number 46.

Admit: “You” Attorney at Law were retained by Co-Defendant(s) Joyce M. Guy and Edward McCray in June of 2009 cause No. A-180805 in the 58th Judicial District Court of Jefferson County Texas.

Request Number 47.

Admit: “You” Attorney at Law were retained by Co-Defendant(s) Joyce M. Guy and Edward McCray in July of 2009 cause No. A-180805 in the 58th Judicial District Court of Jefferson County Texas.

Request Number 48.

Admit: “You” Attorney at Law were retained by Co-Defendant(s) Joyce M. Guy and Edward McCray in August of 2009 cause No. A-180805 in the 58th Judicial District Court of Jefferson County Texas.

Request Number 49.

Admit: “You” Attorney at Law were retained by Co-Defendant(s) Joyce M. Guy and Edward McCray in September of 2009 cause No. A-180805 in the 58th Judicial District Court of Jefferson County Texas.

Request Number 50.

Admit: “You” Attorney at Law were retained by Co-Defendant(s) Joyce M. Guy and Edward McCray in October of 2009 cause No. A-180805 in the 58th Judicial District Court of Jefferson County Texas.

Request Number 51.

Admit: “You” Attorney at Law were retained by Co-Defendant(s) Joyce M. Guy and Edward McCray in May of 2008 cause No. A-180805 in the 58th Judicial District Court of Jefferson County Texas to Keep all of Pro Se Plaintiff Discovery request of Interrogatories, Request of Admission, and Request for Disclosure secret filing away from the Honorable Court records and you simply not reply at all.

Request Number 52.

Admit: “You” Attorney at Law were retained by Co-Defendant(s) Joyce M. Guy and Edward McCray in June of 2008 cause No. A-180805 in the 58th Judicial District Court of Jefferson County Texas to Keep all of Pro Se Plaintiff Discovery request of Interrogatories, Request of Admission, and Request for Disclosure secret filing away from the Honorable Court records and you simply not reply at all..

Request Number 53.

Admit: “You” Attorney at Law were retained by Co-Defendant(s) Joyce M. Guy and Edward McCray in July of 2008 cause No. A-180805 in the 58th Judicial District Court of Jefferson County Texas to Keep all of Pro Se Plaintiff Discovery request of Interrogatories, Request of Admission, and Request for Disclosure secret filing away from the Honorable Court records and you simply not reply at all..

Request Number 54.

Admit: “You” Attorney at Law were retained by Co-Defendant(s) Joyce M. Guy and Edward McCray in August of 2008 cause No. A-180805 in the 58th Judicial District Court of Jefferson County Texas to Keep all of Pro Se Plaintiff Discovery request of Interrogatories, Request of Admission, and Request for Disclosure secret filing away from the Honorable Court records and you simply not reply at all..

Request Number 55.

Admit: “You” Attorney at Law were retained by Co-Defendant(s) Joyce M. Guy and Edward McCray in September of 2008 cause No. A-180805 in the 58th Judicial District Court of Jefferson County Texas to Keep all of Pro Se Plaintiff Discovery request of Interrogatories, Request of Admission, and Request for Disclosure secret filing away from the Honorable Court records and you simply not reply at all..

Request Number 56.

Admit: “You” Attorney at Law were retained by Co-Defendant(s) Joyce M. Guy and Edward McCray in October of 2008 cause No. A-180805 in the 58th Judicial District Court of Jefferson County Texas to Keep all of Pro Se Plaintiff Discovery request of Interrogatories, Request of Admission, and Request for Disclosure secret filing away from the Honorable Court records and you simply not reply at all.

Request Number 57.

Admit: “You” Attorney at Law were retained by Co-Defendant(s) Joyce M. Guy and Edward McCray in November of 2008 cause No. A-180805 in the 58th Judicial District Court of Jefferson County Texas to Keep all of Pro Se Plaintiff Discovery request of Interrogatories, Request of Admission, and Request for Disclosure secret filing away from the Honorable Court records and you simply not reply at all.

Request Number 58.

Admit: “You” Attorney at Law were retained by Co-Defendant(s) Joyce M. Guy and Edward McCray in December of 2008 cause No. A-180805 in the 58th Judicial District Court of Jefferson County Texas to Keep all of Pro Se Plaintiff Discovery request of Interrogatories, Request of Admission, and Request for Disclosure secret filing away from the Honorable Court records and you simply not reply at all.

Request Number 59.

Admit: “You” Attorney at Law were retained by Co-Defendant(s) Joyce M. Guy and Edward McCray in January of 2009 cause No. A-180805 in the 58th Judicial District Court of Jefferson County Texas to Keep all of Pro Se Plaintiff Discovery request of Interrogatories, Request of Admission, and Request for Disclosure secret filing away from the Honorable Court records and you simply not reply at all.

Request Number 60.

Admit: “You” Attorney at Law were retained by Co-Defendant(s) Joyce M. Guy and Edward McCray in February of 2009 cause No. A-180805 in the 58th Judicial District Court of Jefferson County Texas to Keep all of Pro Se Plaintiff Discovery request of Interrogatories, Request of Admission, and Request for Disclosure secret filing away from the Honorable Court records and you simply not reply at all.

Request Number 61.

Admit: “You” Attorney at Law were retained by Co-Defendant(s) Joyce M. Guy and Edward McCray in March of 2009 cause No. A-180805 in the 58th Judicial District Court of Jefferson County Texas to Keep all of Pro Se Plaintiff Discovery request of Interrogatories, Request of Admission, and Request for Disclosure secret filing away from the Honorable Court records and you simply not reply at all.

Request Number 62.

Admit: “You” Attorney at Law were retained by Co-Defendant(s) Joyce M. Guy and Edward McCray in April of 2009 cause No. A-180805 in the 58th Judicial District Court of Jefferson County Texas to Keep all of Pro Se Plaintiff Discovery request of Interrogatories, Request of Admission, and Request for Disclosure secret filing away from the Honorable Court records and you simply not reply at all.

Request Number 63.

Admit: “You” Attorney at Law were retained by Co-Defendant(s) Joyce M. Guy and Edward McCray in May of 2009 cause No. A-180805 in the 58th Judicial District Court of Jefferson County Texas to Keep all of Pro Se Plaintiff Discovery request of Interrogatories, Request of Admission, and Request for Disclosure secret filing away from the Honorable Court records and you simply not reply at all.

Request Number 64.

Admit: “You” Attorney at Law were retained by Co-Defendant(s) Joyce M. Guy and Edward McCray in June of 2009 cause No. A-180805 in the 58th Judicial District Court of Jefferson County Texas to Keep all of Pro Se Plaintiff Discovery request of Interrogatories, Request of Admission, and Request for Disclosure secret filing away from the Honorable Court records and you simply not reply at all.

Request Number 65.

Admit: “You” Attorney at Law were retained by Co-Defendant(s) Joyce M. Guy and Edward McCray in July of 2009 cause No. A-180805 in the 58th Judicial District Court of Jefferson County Texas to Keep all of Pro Se Plaintiff Discovery request of Interrogatories, Request of Admission, and Request for Disclosure secret filing away from the Honorable Court records and you simply not reply at all.

Request Number 66.

Admit: “You” Attorney at Law were retained by Co-Defendant(s) Joyce M. Guy and Edward McCray in August of 2009 cause No. A-180805 in the 58th Judicial District Court of Jefferson County Texas to Keep all of Pro Se Plaintiff Discovery request of Interrogatories, Request of Admission, and Request for Disclosure secret filing away from the Honorable Court records and you simply not reply at all.

Request Number 67.

Admit: “You” Attorney at Law were retained by Co-Defendant(s) Joyce M. Guy and Edward McCray in September of 2009 cause No. A-180805 in the 58th Judicial District Court of Jefferson County Texas to Keep all of Pro Se Plaintiff Discovery request of Interrogatories, Request of Admission, and Request for Disclosure secret filing away from the Honorable Court records and you simply not reply at all.

Request Number 68.

Admit: “You” Attorney at Law Knew you was acting “Attorney of Record in April and May of 2008 cause No. A-180805 in the 58th Judicial District Court of Jefferson County Texas and did not file a “Motion for Withdrawal in April and May of 2008

Request Number 69.

Admit: “You” Attorney at Law Knew you was acting “Attorney of Record in June of 2008 cause No. A-180805 in the 58th Judicial District Court of Jefferson County Texas and did not file a “Motion for Withdrawal in June of 2008

Request Number 70.

Admit: “You” Attorney at Law Knew you was acting “Attorney of Record in July of 2008 cause No. A-180805 in the 58th Judicial District Court of Jefferson County Texas and did not file a “Motion for Withdrawal in July of 2008

Request Number 71.

Admit: “You” Attorney at Law Knew you was acting “Attorney of Record in August of 2008 cause No. A-180805 in the 58th Judicial District

Court of Jefferson County Texas and did not file a “Motion for Withdrawal in August of 2008

Request Number 72.

Admit: “You” Attorney at Law Knew you was acting “Attorney of Record in September of 2008 cause No. A-180805 in the 58th Judicial District Court of Jefferson County Texas and did not file a “Motion for Withdrawal in September of 2008

Request Number 73.

Admit: “You” Attorney at Law Knew you was acting “Attorney of Record in October of 2008 cause No. A-180805 in the 58th Judicial District Court of Jefferson County Texas and did not file a “Motion for Withdrawal in October of 2008

Request Number 74.

Admit: “You” Attorney at Law Knew you was acting “Attorney of Record in November of 2008 cause No. A-180805 in the 58th Judicial District Court of Jefferson County Texas and did not file a “Motion for Withdrawal in November of 2008

Request Number 75.

Admit: “You” Attorney at Law Knew you was acting “Attorney of Record in December of 2008 cause No. A-180805 in the 58th Judicial District Court of Jefferson County Texas and did not file a “Motion for Withdrawal in December of 2008

Request Number 76.

Admit: “You” Attorney at Law Knew you was acting “Attorney of Record in January of 2009 cause No. A-180805 in the 58th Judicial District Court of Jefferson County Texas and did not file a “Motion for Withdrawal in January of 2009

Request Number 77.

Admit: “You” Attorney at Law Knew you was acting “Attorney of Record in February of 2009 cause No. A-180805 in the 58th Judicial District Court of Jefferson County Texas and did not file a “Motion for Withdrawal in February of 2009

Request Number 78.

Admit: “You” Attorney at Law Knew you was acting “Attorney of Record in March of 2009 cause No. A-180805 in the 58th Judicial District Court of Jefferson County Texas and did not file a “Motion for Withdrawal in March of 2009

Request Number 79.

Admit: “You” Attorney at Law Knew you was acting “Attorney of Record in April of 2009 cause No. A-180805 in the 58th Judicial District Court of Jefferson County Texas and did not file a “Motion for Withdrawal in April of 2009

Request Number 80.

Admit: “You” Attorney at Law Knew you was acting “Attorney of Record in May of 2009 cause No. A-180805 in the 58th Judicial District Court of Jefferson County Texas and did not file a “Motion for Withdrawal in May of 2009

Request Number 81.

Admit: “You” Attorney at Law Knew you was acting “Attorney of Record in June of 2009 cause No. A-180805 in the 58th Judicial District Court of Jefferson County Texas and did not file a “Motion for Withdrawal in June of 2009

Request Number 82.

Admit: “You” Attorney at Law Knew you was acting “Attorney of Record in July of 2009 cause No. A-180805 in the 58th Judicial District Court of Jefferson County Texas and did not file a “Motion for Withdrawal in July of 2009

Request Number 83.

Admit: “You” Attorney at Law Knew you was acting “Attorney of Record in August of 2009 cause No. A-180805 in the 58th Judicial District Court of Jefferson County Texas and did not file a “Motion for Withdrawal in August of 2009

Request Number 84.

Admit: “You” Attorney at Law Knew you was acting “Attorney of Record in September of 2009 cause No. A-180805 in the 58th Judicial District Court of Jefferson County Texas and did not file a “Motion for Withdrawal in September of 2009

Request Number 84.

Admit: “You” Attorney at Law Knew you was acting “Attorney of Record in October of 2009 cause No. A-180805 in the 58th Judicial District Court of Jefferson County Texas and did not file a “Motion for Withdrawal in October of 2009

Request Number 85.

Admit: “You” Attorney at Law Knew you was acting “Attorney of Record in November of 2009 cause No. A-180805 in the 58th Judicial District Court of Jefferson County Texas and did in Facts and Circumstances file a “Motion for Withdrawal” as Attorney of record for the behalf of the Co-Defendant(s) Joyce M. Guy and Edward McCray herein on November 13th 2009 @ 10:22 AM in the Judicial District “Clerk of Court Office” of Jefferson County Texas.

Request Number 86.

Admit: “You” Attorney at Law Knew you was acting “Attorney of Record in December of 2007 cause No. A-180805 in the 58th Judicial District Court of Jefferson County Texas and did not file a “Motion for Withdrawal throughout the dates of March of 2007 as Attorney of record for the behalf of the Co-Defendant(s) Joyce M. Guy and Edward McCray herein.

Request Number 87.

Admit: “You” Attorney at Law was retained by Co-Defendant(s) Joyce. M. Guy and Edward McCray herein cause No. A-180805 and “You” Attorney at Law appear before a hearing at the 58th Judicial District Court of Jefferson County Texas on September 11th, 2009 before the Honorable Bob Wortham and your Clients Co-Defendant(s) Joyce. M. Guy and Edward McCray herein

Were through “You” were order to respond to Pro Se Plaintiff Discovery request of Interrogatories, Request of Admission, and Request for Disclosure “You” held in your possession, custody and legal control since dates of April 2nd 2008 and April 11, 2008, that “You” refused to respond to throughout the dates of September 11th, 2009 at this hearing before the Honorable Bob Wortham

Request Number 88.

Admit: “You” Attorney at Law was retained by Co-Defendant(s) Joyce. M. Guy and Edward McCray herein cause No. A-180805 and “You” Attorney at Law appear before a hearing at the 58th Judicial District Court of

Jefferson County Texas on August 28th, 2009 before the Honorable Bob Wortham and your Clients Co-Defendant(s) Joyce. M. Guy and Edward McCray herein was required to respond to a Motion Pro Se Plaintiff filed namely a (TRO) Temporary Restraining Order Against Co-Defendant “Joyce M. Guy” herein

Request Number 89.

Admit: “You” Attorney at Law was retained by Co-Defendant(s) Joyce. M. Guy and Edward McCray herein cause No. A-180805 and “You” Attorney at Law appear before a hearing at the 58th Judicial District Court of Jefferson County Texas on August 28th, 2009 before the Honorable Bob Wortham

And your Clients Co-Defendant(s) Joyce. M. Guy and Edward McCray herein was required to respond to a Motion Pro Se Plaintiff filed namely a Motion for a Guardian over “Norma Guy” Natural Mother to Co-Defendant Joyce M. Guy whom had power of Attorney of said “Mother”.

Request Number 90.

Admit: “You” Attorney at Law was retained by Co-Defendant(s) Joyce. M. Guy and Edward McCray herein cause No. A-180805 and had in your full possession, custody and legal control discovery request of Interrogatories, Request of Admission, and Request for Disclosure Pro Se Plaintiff mailed to “You” on the dates of April 2nd 2008 and April 11, 2008, and did not respond to any of said discovery request

When “You” Attorney at Law appear before a hearing at the 58th Judicial District Court of Jefferson County Texas on August 28th, 2009 before the Honorable Bob Wortham and your Clients Co-Defendant(s) Joyce. M. Guy and Edward McCray herein

Was required to respond to a Motion Pro Se Plaintiff filed namely a Motion for a Guardian over “Norma Guy” Natural Mother to Co-Defendant Joyce M. Guy whom had power of Attorney of said “Mother” and “You” did

not respond to discovery request of Interrogatories, Request for Admission, and Request for Disclosure on August 28th, 2009.

Request Number 91.

Admit: “You” Attorney at Law was retained by Co-Defendant(s) Joyce. M. Guy and Edward McCray herein cause No. A-180805 and had in your full possession, custody and legal control discovery request of Interrogatories, Request of Admission, and Request for Disclosure Pro Se Plaintiff mailed to “You” on the dates of April 2nd 2008 and April 11, 2008 and that

“You” refused to respond to any formal legal reply of some sorts to said discovery request and “You” attended two Hearing before the Honorable Bob Wortham 58th Judicial District Court of Jefferson County Texas on dates of August 28th, 2009 and September 11th, 2009 while still not responding to said discovery request of Interrogatories, Request of Admission, and Request for Disclosure Pro Se Plaintiff mailed to “You” on the dates of April 2nd 2008 and April 11, 2008.

Request Number 92.

Admit: “You” Attorney at Law was retained by Co-Defendant(s) Joyce. M. Guy and Edward McCray herein cause No. A-180805 at the old mailing address 448 DeQueen blvd. in Port Arthur Texas in December of 2007 and “You” having known Co-Defendant(s) last known address to be 5050 east 7th street in Port Arthur Texas77642 in the year 2009 up to November 13th of 2009

“Your” knowing full well of this change of mailing address and Co-Defendant(s) Joyce. M. Guy and Edward McCray living at a different location other then 448 DeQueen Blvd. in Port Arthur Texas while this civil suit still ongoing in the 58th Judicial District Court of Jefferson County Texas..

Request Number 93.

Admit: “You” Attorney at Law was retained by Co-Defendant(s)

Joyce. M. Guy and Edward McCray herein cause No. A-180805 at the old

mailing address 448 DeQueen blvd. in Port Arthur Texas in December of

2007 and having full knowledge that the old home was being completely

disassembled down to the ground and a “New Home” being replaced in

2009 at the old mailing address 448 DeQueen blvd. in Port Arthur Texas

And that is why “Your” having full knowledge of Co-Defendant(s)

Joyce. M. Guy and Edward McCray herein cause No. A-180805 and that is

why “You” are having known Co-Defendant(s) Joyce. M. Guy and Edward

McCray last known address to be 5050 east 7th street in Port Arthur

Texas77642 in the year 2009 up to November 13th of 2009.

Request Number 94.

Admit: “You” Attorney at Law was retained by Co-Defendant(s)

Joyce. M. Guy and Edward McCray herein cause No. A-180805 at the old

mailing address 448 DeQueen blvd. in Port Arthur Texas 77640 in

December of 2007 and mailed to Co-Defendant(s) Joyce. M. Guy and

Edward McCray herein ”Your” Motion for withdrawal “You” filed on

November 13th 2009 whereby “You” mailed

“Your” Motion for withdrawal to 5050 east 7th street in Port Arthur

Texas 77642 whereby your having full knowledge of Co-Defendant(s) last

known address to be at 5050 east 7th street in Port Arthur Texas 77642

thereafter the knowledge of Co-Defendant(s) Joyce. M. Guy and Edward

McCray herein living in the dwelling located at 448 DeQueen blvd. in Port

Arthur Texas 77640.

Request Number 95.

Admit: “You” Attorney at Law was not going to mail a copy of “Your”

Motion for withdrawal to the dwelling located at 448 DeQueen blvd. in Port

Arthur Texas 77640 on or about November 13th of 2009 you filed in

Jefferson County Clerk of Court Office knowingly that the dwelling located

at 448 DeQueen blvd. in Port Arthur Texas no longer exist, and Construction

of a New Home had commence in the year of 2009 for the Co-Defendant(s)

Joyce. M. Guy and Edward McCray herein.

Request Number 96.

Admit: “You” Attorney at Law was retained by Co-Defendant(s) Joyce. M. Guy and Edward McCray herein cause No. A-180805 on or about December 18th 2007 and did “You” did not filed a Motion for withdrawal on or about June 18th 2009 when Co-Defendant(s) Joyce. M. Guy and Edward McCray herein transfer property dwelling located at 448 DeQueen blvd. in Port Arthur Texas to “The Department of Housing & Community Affairs” for a “New Home” during the same time frame “You” Attorney at Law was retained by Co-Defendant(s) Joyce. M. Guy and Edward McCray herein cause No. A-180805

And “You” had in your full possession, custody and legal control discovery request of Interrogatories, Request of Admission, and Request for Disclosure Pro Se Plaintiff mailed to “You” on the dates of April 2nd 2008 and April 11, 2008, and “You” did not respond to any of said discovery request until on or about October 14th 2009

Request Number 97.

Admit: “You” Attorney at Law was retained by Co-Defendant(s) Joyce. M. Guy and Edward McCray herein cause No. A-180805 on or about December 18th 2007 and”You” did not filed a Motion for withdrawal on or about June 18th 2009 when Co-Defendant(s) Joyce. M. Guy and Edward McCray herein filed with The County Clerk office in Jefferson County Texas “

“Financing Statement” in connection with “The Department of Housing & Community Affairs” for a “New Home” during the same time frame “You” Attorney at Law was retained by Co-Defendant(s) Joyce. M. Guy and Edward McCray herein cause No. A-180805

And “You” had in “Your” full possession, custody and legal control discovery request of Interrogatories, Request of Admission, and Request for Disclosure Pro Se Plaintiff mailed to “You” on the dates of April 2nd 2008 and April 11, 2008, and “You” did not respond to any of said discovery request until on or about October 14th 2009.

Request Number 98.

Admit: “You” Attorney at Law was retained by Co-Defendant(s) Joyce. M. Guy and Edward McCray herein cause No. A-180805 on or about December 18th 2007 and did not filed a Motion for withdrawal on or about June 18th 2009 when Co-Defendant(s) Joyce. M. Guy and Edward McCray herein had a

“Mechanics Lien” filed against them by “SWMJ Construction Inc.” filed with The County Clerk office in Jefferson County Texas “or about June 18th 2009 during the same time frame “You” Attorney at Law was retained by Co-Defendant(s) Joyce. M. Guy and Edward McCray herein cause No. A-180805

And “You” had in “Your” full possession, custody and legal control discovery request of Interrogatories, Request for Admission, and Request for Disclosure Pro Se Plaintiff mailed to “You” on the dates of April 2nd 2008 and April 11, 2008, and “You” did not respond to any of said discovery request until on or about October 14th 2009.

Request Number 99.

Admit: “You” Attorney at Law was retained by Co-Defendant(s) Joyce. M. Guy and Edward McCray herein cause No. A-180805 on or about December 18th 2007 as was requested to comply to Texas rules of Civil Procedures 30 days later with a response to Pro Se Plaintiff Discovery request “You” had in your full possession, custody and legal control, said discovery request of Interrogatories, Request of Admission, and Request for Disclosure Pro Se Plaintiff mailed to “You” on the dates of April 2nd 2008 and April 11, 2008, and

“You” did not respond to any of said discovery request (30) days later

as required and demanded but until in the time frame of on or about

October 14th 2009 when your response to Discovery Request in Civil No. A-

180805

Some (1) year and (6) months plus days later as “You” was requested complying with Texas rules of Civil Procedures, 194.2., 197, and 198. Request of Interrogatories, Request of Admission, and Request for Disclosure

Request Number 100.

Admit: “You” Attorney at Law was retained by Co-Defendant(s) Joyce. M. Guy and Edward McCray herein cause No. A-180805 on or about December 18th 2007 you filed a General Denial and on November 13th 2009 at 10:22 am “You” filed a Motion to Withdrawal as Counsel from Co-Defendant(s) herein “Joyce M. Guy and Edward McCray Civil No. A-180805 filed in The Jefferson County 58th Judicial District Court in Jefferson County Texas.

Request Number 101.

Admit: Texas Rules of Civil Procedures 194.2. (Plaintiff) “Request for Disclosure” require mailed to you on the dates of April 2nd 2008 and April 11, 2008“You” to respond to on behalf of Co-Defendant(s) Joyce. M. Guy and Edward McCray herein cause No. A-180805 (30) days thereafter mailing of service upon “You” to so reply

Request Number 102.

Admit: Texas Rules of Civil Procedures 197 (Plaintiff) “Interrogatories” mailed to “You” ” on the dates of April 2nd 2008 and April 11, 2008 require “You” to respond to on behalf of Co-Defendant(s) Joyce. M. Guy and Edward McCray herein cause No. A-180805 (30) days thereafter mailing of service upon “You” to so reply

Request Number 103.

Admit: Texas Rules of Civil Procedures 198 (Plaintiff) “Interrogatories” mailed to “You” ” on the dates of April 2nd 2008 and April 11, 2008 require “You” to respond to on behalf of Co-Defendant(s) Joyce.

M. Guy and Edward McCray herein cause No. A-180805 (30) days thereafter mailing of service upon “You” to so reply

Request Number 104.

Admit: “You” Attorney at Law are partly “Responsible for the damages suffered by Pro Se Plaintiff herein.

Request Number 105.

Admit: “You” Attorney at Law are fully “Responsible for the damages suffered by Pro Se Plaintiff herein.

Request Number 106.

Admit: “You” Attorney at Law do not have any defenses to the claims against you contained in Pro Se Plaintiff’s Complaint

Request Number 107.

Admit: “You” Attorney at Law that none of the denials contained in your answer to Pro Se Plaintiff’s Complaint have any Merit.

Request Number 108.

Admit: “You” Attorney at Law that you signed the “response to Plaintiff’s Motion for Sanctions attached as document #1 herein

Request Number 109.

Admit: “You” Attorney at Law that you signed the “Motion for Withdrawal of Counsel” On November 13th, 2009 filed at 10:22 am Jefferson County Texas, Courthouse Clerk of Court Office attached as document #2 attached herein

Request Number 110.

Admit: “You” Attorney at Law that “You” supplied Co-Defendant(s) “Joyce M. Guy” and Edward McCray last known addresses to be that of 5050 east 7th street in Port Arthur Texas 77642 in November 13th 2009 on

the attached document #2 herein containing “Your” signature. “Motion for Withdrawal of Counsel” On November 13th, 2009 filed at 10:22 am Jefferson County Texas, Courthouse Clerk of Court Office

Request Number 111.

Admit: “You” Attorney at Law that “You did not file a

“Motion for Withdrawal of Counsel” attached as document #2 herein until November 13th, 2009 filed at 10:22 am Jefferson County Texas, Courthouse Clerk of Court Office and that you were legally retain as Attorney of Law Texas Bar. No. 24058299 to attended (2) court hearing before the 58th Judicial District Court in Jefferson County Texas for the legal behalf of Co-Defendant(s) Joyce. M. Guy and Edward McCray herein cause No. A-180805 on the dates of “August 28th 2009 and September 11th 2009

Request Number 112.

Admit: “You” Attorney at Law that “You” signed the “Response to First Set of Interrogatories of Plaintiff Louis Charles Hamilton II on October 14th 2009 attached document #3 herein containing “Your” signature, that “You” Attorney at Law had in “Your” legal possession, custody and control on the dates of April 2nd 2008 and April 11, 2008.

Request Number 113.

Admit: “You” Attorney at Law that “You” signed the “Response to Request for Admissions of Plaintiff Louis Charles Hamilton II on October 14th 2009 attached document #4 herein containing “Your” signature, that “You” Attorney at Law had in “Your” legal possession, custody and control on the dates of April 2nd 2008 and April 11, 2008.

Request Number 114.

Admit: “You” Attorney at Law that “You” were “monetary retain” to file a General Denial on December 18th 2007 and that you were legally retained as Attorney of Law Texas Bar. No. 24058299 to attended (2) court

hearing before the 58th Judicial District Court in Jefferson County Texas for the legal behalf of Co-Defendant(s) Joyce. M. Guy and Edward McCray herein cause No. A-180805 on the dates of “August 28th 2009 and September 11th 2009

But “You” was “monetary retain” to keep also all discovery request phase of request of Interrogatories, Request for Admission, and Request for Disclosure you had in your possession, custody and legal control “Absolutely Secret”, Private, and not to be a part of the Pro Se Plaintiff herein ongoing civil court proceeding against Co-Defendant(s) Joyce. M. Guy and Edward McCray herein while “Your” being acting Attorney of record for cause No. A-180805 filed in the Jefferson County Texas Courthouse

Request Number 115.

Admit: “You” Attorney at Law that you were “monetary retain” to file a “General Denial” on December 18th 2007 for the Co-Defendant(s) Joyce. M. Guy and Edward McCray herein then “You” Attorney at Law

Were monetary retain as legal counsel “once again” on August 28th 2009 to attend a Court hearing same cause No. A-180805 filed in the Jefferson County Texas Courthouse for the Co-Defendant(s) Joyce. M. Guy and Edward McCray herein then

“You” Attorney at Law were retained “another once” as legal counsel again on September 11th 2009 to attend another separate court hearing in the same cause No. A-180805 filed in the Jefferson County Texas Courthouse

But “You” Attorney at Law at no time frame between the dates of April 2nd 2008 and April 11, 2008, throughout September 14th 2009 was monetary retain by the Co-Defendant(s) Joyce. M. Guy and Edward McCray herein

To file and respond to any of the Pro Se Plaintiff Discovery request “You” had in your full possession, custody and legal control, said discovery request of Interrogatories, Request of Admission, and Request for Disclosure Pro Se Plaintiff mailed to

“You” on the dates of April 2nd 2008 and April 11th 2008 for the same cause No. A-180805 filed in the Jefferson County Texas Courthouse.

Request Number 116.

Admit: “You” Attorney at Law that “You” were “monetary retain” to file a General Denial on December 18th 2007 and that you were legally retained once again at some point as acting Attorney of Law Texas Bar. No. 24058299 to prepare and be ready to attended (2) court hearing before the 58th Judicial District Court in Jefferson County Texas for the legal behalf of Co-Defendant(s) Joyce. M. Guy and Edward McCray herein cause No. A-180805 on the dates of “August 28th 2009 and September 11th 2009

And during this same time frame of your retain services on September 2nd of 2009 before “Your” September 11th 2009 hearing No. A-180805 that required “You” to produce Pro Se Plaintiff said discovery request on behalf of Co-Defendant(s) Joyce M. Guy and Edward McCray herein

Pro Se Plaintiff herein filed on September 2nd of 2009 “inquiry, investigation, and complaint” #21883 with the “State of Texas, Department of Aging and Disability Services” regarding GNG Service Company of Co-Defendant “Joyce M. Guy” herein in violation of Health and Safety Code Chapter 142 by

Co-Defendant “Joyce M. Guy” herein engaging in home health or personal assistance services, which includes hands-on personal care; by representing to the public that Co-Defendant “Joyce M. Guy” herein is a provider of home health, or personal assistance services which includes hands-on personal care for “Pay”

Co-Defendant “Joyce M. Guy” herein never having a HCSSA license and immediately cease providing home health services without said HCSSA licensed attached document #5 and # 6 herein dated December 1s t, 2009 and January 7th 2010

Request Number 117.

Admit: “You” Attorney at Law that “You” were fully aware during the time frame of December 18th 2007 throughout “Your” being acting Attorney of record until November 13th 2009 your being aware Pro Se Plaintiff was making “inquiry, investigation, and discovery requests into the past history of your “Clients” Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein.

Request Number 118.

Admit: “You” Attorney at Law that “You” signed the “Response to First Set of Interrogatories of Plaintiff Louis Charles Hamilton II on October 14th 2009 attached document #3 herein containing “Your” signature, that “You” did not forward said discovery request back to the Pro Se Plaintiff herein their after (60) days of said discovery request being in your full legal possession, custody, and legal control on or about the dates of April 2nd 2008 and April 11, 2008.

Request Number 119.

Admit: “You” Attorney at Law that “You” signed the “Request for Admission of Plaintiff Louis Charles Hamilton II on October 14th 2009 attached document #2 herein containing “Your” signature,

That “You” did not forward said discovery request back to the Pro Se Plaintiff herein their after (60) days of said discovery request being in your full legal possession, custody, and legal control on or about the dates of April 2nd 2008 and April 11, 2008.

Request Number 120.

Admit: “You” Attorney at Law that “You” signed the “Response to First Set of Interrogatories of Plaintiff Louis Charles Hamilton II on October 14th 2009 attached document #3 herein containing “Your” signature, that

“You” did not forward all of said legal discovery request “docket No. A-180805” being in “Your” full legal possession, custody, and legal control on or about the dates of April 2nd 2008 and April 11, 2008

Being forward (30) to (60) days thereafter to any other Law Office or Attorney(s) other then “Yourself” for the “Legal Behalf of the Co-Defendant(s) Joyce M. Guy and Edward McCray herein ongoing Civil Suit in Common Law.

Request Number 121.

Admit: “You” Attorney at Law that “You” signed the “Request for Admission of Plaintiff Louis Charles Hamilton II on October 14th 2009 attached document #2 herein containing “Your” signature,

“You” did not forward all of said legal discovery request “docket No. A-180805” being in “Your” full legal possession, custody, and legal control on or about the dates of April 2nd 2008 and April 11, 2008

Being Forward (30) to (60) days thereafter to any other Law Office or Attorney(s) other then “Yourself” for the “Legal Behalf of the Co-Defendant(s) Joyce M. Guy and Edward McCray herein ongoing Civil Suit in Common Law.

Request Number 122.

Admit: “You” Attorney at Law that “You” received and had in “Your” possession, custody, and legal control from Pro Se Plaintiff “Louis Charles Hamilton II” herein a “Motion for Production of Document(s) dated August 12th 2009” on the certificate of mailing services for the same cause No. A-180805 filed in the Jefferson County Texas Courthouse

Said Motion for Production of Document(s) requested “among other things” copies of the Property Deeds of the dwelling of 448 DeQueen Blvd. in Port Arthur Texas.

That’s being in the possession, custody and legal control of the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein

Request Number 123.

Admit: “You” Attorney at Law that “You” received and had in “Your” possession, custody, and legal control from Pro Se Plaintiff “Louis Charles

Hamilton II” herein a “Motion for Production of Document(s) dated August 12th 2009” on the certificate of mailing services for the same cause No. A-180805 filed in the Jefferson County Texas Courthouse and

“You” Attorney at Law was retain to attended a hearing on August 28th 2009 (16) days later after “Your” receiving a “Motion for Production of Document(s) dated August 12th 2009” for the Behalf of the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein

While The Interrogatories, Request of Admission, and Request for Disclosure Pro Se Plaintiff mailed to “You” on the dates of April 2nd 2008 and April 11, 2008, in accordance with the Texas Rules of Civil Procedures 194.2, 197, and 198, in cause No. A-180805 “You” Attorney at Law refused to respond and that on the date of “August 12th 2009”

And “You” Attorney at Law did not file any Motion for withdrawal on “August 12th 2009 from cause No. A-180805 filed in the Jefferson County Texas Courthouse.

Request Number 124.

Admit: “You” Attorney at Law that “You” knew from the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein

That the “Property Deed of the dwelling of 448 DeQueen Blvd. in Port Arthur Texas. Pro Se Plaintiff sent “You” herein a “Motion for Production of Document(s) dated August 12th 2009 for said “Property Deeds that’s being in the possession, custody and legal control of the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein

During this same time frame “Your” being acting Attorney of record cause No. A-180805 filed in the Jefferson County Texas Courthouse said “Property Deeds” was Legally Transfer to the Texas Department of Housing & Community Affairs on June 18th 2009 as described by “Jefferson County Real Estate Index in attached document #7 herein

Request Number 125.

Admit: “You” Attorney at Law that “You” refused to respond to any of Pro Se Plaintiff “Motion for Production of Document(s) dated August 12th 2009” on the certificate of mailing services for the same cause No. A-180805 filed in the Jefferson County Texas Courthouse (30) days thereafter service upon

“You” for the behalf of the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein and “You” did not file a Motion for withdrawal on September 9th 2009 while being in the possession, custody and legal control Pro Se Plaintiff “Motion for Production of Document(s) dated August 12 th 2009”

Request Number 126.

Admit: “You” Attorney at Law that “You” refused to respond to any of Pro Se Plaintiff “Motion for Production of Document(s) dated August 12 th 2009” on the certificate of mailing services for the same cause No. A-180805 filed in the Jefferson County Texas Courthouse (30) days thereafter service upon “You” for the behalf of the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein

And “You” however in facts was retain to attend a hearing on the date of August 28th 2009 services for the same cause No. A-180805 in the capacity as Attorney of Record some (16) days after services of “Motion for Production of Document(s) dated August 12th 2009” on the certificate of mailing services being in “Your” Possession, custody, and Control

Which “You” during this same “Time Frame” However were personally present for on the dates of August 28th 2009 hearing thereafter

While “You” already 100% being in full refusal to respond to any Pro Se Plaintiff herein discovery request in “Your” full possession, custody and legal control, discovery request of Interrogatories, Request of Admission, and Request for Disclosure Pro Se Plaintiff mailed to “You” on the dates of April 2nd 2008 and April 11, 2008 the past year.

Request Number 127.

Admit: “You” Attorney at Law that “You” refused to respond to any of Pro Se Plaintiff “Motion for Production of Document(s) dated August 12th 2009” on the certificate of mailing services for the same cause No. A-180805 filed in the Jefferson County Texas Courthouse (30) days thereafter service upon “You” for the behalf of the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein

And “You” however in facts was retain to attend a hearing on the date of September 11th 2009 services for the same cause No. A-180805 in the capacity as Attorney of Record some (16) days after services of “Motion for Production of Document(s) dated August 12th 2009” on the certificate of mailing services being in “Your” Possession, custody, and Control

Which “You” were during this “same time frame” personally present for one said hearing on the dates of September 11th 2009 hearing thereafter

While “You” already being in 100% full refusal to respond to any Pro Se Plaintiff herein discovery request in “Your” full possession, custody and legal control, discovery request of Interrogatories, Request of Admission, and Request for Disclosure Pro Se Plaintiff mailed to “You” on the dates of April 2nd 2008 and April 11, 2008 the past year.

Request Number 128. Admit: “You” Attorney at Law that “Jefferson County Real Estate

Index” Instrument #2009022762 in Attached document #7 herein shown the Legal Transfer of the property deed of the Co-Defendant(s) herein Joyce M. Guy and Edward McCray” dwelling located at 448 DeQueen Blvd. in Port Arthur Texas herein on the dates of June 18th 2009 to “The Texas Department of Housing & Community Affairs

While Which “Your” in full refusal to respond to Pro Se Plaintiff

“Motion for Production of Document(s) dated August 12th 2009”on the certificate of mailing services for the same cause No. A-180805 filed in the Jefferson County Texas Courthouse (30) days thereafter service upon “You” for the behalf of the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein copies of such “Property Deeds” ”

For the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas being already complained of in a among other cause of action “Breach of Contract dispute” in a civil suit in common law before the 58th Judicial District Court of Jefferson County Texas cause No. A-180805.

Request Number 129.

Admit: “You” Attorney at Law that “You” having in “Your” full possession, custody and legal control, over Pro Se Plaintiff herein “Motion to Compel” Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein with mailing service date executed on September 9th 2009 same cause No. A-180805

While “You” already being in 100% full refusal to respond to any Pro Se Plaintiff herein discovery request in “Your” full possession, custody and legal control, discovery request of Interrogatories, Request of Admission, and Request for Disclosure Pro Se Plaintiff mailed to “You” on the dates of April 2nd 2008 and April 11, 2008 the past year same cause No. A-180805,

While “You” were already during this “same time frame” personally present for one said hearing on the dates of September 11th 2009 hearing thereafter same cause No. A-180805

While “You” were already during this “same time frame” personally present for one said hearing on the dates of August 28th 2009 hearing thereafter not filing a “Motion for withdrawal” same cause No. A-180805

While “You” were already during this “same time frame” ” refused to respond to any of Pro Se Plaintiff “Motion for Production of Document(s) dated August 12th 2009” on the certificate of mailing services for the same cause No. A-180805 filed in the Jefferson County Texas Courthouse (30) days thereafter service upon

“You” for the behalf of the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein to Produce among other things copies of Property deed for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas (Lot) 1-2 blk. 172 (Port Arthur Texas) same cause No. A-180805

While “You” Attorney at Law refusal to file “Your” “Motion for “Your” withdrawal on or before next 58th Judicial District Court in Jefferson County Texas hearing on the dates set for September 11th 2009 same cause No. A-180805.

While “You” did personally appeared as acting Attorney of Record for same cause No. A-180805 on the dates of September 11th 2009.

But “Your” never replying to or responding to any such discovery request sought by the Pro Se Plaintiff herein as described herein “Request for Admission” # 129.

Request Number 130.

Admit: “You” Attorney at Law that “You” knew Texas rules of Civil Procedures 196. Govern “Motion for Production of Documents” require “You” to respond to (30) days thereafter service upon you such a Motion for Production of Documents.

Request Number 131.

Admit: “You” Attorney at Law that “You” knew Texas rules of Civil Procedures 196. Govern “Motion for Production of Documents” require “You” to respond to (30) days thereafter service upon you for such a Motion for Production of Documents and “You” Attorney at law refuse to respond (30) days thereafter service upon you on dates of Service of mailing date August 12th 2009.

Request Number 132.

Admit: “You” Attorney at Law that “You” knew Texas rules of Civil Procedures 196. Govern “Motion for Production of Documents” require “You” to respond to (30) days thereafter service upon you for such a Motion for Production of Documents and

“You” Attorney at law refuse to respond (30) days thereafter service upon you on dates of Service of mailing date August 12th 2009 for said Production copies of “Property Deeds” for the dwelling located at 448

DeQueen Blvd. in Port Arthur Texas (Lot) 1-2 blk. 172 (Port Arthur Texas) same cause No. A-180805

But “Your” in 100% refusal to File a simple Motion for “Your” withdrawal of Counsel for the behalf of the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein during the time frame dates of August 12th 2009.

Request Number 133.

Admit: “You” Attorney at Law that “Your” Legal Expert in the capacity of “Attorney at Law” specialties skills “among other things” are described expert in Criminal Defense, “Fraud”, Insurance and Personal Injury at two legal law firms locations in Jefferson County, Port Arthur Texas

Request Number 134.

Admit: “You” Attorney at Law that “Your” reply in your response to Pro Se Plaintiff motion for sanctions dated the 11th day of September 2009 you state of having any knowledge of “Required Pro Se Plaintiff discovery request for admissions, interrogatories and Disclosure on or about the dates of April 2nd 2008 and April 11, 2008 as described in Document # 1 attached herein.

Request Number 135.

Admit: “You” Attorney at Law that on Document # 1 containing your correct Texas Bar No. 24058299

Request Number 136.

Admit: “You” Attorney at Law that on Document # 8 58th Judicial District Court of Jefferson County Texas “Case Ledger” that on March 14 th 2008 is the correct “actual date” your having full knowledge of Required Pro Se Plaintiff discovery request for admissions, interrogatories and Disclosure for cause No. A-180805

Request Number 137.

Admit: “You” Attorney at Law that “Your” reply in your response to Pro Se Plaintiff motion for sanctions dated the 11th day of September 2009 Document # 1 herein

You state of having any knowledge of “Required Pro Se Plaintiff discovery request for admissions, interrogatories and Disclosure on or about the dates of April 2nd 2008 and April 11, 2008 as described in Document # 1 attached herein

And this is not-correct and completely a false statement made by “you” “Attorney at Law” in regards to the correct dates of “Your” having knowledge of Pro Se Plaintiff discovery request for admissions, interrogatories and Disclosure

And the correct date is March 14th 2008 “Your” having actual knowledge of “Required Pro Se Plaintiff discovery request for admissions, interrogatories and Disclosure as described in Document # 8 herein 58th Judicial District Court of Jefferson County Texas “Case Ledger”

Request Number 138.

Admit: “You” Attorney at Law that is “Your” signature on Document # 9 attached herein “Your” Affidavit in Support of your reply to Pro Se Plaintiff Motion for sanctions dated 11th day of September 2009 and Document # 9 contain a false verification on oath of “Your” sworn statement made by “you”

And “Your” having actual knowledge of “Required Pro Se Plaintiff discovery request for admissions, interrogatories and Disclosure as described in Document # 8 herein 58th Judicial District Court of Jefferson County Texas “Case Ledger”

Request Number 139.

Admit: “You” Attorney at Law that “Your” Affidavit in support of your reply to Pro Se Plaintiff “Motion for Sanctions” against you Document

#9 herein with false statement made by “You” was Placed in the United States Mail and Publically Mailed to the Pro Se Plaintiff herein at P.O. Box 342 Port Arthur Texas 77640

Request Number 140.

Admit: You” Attorney at Law that “Your” Affidavit in support of your reply to Pro Se Plaintiff “Motion for Sanctions” against you Document #9 herein with false statement made by “You” was Placed in the United States Mail and Publically Mailed to Co -Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein Cause No. A-180805

Request Number 141.

Admit: You” Attorney at Law that “Your” Affidavit in support of your reply to Pro Se Plaintiff “Motion for Sanctions” against you Document #9 herein with false statement made by “You” was Placed in the United States Mail and Publically Mailed to The Jefferson County Texas Court House “Clerk of District Court” for cause No. A-180805

Request Number 142.

Admit: You” Attorney at Law that “Your” Affidavit in support of your reply to Pro Se Plaintiff “Motion for Sanctions” against you Document #9 herein with false statement made by “You” was Placed in the United States Mail and Publically Mailed to The Jefferson County Texas Court House “Clerk of District Court” for cause No. A-180805

And was electronically computer filed in Document # 8 herein 58th Judicial District Court of Jefferson County Texas “Case Ledger” and Court Records for cause No. A-180805

Request Number 143.

Admit: “You” Attorney at Law that “Your” reply/respond to Pro Se Plaintiff “Motion for Sanctions” against you Document #1 herein with false statement made by “You” was Placed in the United States Mail and Publically Mailed to the Pro Se Plaintiff herein at P.O. Box 342 Port Arthur Texas 77640

Request Number 144.

Admit: “You” Attorney at Law that “Your” reply/respond to Pro Se Plaintiff “Motion for Sanctions” against you Document #1 herein with false statement made by “You” was Placed in the United States Mail and Publically Mailed to Co -Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein Cause No. A-180805

Request Number 145.

Admit: “You” Attorney at Law that “Your” reply/respond to Pro Se Plaintiff “Motion for Sanctions” against you Document #1 herein with false statement made by “You” was Placed in the United States Mail and Publically Mailed to The Jefferson County Texas Court House “Clerk of District Court” for cause No. A-180805

Request Number 146.

Admit: “You” Attorney at Law that “Your” reply/respond to Pro Se Plaintiff “Motion for Sanctions” against you Document #1 herein with false statement made by “You” was Placed in the United States Mail and Publically Mailed to The Jefferson County Texas Court House “Clerk of District Court” for cause No. A-180805

And was electronically computer filed in Document # 8 herein 58th Judicial District Court of Jefferson County Texas “Case Ledger”

Request Number 147.

Admit: “You” Attorney at Law that “Your” Affidavit in support of your reply to Pro Se Plaintiff “Motion for Sanctions” against you Document #9 herein with false statement made by “You” was Placed in the United States Mail and Publically Mailed to the Pro Se Plaintiff herein at P.O. Box 342 Port Arthur Texas 77640

During this same time frame “Your” being acting Attorney of record cause No. A-180805 filed in the Jefferson County Texas Courthouse said “Property Deeds” for the dwelling located at 448 DeQueen Blvd. in Port

Arthur Texas of the Co-Defendant(s) “Joyce M. Guy and Edward McCray herein

Was Legally Transfer to the Texas Department of Housing & Community Affairs on June 18th 2009 as described by “Jefferson County Real Estate Index in attached document #7 herein for a $76,000.00 U. S. Dollars Housing Grant

Request Number 148.

Admit: You” Attorney at Law that “Your” Affidavit in support of your reply to Pro Se Plaintiff “Motion for Sanctions” against you Document #9 herein with false statement made by “You” was Placed in the United States Mail and Publically Mailed to Co -Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein Cause No. A-180805

During this same time frame “Your” being acting Attorney of record cause No. A-180805 filed in the Jefferson County Texas Courthouse said “Property Deeds” ” for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas of the Co-Defendant(s) “Joyce M. Guy and Edward McCray herein

Was Legally Transfer to the Texas Department of Housing & Community Affairs on June 18th 2009 as described by “Jefferson County Real Estate Index in attached document #7 herein for a $76,000.00 U. S. Dollars Housing Grant

Request Number 149.

Admit: You” Attorney at Law that “Your” Affidavit in support of your reply to Pro Se Plaintiff “Motion for Sanctions” against you Document #9 herein with false statement made by “You” was Placed in the United States Mail and Publically Mailed to The Jefferson County Texas Court House “Clerk of District Court” for cause No. A-180805

During this same time frame “Your” being acting Attorney of record cause No. A-180805 filed in the Jefferson County Texas Courthouse said “Property Deeds” ” for the dwelling located at 448 DeQueen Blvd. in Port

Arthur Texas of the Co-Defendant(s) “Joyce M. Guy and Edward McCray herein

Was Legally Transfer to the Texas Department of Housing & Community Affairs on June 18th 2009 as described by “Jefferson County Real Estate Index in attached document #7 herein for a $76,000.00 U. S. Dollars Housing Grant

Request Number 150.

Admit: You” Attorney at Law that “Your” Affidavit in support of your reply to Pro Se Plaintiff “Motion for Sanctions” against you Document #9 herein with false statement made by “You” was Placed in the United States Mail and Publically Mailed to The Jefferson County Texas Court House “Clerk of District Court” for cause No. A-180805

And was electronically computer filed in Document # 8 herein 58th Judicial District Court of Jefferson County Texas “Case Ledger” and Court Records for cause No. A-180805

During this same time frame “Your” being acting Attorney of record cause No. A-180805 filed in the Jefferson County Texas Courthouse said “Property Deeds” ” for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas of the Co-Defendant(s) “Joyce M. Guy and Edward McCray herein

Was Legally Transfer to the Texas Department of Housing & Community Affairs on June 18th 2009 as described by “Jefferson County Real Estate Index in attached document #7 herein for a $76,000.00 U. S. Dollars Housing Grant

Request Number 151.

Admit: “You” Attorney at Law that “Your” reply/respond to Pro Se Plaintiff “Motion for Sanctions” against you Document #1 herein with false statement made by “You” was Placed in the United States Mail and Publically Mailed to the Pro Se Plaintiff herein at P.O. Box 342 Port Arthur Texas 77640

During this same time frame “Your” being acting Attorney of record cause No. A-180805 filed in the Jefferson County Texas Courthouse said “Property Deeds” ” for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas of the Co-Defendant(s) “Joyce M. Guy and Edward McCray herein

Was Legally Transfer to the Texas Department of Housing & Community Affairs on June 18th 2009 as described by “Jefferson County Real Estate Index in attached document #7 herein for a $76,000.00 U. S. Dollars Housing Grant

Request Number 152.

Admit: “You” Attorney at Law that “Your” reply/respond to Pro Se Plaintiff “Motion for Sanctions” against you Document #1 herein with false statement made by “You” was Placed in the United States Mail and Publically Mailed to Co -Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein Cause No. A-180805

During this same time frame “Your” being acting Attorney of record cause No. A-180805 filed in the Jefferson County Texas Courthouse said “Property Deeds” ” for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas of the Co-Defendant(s) “Joyce M. Guy and Edward McCray herein

Was Legally Transfer to the Texas Department of Housing & Community Affairs on June 18th 2009 as described by “Jefferson County Real Estate Index in attached document #7 herein for a $76,000.00 U. S. Dollars Housing Grant

Request Number 153.

Admit: “You” Attorney at Law that “Your” reply/respond to Pro Se Plaintiff “Motion for Sanctions” against you Document #1 herein with false statement made by “You” was Placed in the United States Mail and Publically Mailed to The Jefferson County Texas Court House “Clerk of District Court” for cause No. A-180805

During this same time frame “Your” being acting Attorney of record cause No. A-180805 filed in the Jefferson County Texas Courthouse said “Property Deeds” ” for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas of the Co-Defendant(s) “Joyce M. Guy and Edward McCray herein

Was Legally Transfer to the Texas Department of Housing & Community Affairs on June 18th 2009 as described by “Jefferson County Real Estate Index in attached document #7 herein for a $76,000.00 U. S. Dollars Housing Grant

Request Number 154.

Admit: “You” Attorney at Law that “Your” reply/respond to Pro Se Plaintiff “Motion for Sanctions” against you Document #1 herein with false statement made by “You” was Placed in the United States Mail and Publically Mailed to The Jefferson County Texas Court House “Clerk of District Court” for cause No. A-180805 by “You”

And was electronically computer filed in Document # 8 herein 58th Judicial District Court of Jefferson County Texas “Case Ledger”

During this same time frame “Your” being acting Attorney of record cause No. A-180805 filed in the Jefferson County Texas Courthouse said “Property Deeds” ” for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas of the Co-Defendant(s) “Joyce M. Guy and Edward McCray herein

Was Legally Transfer to the Texas Department of Housing & Community Affairs on June 18th 2009 as described by “Jefferson County Real Estate Index in attached document #7 herein for a $76,000.00 U. S. Dollars Housing Grant

Request Number 155.

Admit: “You” Attorney at Law that “You” filed Co-Defendant “Joyce M. Guy “ herein “Affidavit in Support” of “Your” response reply to Pro Se Plaintiff Motion for Sanctions against you Dated September 11th 2009 attached document # 10 herein

Request Number 156.

Admit: “You” Attorney at Law that on Document # 10 herein Co-Defendant “Joyce M. Guy” herein “Sworn Affidavit Statement States among other things “being personally acquainted with the facts alleged”, Retained Defendant (You) to draft and file a general denial on Co-Defendant Behalf.

Co-Defendant did not retain (You) to represent (Co-Defendant)

beyond drafting and filing a general denial on my behalf until sometime in August of 2009 when (You) informed me that Pro Se Plaintiff secured a hearing with regards to this lawsuit (A-180805)

(You) informed (Co-Defendant) between April 2nd 2008 and April 11th

2008 about Pro Se Plaintiff discovery request It was (Co-Defendant) decision and not (You) not to respond to the

discovery request of Pro Se Plaintiff. Request Number 157.

Admit: You having full legal “Attorney at Law” knowledge of Required Pro Se Plaintiff discovery request for admissions, interrogatories and Disclosure for cause No. A-180805 as Co-Defendant “Joyce M. Guy” and “You” corroborate the same facts in refusal to respond to discovery for over a full year in document #1 and document # 10 attached herein

Request Number 158.

Admit: “You” Attorney at Law that “You” drafted Co-Defendant “Joyce M. Guy” herein “Affidavit” dated September 11th 2009 for “Your” own Defense response reply to Pro Se Plaintiff Motion for Sanctions against “You” dated September 11th 2009 attached

In “Your” response to Pro Se Plaintiff motion for sanctions dated the 11th day of September 2009 Document # 1 herein

You state of having any knowledge of “Required Pro Se Plaintiff discovery request for admissions, interrogatories and Disclosure on or about the dates of April 2nd 2008 and April 11, 2008 as described in Document # 1 attached herein having any knowledge of “Required Pro Se Plaintiff discovery request for admissions, interrogatories and Disclosure on or about the dates of April 2nd 2008 and April 11, 2008 and as described in Document # 10 attached herein

And further Admit this is not-correct and completely a false statement made by “you” “Attorney at Law” and made by your client being Co-Defendant “Joyce M. Guy” herein in regards to the correct dates of “Your” both legally having knowledge of Pro Se Plaintiff discovery request for admissions, interrogatories and Disclosure

And the correct date is March 14th 2008 “Your” having actual knowledge of “Required Pro Se Plaintiff discovery request for admissions, interrogatories and Disclosure as described in Document # 8 herein 58 th Judicial District Court of Jefferson County Texas “Case Ledger”

Request Number 159.

Admit: “You” Attorney at Law that “Your” Affidavit in support of your reply to Pro Se Plaintiff “Motion for Sanctions” against you Document #9 herein and your response to Pro Se Plaintiff Motion for sanctions against “You” Document # 1 herein and Co-Defendant “Joyce M. Guy” “Affidavit in support of “You” document # 10 herein

Contain false statement made by “You” and Co-Defendant “Joyce M. Guy having any knowledge of “Required Pro Se Plaintiff discovery request for admissions, interrogatories and Disclosure on or about the dates of April 2nd 2008 and April 11, 2008 and as described in Document #1 and #10 attached herein

And further Admit all three documents #1, #9 and #10 was Placed in the United States Mail and Publically Mailed to the Pro Se Plaintiff herein at P.O. Box 342 Port Arthur Texas 77640 by “You”

Request Number 160.

Admit: “You” Attorney at Law that “Your” Affidavit in support of your reply to Pro Se Plaintiff “Motion for Sanctions” against you Document #9 herein and your response to Pro Se Plaintiff Motion for sanctions against “You” Document # 1 herein and Co-Defendant “Joyce M. Guy” “Affidavit in support of “You” document # 10 herein

Contain false statement made by “You” and Co-Defendant “Joyce M. Guy having any knowledge of “Required Pro Se Plaintiff discovery request for admissions, interrogatories and Disclosure on or about the dates of April 2nd 2008 and April 11, 2008 and as described in Document #1 and #10 attached herein

And further admit all three documents #1, #9 and #10 was Placed in the United States Mail and Publically Mailed to Co -Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein Cause No. A-180805

Request Number 161.

Admit: “You” Attorney at Law that “Your” Affidavit in support of your reply to Pro Se Plaintiff “Motion for Sanctions” against you Document #9 herein and your response to Pro Se Plaintiff Motion for sanctions against “You” Document # 1 herein and Co-Defendant “Joyce M. Guy” “Affidavit in support of “You” document # 10 herein

Contain false statement made by “You” and Co-Defendant “Joyce M. Guy having any knowledge of “Required Pro Se Plaintiff discovery request for admissions, interrogatories and Disclosure on or about the dates of April 2nd 2008 and April 11, 2008 and as described in Document #1 and #10 attached herein

And further Admit all three documents #1, #9 and #10 was Placed in the United States Mail and Publically Mailed to The Jefferson County Texas Court House “Clerk of District Court” for cause No. A-180805

Request Number 162.

Admit: “You” Attorney at Law that “Your” Affidavit in support of your reply to Pro Se Plaintiff “Motion for Sanctions” against you Document #9 herein and your response to Pro Se Plaintiff Motion for sanctions against

“You” Document # 1 herein and Co-Defendant “Joyce M. Guy” “Affidavit in support of “You” document # 10 herein

Contain false statement made by “You” and Co-Defendant “Joyce M. Guy having any knowledge of “Required Pro Se Plaintiff discovery request for admissions, interrogatories and Disclosure on or about the dates of April 2nd 2008 and April 11, 2008 and as described in Document #1 and #10 attached herein

And further Admit all three documents #1, #9 and #10 was Placed in the United States Mail and

Publically Mailed to The Jefferson County Texas Court House “Clerk of District Court” for cause No. A-180805

And was electronically computer filed in Document # 8 herein 58th Judicial District Court of Jefferson County Texas “Case Ledger” and Court Records for cause No. A-180805

Request Number 163.

“You” Attorney at Law that “Your” Affidavit in support of your reply to Pro Se Plaintiff “Motion for Sanctions” against you Document #9 herein and your response to Pro Se Plaintiff Motion for sanctions against “You” Document # 1 herein and Co-Defendant “Joyce M. Guy” “Affidavit in support of “You” document # 10 herein

Contain false statement made by “You” and Co-Defendant “Joyce M. Guy having any knowledge of “Required Pro Se Plaintiff discovery request for admissions, interrogatories and Disclosure on or about the dates of April 2nd 2008 and April 11, 2008 and as described in Document #1 and #10 attached herein

And further Admit all three documents #1, #9 and #10 was Placed in the United States Mail and

Publically Mailed to The Jefferson County Texas Court House “Clerk of District Court” for cause No. A-180805

And was electronically computer filed in Document # 8 herein 58th Judicial District Court of Jefferson County Texas “Case Ledger” and Court Records for cause No. A-180805

During this same time frame “Your” being acting Attorney of record cause No. A-180805 filed in the Jefferson County Texas Courthouse said “Property Deeds” for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas of the Co-Defendant(s) “Joyce M. Guy and Edward McCray herein

Was Legally Transfer to the Texas Department of Housing & Community Affairs on June 18th 2009 as described by “Jefferson County Real Estate Index in attached document #7 herein for a $76,000.00 U. S. Dollars Housing Grant.

Request Number 164.

Admit: You” Attorney at Law that Co- Defendant Joyce M. Guy” herein supply the following Answer to Pro Se Plaintiff Interrogatories Document # 11 attached herein pursuant to Rule 197 of the Texas Rules of Civil Procedures at Question: 10, 11, 12, 13, 14, 15, and 16.

10. Where is the Funding for the New Home?

Answer: Federal Grant

11. What are the terms and conditions of any contract in regards to the new home?

Answer: Federal Government built home free of charge Defendant must remain in home for at least 3 years.

12. What is the entire cost of the construction for the new home?

Answer: $76,000.00 U.S. Dollars

13. How is the city of Port Arthur Involved?

Answer: Not involved

14. How is the State of Texas Involved?

Answer: Not Involved

15. How is the Federal Government involved?

Answer: Federal Grant

16. How much money did the Co-Defendant actually paid for the new home construction?

Answer: No money paid by Co-Defendant

Request Number 165.

Admit: You” Attorney at Law that Co- Defendant Joyce M. Guy” herein supply the following “false and fraudulent” Answer to Pro Se Plaintiff Interrogatories Document # 11 attached herein at question number 14

14. How is the State of Texas Involved?

Answer: Not Involved

In comparison to Pro Se Plaintiff attached Document # 7 here in showing during this same time frame “Your” being acting Attorney of record cause No. A-180805

said “Property Deeds” for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas of the Co-Defendant(s) “Joyce M. Guy and Edward McCray herein collectively custody, control and legal possession

Was Legally Transfer to the Texas Department of Housing & Community Affairs on June 18th 2009 as described by “Jefferson County Real Estate Index in attached document #7 herein for a $76,000.00 U. S. Dollars Housing Grant. Instrument # 2009022762.

Request Number 166.

And further Admit that Documents #11 that Co- Defendant Joyce M. Guy” herein supply the following “false and fraudulent” Answer to Pro Se Plaintiff Interrogatories was Placed in the United States Mail and

Publically Mailed to the Jefferson County Texas Court House “Clerk of District Court” for cause No. A-180805

And was electronically computer filed in Document # 8 herein 58th Judicial District Court of Jefferson County Texas “Case Ledger” and Court Records for cause No. A-180805

Request Number 167.

And further Admit that Documents #11 that Co- Defendant Joyce M. Guy” herein supply the following “false and fraudulent” Answer to Pro Se Plaintiff Interrogatories was Placed in the United States Mail and

Publically Mailed to the Jefferson County Texas Court House “Clerk of District Court” for cause No. A-180805

And was electronically computer filed in Document # 8 herein 58th Judicial District Court of Jefferson County Texas “Case Ledger” and Court Records for cause No. A-180805

And was Placed in the United States Mail and publically mailed to the Pro Se Plaintiff herein.

Request Number 168.

And further Admit that Documents #11 that Co- Defendant Joyce M. Guy” herein supply the following “false and fraudulent” Answer to Pro Se Plaintiff Interrogatories was Placed in the United States Mail and

Publically Mailed to the Jefferson County Texas Court House “Clerk of District Court” for cause No. A-180805

And was electronically computer filed in Document # 8 herein 58th Judicial District Court of Jefferson County Texas “Case Ledger” and Court Records for cause No. A-180805

And was Placed in the United States Mail and publically mailed to the Pro Se Plaintiff herein.

During this same time frame “Your” being acting Attorney of record cause No. A-180805 filed in the Jefferson County Texas Courthouse said “Property Deeds” ” for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas of the Co-Defendant(s) “Joyce M. Guy and Edward McCray herein

Was Legally Transfer to the Texas Department of Housing & Community Affairs on June 18th 2009 as described by “Jefferson County Real Estate Index in attached document #7 herein for a $76,000.00 U. S. Dollars Housing Grant

Request Number 169.

Admit: You” Attorney at Law that “You” and Co-Defendant “Joyce M. Guy” herein supply “Your” response to the following Answer to Pro Se Plaintiff Interrogatories Document # 11 attached herein pursuant to Rule 197 of the Texas Rules of Civil Procedures at Question: 10, 11, 12, 13, 14, 15, and 16. In October 14th 2009

During this same time frame “Your” being acting Attorney of record cause No. A-180805 filed in the Jefferson County Texas Courthouse said “Property Deeds” ” for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas of the Co-Defendant(s) “Joyce M. Guy and Edward McCray herein being a Party to a $10,800.00 U.S. Dollars “Breach of Construction Contract dispute said dwelling

Was “Already Completely Legally Transfer” to the Texas Department of Housing & Community Affairs on June 18th 2009

As described by “Jefferson County Real Estate Index in attached document #7 herein for a $76,000.00 U. S. Dollars Housing Grant

Request Number 170.

And further Admit that Documents #11 attached herein that Co- Defendant Joyce M. Guy” herein supply “false and fraudulent” Answer to Pro Se Plaintiff Interrogatories at question # 14 was legally requested by Pro Se Plaintiff herein on March 14th 2008 but

“You” did not submit Co- Defendant Joyce M. Guy” herein supplied “false and fraudulent” Answer until October 14th 2009 against Rule 197 of the Texas Rules of Civil Procedures (30) days limit in filing a timely response to Pro Se Plaintiff herein.

Being an actual year later “Your” finally forward actual “false and fraudulent” answers of Co- Defendant Joyce M. Guy” Interrogatories at question # 14 herein attached Document # 11 herein Legally “You” placed in the United States Mail and Publically Mailed to The Jefferson County Texas Court House “Clerk of District Court” for cause No. A-180805

And was electronically computer filed in Document # 8 herein 58th Judicial District Court of Jefferson County Texas “Case Ledger”

And Copies

Request Number 171.

And further Admit that Documents #11 attached herein that Co- Defendant Joyce M. Guy” herein supply “false and fraudulent” Answer to Pro Se Plaintiff Interrogatories at question # 14 which was legally requested by Pro Se Plaintiff herein on March 14th 2008 but

“You” did not submit Co- Defendant Joyce M. Guy” herein supplied “false and fraudulent” Answer until October 14th 2009 against Rule 197 of the Texas Rules of Civil Procedures (30) days limit in filing a timely response to Pro Se Plaintiff herein.

Being an actual year later “You’re” finally forward actual “false and fraudulent” answers of Co- Defendant Joyce M. Guy” Interrogatories at question # 14 herein attached Documents # 11 herein

Legally “You” placed said Interrogatories response in the United States Mail and Publically Mailed to The Jefferson County Texas Court House “Clerk of District Court” for cause No. A-180805

And this Document # 11 was electronically computer filed in Document # 8 herein 58th Judicial District Court of Jefferson County Texas “Case Ledger” and Court Records thereof

And Copies of such “false and fraudulent” Answer to Pro Se Plaintiff Interrogatories being actual “false and fraudulent” answers of Co- Defendant Joyce M. Guy” Interrogatories at question # 14 herein attached Document # 11 herein Legally

“You” placed this legal Document in the United States Mail and publically mailed also to the Pro Se Plaintiff mailing address at P.O. Box 342 in Port Arthur Texas 77640

Request Number 172.

Admit: You” Attorney at Law that “You” Drafted the Court Order Judge Bob Wortham gave his approval on, placed his signature upon said “Court Order” issued in “Your” favor on December 11th 2009 which said 58th Judicial District Court Order of Jefferson County Texas was electronically computer filed in Document # 8 herein 58th Judicial District Court of Jefferson County Texas “Case Ledger” and all Court Records thereof For “Your” Withdrawal as “Attorney of Record” Cause No. A-180805 as described in attached Document # 12 herein 58th Judicial District Court of Jefferson County Texas “Docket Report”

Request Number 173.

Admit: You” Attorney at Law that these “Chain of Events” are “True” of “Your” attend a hearing held on the date of December 11th 2009 for “Your” Withdrawal as acting “Attorney of Record” as “Your” being Acting Attorney of Record since December 18th 2007 – December 11th 2009 1 year, 11 months and 11 days your officially active attorney of record in

Cause No. A-180805 as described in attached Document # 12 herein 58th Judicial District Court of Jefferson County Texas “Docket Report” With a “Court Order” on file of approval of “Your withdrawal from Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively from cause No. A-180805 And as described in attached Document # 8 herein 58th Judicial District Court of Jefferson County Texas “Case Ledger” And “Your” Affidavit in support of “Your” reply to Pro Se Plaintiff “Motion for Sanctions” against “You” Document #9 herein contain with false statement made by “You” of “Your” having only knowledge of “Required Pro Se Plaintiff discovery request for admissions, interrogatories and Disclosure on or about the dates of April 2nd 2008 and April 11, 2008 Which “You” already had Placed in the United States Mail and Publically Mailed to The Jefferson County Texas Court House “Clerk of District Court” for cause No. A-180805

And this document was electronically computer filed in Document # 8 herein 58th Judicial District Court of Jefferson County Texas “Case Ledger” and The Court Records for cause No. A-180805

During this same time frame “Your” being acting Attorney of record for cause No. A-180805 filed in the Jefferson County Texas Courthouse

The said “Property Deeds” a issue” for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas of the Co-Defendant(s) “Joyce M. Guy and Edward McCray herein

Was already legally Completely Transfer to the Texas Department of Housing & Community Affairs on the date of June 18th 2009 as described by “Jefferson County Real Estate Index” in attached document #7 herein for a $76,000.00 U. S. Dollars Housing Grant

And “You” then after said dwelling being a party to this civil suit A-180805 was transfer for said $76,000.00 U. S. Dollars Housing Grant and the old one completely destroyed

“You” there after then attend a Hearing dated on December 11th 2009 after “Your” already done supplying “false information” as “You” made in “Your” Response to Motion for Sanctions Document dated September 11th 2009, being Document # 1 attached herein of

“Your” having only knowledge of “Required” Pro Se Plaintiff discovery request for admissions, interrogatories and Disclosure on or about the dates of April 2nd 2008 and April 11, 2008 In comparison to attached Document # 12 herein 58th Judicial District Court of Jefferson County Texas “Docket Report” showing “You” officially having said Discovery request clearly back in March 14th 2009 as described in attached Document # 12 herein 58th Judicial District Court of Jefferson County Texas “Docket Report” And ”You” then later used this “false information” for “Your” Withdrawal as acting “Attorney of Record” as described in attached Document # 2 herein “Your Motion for withdrawal” from Cause No. A-180805 As “You” further stated “You” were only retain to file a “General Denial” (Only) which “You” did on December 18th 2007, But “Your” legal representation in the capacity of an acting “Attorney at Law” in and for the State of Texas did not officially end for the Co-Defendant “Joyce M. Guy and Edward McCray” herein collectively until “December 11th 2009 Which “You” completely refused throughout this entire time frame to simply turnover “among other things” Production of copies the “Property deeds” for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas which was request “You” and The Co-Defendant(s) collectively to do so in Pro Se Plaintiff Motion for Document(s) dated August 12th 2009

As described in attached Document # 12 herein 58th Judicial District Court of Jefferson County Texas “Docket Report” But “Your” still officially makes “False Claims” in Court Records “Your” only being official retain as “Attorney at Law” duties from the Time frame of December 18th 2007 – December 11th 2009 was to file a “General Denial” (only) As “Your” in real life time “factual events and legal circumstances” claiming before the 58th Judicial District Court of Jefferson County Texas these facts as such described in Document #1 in “Your” response to Motion for sanctions against “You” and as Co-Defendant “Joyce M. Guy” herein also claiming in Document # 10 Co-Defendant “Joyce M. Guy” “Affidavit” in support of “Your” false claims Which Her Fraudulent statement “Affidavit” no less is in fact in support of “You” so no sanction being imposed again “You” which Co-Defendant “Joyce M. Guy” herein “Affidavit” in cause No. A-180805 Contains the same “false material information” as “Your” Supplying in knowledge of having possession, custody and legal control of Pro Se Plaintiff Discovery request as Described in Pro Se Plaintiff attached Document # 1 herein “Your” response to Motion for sanctions against “You” but “However” at the same time frame chain of events “Your” being officially present at two Court hearing on August 12th 2009 and on September 11th 2009 in the capacity of acting “Attorney of Record” but not retain to be there at all and no motion for youe withdrawal as acting Attorney of Record being official on file with the Jefferson County Civil Clerk of Court office until the date of November 13th 2009 for “Your” official withdrawal But however no less “Your” in “factual events and legal circumstances” “physically officially present” in “human life form of some sorts” breathing and quite in fact officially alive and present at “two required Court hearing being held on August 12th 2009 and on September 11th 2009 and

“Your” acting in the capacity of acting “Attorney of Record” during these said “Two Live Court Hearings” which “You” claim “Your” not even retain for at all but as Described in attached Document # 8 herein the 58th Judicial District Court of Jefferson County Texas “Case Ledger” that “Your” acting “Attorney of Record” But meanwhile “Your” 100% officially claiming “Your” not retain to be there and this never even happen as “Your” making this false claim in attached Document # 1 herein “Your” response to Motion for sanctions against “You” that the only understanding “Your” having is filed a “General Denial” (Only) as this was “Your” only Duties Which “Your” still making such claims in December 11th 2009 at the hearing “Your” request to be now removal as acting “Attorney of Record” while “Your” stating to the 58th Judicial District Court of Jefferson County Texas of a state of physically only legally being in a state of retain duties which is completed after December 18th 2007 for the sole purpose of “Your” filing a simple “General Denial” (Only) for Co-Defendant “Joyce M. Guy” and Edward McCray legal behalf collectively as “Your” Official claim to this is so official stated in this attached Document # 1 herein “Your” response to Motion for sanctions against “You” and as described and collaborated in Co-Defendant “Joyce M. Guy” herein “Sworn” statement no less also claiming in Document # 10 her “Affidavit” in support of “You” While attached Document No. # 8 herein the 58th Judicial District Court of Jefferson County Texas “Case Ledger” showing “You” being in possession of numerous Discovery Documents and Legal Motions for the Co-Defendant(s) collectively behalf starting on March 14th 2008 While attached Document No. # 8 herein the 58th Judicial District Court of Jefferson County Texas “Case Ledger” also showing “Required Pro Se Plaintiff discovery request for admissions, interrogatories and Disclosure being in

“Your” claiming was in “Your” legal possession, custody and legal control on or about the dates of April 2nd 2008 and April 11, 2008 that

“Your” making continue false claims to about these dates of “factual events and legal circumstances” which do not officially exist at all as described in Pro Se Plaintiff attached Document No. # 8 herein the 58th Judicial District Court of Jefferson County Texas “Case Ledger”

With the “Chain of continual “factual events and legal circumstances” showing also Co-Defendant Joyce M. Guy” herein supplies the following “false and fraudulent” Answer to Pro Se Plaintiff Interrogatories Document # 11 attached herein at question number 14

14. How is the State of Texas Involved?

Answer: Not Involved

In comparison to Pro Se Plaintiff attached Document # 7 here in showing during this same time frame “Your” being acting Attorney of record cause No. A-180805

Said “Property Deeds” for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas of the Co-Defendant(s) “Joyce M. Guy and Edward McCray herein collectively custody, control and legal possession

Was legally in all “factual events and legal circumstances” Transfer to the “Texas Department of Housing & Community Affairs” on the date of June 18th 2009

As described by “Jefferson County Real Estate Index” Instrument # 2009022762. And The Federal Government not being described as a Party

In attached document #7 herein for a $76,000.00 U. S. Dollars Housing Grant that Co Defendant “Joyce M. Guy” thus making conflicting false claims that in all “factual events and legal circumstances” that the Federal Government provided provision of $76,000.00 U. S. Dollars Housing Grant never happen as Co-Defendant “Joyce M. Guy” herein making such a legal claim in Pro Se Plaintiff attached Document # 11 “Interrogatories” of Co-Defendant “Joyce M. Guy” claims of Funding

For the Property located at 448 DeQueen Blvd. in Port Arthur Texas which said Property being a party to a “Breach of Construction Contract” since the

dates of November 17th 2007 as this is to be the “True Chain of “factual events and legal circumstances” involving “You” Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299

whom “Your” in a retain “Attorney at Law” refusal state of some sort to supply a legal response during the months of April of 2008, May of 2008,

June of 2008, July of 2008, August of 2008, September of 2008, October of 2008, November of 2008, December of 2008, January of 2009, February of

2009, March of 2009, April of 2009, May of 2009, June of 2009, July of 2009, August of 2009, September of 2009

In a timely manner to said Discovery request “Your” having in “Your”

Legal possession, custody and control over since March 14th 2008 as legally

described in Pro Se Plaintiff Document No. # 8 attached herein being the official 58th Judicial District Court of Jefferson County Texas “Case Ledger” for Civil Cause No. A-180805.

And this is not in “Violations of Rule 193.1 of the Texas Rules of Civil Procedure of “Your” responds to discovery in a timely manner for cause of action against Co-Defendant(s) Joyce M. Guy and Edward McCray collectively herein.

Request Number 174.

Admit: You” Attorney at Law that “You” filed document # 1 herein “Your response to Motion for sanctions against you in the Jefferson County Texas “Clerk of Court” office using the “United States Mailing System”. And you further forward such document #1 herein to the Pro Se Plaintiff while still using the “United States mailing system”.

Request Number 175.

Admit: You” Attorney at Law that “You” filed document # 1 herein “Your response to Motion for sanctions in the Jefferson County Texas “Clerk of

Court” office and obtain “Judge Bob Worthham” approval for you withdrawal As being described on Document # 8 attached herein 58th Judicial District Court of Jefferson County Texas case ledger Docket No. A-180805

Request Number 176.

Admit: You” Attorney at Law that “You” forward such Document #1 Your response to Motion for sanctions against you herein to the Pro Se Plaintiff while still using the “United States mailing system”.

Request Number 177.

Admit: You” Attorney at Law that “You” did in real “factual circumstances” obtain “Judge Bob Worthham” approval for your withdrawal as acting “Attorney of Record” on Document # 2 attached herein “Your Motion for withdrawal” While “Your” being in complete refusal to submit and reply to Pro Se Plaintiff “Discovery request” until “October 14th 2010 which “You” had in your possession as “You” are claiming since April of 2008 As you are so order by Co-Defendant “Joyce M. Guy” herein to not submit to any such discovery request in a “timely fashion” as required by Texas rules of Civil Procedure” to Pr Se Plaintiff discovery requests

as stated on Document # 10 attached herein Co-Defendant “Joyce M.

Guy” affidavit in support of ”You” to not reply to required discovery of Pro Se Plaintiff while your being the fully legal retain “Attorney of

Record” for cause no. A-180805

From the time frame dates of December 18th 2007 throughout December 11th 2009 as Document # 12 attached herein showing “Judge Bob

Wortham” approval for your motion for withdrawal as acting “Attorney of Record being granted on December 11th 2009

While Co-Defendant(s) Edward McCray and Joyce M. Guy” herein

collectively in all “factual events and legal circumstances” (Already)Transfer to the “Texas Department of Housing & Community Affairs” Said “Property Deeds” for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas on the date of June 18th 2009

As described by “Jefferson County Real Estate Index” Instrument # 2009022762 in attached exhibit #7 herein “while “Your” further admit that

Said “Property”, dwelling, and deeds thereof “already being a material evidence and actual Party of a Civil suit in common law since November

26th 2007 when Pro Se Plaintiff herein filed “original Complaint A-180805 against Co-Defendant(s) Edward McCray and Joyce M. Guy” herein

collectively

Request Number 178.

Admit: You” Attorney at Law that “You” was so order and legally retain for you “Attorney at Law” services by Co-Defendant Joyce M. Guy” herein collectively as described in attached Document # 10 herein

Co-Defendant “Joyce M. Guy” affidavit” as this was required for “You” in the capacity of acting “Attorney of Record in cause No. A-

180805 during the months of April of 2008, May of 2008, June of 2008, July of 2008, August of 2008, September of 2008, October of 2008, November of

2008, December of 2008, January of 2009, February of 2009, March of 2009, April of 2009, May of 2009, June of 2009, July of 2009, August of 2009, September of 2009 to not respond

In a timely manner at all to said Discovery request of Pro Se Plaintiff “Your” having in “Your” Legal possession, custody and control over since

March 14th 2008 as legally described in Pro Se Plaintiff Document No. # 8 attached herein being the official 58th Judicial District Court of Jefferson County Texas “Case Ledger” for Civil Cause No. A-180805. And as “Your” claiming in Document # 1 attached Herein “You”

Further admit this is not in “Violations of Rule 193.1 of the Texas Rules of Civil Procedure of “Your” responds to filing a discovery in a “timely manner” for cause of action against Co-Defendant(s) Joyce M. Guy and Edward McCray collectively herein.

Which your acting Attorney of record and retain to not submit to any discovery request of the Pro Se Plaintiff in docket No. A-180805 until provision of $76,000.00 U. S. Dollars Housing Grant was applied for, executed and achieved by Co-Defendant(s) “Joyce M. Guy and Edward McCray herein collectively for the property located at 448 DeQueen Blvd. in Port Arthur Texas. (Block 172, Lot 1-2)

Request Number 179.

Admit: You” Attorney at Law that “You” always never file “Discovery requests” in a timely fashion as required by Texas Rules of

Civil Procedures to any “opposing counsel and any Pro Se Plaintiffs”. When “Your” retain clients require you to cover up all discovery

requests being made against them as being described in Document # 8 attached herein “Your” having possession, custody and legal control

over said “Discovery Request” of the Pro Se Plaintiff and this is your legal retain duties in the capacity of a “Attorney at Law” in and for the

State of Texas “Your” Attorney at Law” Bar No. 24058299.

Request Number 180.

Admit: You” Attorney at Law that “You” was so order by Co-

Defendant Joyce M. Guy” herein collectively as described in attached Document # 10 herein Co-Defendant “Joyce M. Guy” affidavit”

As this was required for “Your” retain duties as acting “Attorney of

Record” during the months of April of 2008, May of 2008, June of 2008, July of 2008, August of 2008, September of 2008, October of 2008,

November of 2008, December of 2008, January of 2009, February of 2009, March of 2009, April of 2009, May of 2009, June of 2009, July of 2009,

August of 2009, September of 2009 to not respond at all

In a timely manner to said “Discovery request” of Pro Se Plaintiff “Your” having in “Your” Legal possession, custody and control over since

March 14th 2008 as legally described in Pro Se Plaintiff Document No. # 8 attached herein being the official 58th Judicial District Court of Jefferson County Texas “Case Ledger” for Civil Cause No. A-180805.

“You” was so “Order” and retain by Co-Defendant Joyce M. Guy” herein to represent all legal interest against Pro Se Plaintiff herein in

cause No. A-180805 at (2) court hearing dated “August 28 th 2009 and September 11th 2009

While “Your” claiming “Your” only official retain legal services obligations was to filing a “General Denial” on December 18 th 2007 as

described in Document # 1”Your response to motion for sanctions against “You” but you did attended (2) said court hearing dated “August 28th 2009 and September 11th 2009

Request Number 181.

Admit: You” Attorney at Law that the 58th Judicial District Court

of Jefferson County Texas “Case Ledger” showing “You” being in possession of numerous Discovery Documents and Legal Motions for the Co-Defendant(s) “Joyce M. Guy and Edward McCray herein collectively

behalf starting on March 14th 2008 such a discovery process started

While attached Document No. # 8 herein the 58th Judicial District Court of Jefferson County Texas “Case Ledger” also showing “Required Pro Se Plaintiff discovery made to “You” being request for admissions, interrogatories and Disclosure being in

“Your” legal possession, custody and legal control on or about the dates of April 2nd 2008 and April 11, 2008 that “Your” making continue false claims to about these dates of “factual events and legal circumstances” which do not officially exist at all as described in Pro Se Plaintiff attached Document No. # 8 herein the 58th Judicial District Court of Jefferson County Texas “Case Ledger”

” You” was so order by Co-Defendant Joyce M. Guy” herein as

described in attached Document # 10 herein Co-Defendant “Joyce M. Guy” affidavit” as this was required for “Your” retain legal duties as

acting “Attorney of Record” during the months of April of 2008, May of 2008, June of 2008, July of 2008, August of 2008, September of 2008,

October of 2008, November of 2008, December of 2008, January of 2009, February of 2009, March of 2009, April of 2009, May of 2009, June of 2009, July of 2009, August of 2009, September of 2009 to not respond at all

In a timely manner to said “Discovery request” of Pro Se Plaintiff “Your” having in “Your” Legal possession, custody and control over since

March 14th 2008 as legally described in Pro Se Plaintiff Document No. # 8 attached herein being the official 58th Judicial District Court of Jefferson County Texas “Case Ledger” for Civil Cause No. A-180805 and “You” refusal to withdrawal “Your” self during this same time frame.

Request Number 182.

Admit: You” Attorney at Law that “You” Was so order by Co-Defendant Joyce M. Guy” herein collectively as described in attached Document # 10 herein Co-Defendant “Joyce M. Guy” affidavit”

As this was required for “Your” retain legal duties as acting “Attorney

of Record” during the months of April of 2008, May of 2008, June of 2008, July of 2008, August of 2008, September of 2008, October of 2008,

November of 2008, December of 2008, January of 2009, February of 2009, March of 2009, April of 2009, May of 2009, June of 2009, July of 2009,

August of 2009, September of 2009 to not respond at all

In a timely manner to said “Discovery request” of Pro Se Plaintiff “Your” having in “Your” Legal possession, custody and control over since

March 14th 2008 as legally described in Pro Se Plaintiff Document No. # 8 attached herein being the official 58th Judicial District Court of Jefferson County Texas “Case Ledger” for Civil Cause No. A-180805

And “Your” additional duties include for “Your” official retain “Attorney at Law” skills to keep the Production of documents in said production of the “Property Deeds” being conceal from this “civil action” and Pro Se Plaintiff between the dates of August 12th 2009 throughout December 11th 2009 while “Your” acting Attorney of record

While “Your” further admitting Co-Defendant(s) Edward McCray and

Joyce M. Guy” herein collectively in all “factual events and legal circumstances” commenced the legal Transfer to the “Texas Department of Housing & Community Affairs” provided provision of $76,000.00 U. S. Dollars Housing Grant as described in Document # 7 attached herein “Jefferson County Texas Property search Index

Said “Property Deeds” for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas on the date of June 18th 2009 being legally transfer while “You’re” acting “Attorney of Record.

As described by “Jefferson County Real Estate Index” Instrument # 2009022762 in attached exhibit #7 herein “

While “Your” further admit that Said “Property”, dwelling, and deeds

thereof “already being a “material evidence” and actual party of a Civil suit in common law since for a “Breach of Construction Contract in excess of

$10,800.00 U.S. Dollars since

November 26th 2007 when Pro Se Plaintiff herein filed “Original Complaint” A-180805 against Co-Defendant(s) Edward McCray and Joyce M. Guy”

herein collectively.

Request Number 183.

Admit: You” Attorney at Law that “You” having always refuse to comply and submit to Texas rules of Civil Procedures. Against all Pro Se Plaintiffs when “Your” numerous clients retain “You” to so do in the

legal Profession as acting “Attorney of Record” ...

Request Number 184.

Admit: You” Attorney at Law that “Your” additional legal duties include for “Your” official retain “Attorney at Law” skills to keep the Production of documents in said production of the “Property Deeds” being conceal from this “civil action” between the dates of August 12th 2009 throughout December 11th 2009 while “Your” acting Attorney of record

Request Number 185.

Admit: You” Attorney at Law that “Your” additional legal duties include for “Your” official retain “Attorney at Law” skills to keep the Production of documents in said production of the “Property Deeds” being conceal from this “civil action” between the dates of August 12th 2009 throughout the dates of November 13th 2009 and you did not file a Motion for withdrawal as acting Attorney of record between the date of December 18th 2007 throughout November 12th 2009,

While Co-Defendant(s) Joyce M. Guy and Edward McCray herein

collectively in all “factual events and legal circumstances” commenced the legal Transfer to the “Texas Department of Housing & Community Affairs” provided provision of $76,000.00 U. S. Dollars Housing Grant as described in Document # 7 attached herein “Jefferson County Texas Property search Index

Said “Property Deeds” for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas before the date of June 18th 2009 when deeds was being legally transfer while “You’re” acting “Attorney of Record.

As described by “Jefferson County Real Estate Index” Instrument # 2009022762 in attached exhibit #7 herein “

While “Your” further admit that Said “Property”, dwelling, and deeds thereof “already being a material evidence and actual party of a Civil suit in

Common law since 2007 for a “Breach of Construction Contract in excess of $10,800.00 U.S. Dollars

November 26th 2007 when Pro Se Plaintiff herein filed “original Complaint

A-180805 against Co-Defendant(s) Edward McCray and Joyce M. Guy” herein collectively.

Request Number 186.

Admit: You” Attorney at Law that after December 18th of 2007 when you filed said “General Denial” as “Your” claiming this was “Your”

only legal duties as described in Document # 1 attached herein “Your” response to motion for sanctions against “You” additionally Admit “You”

could have filed a “Motion for immediately “Your” withdrawal from cause No. A-180805 at this time frame but “Your” legal choice was to continue being acting “Attorney of record during the month of December of 2007

Request Number 187.

Admit: You” Attorney at Law that after December 18th of 2007

“You could have filed a “Motion for “Your” immediately withdrawal from cause No. A-180805 but “Your” legal choice was to continue being acting “Attorney of record during the month of January 2008

Request Number 188.

Admit: You” Attorney at Law that after December 18th of 2007 “You” could have filed a “Motion for “Your” immediately withdrawal from cause No. A-180805 but “Your” legal choice was to continue being acting

“Attorney of record during the month of February 2008

Request Number 189.

Admit: You” Attorney at Law that after December 18th of 2007 you could have filed a “Motion for “Your” immediately withdrawal from cause No. A-180805 but “Your” legal choice was to continue being acting

“Attorney of record during the month of March of 2008

Request Number 190.

Admit: You” Attorney at Law that after December 18th of 2007 you could have filed a “Motion for “Your” immediately withdrawal from cause No. A-180805 but “Your” legal choice was to continue being acting

“Attorney of record during the month of April of 2008

Request Number 191.

Admit: You” Attorney at Law that after December 18th of 2007 you could have filed a “Motion for “Your” immediately withdrawal from cause No. A-180805 but “Your” legal choice was to continue being acting

“Attorney of record during the month of May of 2008

Request Number 192.

Admit: You” Attorney at Law that after December 18th of 2007 you could have filed a “Motion for “Your” immediately withdrawal from cause No. A-180805 but “Your” legal choice was to continue being acting

“Attorney of record during the month of June of 2008

Request Number 193.

Admit: You” Attorney at Law that after December 18th of 2007 you could have filed a “Motion for “Your” immediately withdrawal from cause No. A-180805 but “Your” legal choice was to continue being acting

“Attorney of record during the month of July of 2008

Request Number 194.

Admit: You” Attorney at Law that after December 18th of 2007 you could have filed a “Motion for “Your” immediately withdrawal from cause No. A-180805 but “Your” legal choice was to continue being acting

“Attorney of record during the month of August of 2008

Request Number 192.

Admit: You” Attorney at Law that after December 18th of 2007 you could have filed a “Motion for “Your” immediately withdrawal from cause No. A-180805 but “Your” legal choice was to continue being acting

“Attorney of record during the month of September of 2008

Request Number 193.

Admit: You” Attorney at Law that after December 18th of 2007 you could have filed a “Motion for “Your” immediately withdrawal from cause No. A-180805 but “Your” legal choice was to continue being acting

“Attorney of record during the month of October of 2008

Request Number 194.

Admit: You” Attorney at Law that after December 18th of 2007 you could have filed a “Motion for “Your” immediately withdrawal from cause No. A-180805 but “Your” legal choice was to continue being acting

“Attorney of record during the month of November of 2008

Request Number 195.

Admit: You” Attorney at Law that after December 18th of 2007 you could have filed a “Motion for “Your” immediately withdrawal from cause No. A-180805 but “Your” legal choice was to continue being acting

“Attorney of record during the month of December of 2008

Request Number 196.

Admit: You” Attorney at Law that after December 18th of 2007 you could have filed a “Motion for “Your” immediately withdrawal from cause No. A-180805 but “Your” legal choice was to continue being acting

“Attorney of record during the month of January 2009

Request Number 197.

Admit: You” Attorney at Law that after December 18th of 2007 you could have filed a “Motion for “Your” immediately withdrawal from cause No. A-180805 but “Your” legal choice was to continue being acting

“Attorney of record during the month of February 2009

Request Number 198.

Admit: You” Attorney at Law that after December 18th of 2007 you could have filed a “Motion for “Your” immediately withdrawal from cause No. A-180805 but “Your” legal choice was to continue being acting

“Attorney of record during the month of March of 2009

Request Number 199.

Admit: You” Attorney at Law that after December 18th of 2007 you could have filed a “Motion for “Your” immediately withdrawal from cause No. A-180805 but “Your” legal choice was to continue being acting

“Attorney of record during the month of April of 2009

Request Number 200.

Admit: You” Attorney at Law that after December 18th of 2007 you could have filed a “Motion for “Your” immediately withdrawal from cause No. A-180805 but “Your” legal choice was to continue being acting

“Attorney of record during the month of May of 2009

Request Number 201.

Admit: You” Attorney at Law that after December 18th of 2007 you could have filed a “Motion for “Your” immediately withdrawal from cause No. A-180805 but “Your” legal choice was to continue being acting

“Attorney of record during the month of June of 2009

Request Number 202.

Admit: You” Attorney at Law that after December 18th of 2007 you could have filed a “Motion for “Your” immediately withdrawal from cause No. A-180805 but “Your” legal choice was to continue being acting

“Attorney of record during the month of July of 2009

Request Number 203.

Admit: You” Attorney at Law that after December 18th of 2007 you could have filed a “Motion for “Your” immediately withdrawal from cause No. A-180805 but “Your” legal choice was to continue being acting

“Attorney of record during the month of August of 2009

Request Number 204.

Admit: You” Attorney at Law that after December 18th of 2007 you could have filed a “Motion for “Your” immediately withdrawal from cause No. A-180805 but “Your” legal choice was to continue being acting

“Attorney of record during the month of September of 2009

Request Number 205.

Admit: You” Attorney at Law that after December 18th of 2007 you could have filed a “Motion for “Your” immediately withdrawal from cause No. A-180805 but “Your” legal choice was to continue being acting

“Attorney of record during the month of October of 2009

Request Number 206.

Admit: You” Attorney at Law that in cause No. A-180805 “Your” physically present at (2) court hearing dated on “August 28th 2009 and on September 11th 2009

While “Your” claiming “Your” (only) official retain legal services

obligations was to filing a “General Denial” on December 18 th 2007 as described in Document # 1 attached herein

Your response to motion for sanctions against “You” and “You” was never legally retain to attend said hearing dates but was in legal factual event, circumstances and duties thereof acting Attorney of

Record on “August 28th 2009 and September 11th 2009 for the legal behalf of the Co-Defendant(s) “Joyce M. Guy and Edward McCray”

collectively herein in cause No. A-180805.

Request Number 207.

Admit that Said “Property”, dwelling, and deeds thereof “already being a issue of “material evidence” and actual party thereof a Civil suit in

Common law in the State of Texas since November 26th of 2007 for a “Breach of Construction Contract in excess of $10,800.00 U.S. Dollars

And “Your” having legal knowledge Pro Se Plaintiff herein stated in the “Original Complaint” A-180805 File November 26th 2007 Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein had already

squander all of the “Insurances monies” being paid out to fix said dwelling

for the property located at 448 DeQueen Blvd. in Port Arthur Texas. (Block 172, Lot 1-2) as a result of damages cause by Hurricanes Humberto.

While during this time frame of a Civil suit “Original Complaint”

A-180805 File November 26th 2007all “factual events and legal circumstances” Co-Defendant(s) “Joyce M. Guy and Edward McCray”

collectively herein

Commenced the “legal Transfer” to the “Texas Department of Housing & Community Affairs” to provided provision of $76,000.00 U. S. Dollars Housing Grant as described in Document # 7 attached herein “Jefferson County Texas Property search Index” instrument # 2009022762

Said “Property Deeds” for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas on the date of June 18th 2009 being legally transfer to “Texas Department of Housing & Community Affairs ”while “You’re” acting “Attorney of Record.

As described by in Pro Se Plaintiff in attached Document namely “Jefferson County Real Estate Index” Instrument # 2009022762 in document #7

attached herein

“After Pro Se Plaintiff herein stated to “You” in the “Original Complaint”

A-180805 File November 26th 2007 Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein had already squandered all of the

“Insurances monies” being paid out to fix said dwelling for the property located at 448 DeQueen Blvd. in Port Arthur Texas. (Block 172, Lot 1-2) as a

result of damages cause by “Hurricanes Humberto”.

Request Number 208.

Admit that Said “Property”, dwelling, and deeds thereof “already being a “material evidence” and actual party of a Civil suit in Common law

in the State of Texas since November 26th of 2007 for a “Breach of Construction Contract in excess of $10,800.00 U.S. Dollars docket NO. A-

180805

And “Your” having legal knowledge Pro Se Plaintiff herein stated to “You” in the “Original Complaint” A-180805 File November 26th 2007 Co-

Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein had already squander all of the “Insurances monies” being paid out to fix said

dwelling for the property located at 448 DeQueen Blvd. in Port Arthur Texas. (Block 172, Lot 1-2) as a result of damages cause by “Hurricanes Rita”.

While during this time frame of a Civil suit “Original Complaint”

A-180805 File November 26th 2007all “factual events and legal circumstances” Co-Defendant(s) “Joyce M. Guy and Edward McCray”

collectively herein

Commenced the legal Transfer to the “Texas Department of Housing & Community Affairs” provided provision of $76,000.00 U. S. Dollars Housing Grant as described in Document # 7 attached herein “Jefferson County Texas Property search Index

Said “Property Deeds” for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas on the date of June 18th 2009 being legally transfer while “You’re” acting “Attorney of Record.

As described by “Jefferson County Real Estate Index” Instrument # 2009022762 in attached exhibit #7 herein

Request Number 209.

Admit that Said “Property”, dwelling, and deeds thereof “already being a “material evidence” and actual party of a Civil suit in Common law in the State of Texas since November 26th of 2007 for a “Breach of

Construction Contract in excess of $10,800.00 U.S. Dollars docket No. A-180805

And “Your” having legal knowledge Pro Se Plaintiff herein stated to “You” in the “Original Complaint” A-180805 File November 26th 2007 Co-

Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein had already squander all of the “Insurances monies” being paid out to fix said

dwelling for the property located at 448 DeQueen Blvd. in Port Arthur Texas. (Block 172, Lot 1-2) as a result of damages cause by “Hurricanes Ike”.

While during this time frame of a Civil suit “Original Complaint”

A-180805 File November 26th 2007all “factual events and legal circumstances” Co-Defendant(s) “Joyce M. Guy and Edward McCray”

collectively herein

Commenced the legal Transfer to the “Texas Department of Housing & Community Affairs” provided provision of $76,000.00 U. S. Dollars Housing Grant as described in Document # 7 attached herein “Jefferson County Texas Property search Index

Said “Property Deeds” for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas on the date of June 18th 2009 being legally transfer while “You’re” acting “Attorney of Record.

As described by “Jefferson County Real Estate Index” Instrument # 2009022762 in attached Document exhibit #7 herein

Request Number 210

Admit that Said “Property”, dwelling, and deeds thereof “already being a “material evidence” and actual party of a Civil suit in Common law in the State of Texas since November 26th of 2007 for a “Breach of

Construction Contract in excess of $10,800.00 U.S. Dollars docket No. A-180805

The Honorable 58th Judicial District Court of Jefferson County Texas

ordered” Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively

herein to produce all records, for property damages caused by Hurricanes “Rita”, Humberto, and Ike” ,

And the Production of said Property Deeds for dwelling and the property located at 448 DeQueen Blvd. in Port Arthur Texas. (Block 172, Lot 1-2) as

being described in Pro Se Plaintiff attached Document # 13herein namely Order of the 58th Judicial District Court of Jefferson County Texas.

Which “You” refused to produce such discovery request of property deeds

said dwelling for the property located at 448 DeQueen Blvd. in Port Arthur Texas. (Block 172, Lot 1-2) in an ”timely fashion”

And “You” refused at the same time to produce all records, for property

dwelling and the property located at 448 DeQueen Blvd. in Port Arthur Texas. (Block 172, Lot 1-2) damages caused by Hurricanes “Rita”, Humberto, and Ike” in a “timely fashion” while your acting retain “Attorney

of record” between the time frame of December 18th 2007 throughout the dates of December 10th 2009

Request Number 211.

Admit: You” Attorney at Law that “You” are prohibited from committing a serious crime or commit any other criminal act that reflects adversely on the lawyer's honesty, trustworthiness or fitness as a lawyer in other respects;

Request Number 212.

Admit: You” Attorney at Law that “You” are prohibited from engages in conduct involving dishonesty, fraud, deceit or misrepresentation;

Request Number 213.

Admit: You” Attorney at Law that “You” are prohibited from engages in conduct constituting obstruction of justice;

Request Number 214.

Admit: You” Attorney at Law that “You” are prohibited from engages in conduct that constitutes barratry as defined by the law of this state

Request Number 215.

Admit: You” Attorney at Law that “You” are prohibited from violates any other laws of this state relating to the professional conduct of lawyers and to the practice of law.

Request Number 216.

Admit: You” Attorney at Law that “You” are prohibited from any misdemeanor involving theft, embezzlement, or fraudulent or reckless misappropriation of money or other property; or any attempt, conspiracy, or solicitation of another to commit any of the foregoing crimes.

Request Number 217.

Admit: You” Attorney at Law that “You” are prohibited from knowingly assist a client in the commission of a criminal act or a fraudulent act

Request Number 218.

Admit: You” Attorney at Law that “You” must disclose a material fact to a third party if the lawyer knows that the client is perpetrating a crime or a fraud and the lawyer knows that disclosure is necessary to prevent the lawyer from becoming a party to that crime or fraud.

Request Number 219.

Admit: You” Attorney at Law that “You” are prohibited from hiding, concealing all legal discovers that a client has committed a criminal or fraudulent act in the course of which the lawyer's services have been used, or that the client is committing or intends to commit any criminal or fraudulent act,

Request Number 220.

Admit: You” Attorney at Law that “You” are prohibited from failing to disclose a material fact to a third person when disclosure is necessary to avoid making the lawyer a party to a criminal act or knowingly assisting a fraudulent act perpetrated by a client

Request Number 221.

Admit: You” Attorney at Law that “You” are prohibited from making a false statement of material fact or law to a third person

Request Number 222.

Admit: You” Attorney at Law that “You” have a duty to decline or terminate representation in such situations, discovers that a client has committed a criminal or fraudulent act in the course of which the lawyer's services have been used, or that the client is committing or intends to commit any criminal or fraudulent act,

Request Number 223.

Admit: You” Attorney at Law that “You” have a duty to decline or terminate representation in such situations, Client conduct involving dishonesty, fraud, deceit or misrepresentation;

Request Number 224.

Admit: You” Attorney at Law that in U.S. Cause 1:2010-CV-00055 Pro Se Plaintiff filed Complaint against “You” and Co-Defendant(s) “Joyce

M. Guy and “Edward McCray” herein collectively charging among other things (RICO) “Obstruction of Justice” Fraud from events and

circumstances surrounding civil suit in common law filed in Jefferson county Texas cause No. A-180805 as being also described in U. S. Cause 1:2014-CV-592 herein now.

Request Number 225.

Admit: You” Attorney at Law that “You” also in U.S. Cause 1:2010-

CV-00055 Pro Se Plaintiff filed Complaint against “You” and Co-Defendant(s) “Joyce M. Guy and “Edward McCray” herein collectively

That once again the Co-Defendant(s) “Joyce M. Guy and “Edward

McCray” herein collectively physically ‘retain” your legal services and representation for their legal interest for the First Federal Complaint”,

U.S. Cause 1:2010-CV-00055

Request Number 226.

Admit: You” Attorney at Law that “You” also in U.S. Cause 1:2010-CV-00055 also retain your legal services to cover up all of your combine criminal (RICO) activities, Fraud of the 58th Judicial District Court,

against the Pro Se Plaintiff “Louis Charles Hamilton II” herein as described in U.S. Cause 1:2010-CV-00055 and U. S. Cause 1:2014-CV-

592 herein now.

Request Number 227.

Admit: You” Attorney at Law that there after Pro Se Plaintiff filed Complaint against “You” and Co-Defendant(s) “Joyce M. Guy and “Edward McCray” herein collectively in U.S. Cause 1:2010-CV-00055

on February 2nd 2010

That Said “Property”, dwelling, and deeds thereof “already being a issue of “material evidence” and actual party thereof in a Civil suit in

Common law in the State of Texas

Since November 26th of 2007 for a “Breach of Construction Contract in excess of $10,800.00 U.S. Dollars

The “Texas Department of Housing & Community Affairs” release and terminated said possession, custody and control of “Property Deeds, back into the possession, custody and legal control to the Co-Defendant(s)

“Joyce M. Guy and “Edward McCray” herein collectively on April 14th

2014 as described in Pro Se Plaintiff attached Document # 7 attached herein “Jefferson County Texas Property search Index

Request Number 228.

Admit: You” Attorney at Law that That Said “Property”, dwelling,

and deeds thereof “already being a issue of “material evidence” and actual party thereof in a Civil suit in Common law in the State of Texas

Since November 26th of 2007 for a “Breach of Construction Contract

in excess of $10,800.00 U.S. Dollars for dwelling and the property located at 448 DeQueen Blvd. in Port Arthur Texas. (Block 172, Lot 1-2)

The same ”deeds” for dwelling and the property located at 448 DeQueen Blvd. in Port Arthur Texas. (Block 172, Lot 1-2) is also being in the

active possession, custody and legal control of “Texas Department of Housing & Community Affairs”

During the same time frame of “June 18th 2009 throughout July 22nd 2013 as described in Pro Se Plaintiff attached Document # 7 attached herein “Jefferson County Texas Property search Index” while “Your” acting “Attorney of Record” in Cause No. A-180805

Request Number 229.

Admit: You” Attorney at Law that Said “Property”, dwelling, and

deeds thereof “already being a issue of “material evidence” and actual party thereof in a Civil suit in Common law in the State of Texas

Since November 26th of 2007 for a “Breach of Construction Contract

in excess of $10,800.00 U.S. Dollars

Said Property Deeds is also being in the active possession, custody and legal control of “Texas Department of Housing & Community Affairs”

During the time frame of “June 18th 2009 throughout the dates of November 10th 2009 while “Your” acting “Attorney of Record” being request to Produce said Property deeds on the August 12th 2009 and “You” on behalf of your client never respond to said motion for Production in a timely fashion.

Request Number 230.

Admit: while “Your” representing said Co-Defendant(s) herein collectively “You” never ever produce an actual physical copy(s) of said Property deeds for dwelling and the property located at 448 DeQueen Blvd. in Port Arthur Texas. (Block 172, Lot 1-2) also same property deeds being in

the

Active physical possession, custody and legal control of “Texas Department of Housing & Community Affairs” During the same time frame of “June 18th 2009 throughout July 22nd 2013 as being described in Pro Se

Plaintiff attached Document # 7 herein the “Jefferson County Texas Property search Index” (Public Record).

Request Number 231.

Admit: You” Attorney at Law that Said “Property”, dwelling, and deeds thereof “already being a issue of “material evidence” and actual party

thereof in a Civil suit in Common law in the State of Texas cause No. A-180805

During the actual time frame dates between November 26th of 2007

for a “Breach of Construction Contract in excess of $10,800.00 U.S. Dollars

Throughout July 22nd 2013 of actual Active physical possession, custody and legal control in connection with the “Texas Department of Housing & Community Affairs” as being described in Pro Se Plaintiff attached Document # 7 herein the “Jefferson County Texas Property search Index” (Public Record).

Request Number 232.

Admit: You” Attorney at Law that “You” also in U.S. Cause 1:2010-CV-00055 that in “Your” defense of U.S. Cause 1:2010-CV-

00055 “You” commenced in the actual cover up, destruction, concealment of your (RICO), Fraud, Obstruction of Justice” activities

involved thereof and all records, documents, and material evidence derive thereof.

Request Number 233.

Admit: You” Attorney at Law that “You” refuse to disclosed material facts and evidences supporting Pro Se Plaintiff claims made of

numerous crimes, fraud, fraudulent business collectively perpetrating during past Hurricanes “Rita, Humberto, and Ike”. As being fully

described in this U. S. Cause 1:2014-CV-592 herein now.

And the actual Fraudulent activities of the Co-Defendant(s) “Joyce M. Guy and “Edward McCray” herein collectively

Surrounding the now physical possession, custody and legal control of said “Property Deeds” in connection with the “Texas Department of Housing & Community Affairs” $76,000.00 U.S. Dollars housing Grant as being described in Pro Se Plaintiff attached Document # 7 herein the “Jefferson County Texas Property search Index” (Public Record).

When Said “Property”, dwelling, and deeds thereof “already being a issue of “material evidence” and actual party thereof in a Civil suit in

Common law in the State of Texas cause No. A-180805

Since November 26th of 2007 for a “Breach of Construction Contract in excess of $10,800.00 U.S. Dollars.

Request Number 234.

Admit: You” Attorney at Law that “You” monetary retain for your legal services to not disclosed all material facts and evidences

supporting Pro Se Plaintiff claims made of numerous crimes, fraud, fraudulent business collectively perpetrating during past Hurricanes

“Rita, Humberto, and Ike”.

As being fully described in this U. S. Cause 1:2014-CV-592 herein now.

Request Number 235.

Admit: “You” were “monetary retain” for your legal services to not disclose all material facts and evidences surrounding the actual

ongoing during a civil suit Fraudulent activities of the Co-Defendant(s) “Joyce M. Guy and “Edward McCray” herein collectively

Surrounding the now physical possession, custody and legal control of said “Property Deeds” in connection with the “Texas Department of Housing & Community Affairs” $76,000.00 U.S. Dollars housing Grant as being described in Pro Se Plaintiff attached Document # 7 herein the “Jefferson County Texas Property search Index” (Public Record).

When Said “Property”, dwelling, and deeds thereof “already being a

issue of “material evidence” and actual party thereof in a Civil suit in Common law in the State of Texas cause No. A-180805, as also described in U.S. Cause 1:2010-CV-00055, and

Since November 26th of 2007 for a “Breach of Construction Contract in excess of $10,800.00 U.S. Dollars.

Request Number 236.

Admit: “You” Defendant “Antoine L. Freeman J.D. (Attorney at Law) Texas Bar No. 24058299 were not “monetary retain” for your legal services in a legal contract but enter into a A secrete negotiable instrument document guaranteeing the payment of a specific amount of cash money, or liquid non traceable assets, or Drugs namely “Crack Cocaine”

Either on demand, or at a set time of secluding pay off’s, More specifically

Co-Defendant(s) “Joyce M. Guy and Edward McCray” secretly retain “You” and “Your” legal services herein to cover up all Material facts supporting Pro Se Plaintiff claims made of numerous crimes, fraud, fraudulent business Co-Defendant(s) collectively perpetrating during past Hurricanes “Rita, Humberto, and Ike”.

To include but not limited to the Co-Defendant(s) “Joyce M. Guy and “Edward McCray” herein collectively being fully 100% involved, engaged in this dishonest, deceitful quite fraudulent bogus transfer of “property and deeds” thereof and “Your” secrete negotiable instrument document guaranteeing the payment of a specific amount of secrete cash money, or hidden liquid able assets, or Drugs namely “Crack Cocaine” either on demand, or at a set time of secluding pay off’s, More specifically

For you legal “Attorney at Law” services provisions guaranteeing the payment of a specific amount of secrete cash money, or hidden liquid able assets, or Drugs namely “Crack Cocaine” for you to not further disclosed this additional “material facts” said “property and deeds thereof was in the custody, possession and legal control of the

“Texas Department of Housing & Community Affairs” as described in Pro Se Plaintiff attached Document # 7 attached herein “Jefferson County Texas Property search Index” Instrument # 2014012455

While you’re still acting Attorney of Record in ongoing civil suit A-180805 58th Judicial District Court of Jefferson County Texas between the time frame of

the December 18th 2007- throughout December 11th 2009 ending your representation for cause No. A-180805.

Request Number 237.

Admit: “You” Defendant “Antoine L. Freeman J.D. (Attorney at Law) Texas Bar No. 24058299 were not “monetary retain” for your legal services in a legal public contract for Attorney services but enter into a secrete negotiable instrument document guaranteeing the payment of a specific amount of cash money, or liquid able secrete assets, or Drugs namely “Crack Cocaine”

Either on demand, Or at a set time of secluding “Your” hidden pay off’s,

More specifically that there after “You” filed the original “General Denial” as claiming on December 18th 2007 and Officially on Docket No. A-180805,

There are no official legal documented contracts, ledgers with banking drafts, paper/computer accounting, promissory notes, bills of exchange, banknotes, and photo copies of cashed cheques,

Money orders standing as actual physical proof of “Your” Legal “Attorney at Law” services from the “Time Frame” dates of January 1s t 2008 - February 28th 2010 throughout when you’re represented

Also secretly for the negotiable instrument document guaranteeing the payment of a specific amount of cash laundry and racket money, or liquid non traceable secrete assets, or Drugs namely “Crack Cocaine”

Either on demand, Or at a set time of secluding “Your” hidden pay off’s, in “Your” legal appearance for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf in U.S. Cause No. 1:2010-CV-00055

Further admitting there are no official legal documented contracts, ledgers with banking drafts, paper/computer accounting, promissory notes, bills of exchange, banknotes, and photo copies of cashed cheques,

Money orders standing as actual physical proof of “Your” Legal “Attorney at Law” services in U.S. Cause No. 1:2010-CV-00055 also…?

Request Number 238. Admit:

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 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.

And you were fully not in that term “Attorney of Record”, a party thereof from December 18th 2007 throughout the exact dates in time of November 13th 2009 10:22 AM when you file a “Motion for Withdrawal” in cause No. A-180805…?

Request Number 239.

Admit:

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 and they 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 ̍ siː/ or /ˌproʊ ̍ seɪ/) means advocating on one's own behalf before a court, rather than being represented by a lawyer namely “You” Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” Bar No. 24058299 herein

As “Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein collectively “Appeared” official Pro Se 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 being admitted herein

As such said Co-Defendant(s) collectively being said Pro Se counsel of record fully acting as such for their very own “legal interest” against the said Pro

Se Plaintiff Louis Charles Hamilton II herein from the exact the exact “time frame dates” of December 19th 2007 throughout December 11th 2009…

Request Number 240.

Admit:

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 December 18th 2007 throughout the exact dates of November 11s t 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,

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 Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein directly not having any physical Usage of the “United States Mailing System” surround civil court event thereafter December 18th 2007 throughout the exact dates of November 11s t 2009 for their “legal behalf” of said Co-Defendant(s) collectively through the “United States Mailing System”

Request Number 241.

Admit:

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 “Anita Becker” thereafter December 18th 2007

throughout the exact dates of November 11s t 2009 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805.

Namely on hearing dates of August 28th, 2009

Request Number 242.

Admit:

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 “Anita Becker” thereafter December 18th 2007 throughout the exact dates of November 11s t 2009 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805.

Namely on hearing date of September 11th 2009

Request Number 243.

Admit:

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 December 18th 2007 throughout the exact dates of November 11th 2009 involved in cause No. A-180805

Request Number 244.

Admit:

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 December 18th 2007 throughout the exact dates of November 11s t 2009 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805

Request Number 245.

Admit:

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 December 18th 2007 throughout the exact dates of November 11s t 2009 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805

Request Number 246.

Admit:

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 December 18th 2007 throughout the exact dates of November 11s t 2009 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805

Request Number 247.

Admit:

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 December 18th 2007 throughout the exact dates of November 11s t 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”.

Request Number 248.

Admit:

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 and Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein collectively there after December 18th 2007 was acting fully “Pro Se” in all legal matters, and hearing before the court, and all records derive thereof

In a civil suit in the 58th Judicial District Court of Jefferson County Texas filed in Cause No. A-180805 admitting that you “Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein 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

“Your” only being retain for such services, as describe by a contract between “You” and Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein

For all legal services simply thereof required for such professional legal services to file a simple “General Denial” (Only) on December 18th 2007

Request Number 249.

Admit:

In that Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein collectively was acting as Pro Se (Counsel of record) and physically involved with

inner actions on live “court transcripts” with the 58th Court reporters “Anita Becker” thereafter December 18th 2007 throughout the exact dates of November 11s t 2009 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” own “legal behalf” in cause No. A-180805.

Namely that Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein was acting Pro Se (Counsel of record) on hearing dates of August 28 th, 2009 before “58th Court Reporter” Anita Becker” other than “Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein

Request Number 250.

Admit:

In that Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein was acting as Pro Se (Counsel of record) and physically involved with inner actions on live “court transcripts” with the 58th Court reporters “Anita Becker” thereafter December 18th 2007 throughout the exact dates of November 11s t 2009 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” own “legal behalf” in cause No. A-180805.

Namely that Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein was acting Pro Se (Counsel of record) on hearing date of September 11th 2009 before “58th Court Reporter” Anita Becker” other than “Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein

Request Number 251.

Admit:

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” Texas Bar No. 24058299 herein “Your” absolute 100% solid “set” in concrete, stone, chisel ink “You” being named “Chief Defendant” (Attorney at Law) herein “legally entertaining” such that your “contentions” before a

“Honorable 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 to the exact date of December 11th 2009” being fully 100% Pro Se for their own legal interest.

Request Number 252.

Admit:

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

And “You” filed “You’re” immediately “Motion for withdrawal of counsel” of record between the exact dates of December 18th 2007 throughout the exact dates of November 11s t 2009 from cause No. A-180805 filed in Jefferson County Texas Courthouse. Request Number 253.

Admit:

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

And that said Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” Texas Bar No. 24058299 herein was not on any “court transcript recording” of “Anita Becker” on the hearing date of exactly August 28th 2009 before the 58th Judicial District Court of Jefferson County Texas Docket No. A-180805

In which “You” Defendant (Attorney at law) herein admit “You” did not “cross examine” a “Subpoena Witness” herein namely one “Allen T. Guy” natural brother to the Co-Defendant “Joyce M. Guy” herein.

In the term Subpena - (subpoena): (suh-pea-nah) n. an order of the court for a witness to appear at a particular time and place to testify and/or produce documents in the control of the witness (if a "subpena duces tecum").

A subpena is used to obtain testimony from a witness at both depositions (testimony under oath taken outside of court) and at trial. Subpenas are usually issued automatically by the court clerk but must be served personally on the party being summoned.

Failure to appear as required by the subpena can be punished as contempt of court if it appears the absence was intentional or without cause.

In the term Cross-Examination - n. the opportunity for the attorney (or an unrepresented party) to ask questions in court of a witness who has testified in a trial on behalf of the opposing party.

The questions on cross-examination are limited to the subjects covered in the direct examination of the witness, but importantly, the attorney may ask

leading questions, in which he/she is allowed to suggest answers or put words in the witness's mouth.

(For example, "Isn't it true that you told Mrs. Jones she had done nothing wrong?" which is leading, as compared to "Did you say anything to Mrs. Jones?") A strong cross-examination (often called just "cross" by lawyers and judges) can force contradictions, expressions of doubts or even complete obliteration of a witness's prior carefully rehearsed testimony.

On the other hand, repetition of a witness’s story, vehemently defended, can strengthen his/her credibility.

In the term Testimony - n. oral evidence given under oath by a witness in

answer to questions posed by attorneys at trial or at a deposition (questioning

under oath outside of court).

In the term Testify - v. to give oral evidence under oath in answer to questions posed by attorneys either at trial or at a deposition (testimony under oath outside of court), with the opportunity for opposing attorneys to cross-examine the witness in regard to answers given.

In the term Transcript - n. the written record of all proceedings, including testimony, in a trial, hearing or deposition (out-of-court testimony under oath). Jurisdictions vary as to whether the attorneys' final arguments are recorded, with the Federal Court Reporter Act, but not all states, requiring inclusion.

A copy of the transcript may be ordered from the court reporter and a fee paid for the transcription and first copy; if the opposing party also wants a copy, the cost will not include the transcription fee.

In most appeals a copy of the transcript is required so that the court of appeals can review the entire proceedings in the trial court. Copies of depositions may be ordered for a fee from the court reporter who took down the testimony. Transcripts are not printed from the record unless transcription is requested

And that said Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” Texas Bar No. 24058299 herein the term Testimony, In the term Testify, In the term Cross-Examination, In the term Transcript,

In the term Subpena being fully not involved thereof, or making any legal representation, presentation, as acting “Attorney of record” on any “court transcript recording” of “Anita Becker” on the hearing date of exactly August 28 th 2009 appearing before “Judge Bob Wortham” of the 58th Judicial District Court of Jefferson County Texas.

Request Number 254.

Admit:

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

And that said Co-Defendant(s) “Joyce M. Guy and Edward McCray” (Herein) collectively was acting “Pro Se” on “court transcript recording” of “Anita Becker” on the hearing date of exactly August 28th 2009 before the 58th Judicial District Court of Jefferson County Texas Docket No. A-180805

In which “You” Chief Defendant (Attorney at law) herein admit that said Co-Defendant(s) “Joyce M. Guy and Edward McCray” (Herein) collectively was acting “Pro Se” and physically “cross examine” a “Subpoena Witness” herein namely one “Allen T. Guy” natural brother to the Co-Defendant “Joyce M. Guy” herein.

In the term Subpena - (subpoena): (suh-pea-nah) n. an order of the court for a witness to appear at a particular time and place to testify and/or produce documents in the control of the witness (if a "subpena duces tecum").

A subpena is used to obtain testimony from a witness at both depositions (testimony under oath taken outside of court) and at trial. Subpenas are usually issued automatically by the court clerk but must be served personally on the party being summoned.

Failure to appear as required by the subpena can be punished as contempt of court if it appears the absence was intentional or without cause.

In the term Cross-Examination - n. the opportunity for the attorney (or an unrepresented party) to ask questions in court of a witness who has testified in a trial on behalf of the opposing party.

The questions on cross-examination are limited to the subjects covered in the direct examination of the witness, but importantly, the attorney may ask leading questions, in which he/she is allowed to suggest answers or put words in the witness's mouth.

(For example, "Isn't it true that you told Mrs. Jones she had done nothing wrong?" which is leading, as compared to "Did you say anything to Mrs. Jones?") A strong cross-examination (often called just "cross" by lawyers and judges) can force contradictions, expressions of doubts or even complete obliteration of a witness's prior carefully rehearsed testimony.

On the other hand, repetition of a witness’s story, vehemently defended, can strengthen his/her credibility.

In the term Testimony - n. oral evidence given under oath by a witness in

answer to questions posed by attorneys at trial or at a deposition (questioning

under oath outside of court).

In the term Testify - v. to give oral evidence under oath in answer to questions posed by attorneys either at trial or at a deposition (testimony under oath outside of court), with the opportunity for opposing attorneys to cross-examine the witness in regard to answers given.

In the term Transcript - n. the written record of all proceedings, including testimony, in a trial, hearing or deposition (out-of-court testimony under oath). Jurisdictions vary as to whether the attorneys' final arguments are recorded, with the Federal Court Reporter Act, but not all states, requiring inclusion.

A copy of the transcript may be ordered from the court reporter and a fee paid for the transcription and first copy; if the opposing party also wants a copy, the cost will not include the transcription fee.

In most appeals a copy of the transcript is required so that the court of appeals can review the entire proceedings in the trial court. Copies of depositions may be ordered for a fee from the court reporter who took down the testimony. Transcripts are not printed from the record unless transcription is requested

And that said Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” Texas Bar No. 24058299 herein

In the term Testimony, in the term Testify, in the term Cross-Examination, in the term Transcript, in the term Subpoena

“You” being fully not involved thereof, or making any legal representation, presentation, as acting “Attorney of record” on any “court transcript recording” of “Anita Becker” on the hearing date of exactly August 28 th 2009 appearing before “Judge Bob Wortham” of the 58th Judicial District Court of Jefferson County Texas

And it was in fact said Co-Defendant(s) “Joyce M. Guy and Edward McCray” (Herein) collectively was acting “Pro Se” and fully involved In the term Testimony, In the term Testify, In the term Cross-Examination, In the term Transcript, In the term Subpoena of witness “Allen T. Guy” named herein.

By, _______________________________

Louis Charles Hamilton II

Pro Se Plaintiff

P.O. Box 17524

Sugar Land Texas 77496