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In The United States DistrictCourt
For The Eastern Division of Texas
Beaumont Division
Louis Charles Hamilton II
Pro Se Pl...
Where this causeis pending and a copy delivered to the writer within thirty
(30) days fromthe serving of this request upon...
Obligations” as acting retain” Counsel of Record “for the Co-Defendant(s) Joyce
M. Guy and Edward McCray herein
in the ent...
Request Number 7.
Admit: that “You” being in full possession, custody, and legalcontrol over
Pro Se Plaintiff Discovery re...
Admit: “You” did not file a “Motion for withdrawalof Counsel” to causeNo.
A-180805 between thedates of April 2nd
2008 and ...
Request Number 11.
Admit: that “You” in causeNo. A-180805 “Between” thedates of April 2nd
2008 and April 11, 2008, through...
Request Number 13.
Admit: “You” did not request a longer extension of time fromthe Pro Se
Plaintiff herein and agree upon ...
between the dates of April2nd
2008 and April 11, 2008, throughoutthedates of
October 14th
2009
“Your” being granted a long...
“You” wanted to file a Motion for withdrawalin cause No. A-180805from
being acting Attorney of Record on the behalf of Co-...
Admit: “You” did in fact legally representCo-Defendant(s) JoyceM. Guy
and Edward McCray as acting Attorney of Record in ca...
Admission, and Request for Disclosurein the time framedates of April 2nd
2008 and April 11, 2008 throughoutSeptember 1st
2...
Admit: “You” Attorney at Law were retained by Co-Defendant(s)
Joyce M. Guy and Edward McCray in January of 2008 causeNo. A...
Admit: “You” Attorney at Law were retained by Co-Defendant(s)
Joyce M. Guy and Edward McCray in June of 2008 causeNo. A-
1...
Request Number 40.
Admit: “You” Attorney at Law were retained by Co-Defendant(s)
Joyce M. Guy and Edward McCray in Decembe...
Admit: “You” Attorney at Law were retained by Co-Defendant(s)
Joyce M. Guy and Edward McCray in May of 2009 causeNo. A-180...
Request Number 51.
Admit: “You” Attorney at Law were retained by Co-Defendant(s)
Joyce M. Guy and Edward McCray in May of ...
Request Number 55.
Admit: “You” Attorney at Law were retained by Co-Defendant(s)
Joyce M. Guy and Edward McCray in Septemb...
Request Number 59.
Admit: “You” Attorney at Law were retained by Co-Defendant(s)
Joyce M. Guy and Edward McCray in January...
Request Number 63.
Admit: “You” Attorney at Law were retained by Co-Defendant(s)
Joyce M. Guy and Edward McCray in May of ...
Request Number 67.
Admit: “You” Attorney at Law were retained by Co-Defendant(s)
Joyce M. Guy and Edward McCray in Septemb...
Court of Jefferson County Texas and did not file a “Motion for Withdrawal
in Augustof 2008
Request Number 72.
Admit: “You”...
Admit: “You” Attorney at Law Knew you was acting “Attorney of
Record in January of 2009 causeNo. A-180805in the 58th
Judic...
Admit: “You” Attorney at Law Knew you was acting “Attorney of
Record in June of 2009 causeNo. A-180805 in the 58th
Judicia...
Admit: “You” Attorney at Law Knew you was acting “Attorney of
Record in November of 2009 causeNo. A-180805 in the 58th
Jud...
Jefferson County Texas on August28th
, 2009 beforetheHonorable Bob
Worthamand your Clients Co-Defendant(s) Joyce. M. Guy a...
not respond to discovery requestof Interrogatories, Requestfor Admission,
and Request for Disclosureon August28th
, 2009.
...
Admit: “You” Attorney at Law was retained by Co-Defendant(s)
Joyce. M. Guy and Edward McCray herein cause No. A-180805 att...
at 448 DeQueen blvd. in Port Arthur Texas no longer exist, and Construction
of a New Home had commence in the year of 2009...
And “You” had in “Your” full possession, custodyand legal control
discovery requestof Interrogatories, Requestof Admission...
October 14th
2009 when your responseto Discovery Requestin Civil No. A-
180805
Some (1) year and (6) months plus days late...
M. Guy and Edward McCray herein causeNo. A-180805 (30) days thereafter
mailing of service upon “You” to so reply
Request N...
the attached document #2 herein containing “Your” signature. “Motion for
Withdrawalof Counsel” On November 13th, 2009 file...
hearing beforethe 58th
Judicial DistrictCourt in Jefferson County Texas for
the legal behalf of Co-Defendant(s) Joyce. M. ...
“You” on the dates of April 2nd
2008 and April11th
2008 for thesame
causeNo. A-180805 filed in the Jefferson County Texas ...
Admit: “You” Attorney at Law that “You” were fully awareduring the
time frame of December 18th
2007 throughout“Your” being...
Being forward (30) to (60) days thereafter to any other Law Officeor
Attorney(s) other then “Yourself” for the “Legal Beha...
Hamilton II” herein a “Motion for Production of Document(s) dated August
12th
2009” on the certificate of mailing services...
Admit: “You” Attorney at Law that “You” refused to respond to any
of Pro Se Plaintiff “Motion for Production of Document(s...
Admit: “You” Attorney at Law that “You” refused to respond to any
of Pro Se Plaintiff “Motion for Production of Document(s...
For the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas
being already complained of in a among other causeof ac...
While “You” Attorney at Law refusalto file “Your” “Motion for “Your”
withdrawalon or before next 58th
Judicial DistrictCou...
DeQueen Blvd. in PortArthur Texas (Lot) 1-2 blk. 172 (PortArthur Texas)
same causeNo. A-180805
But “Your” in 100% refusalt...
Request Number 137.
Admit: “You” Attorney at Law that “Your” reply in your responseto
Pro Se Plaintiff motion for sanction...
#9 herein with false statement made by “You” was Placed in the United
States Mail and Publically Mailed to the Pro Se Plai...
Request Number 144.
Admit: “You” Attorney at Law that “Your” reply/respond to Pro Se
Plaintiff “Motion for Sanctions” agai...
Arthur Texas of the Co-Defendant(s) “JoyceM. Guy and Edward McCray
herein
Was Legally Transfer to the Texas Department of ...
Arthur Texas of the Co-Defendant(s) “JoyceM. Guy and Edward McCray
herein
Was Legally Transfer to the Texas Department of ...
During this sametime frame “Your” being acting Attorney of record
causeNo. A-180805 filed in the Jefferson County Texas Co...
During this sametime frame “Your” being acting Attorney of record
causeNo. A-180805 filed in the Jefferson County Texas Co...
Request Number 156.
Admit: “You” Attorney at Law that on Document# 10 herein Co-
Defendant “JoyceM. Guy” herein “Sworn Aff...
You state of having any knowledgeof “Required Pro Se Plaintiff
discovery requestfor admissions, interrogatories and Disclo...
Admit: “You” Attorney at Law that “Your” Affidavitin supportof
your reply to Pro Se Plaintiff “Motion for Sanctions” again...
“You” Document# 1 herein and Co-Defendant “JoyceM. Guy” “Affidavit in
supportof “You” document # 10 herein
Contain false s...
And was electronically computer filed in Document# 8 herein 58th
Judicial DistrictCourt of Jefferson County Texas “Case Le...
14. How is the State of Texas Involved?
Answer: Not Involved
15. How is the Federal Government involved?
Answer: FederalGr...
And further Admit that Documents #11 that Co- Defendant JoyceM.
Guy” herein supply the following “false and fraudulent” An...
And was electronically computer filed in Document# 8 herein 58th
Judicial DistrictCourt of Jefferson County Texas “Case Le...
Request Number 170.
And further Admit that Documents #11 attached herein that Co-
Defendant JoyceM. Guy” herein supply “fa...
Legally “You” placed said Interrogatories response in the United
States Mail and Publically Mailed to The Jefferson County...
Cause No. A-180805 as described in attached Document# 12 herein 58th
Judicial DistrictCourt of Jefferson County Texas “Doc...
Pro Se “Louis Charles Hamilton II” REQUESTS FOR ADMISSION, Cause No. 1:14-CV-592 Defendant “Antoine L. Freeman J. D. "Atto...
Pro Se “Louis Charles Hamilton II” REQUESTS FOR ADMISSION, Cause No. 1:14-CV-592 Defendant “Antoine L. Freeman J. D. "Atto...
Pro Se “Louis Charles Hamilton II” REQUESTS FOR ADMISSION, Cause No. 1:14-CV-592 Defendant “Antoine L. Freeman J. D. "Atto...
Pro Se “Louis Charles Hamilton II” REQUESTS FOR ADMISSION, Cause No. 1:14-CV-592 Defendant “Antoine L. Freeman J. D. "Atto...
Pro Se “Louis Charles Hamilton II” REQUESTS FOR ADMISSION, Cause No. 1:14-CV-592 Defendant “Antoine L. Freeman J. D. "Atto...
Pro Se “Louis Charles Hamilton II” REQUESTS FOR ADMISSION, Cause No. 1:14-CV-592 Defendant “Antoine L. Freeman J. D. "Atto...
Pro Se “Louis Charles Hamilton II” REQUESTS FOR ADMISSION, Cause No. 1:14-CV-592 Defendant “Antoine L. Freeman J. D. "Atto...
Pro Se “Louis Charles Hamilton II” REQUESTS FOR ADMISSION, Cause No. 1:14-CV-592 Defendant “Antoine L. Freeman J. D. "Atto...
Pro Se “Louis Charles Hamilton II” REQUESTS FOR ADMISSION, Cause No. 1:14-CV-592 Defendant “Antoine L. Freeman J. D. "Atto...
Pro Se “Louis Charles Hamilton II” REQUESTS FOR ADMISSION, Cause No. 1:14-CV-592 Defendant “Antoine L. Freeman J. D. "Atto...
Pro Se “Louis Charles Hamilton II” REQUESTS FOR ADMISSION, Cause No. 1:14-CV-592 Defendant “Antoine L. Freeman J. D. "Atto...
Pro Se “Louis Charles Hamilton II” REQUESTS FOR ADMISSION, Cause No. 1:14-CV-592 Defendant “Antoine L. Freeman J. D. "Atto...
Pro Se “Louis Charles Hamilton II” REQUESTS FOR ADMISSION, Cause No. 1:14-CV-592 Defendant “Antoine L. Freeman J. D. "Atto...
Pro Se “Louis Charles Hamilton II” REQUESTS FOR ADMISSION, Cause No. 1:14-CV-592 Defendant “Antoine L. Freeman J. D. "Atto...
Pro Se “Louis Charles Hamilton II” REQUESTS FOR ADMISSION, Cause No. 1:14-CV-592 Defendant “Antoine L. Freeman J. D. "Atto...
Pro Se “Louis Charles Hamilton II” REQUESTS FOR ADMISSION, Cause No. 1:14-CV-592 Defendant “Antoine L. Freeman J. D. "Atto...
Pro Se “Louis Charles Hamilton II” REQUESTS FOR ADMISSION, Cause No. 1:14-CV-592 Defendant “Antoine L. Freeman J. D. "Atto...
Pro Se “Louis Charles Hamilton II” REQUESTS FOR ADMISSION, Cause No. 1:14-CV-592 Defendant “Antoine L. Freeman J. D. "Atto...
Pro Se “Louis Charles Hamilton II” REQUESTS FOR ADMISSION, Cause No. 1:14-CV-592 Defendant “Antoine L. Freeman J. D. "Atto...
Pro Se “Louis Charles Hamilton II” REQUESTS FOR ADMISSION, Cause No. 1:14-CV-592 Defendant “Antoine L. Freeman J. D. "Atto...
Pro Se “Louis Charles Hamilton II” REQUESTS FOR ADMISSION, Cause No. 1:14-CV-592 Defendant “Antoine L. Freeman J. D. "Atto...
Pro Se “Louis Charles Hamilton II” REQUESTS FOR ADMISSION, Cause No. 1:14-CV-592 Defendant “Antoine L. Freeman J. D. "Atto...
Pro Se “Louis Charles Hamilton II” REQUESTS FOR ADMISSION, Cause No. 1:14-CV-592 Defendant “Antoine L. Freeman J. D. "Atto...
Pro Se “Louis Charles Hamilton II” REQUESTS FOR ADMISSION, Cause No. 1:14-CV-592 Defendant “Antoine L. Freeman J. D. "Atto...
Pro Se “Louis Charles Hamilton II” REQUESTS FOR ADMISSION, Cause No. 1:14-CV-592 Defendant “Antoine L. Freeman J. D. "Atto...
Pro Se “Louis Charles Hamilton II” REQUESTS FOR ADMISSION, Cause No. 1:14-CV-592 Defendant “Antoine L. Freeman J. D. "Atto...
Pro Se “Louis Charles Hamilton II” REQUESTS FOR ADMISSION, Cause No. 1:14-CV-592 Defendant “Antoine L. Freeman J. D. "Atto...
Pro Se “Louis Charles Hamilton II” REQUESTS FOR ADMISSION, Cause No. 1:14-CV-592 Defendant “Antoine L. Freeman J. D. "Atto...
Pro Se “Louis Charles Hamilton II” REQUESTS FOR ADMISSION, Cause No. 1:14-CV-592 Defendant “Antoine L. Freeman J. D. "Atto...
Pro Se “Louis Charles Hamilton II” REQUESTS FOR ADMISSION, Cause No. 1:14-CV-592 Defendant “Antoine L. Freeman J. D. "Atto...
Pro Se “Louis Charles Hamilton II” REQUESTS FOR ADMISSION, Cause No. 1:14-CV-592 Defendant “Antoine L. Freeman J. D. "Atto...
Pro Se “Louis Charles Hamilton II” REQUESTS FOR ADMISSION, Cause No. 1:14-CV-592 Defendant “Antoine L. Freeman J. D. "Atto...
Pro Se “Louis Charles Hamilton II” REQUESTS FOR ADMISSION, Cause No. 1:14-CV-592 Defendant “Antoine L. Freeman J. D. "Atto...
Pro Se “Louis Charles Hamilton II” REQUESTS FOR ADMISSION, Cause No. 1:14-CV-592 Defendant “Antoine L. Freeman J. D. "Atto...
Pro Se “Louis Charles Hamilton II” REQUESTS FOR ADMISSION, Cause No. 1:14-CV-592 Defendant “Antoine L. Freeman J. D. "Atto...
Pro Se “Louis Charles Hamilton II” REQUESTS FOR ADMISSION, Cause No. 1:14-CV-592 Defendant “Antoine L. Freeman J. D. "Atto...
Pro Se “Louis Charles Hamilton II” REQUESTS FOR ADMISSION, Cause No. 1:14-CV-592 Defendant “Antoine L. Freeman J. D. "Atto...
Pro Se “Louis Charles Hamilton II” REQUESTS FOR ADMISSION, Cause No. 1:14-CV-592 Defendant “Antoine L. Freeman J. D. "Atto...
Pro Se “Louis Charles Hamilton II” REQUESTS FOR ADMISSION, Cause No. 1:14-CV-592 Defendant “Antoine L. Freeman J. D. "Atto...
Pro Se “Louis Charles Hamilton II” REQUESTS FOR ADMISSION, Cause No. 1:14-CV-592 Defendant “Antoine L. Freeman J. D. "Atto...
Pro Se “Louis Charles Hamilton II” REQUESTS FOR ADMISSION, Cause No. 1:14-CV-592 Defendant “Antoine L. Freeman J. D. "Atto...
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Pro Se “Louis Charles Hamilton II” REQUESTS FOR ADMISSION, Cause No. 1:14-CV-592 Defendant “Antoine L. Freeman J. D. "Attorney at Law"

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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

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Pro Se “Louis Charles Hamilton II” REQUESTS FOR ADMISSION, Cause No. 1:14-CV-592 Defendant “Antoine L. Freeman J. D. "Attorney at Law"

  1. 1. In The United States DistrictCourt For The Eastern Division of Texas Beaumont Division Louis Charles Hamilton II Pro Se Plaintiff Vs. CauseNo. 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 REQUESTSFORADMISSION,SETONE To: Antoine L. Freeman J. D. Attorney at Law AND HIS COUNSEL OF RECORD: Pursuantto the provisions of Federal Rule of Civil Procedure36, it is hereby requested and demanded of Defendant Antoine L. Freeman J. D. (hereinafter “YOU” or “YOUR”), that YOUmake admissions of the following statements of fact which are materially pertinent to Plaintiff claims hereto in accordancewith Rule 36, Under which rule of procedurethis requestfor admissions is made, thereby answering the following facts in the above-entitled and number cause, and that such answers besworn to and filed promptly in the office of the District Clerk
  2. 2. Where this causeis pending and a copy delivered to the writer within thirty (30) days fromthe 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 accordancewith 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) JoyceM. Guy and Edward McCray herein (Only) retain the legal services of Antoine L. Freeman J.D. (Attorney at Law) for the purposeof (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 SePlaintiff herein. Request Number 2. Admit: That You on December 18th 2007 filed for Co-Defendant(s) JoyceM. 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 suitin the 58th Judicial District Courtof Jefferson County Texas. Request Number 3. Admit: That you on November 13th 2009 10:22 amfiled with “Lolita Ramos”, Clerk, and District Courtof Jefferson County, Texas A Motion for to Withdrawalof CounselfromCo-Defendant(s) JoyceM. 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’reonly “Legal Duties” and “Fiduciary
  3. 3. 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 suitin common law” time frameof 1 year, 10 months and 13 days filed in the 58th JudicialDistrict Court of Jefferson County Texas before the HonorableBob Wortham. Request Number 4. Admit: That you on or about April 2nd 2008 and April11, 2008 you were in possession, custody, and controlof Pro Se Plaintiff Discovery requestfor Interrogatories, Requestof Admission, and Request for Disclosurein accordance with the Texas Rules of Civil Procedures 194.2, 197, and 198, to CauseNo. A- 180805 in a civil suit in the 58th Judicial DistrictCourt of Jefferson County Texas. Request Number 5. Admit: that you did not file a “Motion for withdrawalof Counsel” fromthe Co-Defendant(s) JoyceM. Guy and Edward McCray herein “Between” the dates of December 18th 2007 your claimof filing your “General Denial”(Only) to causeNo. A-180805 to thedate of April 2nd 2008 and April11, 2008, after being in possession, custody, and control over Pro Se Plaintiff Discovery request for Interrogatories, Requestfor Admission, and Request for Disclosurein accordance with the Texas Rules of Civil Procedures 194.2, 197, and 198, during this time frame “You” did not file a “Motion for withdrawalof 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 requestfor Interrogatories, Requestof Admission, and Request for Disclosurein accordancewith the Texas Rules of Civil Procedures 194.2, 197, and 198, fromthedates of April 2nd 2008 and April11, 2008, throughoutOctober 14th 2009 during this time frameof (1) year and (5) months “You” did not file a “Motion for withdrawalof Counselto causeNo. A-180805
  4. 4. Request Number 7. Admit: that “You” being in full possession, custody, and legalcontrol over Pro Se Plaintiff Discovery request for Interrogatories, Requestfor Admission, and Request for Disclosurein accordancewith the Texas Rules of Civil Procedures 194.2, 197, and 198, “Between” the dates of April 2nd 2008 and April11, 2008, throughoutthe 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-180805to 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 Requestfor Interrogatories, Requestfor Admission, and Request for Disclosurein accordancewith the Texas Rules of Civil Procedures 194.2, 197, and 198, “Between” the dates of April 2nd 2008 and April 11, 2008, throughoutthe dates of April 2nd 2009 and April11th 2009 “You” for a time frame of (1) exact year during this said time frameof being in full possession, custody, and legal control over said Pro Se Plaintiff Discovery request for Interrogatories, Requestfor Admission, and Request for Disclosure “You” did not even reply at all to any of the Pro Se Plaintiff Discovery legal request for Interrogatories, Requestof Admission, and Request for Disclosurethat was mailed to you in accordancewith the Texas Rules of Civil Procedures 194.2, 197, and 198, in causeNo. A-180805 filed in the 58th Judicial District Courtof Jefferson County Texas Request Number 9.
  5. 5. Admit: “You” did not file a “Motion for withdrawalof Counsel” to causeNo. A-180805 between thedates of April 2nd 2008 and April11, 2008, throughoutthe dates of April 2nd 2009 and April11th 2009 (1) exactyear “Your” being in full possession, custody, and legal control over Pro Se Plaintiff Discovery requestfor Interrogatories, Requestof Admission, and Request for Disclosurein accordance with the Texas Rules of Civil Procedures 194.2, 197, and 198,. Request Number 10. Admit: “You” did not file a “Motion for withdrawalof Counsel” to causeNo. A-180805, Between the dates of April 2nd 2009 and April11th 2009 while“Your” in full possession, custody, and legalcontrol over Pro Se Plaintiff Discovery request for Interrogatories, Requestof Admission, and Request for Disclosurein accordancewith 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 controlover Pro Se Plaintiff Discovery requestfor Interrogatories, Requestof Admission, and Request for Disclosurein accordancewith the Texas Rules of Civil Procedures 194.2, 197, and 198, . Request Number 11. Admit: Between” the dates of April 2nd 2008 and April11, 2008, “Your” in full possession, custody, and legalcontrol over Pro Se Plaintiff Discovery request for Interrogatories, Requestof Admission, and Request for Disclosurein accordancewith the Texas Rules of Civil Procedures 194.2,197, and 198, “You” werelegally 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 responseand reply to Interrogatories, Requestof Admission, and Request for Disclosurein accordancewith the Texas Rules of Civil Procedures 194.2, 197, and 198,. On or about the dates of April 2nd 2008 and April11th , 2008.
  6. 6. Request Number 11. Admit: that “You” in causeNo. A-180805 “Between” thedates of April 2nd 2008 and April 11, 2008, throughoutthedates of October 14th 2009 “Your” in full possession, custody, and legal control over Pro Se Plaintiff Discovery requestfor Interrogatories, Requestof Admission, and Request for Disclosurein accordance with the Texas Rules of Civil Procedures 194.2, 197, and 198, “You” never informed the HonorableJudge “Bob Wortham” of the 58th Judicial DistrictCourt of Jefferson County Texas “Your” being in complete refusal to file a legal responseand reply to any of the Interrogatories, Requestof Admission, and Request for DisclosurePro Se Plaintiff mailed to “You” on the dates of April 2nd 2008 and April11, 2008, in accordancewith 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 DistrictCourt of Jefferson County Texas between the time frame dates of April 2nd 2008 and April11, 2008, throughoutthedates of April 2nd 2009 and April 11th 2009 (1) exactyear “Your” being in full possession, custody, and legal control over Pro Se Plaintiff Discovery requestfor Interrogatories, Requestof Admission, and Request for Disclosurein accordancewith the Texas Rules of Civil Procedures 194.2, 197, and 198,. “Your” being in complete refusal to file a legal responseand reply to any of the Interrogatories, Requestof Admission, and Request for DisclosurePro Se Plaintiff mailed to “You” on the dates of April 2nd 2008 and April11, 2008, in accordancewith the Texas Rules of Civil Procedures 194.2,197, and 198, in cause No. A-180805for the“Legal behalf” of Co-Defendant(s) JoyceM. Guy and Edward McCray herein.
  7. 7. Request Number 13. Admit: “You” did not request a longer extension of time fromthe Pro Se Plaintiff herein and agree upon in writing to reply to said “Discovery Requestof Interrogatories, Requestof Admission, and Request for DisclosurePro Se Plaintiff mailed to “You” on the dates of April 2nd 2008 and April11, 2008, in accordancewith the Texas Rules of Civil Procedures 194.2,197, and 198, (30) Days after Serviceof said discovery requestin cause No. A-180805for the“Legal behalf” of Co- Defendant(s) JoyceM. Guy and Edward McCray herein. Request Number 14. Admit: “You” did not request a longer extension of time fromthe 58th Judicial DistrictCourt Judge “Bob Wortham” in order to obtain a Court Order of “approval” of the HonorableCourt in “Your” being granted a longer extension of time to reply to all of the said Discovery Requestof Interrogatories, Requestof Admission, and Request for DisclosurePro Se Plaintiff mailed to “You” on the dates of April 2nd 2008 and April11, 2008, in accordancewith the Texas Rules of Civil Procedures 194.2,197, and 198, (30) Days after Serviceof said discovery requestin causeNo. A- 180805 on thedates being described herein April 2nd 2008 and April11th 2008 for the “Legal behalf” of Co-Defendant(s) JoyceM. Guy and Edward McCray herein. Request Number 15. Admit: “You” did not give the 58th Judicial DistrictCourt Judge “Bob Wortham” any Written, or Verbal notice, cellular phone or office phone communication, memo, documents or emails transmission of any type, fax, text,
  8. 8. between the dates of April2nd 2008 and April 11, 2008, throughoutthedates of October 14th 2009 “Your” being granted a longer extension of time to reply to all of the said Discovery Requestof Interrogatories, Requestof Admission, and Request for DisclosurePro Se Plaintiff mailed to “You” on the dates of April 2nd 2008 and April 11, 2008, in accordancewith the Texas Rules of Civil Procedures 194.2, 197, and 198, “Your” were being in full possession, custody, and legal controlover Pro Se Plaintiff said “Discovery requests” in causeNo. A-180805 on the dates being described herein April 2nd 2008 and April11th 2008 for the “Legal behalf” of Co- Defendant(s) JoyceM. Guy and Edward McCray herein. Request Number 16. Admit: “You” did not give the 58th Judicial DistrictCourt Judge “Bob Wortham” or his office clerk or any staff member of the 58th Judicial Court any Written form, or Verbalnotice of somesort, cellular phonecall or office phone communication of any type, memos, documents or emails transmission of any type, faxes, text, between the dates of December 18th 2007 throughoutthedates of April 2nd 2008 and April11, 2008 “You” wanted to file a Motion for withdrawalin cause No. A-180805from being acting Attorney of Record on the behalf of Co-Defendant(s) JoyceM. Guy and Edward McCray herein. Request Number 17. Admit: “You” did not give the 58th Judicial DistrictCourt Judge “Bob Wortham” or his office clerk or any staff member of the 58th Judicial Court any Written form, or Verbalnotice of some sort, cellular phonecall 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 April11, 2008 throughoutthe dates of October 14th 2009
  9. 9. “You” wanted to file a Motion for withdrawalin cause No. A-180805from being acting Attorney of Record on the behalf of Co-Defendant(s) JoyceM. Guy and Edward McCray herein. Request Number 18. Admit: “You” filed before58th Judicial District CourtJudge “Bob Wortham” A Responseto Plaintiff Motion for Sanctions against you with “Your” Affidavit attached signed and dated September 11th 2009. For notreplying to any of the Pro Se Plaintiff Discovery requestbetween the dates of April 2nd 2008 and April 11, 2008 throughout October 13th 2009 in causeNo. A-180805 Request Number 19. Admit: “You” stated before the HonorableCourt in your ResponseMotion for Sanctions document dated September 11th 2009, “You” being retain by Co- Defendant JoyceM. Guy herein for purposeof (Only) writing a general denial so as to avoid a default judgmentbeing rendered against which you filed in December of 2007 in responseto the complaint cause No. A-180805 Request Number 20. Admit: “You” did in fact legally representCo-Defendant(s) JoyceM. Guy and Edward McCray as acting Attorney of Record in cause No. A-180805other then justsimply filing a General Denial between the dates of December 18th 2007 throughoutthe dates of October 14th 2009. Request Number 21. Admit: “You” did in fact legally representCo-Defendant(s) JoyceM. Guy and Edward McCray as acting Attorney of Record in cause No. A-180805during a hearing held on the 28th day of August2009 beforethe HonorableJudge Bob Wortham Request Number 22.
  10. 10. Admit: “You” did in fact legally representCo-Defendant(s) JoyceM. Guy and Edward McCray as acting Attorney of Record in cause No. A-180805other then justsimply filing a General Denial between the dates of December 18th 2007 and filed your certificate of mailing service and responseto said discovery request on the 14th day of October 2009 to Plaintiff said “Discovery Requestof Interrogatories, Requestof Admission, and Request for DisclosurePro Se Plaintiff mailed to “You” on the dates of April 2nd 2008 and April11, 2008, in accordancewith the Texas Rules of Civil Procedures 194.2,197, and 198, for the“Legal behalf” of Co-Defendant(s) JoyceM. 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, Requestof Admission, and Request for DisclosurePro Se Plaintiff mailed to “You” on the dates of April 2nd 2008 and April11, 2008, in accordancewith the Texas Rules of Civil Procedures 194.2,197, and 198, for the“Legal behalf” of Co-Defendant(s) JoyceM. Guy and Edward McCray herein after (30) Days after Service of said discovery requestin causeNo. A-180805 had expired for the “Legal behalf” of Co-Defendant(s) JoyceM. Guy and Edward McCray herein. Request Number 24. Admit: “You” were retain by Co-Defendant(s) JoyceM. Guy and Edward McCray to not reply to any discovery requestof the Pro Se Plaintiff herein cause No. A-180805 requestof Interrogatories,Requestof Admission, and Request for Disclosure in the time framedates of April 2nd 2008 and April 11, 2008 throughoutApril2nd 2009 and April11, 2009 Request Number 25. Admit: “You” were retain by Co-Defendant(s) JoyceM. Guy and Edward McCray to not reply to any discovery requestof the Pro Se Plaintiff herein cause No. A-180805 requestof Interrogatories,Requestof
  11. 11. Admission, and Request for Disclosurein the time framedates of April 2nd 2008 and April 11, 2008 throughoutSeptember 1st 2009 Request Number 26. Admit: “You” claim were retain by Co-Defendant(s) JoyceM. Guy and Edward McCray simply to the Attorney at Law duties of filing a General Denial between the dates of December 18th 2007 butwas acting Attorney of Record throughoutthe dates of November 13th 2009. Request Number 27. Admit: “You” were retained by Co-Defendant(s) JoyceM. Guy and Edward McCray to hide all of the discovery phaseof this civil cause No. A- 180805 fromthePro Se Plaintiff and the 58th Judicial DistrictCourt of Jefferson County Texas and Not allowed Pro Se Plaintiff any legal access at all to said discovery requestof Interrogatories, Requestof Admission, and Request for DisclosurePro Se Plaintiff mailed to “You” on the dates of April 2nd 2008 and April11, 2008, in accordancewith the Texas Rules of Civil Procedures 194.2,197, and 198, for the “Legal behalf” of Co-Defendant(s) JoyceM. Guy and Edward McCray between the dates of April2nd 2008 and April 11, 2008 throughoutthe dates of September 1st 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 causeNo. A- 180805 in the 58th Judicial DistrictCourt of Jefferson County Texas Request Number 29.
  12. 12. Admit: “You” Attorney at Law were retained by Co-Defendant(s) Joyce M. Guy and Edward McCray in January of 2008 causeNo. A-180805 in the 58th Judicial DistrictCourt 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 causeNo. A-180805 in the 58th Judicial DistrictCourt 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 causeNo. A- 180805 in the 58th Judicial DistrictCourt 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 causeNo. A- 180805 in the 58th Judicial DistrictCourt 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 causeNo. A- 180805 in the 58th Judicial DistrictCourt of Jefferson County Texas. Request Number 34.
  13. 13. Admit: “You” Attorney at Law were retained by Co-Defendant(s) Joyce M. Guy and Edward McCray in June of 2008 causeNo. A- 180805 in the 58th Judicial DistrictCourt 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 causeNo. A-180805 in the 58th Judicial DistrictCourt 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 Augustof 2008 causeNo. A- 180805 in the 58th Judicial DistrictCourt 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 causeNo. A- 180805 in the 58th Judicial DistrictCourt 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 causeNo. A-180805 in the 58th Judicial DistrictCourt 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 causeNo. A- 180805 in the 58th Judicial DistrictCourt of Jefferson County Texas.
  14. 14. Request Number 40. Admit: “You” Attorney at Law were retained by Co-Defendant(s) Joyce M. Guy and Edward McCray in December of 2008 causeNo. A-180805 in the 58th Judicial DistrictCourt 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 causeNo. A-180805 in the 58th Judicial DistrictCourt 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 causeNo. A-180805 in the 58th Judicial DistrictCourt 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 causeNo. A-180805 in the 58th Judicial DistrictCourt 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 causeNo. A-180805in the 58th Judicial DistrictCourt of Jefferson County Texas. Request Number 45.
  15. 15. Admit: “You” Attorney at Law were retained by Co-Defendant(s) Joyce M. Guy and Edward McCray in May of 2009 causeNo. A-180805 in the 58th Judicial DistrictCourt 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 causeNo. A-180805in the 58th Judicial DistrictCourt 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 causeNo. A-180805 in the 58th Judicial DistrictCourt 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 Augustof 2009 causeNo. A-180805in the 58th Judicial DistrictCourt 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 causeNo. A- 180805 in the 58th Judicial DistrictCourt 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 causeNo. A-180805 in the 58th Judicial DistrictCourt of Jefferson County Texas.
  16. 16. Request Number 51. Admit: “You” Attorney at Law were retained by Co-Defendant(s) Joyce M. Guy and Edward McCray in May of 2008 causeNo. A-180805 in the 58th Judicial DistrictCourt of Jefferson County Texas to Keep all of Pro Se Plaintiff Discovery requestof Interrogatories, Requestof Admission, and Request for Disclosuresecretfiling away fromthe HonorableCourtrecords 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 causeNo. A-180805in the 58th Judicial DistrictCourt of Jefferson County Texas to Keep all of Pro Se Plaintiff Discovery requestof Interrogatories, Requestof Admission, and Request for Disclosuresecret filing away fromthe HonorableCourtrecords 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 causeNo. A-180805 in the 58th Judicial DistrictCourt of Jefferson County Texas to Keep all of Pro Se Plaintiff Discovery requestof Interrogatories, Requestof Admission, and Request for Disclosuresecretfiling away fromthe HonorableCourtrecords 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 Augustof 2008 causeNo. A-180805in the 58th Judicial DistrictCourt of Jefferson County Texas to Keep all of Pro Se Plaintiff Discovery requestof Interrogatories, Requestof Admission, and Request for Disclosuresecretfiling away fromthe HonorableCourtrecords and you simply not reply at all..
  17. 17. Request Number 55. Admit: “You” Attorney at Law were retained by Co-Defendant(s) Joyce M. Guy and Edward McCray in September of 2008 causeNo. A- 180805 in the 58th Judicial DistrictCourt of Jefferson County Texas to Keep all of Pro Se Plaintiff Discovery requestof Interrogatories, Requestof Admission, and Request for Disclosuresecretfiling away fromthe HonorableCourt 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 causeNo. A-180805 in the 58th Judicial DistrictCourt of Jefferson County Texas to Keep all of Pro Se Plaintiff Discovery requestof Interrogatories, Requestof Admission, and Request for Disclosuresecretfiling away fromthe HonorableCourtrecords 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 causeNo. A- 180805 in the 58th Judicial DistrictCourt of Jefferson County Texas to Keep all of Pro Se Plaintiff Discovery requestof Interrogatories, Requestof Admission, and Request for Disclosuresecretfiling away fromthe HonorableCourt 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 causeNo. A-180805 in the 58th Judicial DistrictCourt of Jefferson County Texas to Keep all of Pro Se Plaintiff Discovery requestof Interrogatories, Requestof Admission, and Request for Disclosuresecretfiling away fromthe HonorableCourtrecords and you simply not reply at all.
  18. 18. Request Number 59. Admit: “You” Attorney at Law were retained by Co-Defendant(s) Joyce M. Guy and Edward McCray in January of 2009 causeNo. A-180805 in the 58th Judicial DistrictCourt of Jefferson County Texas to Keep all of Pro Se Plaintiff Discovery requestof Interrogatories, Requestof Admission, and Request for Disclosuresecretfiling away fromthe HonorableCourtrecords 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 causeNo. A-180805 in the 58th Judicial DistrictCourt of Jefferson County Texas to Keep all of Pro Se Plaintiff Discovery requestof Interrogatories, Requestof Admission, and Request for Disclosuresecretfiling away fromthe HonorableCourtrecords 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 causeNo. A-180805 in the 58th Judicial DistrictCourt of Jefferson County Texas to Keep all of Pro Se Plaintiff Discovery requestof Interrogatories, Requestof Admission, and Request for Disclosuresecretfiling away fromthe HonorableCourtrecords 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 causeNo. A-180805in the 58th Judicial DistrictCourt of Jefferson County Texas to Keep all of Pro Se Plaintiff Discovery requestof Interrogatories, Requestof Admission, and Request for Disclosuresecretfiling away fromthe HonorableCourtrecords and you simply not reply at all.
  19. 19. Request Number 63. Admit: “You” Attorney at Law were retained by Co-Defendant(s) Joyce M. Guy and Edward McCray in May of 2009 causeNo. A-180805 in the 58th Judicial DistrictCourt of Jefferson County Texas to Keep all of Pro Se Plaintiff Discovery requestof Interrogatories, Requestof Admission, and Request for Disclosuresecretfiling away fromthe HonorableCourtrecords 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 causeNo. A-180805in the 58th Judicial DistrictCourt of Jefferson County Texas to Keep all of Pro Se Plaintiff Discovery requestof Interrogatories, Requestof Admission, and Request for Disclosuresecretfiling away fromthe HonorableCourtrecords 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 causeNo. A-180805 in the 58th Judicial DistrictCourt of Jefferson County Texas to Keep all of Pro Se Plaintiff Discovery requestof Interrogatories, Requestof Admission, and Request for Disclosuresecretfiling away fromthe HonorableCourtrecords 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 Augustof 2009 causeNo. A-180805in the 58th Judicial DistrictCourt of Jefferson County Texas to Keep all of Pro Se Plaintiff Discovery requestof Interrogatories, Requestof Admission, and Request for Disclosuresecretfiling away fromthe HonorableCourtrecords and you simply not reply at all.
  20. 20. Request Number 67. Admit: “You” Attorney at Law were retained by Co-Defendant(s) Joyce M. Guy and Edward McCray in September of 2009 causeNo. A- 180805 in the 58th Judicial DistrictCourt of Jefferson County Texas to Keep all of Pro Se Plaintiff Discovery requestof Interrogatories, Requestof Admission, and Request for Disclosuresecretfiling away fromthe HonorableCourt 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 causeNo. A-180805 in the 58th Judicial District Courtof Jefferson County Texas and did not file a “Motion for Withdrawalin April and May of 2008 Request Number 69. Admit: “You” Attorney at Law Knew you was acting “Attorney of Record in June of 2008 causeNo. A-180805 in the 58th Judicial DistrictCourt of Jefferson County Texas and did not file a “Motion for Withdrawalin June of 2008 Request Number 70. Admit: “You” Attorney at Law Knew you was acting “Attorney of Record in July of 2008 causeNo. A-180805in the 58th Judicial District Court of Jefferson County Texas and did not file a “Motion for Withdrawalin July of 2008 Request Number 71. Admit: “You” Attorney at Law Knew you was acting “Attorney of Record in Augustof 2008 causeNo. A-180805 in the 58th Judicial District
  21. 21. Court of Jefferson County Texas and did not file a “Motion for Withdrawal in Augustof 2008 Request Number 72. Admit: “You” Attorney at Law Knew you was acting “Attorney of Record in September of 2008 causeNo. A-180805 in the 58th Judicial District Courtof Jefferson County Texas and did not file a “Motion for Withdrawalin September of 2008 Request Number 73. Admit: “You” Attorney at Law Knew you was acting “Attorney of Record in October of 2008 causeNo. 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 causeNo. 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 causeNo. A-180805in the 58th Judicial District Court of Jefferson County Texas and did not file a “Motion for Withdrawal in December of 2008 Request Number 76.
  22. 22. Admit: “You” Attorney at Law Knew you was acting “Attorney of Record in January of 2009 causeNo. A-180805in 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 causeNo. 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 causeNo. 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 causeNo. A-180805 in the 58th Judicial DistrictCourt of Jefferson County Texas and did not file a “Motion for Withdrawalin April of 2009 Request Number 80. Admit: “You” Attorney at Law Knew you was acting “Attorney of Record in May of 2009 causeNo. A-180805in the 58th Judicial District Court of Jefferson County Texas and did not file a “Motion for Withdrawalin May of 2009 Request Number 81.
  23. 23. Admit: “You” Attorney at Law Knew you was acting “Attorney of Record in June of 2009 causeNo. A-180805 in the 58th Judicial DistrictCourt of Jefferson County Texas and did not file a “Motion for Withdrawalin June of 2009 Request Number 82. Admit: “You” Attorney at Law Knew you was acting “Attorney of Record in July of 2009 causeNo. A-180805in the 58th Judicial District Court of Jefferson County Texas and did not file a “Motion for Withdrawalin July of 2009 Request Number 83. Admit: “You” Attorney at Law Knew you was acting “Attorney of Record in Augustof 2009 causeNo. A-180805 in the 58th Judicial District Court of Jefferson County Texas and did not file a “Motion for Withdrawal in Augustof 2009 Request Number 84. Admit: “You” Attorney at Law Knew you was acting “Attorney of Record in September of 2009 causeNo. A-180805 in the 58th Judicial District Courtof Jefferson County Texas and did not file a “Motion for Withdrawalin September of 2009 Request Number 84. Admit: “You” Attorney at Law Knew you was acting “Attorney of Record in October of 2009 causeNo. 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.
  24. 24. Admit: “You” Attorney at Law Knew you was acting “Attorney of Record in November of 2009 causeNo. 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) JoyceM. Guy and Edward McCray herein on November 13th 2009 @ 10:22 AMin 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 causeNo. A-180805in the 58th Judicial District Court of Jefferson County Texas and did not file a “Motion for Withdrawal throughoutthe dates of March of 2007 as Attorney of record for the behalf of the Co-Defendant(s) JoyceM. 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 beforea hearing at the 58th Judicial District Courtof Jefferson County Texas on September 11th , 2009 beforetheHonorable Bob Worthamand your Clients Co-Defendant(s) Joyce. M. Guy and Edward McCray herein Were through “You” wereorder to respond to Pro Se Plaintiff Discovery requestof Interrogatories, Requestof Admission, and Request for Disclosure“You” held in your possession, custodyand legal control since dates of April 2nd 2008 and April11, 2008, that“You” refused to respond to throughoutthe dates of September 11th , 2009 atthis hearing before the HonorableBob 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 beforea hearing at the 58th Judicial District Courtof
  25. 25. Jefferson County Texas on August28th , 2009 beforetheHonorable Bob Worthamand 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 AgainstCo-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 beforea hearing at the 58th Judicial District Courtof Jefferson County Texas on August28th , 2009 beforetheHonorable 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 whomhad 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 legalcontrol discovery requestof Interrogatories, Requestof Admission, and Request for DisclosurePro Se Plaintiff mailed to “You” on the dates of April 2nd 2008 and April11, 2008, and did not respond to any of said discovery request When “You” Attorney at Law appear before a hearing at the 58th Judicial DistrictCourt of Jefferson County Texas on August28th , 2009 before the HonorableBob Worthamand 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 whomhad power of Attorney of said “Mother” and “You” did
  26. 26. not respond to discovery requestof Interrogatories, Requestfor Admission, and Request for Disclosureon August28th , 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 legalcontrol discovery requestof Interrogatories, Requestof Admission, and Request for DisclosurePro Se Plaintiff mailed to “You” on the dates of April 2nd 2008 and April11, 2008 and that “You” refused to respond to any formal legal reply of somesorts to said discovery requestand “You” attended two Hearing before the HonorableBob Wortham 58th Judicial District Courtof Jefferson County Texas on dates of August28th , 2009 and September 11th , 2009 whilestill not responding to said discovery requestof Interrogatories, Requestof Admission, and Request for DisclosurePro Se Plaintiff mailed to “You” on the dates of April 2nd 2008 and April11, 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 atthe old mailing address 448 DeQueen blvd. in PortArthur Texas in December of 2007 and “You” having known Co-Defendant(s) lastknown address to be 5050 east7th street in PortArthur 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 DistrictCourt of Jefferson County Texas.. Request Number 93.
  27. 27. Admit: “You” Attorney at Law was retained by Co-Defendant(s) Joyce. M. Guy and Edward McCray herein cause No. A-180805 atthe old mailing address 448 DeQueen blvd. in PortArthur 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 PortArthur Texas And that is why “Your” having full knowledgeof Co-Defendant(s) Joyce. M. Guy and Edward McCray herein cause No. A-180805 and thatis why “You” are having known Co-Defendant(s) Joyce. M. Guy and Edward McCray last known address to be 5050 east7th street in PortArthur 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 atthe old mailing address 448 DeQueen blvd. in PortArthur 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 withdrawalto 5050 east7th street in Port Arthur Texas 77642 whereby your having fullknowledgeof Co-Defendant(s) last known address to be at 5050 east7th street in Port Arthur Texas 77642 thereafter the knowledgeof 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 withdrawalto 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 CourtOffice knowingly thatthe dwelling located
  28. 28. 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 withdrawalon or aboutJune 18th 2009 when Co-Defendant(s)Joyce. M. Guy and Edward McCray herein transfer property dwelling located at 448 DeQueen blvd. in PortArthur 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 causeNo. A-180805 And “You” had in your full possession, custody and legal control discovery requestof Interrogatories, Requestof Admission, and Request for DisclosurePro 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 withdrawalon 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 Departmentof 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 causeNo. A-180805
  29. 29. And “You” had in “Your” full possession, custodyand legal control discovery requestof Interrogatories, Requestof Admission, and Request for DisclosurePro 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 withdrawalon 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 thesame time frame “You” Attorney at Law was retained by Co-Defendant(s) Joyce. M. Guy and Edward McCray herein causeNo. A- 180805 And “You” had in “Your” full possession, custodyand legal control discovery request of Interrogatories, Requestfor Admission, and Request for DisclosurePro 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 responseto Pro Se Plaintiff Discovery request “You” had in your full possession, custody and legal control, said discovery requestof Interrogatories, Requestof Admission, and Request for DisclosurePro 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
  30. 30. October 14th 2009 when your responseto Discovery Requestin 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, Requestof 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 Withdrawalas Counsel fromCo- Defendant(s) herein “Joyce M. Guy and Edward McCray Civil No. A-180805 filed in The Jefferson County 58th Judicial District Courtin Jefferson County Texas. Request Number 101. Admit: Texas Rules of Civil Procedures 194.2. (Plaintiff) “Requestfor Disclosure” requiremailed 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 causeNo. A-180805 (30) days thereafter mailing of serviceupon “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 causeNo. 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.
  31. 31. M. Guy and Edward McCray herein causeNo. A-180805 (30) days thereafter mailing of service upon “You” to so reply Request Number 104. Admit: “You” Attorney at Law are partly “Responsiblefor the damages suffered by Pro Se Plaintiff herein. Request Number 105. Admit: “You” Attorney at Law are fully “Responsiblefor 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 “responseto Plaintiff’s Motion for Sanctions attached as document#1 herein Request Number 109. Admit: “You” Attorney at Law that you signed the “Motion for Withdrawalof Counsel” On November 13th , 2009 filed at 10:22 am Jefferson County Texas, CourthouseClerk of CourtOffice attached as document #2 attached herein Request Number 110. Admit: “You” Attorney at Law that “You” supplied Co-Defendant(s) “JoyceM. Guy” and Edward McCray last known addresses to be that of 5050 east7th street in PortArthur Texas 77642 in November 13th 2009 on
  32. 32. the attached document #2 herein containing “Your” signature. “Motion for Withdrawalof Counsel” On November 13th, 2009 filed at 10:22 am Jefferson County Texas, CourthouseClerk of CourtOffice Request Number 111. Admit: “You” Attorney at Law that “You did not file a “Motion for Withdrawalof Counsel” attached as document #2 herein until November 13th, 2009 filed at 10:22 amJefferson County Texas, CourthouseClerk of Court Officeand that you were legally retain as Attorney of Law Texas Bar. No. 24058299 to attended (2) courthearing before the 58th Judicial District Courtin Jefferson County Texas for the legal behalf of Co-Defendant(s) Joyce. M. Guy and Edward McCray herein cause No. A-180805on the dates of “August28th 2009 and September 11th 2009 Request Number 112. Admit: “You” Attorney at Law that “You” signed the “Responseto FirstSet 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 April11, 2008. Request Number 113. Admit: “You” Attorney at Law that “You” signed the “Responseto 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 controlon the dates of April 2nd 2008 and April11, 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
  33. 33. hearing beforethe 58th Judicial DistrictCourt 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 “August28th 2009 and September 11th 2009 But “You” was “monetary retain” to keep also all discovery request phaseof request of Interrogatories, Requestfor Admission, and Request for Disclosureyou had in your possession, custody and legal control “Absolutely Secret”, Private, and not to be a partof 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-180805filed 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 theCo-Defendant(s) Joyce. M. Guy and Edward McCray herein then “You” Attorney at Law Were monetary retain as legal counsel“once again” on August28th 2009 to attend a Court hearing same cause No. A-180805 filed in the Jefferson County Texas Courthousefor the Co-Defendant(s) Joyce. M. Guy and Edward McCray herein then “You” Attorney at Law were retained “another once” as legal counselagain on September 11th 2009 to attend another separatecourt hearing in the samecause No. A-180805 filed in the Jefferson County Texas Courthouse But “You” Attorney at Law at no time framebetween the dates of April 2nd 2008 and April11, 2008, throughoutSeptember 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, custodyand legal control, said discovery request of Interrogatories, Requestof Admission, and Request for DisclosurePro Se Plaintiff mailed to
  34. 34. “You” on the dates of April 2nd 2008 and April11th 2008 for thesame causeNo. 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 prepareand be ready to attended (2) court hearing before the 58th Judicial DistrictCourt in Jefferson County Texas for the legal behalf of Co-Defendant(s) Joyce. M. Guy and Edward McCray herein cause No. A- 180805 on thedates of “August28th 2009 and September 11th 2009 And during this sametime frame of your retain services on September 2nd of 2009 before“Your” September 11th 2009 hearing No. A- 180805 thatrequired “You” to producePro Se Plaintiff said discovery request on behalf of Co-Defendant(s) JoyceM. 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 “JoyceM. Guy” herein in violation of Health and Safety Code Chapter 142 by Co-Defendant“Joyce M. Guy” herein engaging in home health or personalassistanceservices, which includes hands-on personalcare; by representing to the public that Co-Defendant“JoyceM. Guy” herein is a provider of home health, or personalassistanceservices which includes hands-on personalcarefor “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 1st , 2009 and January 7th 2010 Request Number 117.
  35. 35. Admit: “You” Attorney at Law that “You” were fully awareduring the time frame of December 18th 2007 throughout“Your” being acting Attorney of record until November 13th 2009 your being awarePro Se Plaintiff was making “inquiry, investigation, and discovery requests into the past history of your “Clients” Co-Defendant(s) “JoyceM. Guy and Edward McCray” herein. Request Number 118. Admit: “You” Attorney at Law that “You” signed the “Responseto FirstSet 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 requestback to the Pro Se Plaintiff herein their after (60) days of said discovery requestbeing 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 requestback to the Pro Se Plaintiff herein their after (60) days of said discovery requestbeing in your full legal possession, custody,and legal control on or about the dates of April 2nd 2008 and April11, 2008. Request Number 120. Admit: “You” Attorney at Law that “You” signed the “Responseto FirstSet 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“docketNo. A-180805” being in “Your” full legal possession, custody,and legal control on or about the dates of April2nd 2008 and April 11, 2008
  36. 36. Being forward (30) to (60) days thereafter to any other Law Officeor Attorney(s) other then “Yourself” for the “Legal Behalf of the Co- Defendant(s) JoyceM. 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“docketNo. A-180805” being in “Your” full legal possession, custody,and legal control on or about the dates of April2nd 2008 and April 11, 2008 Being Forward (30) to (60) days thereafter to any other Law Officeor Attorney(s) other then “Yourself” for the “Legal Behalf of the Co- Defendant(s) JoyceM. 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 fromPro 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 controlof the Co- Defendant(s) “JoyceM. 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 fromPro Se Plaintiff “Louis Charles
  37. 37. 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 August12th 2009” for theBehalf of the Co-Defendant(s) “JoyceM. Guy and Edward McCray” herein While The Interrogatories, Requestof Admission, and Request for DisclosurePro Se Plaintiff mailed to “You” on the dates of April 2nd 2008 and April 11, 2008, in accordancewith the Texas Rules of Civil Procedures 194.2, 197, and 198, in causeNo. A-180805 “You” Attorney atLaw refused to respond and that on the date of “August12th 2009” And “You” Attorney at Law did not file any Motion for withdrawalon “August12th 2009 fromcauseNo. A-180805filed in the Jefferson County Texas Courthouse. Request Number 124. Admit: “You” Attorney at Law that “You” knew from the Co- Defendant(s) “JoyceM. Guy and Edward McCray” herein That the “Property Deed of the dwelling of 448 DeQueen Blvd. in PortArthur Texas. Pro Se Plaintiff sent“You” herein a “Motion for Production of Document(s) dated August12th 2009 for said “Property Deeds that’s being in the possession, custody and legal control of the Co- Defendant(s) “JoyceM. Guy and Edward McCray” herein During this sametime frame “Your” being acting Attorney of record causeNo. 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 Indexin attached document #7 herein Request Number 125.
  38. 38. Admit: “You” Attorney at Law that “You” refused to respond to any of Pro Se Plaintiff “Motion for Production of Document(s) dated August12th 2009” on the certificate of mailing services for the same causeNo. A- 180805 filed in the Jefferson County Texas Courthouse(30) days thereafter serviceupon “You” for the behalf of the Co-Defendant(s) “JoyceM. Guy and Edward McCray” herein and “You” did not file a Motion for withdrawalon September 9th 2009 whilebeing in the possession, custody and legal control Pro Se Plaintiff “Motion for Production of Document(s) dated August12th 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 August12th 2009” on the certificate of mailing services for the same causeNo. A- 180805 filed in the Jefferson County Texas Courthouse(30) days thereafter serviceupon “You” for the behalf of the Co-Defendant(s) “JoyceM. Guy and Edward McCray” herein And “You” however in facts was retain to attend a hearing on the date of August28th 2009 services for thesame cause No. A-180805 in the capacity as Attorney of Record some (16) days after services of “Motion for Production of Document(s) dated August12th 2009” on the certificate of mailing services being in “Your” Possession, custody, and Control Which “You” during this same “Time Frame” However were personally presentfor on the dates of August28th 2009 hearing thereafter While “You” already 100% being in full refusalto respond to any Pro Se Plaintiff herein discovery requestin “Your” full possession, custodyand legal control, discovery requestof Interrogatories, Requestof Admission, and Request for DisclosurePro Se Plaintiff mailed to “You” on the dates of April 2nd 2008 and April11, 2008 the pastyear. Request Number 127.
  39. 39. Admit: “You” Attorney at Law that “You” refused to respond to any of Pro Se Plaintiff “Motion for Production of Document(s) dated August12th 2009” on the certificate of mailing services for the same causeNo. A- 180805 filed in the Jefferson County Texas Courthouse(30) days thereafter serviceupon “You” for the behalf of the Co-Defendant(s) “JoyceM. 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 thesame causeNo. A-180805 in the capacity as Attorney of Record some(16) days after services of “Motion for Production of Document(s) dated August12th 2009” on thecertificate 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% fullrefusalto respond to any Pro Se Plaintiff herein discovery requestin “Your” full possession, custodyand legal control, discovery requestof Interrogatories, Requestof Admission, and Request for DisclosurePro Se Plaintiff mailed to “You” on the dates of April 2nd 2008 and April11, 2008 the pastyear. 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 refusalto respond to Pro Se Plaintiff “Motion for Production of Document(s) dated August12th 2009”on the certificate of mailing services for the samecause No. A-180805 filed in the Jefferson County Texas Courthouse(30) days thereafter serviceupon “You” for the behalf of the Co-Defendant(s) “JoyceM. Guy and Edward McCray” herein copies of such “Property Deeds” ”
  40. 40. For the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas being already complained of in a among other causeof action “Breach of Contract dispute” in a civil suit in common law beforethe 58th Judicial District Courtof Jefferson County Texas causeNo. A-180805. Request Number 129. Admit: “You” Attorney at Law that “You” having in “Your” full possession, custody and legalcontrol, over Pro Se Plaintiff herein “Motion to Compel” Co-Defendant(s) “JoyceM. Guy and Edward McCray” herein with mailing service date executed on September 9th 2009 samecauseNo. A-180805 While “You” already being in 100% full refusalto respond to any Pro Se Plaintiff herein discovery requestin “Your” full possession, custodyand legal control, discovery requestof Interrogatories, Requestof Admission, and Request for DisclosurePro Se Plaintiff mailed to “You” on the dates of April 2nd 2008 and April11, 2008 the pastyear 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 causeNo. A-180805 While “You” were already during this “same time frame” personally present for one said hearing on the dates of August28th 2009 hearing thereafter not filing a “Motion for withdrawal” samecause 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 August12th 2009” on the certificate of mailing services for the same causeNo. A-180805 filed in the Jefferson County Texas Courthouse(30) days thereafter serviceupon “You” for the behalf of the Co-Defendant(s) “JoyceM. Guy and Edward McCray” herein to Produceamong other things copies of Property deed for the dwelling located at 448 DeQueen Blvd. in PortArthur Texas (Lot) 1-2 blk. 172 (PortArthur Texas) same causeNo. A-180805
  41. 41. While “You” Attorney at Law refusalto file “Your” “Motion for “Your” withdrawalon or before next 58th Judicial DistrictCourt in Jefferson County Texas hearing on the dates set for September 11th 2009 samecauseNo. A- 180805. While “You” did personally appeared as acting Attorney of Record for same causeNo. A-180805 on thedates of September 11th 2009. But “Your” never replying to or responding to any such discovery request soughtby 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 serviceupon 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 serviceupon you for such a Motion for Production of Documents and “You” Attorney at law refuseto respond (30) days thereafter serviceupon you on dates of Service of mailing date August12th 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 serviceupon you for such a Motion for Production of Documents and “You” Attorney at law refuseto respond (30) days thereafter service upon you on dates of Service of mailing date August12th 2009 for said Production copies of “Property Deeds” for the dwelling located at 448
  42. 42. DeQueen Blvd. in PortArthur Texas (Lot) 1-2 blk. 172 (PortArthur Texas) same causeNo. A-180805 But “Your” in 100% refusalto File a simple Motion for “Your” withdrawalof Counselfor the behalf of the Co-Defendant(s) “JoyceM. Guy and Edward McCray” herein during the time frame dates of August12th 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”, Insuranceand PersonalInjuryattwo legal law firms locations in Jefferson County, PortArthur Texas Request Number 134. Admit: “You” Attorney at Law that “Your” reply in your responseto Pro Se Plaintiff motion for sanctions dated the 11th day of September 2009 you state of having any knowledgeof “Required Pro Se Plaintiff discovery request for admissions, interrogatories and Disclosureon or about the dates of April 2nd 2008 and April11, 2008 as described in Document# 1 attached herein. Request Number 135. Admit: “You” Attorney at Law that on Document# 1 containing your correctTexas Bar No. 24058299 Request Number 136. Admit: “You” Attorney at Law that on Document# 8 58th Judicial District Courtof Jefferson County Texas “CaseLedger” that on March 14th 2008 is the correct “actual date” your having full knowledgeof Required Pro Se Plaintiff discovery requestfor admissions, interrogatories and Disclosurefor causeNo. A-180805
  43. 43. Request Number 137. Admit: “You” Attorney at Law that “Your” reply in your responseto Pro Se Plaintiff motion for sanctions dated the 11th day of September 2009 Document # 1 herein You state of having any knowledgeof “Required Pro Se Plaintiff discovery requestfor admissions, interrogatories and Disclosureon or about the dates of April 2nd 2008 and April11, 2008 as described in Document # 1 attached herein And this is not-correctand completely a false statement made by “you” “Attorney at Law” in regards to the correct dates of “Your” having knowledgeof Pro Se Plaintiff discovery requestfor admissions, interrogatories and Disclosure And the correct date is March 14th 2008 “Your” having actual knowledgeof “Required Pro Se Plaintiff discovery requestfor admissions, interrogatories and Disclosureas described in Document # 8 herein 58th Judicial DistrictCourt of Jefferson County Texas “Case Ledger” Request Number 138. Admit: “You” Attorney at Law that is “Your” signatureon Document # 9 attached herein “Your” Affidavitin Supportof 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 requestfor admissions, interrogatories and Disclosureas described in Document# 8 herein 58th Judicial DistrictCourt of Jefferson County Texas “Case Ledger” Request Number 139. Admit: “You” Attorney at Law that “Your” Affidavitin supportof your reply to Pro Se Plaintiff “Motion for Sanctions” againstyou Document
  44. 44. #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 PortArthur Texas 77640 Request Number 140. Admit: You” Attorney at Law that “Your” Affidavit in supportof your reply to Pro Se Plaintiff “Motion for Sanctions” againstyou Document #9 herein with false statement made by “You” was Placed in the United States Mail and Publically Mailed to Co -Defendant(s) “JoyceM. Guy and Edward McCray” collectively herein CauseNo. A-180805 Request Number 141. Admit: You” Attorney at Law that “Your” Affidavit in supportof your reply to Pro Se Plaintiff “Motion for Sanctions” againstyou 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 causeNo. A-180805 Request Number 142. Admit: You” Attorney at Law that “Your” Affidavit in supportof your reply to Pro Se Plaintiff “Motion for Sanctions” againstyou 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 causeNo. A-180805 And was electronically computer filed in Document# 8 herein 58th Judicial DistrictCourt 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 PortArthur Texas 77640
  45. 45. 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) “JoyceM. Guy and Edward McCray” collectively herein CauseNo. 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 DistrictCourt of Jefferson County Texas “Case Ledger” Request Number 147. Admit: “You” Attorney at Law that “Your” Affidavitin supportof your reply to Pro Se Plaintiff “Motion for Sanctions” againstyou 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 PortArthur Texas 77640 During this sametime frame “Your” being acting Attorney of record causeNo. A-180805 filed in the Jefferson County Texas Courthousesaid “Property Deeds” for the dwelling located at 448 DeQueen Blvd. in Port
  46. 46. Arthur Texas of the Co-Defendant(s) “JoyceM. 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 Indexin 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 supportof your reply to Pro Se Plaintiff “Motion for Sanctions” againstyou Document #9 herein with false statement made by “You” was Placed in the United States Mail and Publically Mailed to Co -Defendant(s) “JoyceM. Guy and Edward McCray” collectively herein CauseNo. A-180805 During this sametime frame “Your” being acting Attorney of record causeNo. A-180805 filed in the Jefferson County Texas Courthousesaid “Property Deeds” ” for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas of the Co-Defendant(s) “JoyceM. 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 Indexin 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 supportof your reply to Pro Se Plaintiff “Motion for Sanctions” againstyou 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 causeNo. A-180805 During this sametime frame “Your” being acting Attorney of record causeNo. A-180805 filed in the Jefferson County Texas Courthousesaid “Property Deeds” ” for the dwelling located at 448 DeQueen Blvd. in Port
  47. 47. Arthur Texas of the Co-Defendant(s) “JoyceM. 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 Indexin 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 supportof your reply to Pro Se Plaintiff “Motion for Sanctions” againstyou 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 causeNo. A-180805 And was electronically computer filed in Document# 8 herein 58th Judicial DistrictCourt of Jefferson County Texas “Case Ledger” and Court Records for cause No. A-180805 During this sametime frame “Your” being acting Attorney of record causeNo. A-180805 filed in the Jefferson County Texas Courthousesaid “Property Deeds” ” for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas of the Co-Defendant(s) “JoyceM. 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 Indexin 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 PortArthur Texas 77640
  48. 48. During this sametime frame “Your” being acting Attorney of record causeNo. A-180805 filed in the Jefferson County Texas Courthousesaid “Property Deeds” ” for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas of the Co-Defendant(s) “JoyceM. 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 Indexin 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) “JoyceM. Guy and Edward McCray” collectively herein CauseNo. A-180805 During this sametime frame “Your” being acting Attorney of record causeNo. A-180805 filed in the Jefferson County Texas Courthousesaid “Property Deeds” ” for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas of the Co-Defendant(s) “JoyceM. 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 Indexin 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
  49. 49. During this sametime frame “Your” being acting Attorney of record causeNo. A-180805 filed in the Jefferson County Texas Courthousesaid “Property Deeds” ” for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas of the Co-Defendant(s) “JoyceM. 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 Indexin 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 DistrictCourt of Jefferson County Texas “Case Ledger” During this sametime frame “Your” being acting Attorney of record causeNo. A-180805 filed in the Jefferson County Texas Courthousesaid “Property Deeds” ” for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas of the Co-Defendant(s) “JoyceM. 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 Indexin 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” responsereply to Pro Se Plaintiff Motion for Sanctions againstyou Dated September 11th 2009 attached document # 10 herein
  50. 50. Request Number 156. Admit: “You” Attorney at Law that on Document# 10 herein Co- Defendant “JoyceM. Guy” herein “Sworn AffidavitStatement States among other things “being personally acquainted with the facts alleged”, Retained Defendant (You) to draft and file a general denial on Co-DefendantBehalf. Co-Defendantdid not retain (You) to represent (Co-Defendant) beyond drafting and filing a general denial on my behalf until sometime in Augustof 2009 when (You) informed me that Pro Se Plaintiff secured a hearing with regards to this lawsuit (A-180805) (You) informed (Co-Defendant) between April2nd 2008 and April 11th 2008 aboutPro Se Plaintiff discovery request Itwas (Co-Defendant) decision and not (You) not to respond to the discovery requestof Pro Se Plaintiff. Request Number 157. Admit: You having full legal “Attorney at Law” knowledgeof Required Pro Se Plaintiff discovery requestfor admissions, interrogatories and Disclosurefor causeNo. A-180805 as Co-Defendant“JoyceM. Guy” and “You” corroboratethe same facts in refusalto 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 “JoyceM. Guy” herein “Affidavit” dated September 11th 2009 for “Your” own Defense responsereply to Pro Se Plaintiff Motion for Sanctions against “You” dated September 11th 2009 attached In “Your” responseto Pro Se Plaintiff motion for sanctions dated the 11th day of September 2009 Document# 1 herein
  51. 51. You state of having any knowledgeof “Required Pro Se Plaintiff discovery requestfor admissions, interrogatories and Disclosureon or about the dates of April 2nd 2008 and April11, 2008 as described in Document # 1 attached herein having any knowledgeof “Required Pro Se Plaintiff discovery requestfor admissions, interrogatories and Disclosureon or aboutthe dates of April 2nd 2008 and April11, 2008 and as described in Document # 10 attached herein And further Admit this is not-correctand 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 knowledgeof Pro Se Plaintiff discovery request for admissions, interrogatories and Disclosure And the correct date is March 14th 2008 “Your” having actual knowledgeof “Required Pro Se Plaintiff discovery requestfor admissions, interrogatories and Disclosureas described in Document # 8 herein 58th Judicial DistrictCourt of Jefferson County Texas “Case Ledger” Request Number 159. Admit: “You” Attorney at Law that “Your” Affidavitin supportof your reply to Pro Se Plaintiff “Motion for Sanctions” againstyou Document #9 herein and your responseto Pro Se Plaintiff Motion for sanctions against “You” Document# 1 herein and Co-Defendant “JoyceM. Guy” “Affidavit in supportof “You” document # 10 herein Contain false statement made by “You” and Co-Defendant“JoyceM. Guy having any knowledgeof “Required Pro Se Plaintiff discovery request for admissions, interrogatories and Disclosureon or about the dates of April 2nd 2008 and April11, 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.
  52. 52. Admit: “You” Attorney at Law that “Your” Affidavitin supportof your reply to Pro Se Plaintiff “Motion for Sanctions” againstyou Document #9 herein and your responseto Pro Se Plaintiff Motion for sanctions against “You” Document# 1 herein and Co-Defendant “JoyceM. Guy” “Affidavitin supportof “You” document # 10 herein Contain false statement made by “You” and Co-Defendant“JoyceM. Guy having any knowledgeof “Required Pro Se Plaintiff discovery request for admissions, interrogatories and Disclosureon or about the dates of April 2nd 2008 and April11, 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) “JoyceM. Guy and Edward McCray” collectively herein CauseNo. A-180805 Request Number 161. Admit: “You” Attorney at Law that “Your” Affidavitin supportof your reply to Pro Se Plaintiff “Motion for Sanctions” againstyou Document #9 herein and your responseto Pro Se Plaintiff Motion for sanctions against “You” Document# 1 herein and Co-Defendant “JoyceM. Guy” “Affidavitin supportof “You” document # 10 herein Contain false statement made by “You” and Co-Defendant“JoyceM. Guy having any knowledgeof “Required Pro Se Plaintiff discovery request for admissions, interrogatories and Disclosureon or about the dates of April 2nd 2008 and April11, 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” Affidavitin supportof your reply to Pro Se Plaintiff “Motion for Sanctions” againstyou Document #9 herein and your responseto Pro Se Plaintiff Motion for sanctions against
  53. 53. “You” Document# 1 herein and Co-Defendant “JoyceM. Guy” “Affidavit in supportof “You” document # 10 herein Contain false statement made by “You” and Co-Defendant“JoyceM. Guy having any knowledgeof “Required Pro Se Plaintiff discovery request for admissions, interrogatories and Disclosureon or about the dates of April 2nd 2008 and April11, 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 DistrictCourt” for causeNo. A-180805 And was electronically computer filed in Document# 8 herein 58th Judicial DistrictCourt 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 supportof your reply to Pro Se Plaintiff “Motion for Sanctions” againstyou Document#9 herein and your responseto Pro Se Plaintiff Motion for sanctions against “You” Document # 1 herein and Co-Defendant“JoyceM. Guy” “Affidavit in supportof “You” document # 10 herein Contain false statement made by “You” and Co-Defendant“JoyceM. Guy having any knowledgeof “Required Pro Se Plaintiff discovery request for admissions, interrogatories and Disclosureon or about the dates of April 2nd 2008 and April11, 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 DistrictCourt” for causeNo. A-180805
  54. 54. And was electronically computer filed in Document# 8 herein 58th Judicial DistrictCourt of Jefferson County Texas “Case Ledger” and Court Records for cause No. A-180805 During this sametime frame “Your” being acting Attorney of record causeNo. A-180805 filed in the Jefferson County Texas Courthousesaid “Property Deeds” for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas of the Co-Defendant(s) “JoyceM. 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 Indexin attached document #7 herein for a $76,000.00 U. S. Dollars Housing Grant. Request Number 164. Admit: You” Attorney at Law that Co- DefendantJoyce M. Guy” herein supply the following Answer to Pro Se Plaintiff Interrogatories Document # 11 attached herein pursuantto 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: FederalGrant 11. What are the terms and conditions of any contract in regards to the new home? Answer: FederalGovernmentbuilt home free of chargeDefendant must remain in home for at least 3 years. 12. What is the entire costof 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
  55. 55. 14. How is the State of Texas Involved? Answer: Not Involved 15. How is the Federal Government involved? Answer: FederalGrant 16. How much money did the Co-Defendantactually paid for the new home construction? Answer: No money paid by Co-Defendant Request Number 165. Admit: You” Attorney at Law that Co- DefendantJoyce 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 sametime 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) “JoyceM. Guy and Edward McCray herein collectively custody, controland legal possession Was Legally Transfer to the Texas Department of Housing & Community Affairs on June 18th 2009 as described by “Jefferson County Real Estate Indexin attached document #7 herein for a $76,000.00 U. S. Dollars Housing Grant. Instrument# 2009022762. Request Number 166.
  56. 56. And further Admit that Documents #11 that Co- Defendant JoyceM. 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 CourtHouse“Clerk of District Court” for cause No. A-180805 And was electronically computer filed in Document# 8 herein 58th Judicial DistrictCourt 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 JoyceM. 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 CourtHouse“Clerk of District Court” for cause No. A-180805 And was electronically computer filed in Document# 8 herein 58th Judicial DistrictCourt 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 JoyceM. 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 CourtHouse“Clerk of District Court” for cause No. A-180805
  57. 57. And was electronically computer filed in Document# 8 herein 58th Judicial DistrictCourt 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 sametime frame “Your” being acting Attorney of record causeNo. A-180805 filed in the Jefferson County Texas Courthousesaid “Property Deeds” ” for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas of the Co-Defendant(s) “JoyceM. 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 Indexin 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 “JoyceM. Guy” herein supply “Your” response to the following Answer to Pro Se Plaintiff Interrogatories Document# 11 attached herein pursuantto 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 sametime frame “Your” being acting Attorney of record causeNo. A-180805 filed in the Jefferson County Texas Courthousesaid “Property Deeds” ” for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas of the Co-Defendant(s) “JoyceM. Guy and Edward McCray herein being a Party to a $10,800.00U.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 Indexin attached document #7 herein for a $76,000.00 U. S. Dollars Housing Grant
  58. 58. Request Number 170. And further Admit that Documents #11 attached herein that Co- Defendant JoyceM. Guy” herein supply “falseand fraudulent” Answer to Pro Se Plaintiff Interrogatories atquestion # 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 againstRule 197 of the Texas Rules of Civil Procedures (30) days limitin filing a timely response to Pro Se Plaintiff herein. Being an actual year later “Your” finally forward actual“false and fraudulent” answers of Co- DefendantJoyce 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 DistrictCourt of Jefferson County Texas “Case Ledger” And Copies Request Number 171. And further Admit that Documents #11 attached herein that Co- Defendant JoyceM. Guy” herein supply “falseand fraudulent” Answer to Pro Se Plaintiff Interrogatories atquestion # 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 againstRule 197 of the Texas Rules of Civil Procedures (30) days limitin 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- DefendantJoyce M. Guy” Interrogatories at question # 14 herein attached Documents # 11 herein
  59. 59. 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 causeNo. A-180805 And this Document# 11 was electronically computer filed in Document # 8 herein 58th Judicial DistrictCourt 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 JoyceM. Guy” Interrogatories atquestion # 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 Worthamgave his approval on, placed his signatureupon said “Court Order” issued in “Your” favor on December 11th 2009 which said 58th Judicial DistrictCourt Order of Jefferson County Texas was electronically computer filed in Document # 8 herein 58th Judicial District Court of Jefferson County Texas “CaseLedger” and all CourtRecords thereof For “Your” Withdrawalas “Attorney of Record” Cause No. A-180805 as described in attached Document# 12 herein 58th Judicial DistrictCourt 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” Withdrawalas 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
  60. 60. Cause No. A-180805 as described in attached Document# 12 herein 58th Judicial DistrictCourt of Jefferson County Texas “Docket Report” With a “Court Order” on file of approvalof “Your withdrawalfromCo- Defendant(s) “JoyceM. Guy and Edward McCray” collectively fromcause No. A-180805 And as described in attached Document # 8 herein 58th Judicial District Court of Jefferson County Texas “Case Ledger” And “Your” Affidavitin supportof “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 knowledgeof “Required Pro Se Plaintiff discovery requestfor admissions, interrogatories and Disclosureon or about the dates of April 2nd 2008 and April11, 2008 Which “You” already had Placed in the United States Mail and Publically Mailed to The Jefferson County Texas CourtHouse“Clerk of DistrictCourt” for cause No. A-180805 And this documentwas electronically computer filed in Document # 8 herein 58th Judicial DistrictCourt of Jefferson County Texas “CaseLedger” and The Court Records for cause No. A-180805 During this sametime 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 PortArthur Texas of the Co-Defendant(s) “JoyceM. 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 $76,000.00U. S. Dollars Housing Grant

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