REQUESTS FOR ADMISSION, SET TWO, To: Antoine L. Freeman J. D. Attorney at Law AND HIS COUNSEL OF RECORD U.S. Cause No. 1:14-CV-592

In The UnitedStates District Court
For The EasternDivisionof Texas
Beaumont Division
Louis Charles HamiltonII
Pro Se Plaintiff
Vs. Cause No. 1:14-CV-592
Antoine L. FreemanJ. D.
Defendant
Joyce M. Guy
Edward McCray
Co-Defendant(s)
To Defendant “Antoine L. FreemanJ.D. (Attorney at Law), Pro Se Plaintiff
“Louis Charles HamiltonII” hereinpropounding party
REQUESTSFORADMISSION,SETTWO
To: Antoine L. FreemanJ. D. Attorney at Law AND HIS COUNSEL OF RECORD:
Pursuant to the provisions of Federal Rule of Civil Procedure 36, it is
hereby requestedanddemanded of Defendant
Antoine L. FreemanJ. D. (hereinafter “YOU”or “YOUR”), that YOU make
admissions of the following statements of fact whichare materially pertinent to
Plaintiff claims heretoinaccordance withRule 36,
Under which rule of procedure this request for admissions is made,
thereby answering the following facts inthe above-entitledandnumber cause,
and that such answers be sworn toand filedpromptly in the office of the
District Clerk

Where this cause is pending and a copy deliveredtothe writer within
thirty (30) days from the serving of this request uponyou.
Otherwise, eachof the matter of which an admissionis requestedand
demanded shall be deemedadmittedby you in accordance withRule 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 Chief Defendant Antoine L. FreemanJ. D. “Attorney
at Law”, was acting “Attorney of record”betweenthe exact date of December
18th
2007- June 9th
2009 whendocument #1 attachedherein was filedwiththe
JeffersonCounty Texas Clerk office
namely “Mechanic’s LIEN Contract filedon June 9th
2009 SWMJ
ConstructionInc., 525 N. Sam HoustonPkwy East, Suite 600, Houston, Texas
77060 inconnectionwith a Housing Grant in excess of $72,500.00 U.S Dollars
“Texas Department of Housing and Community affairs”Loan No. 2727 File
No. 1219-2102152 CFDA14.228 Community Development Block Grant Program
(“CDBG”) Hurricanes Katrina, Ritaand Wilma inthe Gulf of Mexico2005
Federally DeclaredDisaster Funding under Departmentof Defense
Appropriations Act, 2006 CDBG DisasterRecovery Program(Homeowner
AssistanceProgram“HAP”)
Or (Sabine Pass RestorationProgram“SPRP”) Awarding Federal Agency:
UnitedStates Department of Housing andUrban Development TDHCA Federal
AwardNumber:B-06-DG-48-0002Federal AwardYear (Year of Awardfrom HUD
to TDHCA):2006 TDHCA AwardYear:2007
For the property locatedat 448DequeenBlvd. inPort Arthur Texas 77640
which you was acting counsel for Co-Defendant(s) Joyce M. Guy and Edward
McCray in a civil suit inthe 58th
Judicial District Court of JeffersonCounty Texas

docket No. A-180805 involving abreachof a $10,800U.S. Dollars construction
contract withthe describedProSe Plaintiff herein.
Request Number 2.
Admit that you Chief Defendant Antoine L. FreemanJ. D. “Attorney at
Law”, herein was acting in the monetary retain capacity as “Attorney of record”
on the exact date of August 28th
2009 as describedindocument #2 attached
hereinJeffersonCounty Texas “Civil Docket”for A-180805 inwhich
Pro Se Plaintiff fileda (TRO) for the full legal protectionof the Co-
Defendant “Joyce M. Guy”, “Mother”
Namely NormaM. Guy and the property locatedat 5050east 7th
Street in
Port Arthur Texas Lot Number (10) in Block Number (4) of Lakeview addition, to
the City of Port Arthur, JeffersonCounty, Texas
As Pro Se Plaintiff filedlegal document and made claims before the
Honorable Jude” Bob Wortham” of the 58 Judicial District Court of Jefferson
County Texas for primary allegations of monetary fraud and scheme advantages
during “Hurricane “Rita”, “Ike” and “Humberto”
Scheme of things relatedtoConstructionstormdamages, derive thereof
in connection, withCo-Defendant “Joyce M. Guy” and the Pro Se Plaintiff herein
and the property at 5050 east 7th
street Repair for Hurricane StormRoofing
damages.
Request Number 3.
Law”, herein was (Not) monetary retain“Attorney of record”on the exact date
of August 28th
2009 as describedindocument #2 attachedhereinJefferson
County Texas “Civil Docket”for A-180805 inwhich
Pro Se Plaintiff fileda (TRO) for the full legal protectionof the Co-
Namely NormaM. Guy and the property locatedat5050east 7th
Street in
Port Arthur Texas Lot Number (10) in Block Number (4) of Lakeviewaddition, to

Scheme of things relatedtoConstructionstorm damages;derive thereof
street needing Repair for Hurricane Storm
Roofing damages. Whicha Court hearing was heldon the 28th
day of August
2009
Request Number 4.
Admit that Pro Se Plaintiff Louis Charles HamiltonII herein Subpoena
Witness namely AllenGuy”, Brother toCo-Defendant “Joyce M. Guy”before the
County Texas as duly under oath saidwitness was under “direct examination”of
the Pro Se Plaintiff “Louis Charles HamiltonII”
For primary allegations andsubject matter of monetary fraud and scheme
advantages during “Hurricane “Rita”, “Ike” and “Humberto”
Scheme of things relatedto Constructionstormdamages derive thereof
Roofing damages.
Which a Court hearing was heldon the 28th
day of August 2009.
Request Number 5.
Law”, herein didin a capacity of a Attorney cross-examination said Subpoena
Witness namely AllenGuy”, Brother toCo-Defendant “Joyce M. Guy” appearing
before the Honorable Jude” BobWortham” of the 58 Judicial District Court of
JeffersonCounty Texas after duly under oath saidwitness was under “direct
examination”of the Pro Se Plaintiff “Louis Charles HamiltonII”
For primary allegations andsubject matter of monetary fraud and scheme
Scheme of things relatedto Constructionstormdamages derive thereof
Roofing damages.

Which a Court hearing was heldon the 28th
day of August 2009.
Request Number 6.
Law”, herein didphysically make the representationandpresentationof cross-
examination said Subpoena Witness namely AllenGuy”, Brother toCo-
Defendant “Joyce M. Guy” before the
Honorable Jude” Bob Wortham” of the 58 Judicial District Court of
JeffersonCounty Texas as duly under oath saidwitness …
But your were not monetary legally retainfor such legal services of a
Court hearing which was heldon the 28th
day of August 2009
As describedby you in attacheddocument #3 “Response toMotionfor
Sanctions” in whichyour claiming your retainlegal service was filing a“General
Denial”on December 18th
2007 (only) inCivil Docket No. A-180805.
Request Number 7.
Law”, herein having elicitedanagreement inwhichCo-Defendant “Joyce M.
Guy” and saidSubpoena Witness namely AllenGuy”, Brother toCo-Defendant
“Joyce M. Guy” appearing before the
Honorable Jude” Bob Wortham” of the 58 Judicial District Court of
JeffersonCounty Texas as duly under oath saidwitness …agree withCo-
Defendant “Joyce M. Guy” toout of their own financial pockets fix saidhome
roofing damages
Located at 5050 east 7th
street after the “private home owner insurance
moneys”for the interest of NormaM. Guy” home having already being
spent/squander upby Co-Defendant “Joyce M. Guy”.
Request Number 8.
Admit Chief Defendant Antoine L. FreemanJ. D. “Attorney at Law”, herein
providedcover up legal services beforethe 58th
Judicial Districtof Jefferson
County Texas for conspire in “Falsificationof “Material facts” that Co-Defendant
“Joyce M. Guy” and saidSubpoena Witness namely AllenGuy”, Brother toCo-

Defendant “Joyce M. Guy” Was toout of their own financial pockets fix said
home roofing damages
Locatedat 5050 east 7th
street after the “private home owner insurance
moneys”for the interest of NormaM. Guy” (Mother) home having already
being spent/squander upby Co-Defendant “Joyce M. Guy” thereafter your
cover up legal services before the 58th
Judicial District Court onAugust 28th
2009
hearing date Co-Defendant “Joyce M. Guy” legally transfer once againanother
property to
“Texas Department of Housing and Community affairs”Loan No. 5866 file
Federally DeclaredDisaster Funding under Department of Defense
AwardNumber:B-06-DG-48-0002Federal AwardYear
(Year of Award from HUD toTDHCA): 2006 TDHCA AwardYear:2007
To obtainon May 28th
2010 inexcess of $54,839.31 U.S. Dollars
“ConstructionGrant”for the property locatedat 5050 east 7th
street inPort
Arthur Texas
As describedhereinProSe Plaintiff attacheddocument #4 Mechanics’s
Lien, Contract Loan No. 5866, File #1219-2355082
Request Number 9.
Law”, herein was never physically present andnot monetary legally retainfor
such legal servicesof a Court hearing which was held on the 28th
day of August
2009 before the
Honorable Bob Wortham, in 58th
Judicial District Court of JeffersonCounty
Texas for the legal behalf of the Co-Defendant(s) Joyce M. Guy and Edward
McCray as describedby you inattached herein document # 3“Response to

Motionfor Sanctions”inwhich your claiming your retainlegal service was filing
a “General Denial”only on December 18th
2007 inCivil Docket No. A-180805.
Request Number 10.
Law”, herein refusal torespondtoall of the Pro Se Plaintiff discovery request
your having inyour legal, possession, custody andcontrol mailedtoyou since
the exact time date of March14th
2008 –
And such Pro Se Plaintiff discovery requestinyour legal, possession,
custody and control throughout August 28th
2009 hearing date as your in
continual refusal toreply/responsetosaiddiscovery request
And further admitting “You”were not monetary legally retainfor such
legal services of aCourt appearance at a hearing which was held on the 28th
day
of August 2009 before the
Honorable Bob Wortham, in 58th
Texas for the legal behalf of the Co-Defendant(s) Joyce M. Guy and Edward
McCray
As describedby you in attachedhereindocument # 3“Response to
Motionfor Sanctions”inwhich your claiming your retainlegal service was filing
a “General Denial”only on December 18th
2007 inCivil Docket No. A-180805and
all suchlegal services of youChief Defendant Antoine L. FreemanJ. D. “Attorney
at Law” fully retainendedthere after December 18th
2007
While you Chief Defendant Antoine L. FreemanJ. D. “Attorney at Law”,
herein admit continual refusal torespondto all of the Pro Se Plaintiff discovery
request your having in your legal, possession, custody, andcontrol being legally
mailedto you in the exact time frame of March 14th
2008
As your continual admit in same “Attorney at Law” refusal to
reply/responsetosaiddiscovery request throughout the 58th
Judicial District
Court of JeffersonCounty Texas hearing date on the 28th
day of August 2009
which you was infact present before the Honorable Court.
Request Number 11.

Law”, herein refusal torespondtoall of the Pro Se Plaintiff discovery request
your having inyour legal, possession, custody andcontrol mailedtoyou since
the exact time date of March14th
2008 –
And such Pro Se Plaintiff discovery requestinyour legal, possession,
custody and control throughout September 11th
2009 hearing date as your in
continual refusal toreply/responsetosaiddiscovery request
To provided actual “obstructionof justice” cover uplegal services before
the 58th
Judicial District of JeffersonCounty Texas “Honorable BobWortham”
for conspire in “Falsificationof all “Material facts” and Subject matter that Co-
Defendant “Joyce M. Guy” and Edward McCray”collectively onJune 9th
2009
when document #1 attachedhereinwas filedwiththe JeffersonCounty Texas
Clerk office
2009 SWMJ
For the property locatedat 448DequeenBlvd. inPort Arthur Texas
77640 whichyou was acting counsel for Co-Defendant(s) Joyce M. Guy and
Edward McCray in a civil suit in the 58th
Judicial District Court of Jefferson
County Texas docket No. A-180805 involving abreachof a

$10,800 U.S. Dollars constructioncontract withthe describedPro Se
Plaintiff herein whichyou Chief Defendant Antoine L. FreemanJ. D. “Attorney at
Law”, hereinfurtherance admitting “Your”legally having ProSe Plaintiff request
for said productionof document for “property deeds”for the For the property
locatedat 448DequeenBlvd. inPort Arthur Texas 77640
Which you Chief Defendant Antoine L. FreemanJ. D. “Attorney at Law”,
herein was acting legal counsel on behalf of for Co-Defendant(s) Joyce M. Guy
and Edward McCray inyour (3) combine continual refusal toproduce said
“property deeds”Lots NumberedOne andTwo (1&2) inBlock Number One
HundredSeventy Two (172) of City of Port Arthur inJeffersonCounty, Texas
From the exact date of March14th
2008 throughout March30th
2015
On or before an upcoming evidentiary hearing heldon March30th
at
10:00 a.m. before
“Honorable Justice”UnitedStates MagistrateJudge Zack Hawthorn at the
Jack Brooks Federal Building, Beaumont Texas
In which said “Property Deeds” still outstanding insaidproductionhaving
never beenhaving beenproduce, and filedinCivil Suit in Common Law in the
58th
Judicial District Court of JeffersonCounty Texas. Evenafter “Court Orders”
being obtain in sucha production.
Request Number 12.
Law”, herein Chief Defendant Antoine L. FreemanJ. D. “Attorney at Law”,
hereinwas acting legal counsel on behalf of for Co-Defendant(s) Joyce M. Guy
and Edward McCray inyour
(3) Combine continual refusal toproduce said “property deeds”Lots
NumberedOne and Two (1&2) in Block Number One HundredSeventy Two
(172) of City of Port Arthur inJeffersonCounty, Texas
2008 throughout November 13th
2009

Request Number 13.
Law”, herein Admit that you Chief Defendant Antoine L. FreemanJ. D. “Attorney
at Law”, herein Chief Defendant Antoine L. FreemanJ. D. “Attorney at Law”,
hereinwas acting legal counsel on behalf of for Co-Defendant(s) Joyce M. Guy
and Edward McCray inyour
(3) Combine continual refusal toproduce said “property deeds”Lots
2008 throughout February 19th
2015
9:00 am which a hearing was heldfor “Contempt of Court” of the 58th
Judicial
District Court of JeffersonCounty Texas for said productionof
“Property deeds”, among other documents being refusal inthis continual
obstructionof justice andhiding, obscuring, and failing to produce said
“property deeds”
Lots NumberedOne and Two (1&2) inBlock Number One Hundred
Seventy Two(172) of City of Port Arthur in JeffersonCounty, Texas whichis
subject matter incivil suit incommon law A-180805
Request Number 14.
that request for admissionquestion (7) and (11) above combine having a
monetary value in Connectionwith
UnitedStates Department of Housing andUrban Development TDHCA
Federal Award
Federally DeclaredDisaster Funding infurther connectiondirectly with
the “Texas Department of Housing and Community affairs” inexcess of
$127,339.31 U.S. Dollars.
Request Number 15.

after your refusal tocomply withTexas Rules of Civil Procedure for the civil legal
interest of the Co-Defendant(s) “Joyce M. Guy and Edward McCray
In which you had inyour legal, possession, custody andControl, between
the actual dates of March14th
2008 throughout October 14th
2009
Said Pro Se Plaintiff Louis Charles HamiltonII hereinDiscovery request for
“among other things”Property Deeds toLots NumberedOne andTwo (1&2) in
Block Number One HundredSeventy Two (172) of City of Port Arthur in
JeffersonCounty, Texas
And saidPro Se Plaintiff Louis Charles HamiltonII hereinDiscovery
request for among other things all constructionestimates for repairs in
relationshiptodamages causedby Hurricane Rita, Humberto, andIke
This is a continual subject matter incivil suit incommon law docket No. A-
180805 well intoMarch of 2015
That you Chief Defendant Antoine L. FreemanJ. D. “Attorney at Law”,
hereinprovidedCo-Defendant(s) “Joyce M. Guy and Edward McCray”
collectively Protectioninsuchsaid failure inthe productionof the Property
Deeds and
All constructionestimatesfor repairs inrelationshiptodamages caused
by Hurricane Rita, Humberto, andIke to the property locatedLots Numbered
One and Two (1&2) in Block Number One HundredSeventy Two (172) of City of
Port Arthur inJeffersonCounty, Texas
Admitting further that as of March30th
2015 saidCo-Defendant(s) “Joyce
M. Guy and Edward McCray”collectively herein have Not filed the actual copies
of said “Property Deeds”toLots NumberedOne andTwo (1&2) inBlock Number
One HundredSeventy Two (172) of City of Port Arthur inJeffersonCounty,
Texas,
And saidCo-Defendant(s) “Joyce M. Guy and Edward McCray”collectively
herein have not filedall constructionestimates for repairs inrelationshipto
damages causedby Hurricane Rita, Humberto, andIke

As requiredinthe files of cause No. A-180805 inthe JeffersonCounty 58th
Judicial District Court
As requiredby lawful Court Order of the 58th
Judicial District as dated the
10th
Day of May 2010 described inattacheddocument # 5 herein58th
Judicial
District Court of JeffersonCounty Texas official “Court Order”.
Request Number 16.
after your refusal tocomply with“Texas Rules of Civil Procedure”inwhich you
had in your legal, possession, custody and actual physical Control, betweenthe
actual dates of March14th
2009
Which is a continual subject matter incivil suit incommon law A-180805
in March of 2015
That you Chief Defendant Antoine L. FreemanJ. D. “Attorney at Law”,
hereinprovidedCo-Defendant(s) “Joyce M. Guy and Edward McCray”
collectively Protection, obstruction, hindrance, andhiding in suchsaid
productionof the Property Deeds
Further providedProtection, obstruction, hindrance, andhiding insuch
said all constructionestimates for repairs inrelationshiptodamages causedby
Hurricane Rita, Humberto, andIke
Admitting further that as of April 30th
2010 whenyouChief Defendant
Antoine L. FreemanJ. D. “Attorney at Law”, hereinrepresented Co-Defendant(s)

“Joyce M. Guy and Edward McCray”collectively inthe U.S. District Court for the
District of Texas, Beaumont DivisionJeffersonCounty, Texas Docket No. 1:10-
CV-005 before the Honorable U.S. Judge MarciaA. Crone and Honorable U.S.
Magistrate KeithF. Giblin
As Describedin attached document # 6 herein “Defendant’s Original
Answer inU.S. District Court No. 1:10-CV-00055being “You”& Joyce M. Guy
and Edward McCray collectively
Admitting further saidCo-Defendant(s) “Joyce M. Guy and Edward
McCray”collectively hereinstillhave Not “officially filed”saidProperty Deeds
to Lots NumberedOne and Two (1&2) in Block Number One HundredSeventy
Two (172) of City of Port Arthur in JeffersonCounty, Texas,
And have not “officially” filedall constructionestimatesfor repairs in
relationshiptodamages causedby Hurricane Rita, Humberto, andIke tothe
“property”locatedat 448 DeQueenBlvd. inPort Arthur Texas
As requiredinthe files of cause No. A-180805 inthe JeffersonCounty 58th
Judicial District Court
As requiredby lawful Court Order of the 58th
Judicial District as dated10th
Day of May 2010 inattacheddocument # 5 herein58th
Judicial District Court of
JeffersonCounty Texas official “Court Order” and no suchfiling has occurredon
April 30th
2010
After Your Chief Defendant Antoine L. FreemanJ. D. “Attorney at Law”,
herein represented Co-Defendant(s) “Joyce M. Guy and Edward McCray”
collectively inthe U.S. District Court for the District of Texas, Beaumont Division
JeffersonCounty, Texas Docket No. 1:10-CV-00055
Before the Honorable U.S. Judge MarciaA. Crone and Honorable U.S.
Magistrate KeithF. Giblin April 30th
2010 as describedinattacheddocument
Request Number 17.
betweenthe actual dates of March14th
2009

relationshiptodamages causedby Hurricane Rita, Humberto, andIke having
not beenproducedbefore the 58th
Texas in civil docket No. A-180805
Request Number 18.
2008 throughout April 30th
2010
Texas in civil docket No. A-180805.
Request Number 19.
2008 throughout March30th
2015
Texas in civil docket No. A-180805.
Request Number 20.

betweenthe actual dates of December 18th
2007 throughout April30th
2010 you
physically representedCo-Defendant(s) Joyce M. Guy and Edward McCray
collectively inJeffersonCounty Judicial District Court Docket No. A-180805
before the Honorable BobWortham
And you physically representedCo-Defendant(s) Joyce M. Guy and
Edward McCray collectively hereinagainin U.S. District Court for the District of
Texas, Beaumont DivisionJeffersonCounty, Texas U.S. Docket No. 1:10-CV-
00055 against the ProSe Plaintiff Louis Charles HamiltonII herein
And Said Pro Se Plaintiff Louis Charles HamiltonII hereinDiscovery
request for “among other things”Property Deeds toLots NumberedOne and
Two (1&2) in Block Number One Hundred Seventy Two(172) of City of Port
Arthur inJeffersonCounty, Texas
relationshiptodamages causedby Hurricane Rita, Humberto, andIke “having
not beenproduced”and filed before the
58th
Judicial District Court of JeffersonCounty Texas as of March30th
2015
Which you Chief Defendant Antoine L. FreemanJ. D. “Attorney at Law”,
hereinhad in your legal, possession, custody andControl, between the actual
dates of March14th
2009
This is a continual subject matter incivil suit incommon law A-180805 in
Marchof 2015 inJeffersonCounty Texas Judicial District.
Request Number 21.

2010 you
00055 onApril 30th
2010 against the ProSe Plaintiff Louis Charles HamiltonII
herein
Magistrate KeithF. Giblin andSaid Pro Se Plaintiff Louis Charles HamiltonII
hereinDiscovery request for “among other things” said“Property Deeds”to
Lots NumberedOne and Two (1&2) in Block Number One Hundred Seventy Two
Texas
Further admitting that Co-Defendant(s) Joyce M. Guy and Edward McCray
collectively hereintransfersaid“Property Deeds”toLots NumberedOne and
Arthur inJeffersonCounty, Texas on June 9th
2009 whendocument #1 attached
hereinwas filedwiththe JeffersonCounty Texas Clerk office
2009 SWMJ

contract withthe describedProSe Plaintiff herein betweenthe dates of
December 18th
2007 throughout
December 11th
2009 at 9:00 am hour when you set a notice of hearing for
your “Motionfor Withdrawal” as describedinPro Se Plaintiff attached
document # 7 “Notice of Hearing”withyour attorney at Law “signature”
Further admitting “you”Chief Defendant Antoine L. FreemanJ. D.
“Attorney at Law”, hereinalso your acting counsel for Co-Defendant(s) Joyce M.
Guy and Edward McCray ina civil suit inthe U.S. District Court for the District of
00055 inApril 30th
2010.
Request Number 22.
Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein
2010 you
hereinDiscovery request for “among other things”Property Deeds toLots

relationshiptodamages causedby Hurricane Rita, Humberto, andIke “having
Texas as of March30th
2015 further admitting that
Co-Defendant(s) Joyce M. Guy and Edward McCray collectively onJune
9th
2009 whendocument #1 attachedhereinwas filedwiththe Jefferson
County Texas Clerk office
2009 SWMJ
77060 inconnectionwitha Housing Grant in excess of $72,500.00 U.S Dollars
For the property locatedat 448 DeQueenBlvd. inPort Arthur Texas 77640
contract withthe describedProSe Plaintiff herein
“Attorney at Law”, hereinalso acting counsel for Co-Defendant(s) Joyce M. Guy
and Edward McCray collectively inacivil suit inthe in U.S. District Court for the

District of Texas, Beaumont DivisionJeffersonCounty, Texas U.S. Docket No.
1:10-CV-00055during the time frame of December 18th
2007 throughout the
time frame of April 30th
2010
When Co-Defendant(s) Joyce M. Guy hereinafter saidProSe Plaintiff
Louis Charles HamiltonII herein fileda(TRO) on August 12th
2009 incivil suit in
common lawdocket No. A-180805for the full legal protectionof the Co-
Street in
County Texas on August 28th
2009 before the “Honorable Court” for primary
allegations of monetary fraud and scheme advantages during “Hurricane “Rita”,
“Ike” and “Humberto”
in connection, withCo-Defendant “Joyce M. Guy” hereinandthe property at
5050 east 7th
street Repair for Hurricane StormRoofing damages,
Admitting further “you”Chief Defendant Antoine L. FreemanJ. D.
“Attorney at Law”, hereinthat saidCo-Defendant “Joyce M. Guy” hereinlegally
transfer once again another property to
“Texas Department of Housing and Community affairs”Loan No. 5866 file
street inPort

Arthur Texas as describedhereinProSe Plaintiff attacheddocument #4
Mechanic’s Lien, Contract LoanNo. 5866, File #1219-2355082
And as further describedinPro Se Plaintiff attacheddocument # 7
“Specific Power of Attorney”relating toreal Property for the behalf of Norma
Guy (the “Principal”), of 5050 7th
street JeffersonCounty, Texas
Hereby appoint “Joyce Guy” of 448 DeQueenBlvd. inJeffersonCounty
Texas as Agent, (Attorney inFact) after ProSe Plaintiff filedlegal document and
made claims before the Honorable Jude” Bob Wortham”of the 58 Judicial
District Court of JeffersonCounty Texas on August 28th
2009 before the
“Honorable Court” for primary allegations of monetary fraud and scheme
5050 east 7th
street Repair for Hurricane StormRoofing damages,
Admitting further “you”Chief Defendant Antoine L. FreemanJ. D.
“Attorney at Law”, herein that combines housing grants for having a monetary
value in Connectionwith
Federal Award
$127,339.31 U.S. Dollars.
Request Number 22.
2008 throughout April 30th
2010 you

hereinDiscovery request for “among other things”Property Deeds toLots
Texas that
Co-Defendant(s) Joyce M. Guy and Edward McCray collectively onJune
9th
2009 whendocument #1 attachedhereinwas filedwiththe Jefferson
County Texas Clerk office
2009 SWMJ
77060 inconnectionwitha Housing Grant in excess of $72,500.00 U.S Dollars
contract withthe describedProSe Plaintiff herein

and Edward McCray collectively inacivil suit inthe in U.S. District Court for the
District of Texas, Beaumont DivisionJeffersonCounty, Texas U.S. Docket No.
1:10-CV-00055during the time frame of December 18th
2007 throughout the
time frame of April 30th
2010
When Co-Defendant(s) Joyce M. Guy hereinafter saidProSe Plaintiff filed
a (TRO) on August 12th
2009 for the full legal protectionof the Co-Defendant
“Joyce M. Guy”, “Mother”
Street in
5050 east 7th
street Repair for Hurricane StormRoofing damages admitting
further saidCo-Defendant “Joyce M. Guy” hereinlegally transfer once again
another property to
“Texas Department of Housing and Community affairs” Loan No. 5866 file
street inPort

Arthur Texas as describedhereinProSe Plaintiff attacheddocument #4
Mechanic’s Lien, Contract LoanNo. 5866, File #1219-2355082
And as further describedinProSe Plaintiff attacheddocument # 7
“Specific Power of Attorney”relating toreal Property for the behalf of Norma
Guy (the “Principal”), of 5050 7th
street JeffersonCounty, Texas
Hereby appoint “Joyce Guy” of 448 DeQueenBlvd. inJeffersonCounty
Texas as Agent, (Attorney inFact) and the property locatedat5050east7th
Street
in Port Arthur Texas Lot Number (10) in Block Number (4) of Lakeviewaddition,
to the City of Port Arthur, JeffersonCounty, Texas combine housing grants
having a monetary value inConnectionwith
Federal Award
$127,339.31 U.S. Dollars
While further admitting “you”Chief Defendant Antoine L. FreemanJ. D.
and Edward McCray collectively legal behalf before the 58th
Judicial District
Court of JeffersonCounty Texas in a
Live hearing before the “Honorable Bob Wortham”on hearing dates of
August 28th
, 2009 and before the “Honorable BobWortham” hearing on dates of
September 11th
, 2009 whichyou
Chief Defendant Antoine L. FreemanJ. D. “Attorney at Law” herein
providedphysical “Oral Arguments”before the “Honorable Court”against said
Pro Se Plaintiff Louis Charles HamiltonII herein while “your”still claiming
Chief Defendant Antoine L. FreemanJ. D. “Attorney at Law” hereinthat
you was never being inthe physical capacity as the acting “attorney of record”
for the Co-Defendant(s) “Joyce M. Guy and Edward McCray”herein legal behalf
betweenthe time frame of December 19th
2007 throughout September 11th
2009 incivil suit incommon law docket No. A-180805
As describedinProSe attachedDocument # 3 herein“Your”response to
Motionfor sanctions against you“Chief Defendant Antoine L. FreemanJ. D.
“Attorney at Law”, herein datedSeptember 11th
2009.

Request Number 23.
betweenthe actual dates of November 13th
2009 10:22 amhour you physically
filed“Motionfor Withdrawal of Counsel”namely ProSe Plaintiff “Louis Charles
HamiltonII” attachedDocument # 8 as statedby “you”
Chief Defendant”herein inparagraph IV: A copy of this motionbearing
the enclosednotice has beendeliveredtothe last knownaddresses of
Defendants. Joyce Guy 5050 7th
street Port Arthur. Texas 77642, andEdward
McCray 5050 7th
street Port Arthur, Texas 77642
While you furtherance Admitting Chief Defendant Antoine L. FreemanJ.
D. “Attorney at Law”, herein betweenthe actual dates of December 18th
2007
throughout at some point date of November 13th
2009 10:22 amhour
Co-Defendant(s) “Joyce M. Guy and Edward McCray” was in fact living on
(172) of City of Port Arthur inJeffersonCounty, Texas namely 448 DeQueen
Blvd. in Port Arthur Texas 77640 whichis the primary address of said Co-
Defendant(s) collectively herein whenyou
“Chief Defendant”herein was retaining for your “Attorney at law” legal
services incivil suit incommonlaw docket No. A-180805 whichthe property 448
DeQueenBlvd. inPort Arthur Texas 77640 is involvedin abreach of
ConstructionContract civil matter beforethe 58th
Judicial District Court of
JeffersonCounty, Texas.
Request Number 24.
betweenthe actual dates of November 13th
2009 10:22 amhour you physically
filed“Motionfor Withdrawal of Counsel”as statedby “you”
Chief Defendant”hereininparagraph IV: A copy of this motionbearing
McCray 5050 7th
“Your” having full legal knowledge that Lots NumberedOne and Two
(1&2) in Block Number One HundredSeventy Two (172) of City of Port Arthur in

Namely the property locatedat 448 DeQueenBlvd. inPort Arthur Texas
77640 whichis the primary “physical evidence”and“physical address”of said
Co-Defendant(s) collectively hereinwhich both“physical evidence”and
“physical home” was completely destroyedinconnectionwith namely
“Mechanic’s LIEN Contract filedonJune 9th
2009 SWMJConstructionInc.,
525 N. Sam HoustonPkwy East, Suite 600, Houston, Texas 77060inconnection
witha Housing Grant in excess of $72,500.00U.S Dollars
which you betweenthe exact time frame of December 18th
2007 throughout
actual date of November 13th
2009 10:22 amhour until you physically filed
“Motionfor Withdrawal of Counsel” was acting counsel for Co-Defendant(s)
Joyce M. Guy and Edward McCray ina civil suit inthe
58th
Judicial District Court of JeffersonCounty Texas docket No. A-180805
involving a breachof a $10,800 U.S. Dollars constructioncontract withthe
describedProSe Plaintiff herein.
Request Number 25.
2007 throughout actual date of
November 13th
2009 10:22 amhour whenyou physically filed“Motionfor

Withdrawal of Counsel” you in this saidtime frame was acting counsel for Co-
Defendant(s) Joyce M. Guy and Edward McCray in a civil suit in the
58th
describedProSe Plaintiff herein admitting furtherance’s
Said Co-Defendant(s) Joyce M. Guy and Edward McCray collectively
engagedin the destructionof physical evidence of aentire home which was
completely destroyed being on
Lots NumberedOne and Two (1&2) in Block Number One Hundred
Seventy Two(172) of City of Port Arthur in JeffersonCounty, Texas
Co-Defendant(s) collectively herein as describedinProSe Plaintiff attached
Document # 1 namely
For the property locatedat 448DequeenBlvd. inPort Arthur Texas
77640.
Request Number 26.

2007 throughout actual date of
November 13th
2009 10:22 amhour you physically filed“Motionfor Withdrawal
of Counsel” you was acting counsel for Co-Defendant(s) Joyce M. Guy and
Edward McCray legal behalf in a civil suit inthe
58th
describedProSe Plaintiff herein.
Request Number 27.
2008 – throughout actual date of
November 13th
2009 10:22 amhour Chief Defendant Antoine L. FreemanJ. D.
“Attorney at Law”, hereinrefusal torespondtoall of the ProSe Plaintiff
discovery requestyour having in your legal, possession, custody andcontrol
mailedto you since the exact time date of March14th
2008 –on behalf of said
Co-Defendant(s) “Joyce M. Guy and Edward McCray”collectively hereinwhile
“you”
Chief Defendant Antoine L. FreemanJ. D. “Attorney at Law”, herein
furtherance’s admitting said Co-Defendant(s) “Joyce M. Guy and Edward
McCray”collectively hereinengagedinthe destructionof “physical evidence”of
an entire home which was completely destroyedbeing on
Co-Defendant(s) collectively hereinandfurtherance’s admitting said
Co-Defendant(s) “Joyce M. Guy and Edward McCray”collectively herein
refusal toproduce to the Pro Se Plaintiff copies of saidproperty deeds for Lots
77640 while you’re still acting “attorney of record”betweenthe actual dates of
December 18th
2007- November13th
2009 10:22 am
With“you” Chief Defendant Antoine L. FreemanJ. D. “Attorney at Law”,
herein infull possession, custody andlegal control over of said ProSe Plaintiff

herein “request for productionof property deeds”for Lots NumberedOne and
77640 inYour”Chief Defendant Antoine L. FreemanJ. D. “Attorney at Law”,
hereinphysical custody, possessionandlegal control betweenthe actual dates
of March14th
2008 – November 13th
2009 10:22 amhour.
Request Number 28.
2007 throughout actual date of April
30th
2010 whenyou filedDefendant’s Original Answer againinU.S. District
Court for the District of Texas, Beaumont DivisionJeffersonCounty, Texas U.S.
Docket No. 1:10-CV-00055 against the ProSe Plaintiff Louis Charles HamiltonII
herein
Magistrate KeithF. Giblinyour Chief Defendant Antoine L. FreemanJ. D.
“Attorney at Law”, herein “your”having full knowledge that betweenthe actual
dates of November 13th
2009 10:22 amhour you physically filed“Motionfor
Withdrawal of Counsel”as statedby “you”
Chief Defendant”hereininparagraph IV: A copy of this motionbearing
McCray 5050 7th
“Your” having full legal knowledge that on Lots NumberedOne and Two
Co-Defendant(s) collectively hereinwhich is both“physical evidence”and

United States Department of Housing andUrban Development TDHCA Federal
to TDHCA):2006 TDHCA AwardYear:2007.
Request Number 29.
2007 throughout actual date of April
30th
2010 whenyou filedDefendant’s Original Answer againinU.S. District
Court for the District of Texas, Beaumont DivisionJeffersonCounty, Texas U.S.
Docket No. 1:10-CV-00055 against the ProSe Plaintiff Louis Charles HamiltonII
herein
Admitting Chief Defendant AntoineL. FreemanJ. D. “Attorney at Law”,
hereinrefusal torespondtoall of the Pro Se Plaintiff discovery request your
having in your legal, possession, custody andcontrol mailedtoyou since the
exact time date of March14th
2008 – on behalf of said
until you Chief Defendant Antoine L. FreemanJ. D. “Attorney at Law”, herein
respondedtoall saiddiscovery request onOctober 14th
, 2009 at whichduring
this time frame of March 14th
2008 October 14th
, 2009
“Your” having full legal knowledge that on Lots NumberedOne and Two

Co-Defendant(s) collectively hereinwhichis both“physical evidence”and
2009 SWMJConstruction Inc.,
As physically describedby youChief Defendant Antoine L. FreemanJ. D.
“Attorney at Law”, herein inPro Se Plaintiff attachedDocument # 9
Defendant(s) responseto“Interrogatories”datedOctober 14th
, 2009 said
property being under a Federal Grant namely Interrogatorieshereinpursuant to
Rule 197 of the Texas Rules of Civil Procedures at Question: 10, 11, 12, 13, 14,
15, and 16.
Request Number 30.
being in full possession, custody andlegal control over saidPro Se Plaintiff
herein“request for productionof property deeds”for Lots NumberedOne and
77640 inYour”Chief Defendant Antoine L. FreemanJ. D. “Attorney at Law”,

hereinphysical custody, possessionandlegal control betweenthe actual dates
of March14th
2008 and such“request for productionof property deeds”for Lots
77640 having not beenproducedto the Pro Se Plaintiff or the 58th
Judicial
District Court of JeffersonCounty Texas throughout actual date of April 30th
2010 whenyou filedDefendant’s Original Answer againinU.S. District Court for
the District of Texas, Beaumont DivisionJeffersonCounty, Texas U.S. Docket No.
1:10-CV-00055against the ProSe Plaintiff Louis Charles HamiltonII herein
Magistrate KeithF. GiblinNamely the property locatedat 448 DeQueenBlvd. in
Port Arthur Texas 77640 whichis the primary “physical evidence”and“physical
address”of saidCo-Defendant(s) collectively hereinwhichis both“physical
evidence”and“physical home” your furtherance’s admitting
Chief Defendant Antoine L. FreemanJ. D. “Attorney at Law”, herein the
primary “physical evidence”and “physical home on saidaddress”of saidCo-
Defendant(s) collectively hereinwas completely destroyedinconnectionwith
namely
525 N. Sam Houston Pkwy East, Suite 600, Houston, Texas 77060inconnection

As your furtherance’s admitting physically being describedby you Chief
Defendant Antoine L. FreemanJ. D. “Attorney at Law”, hereinin ProSe Plaintiff
attachedDocument # 9 Defendant(s) responseto“Interrogatories”dated
October 14th
, 2009
Stating saidproperty being under a Federal Grant namely Interrogatories
questions hereinpursuant toRule 197 of the Texas Rules of Civil Procedures at
Question:10, 11, 12, 13, 14, 15, and16.
Request Number 31.
discovery requestfor “interrogatories”herein filedas ProSe Plaintiff attached
Document # 9 Defendant(s) responseto“Interrogatories”datedOctober 14th
,
2009 in“Your” physical possessionbetweenthe actual dates of March14th
2008
throughout the Dates of October 14th
, 2009 andyour admitting furtherance
Chief Defendant Antoine L. FreemanJ. D. “Attorney at Law”, hereinin
defense after your retaincounsel of record filed Defendant’s Collective Original
Answer againin U.S. District Court for the Districtof Texas, Beaumont Division
JeffersonCounty, Texas U.S. Docket No. 1:10-CV-00055 against the ProSe
Plaintiff Louis Charles HamiltonII herein and “you” Antoine L. FreemanJ. D.
“Attorney at Law”, being Defendant (also) inU.S. District Court for the District
of Texas, Beaumont DivisionJeffersonCounty, Texas U.S. Docket No. 1:10-CV-
00055
Admitting furtherance Chief Defendant Antoine L. FreemanJ. D.
“Attorney at Law”, herein against penalty of perjury Before the Honorable U.S.
Judge MarciaA. Crone and Honorable U.S. Magistrate KeithF. Giblin
admitting whenquestion(12) was asked“what is the entire cost of the
constructionfor the newhome..? Andyou Chief Defendant Antoine L. Freeman
J. D. “Attorney at Law”, hereinand on behalf of Co-Defendant(s) collectively
supply the responded of $76,000
Admitting youare continual making the same “representationand
presentation”Beforethe Honorable U.S. Judge MarciaA. Crone and Honorable

U.S. Magistrate KeithF. Giblinof the Questionunder Federal Rules of Civil
Procedure inYour Answer toInterrogatoriesherein(now) tostill be that of the
false and fraudulent statement response of $76,000 incomparisontoProSe
Plaintiff attached official document # 1 namely
For Lots NumberedOne and Two (1&2) in Block Number One Hundred
Namely the property located at 448 DeQueenBlvd. inPort Arthur Texas
77640 whichsaidCo-Defendant(s) “Joyce M. Guy and Edward McCray”
collectively hereinengagedinthe destructionof “physical evidence”of an
entire home whichwas completely destroyedbeing on
refusal toproduce to the Pro Se Plaintiff copies of said required“property
deeds”for Lots NumberedOne and Two (1&2) in Block Number One Hundred
December 18th
2007- November13th
2009 10:22 amand continual admitting
Chief Defendant Antoine L. FreemanJ. D. “Attorney at Law”, herein saidCo-
Defendant(s) “Joyce M. Guy and Edward McCray”collectively herein

Continual betweenthe date of November 13th
2009 10:22 amthroughout
March30th
2015 refusal toproduce saidproperty deeds for Lots NumberedOne
and Two (1&2) in Block Number One HundredSeventy Two(172) of City of Port
Namely the property locatedat 448 DeQueen Blvd. inPort Arthur Texas
intocivil suit in common law files before the JeffersonCounty Texas 58th
Judicial
District Court evenafter the 58th
Judicial District Court (Order) as describedin
Pro Se Plaintiff attachedDocument # 5 hereinOrder of the 58th
Judicial District
Court Cause No. A-180805 datedMay 10th
2010
Said Co-Defendant(s) “Joyce M. Guy and Edward McCray”collectively
hereininthe productionof said “property deeds”tothe dwelling locatedat Lots
Namely the property locatedat 448 DeQueenBlvd. inPort Arthur Texas.
Request Number 32.
discovery requestfor “interrogatories”herein filedas ProSe Plaintiff attached
Document # 9 Defendant(s) responseto“Interrogatories”datedOctober 14th
,
2009 in“Your” physical possessionbetweenthe actual dates of March14th
2008
throughout the Dates of October 14th
, 2009 andyour admitting furtherance
Chief Defendant Antoine L. FreemanJ. D. “Attorney at Law”, hereinin
defense after your retaincounsel of recordfiled Defendant’s Collective Original
Answer againin
U.S. District Court for the District of Texas, Beaumont DivisionJefferson
County, Texas U.S. Docket No. 1:10-CV-00055against the ProSe Plaintiff Louis
Charles HamiltonII hereinand “you” Antoine L. FreemanJ. D. “Attorney at
Law”, being Defendant (also) in U.S. District Court for the Districtof Texas,
Beaumont DivisionJeffersonCounty, Texas U.S. Docket No. 1:10-CV-00055
Magistrate Keith F. Giblin
Admitting furtherance Chief Defendant Antoine L. FreemanJ. D.
“Attorney at Law”, hereinagainst penalty of perjury Before the Honorable U.S.

admitting whenquestion(14) was asked
“How is the state of Texas Involved..?
And you Chief Defendant Antoine L. FreemanJ. D. “Attorney at Law”,
hereinand on behalf of Co-Defendant(s) “Joyce M. Guy and Edward McCray”
collectively hereincollectively supply the respondedof “Not involved
presentation”Beforethe Honorable U.S. Judge MarciaA. Crone and Honorable
U.S. Magistrate KeithF. Giblinof the Questionunder Federal Rules of Civil
Procedure inYour Answer toInterrogatoriesherein(now) tostill be that of the
false and fraudulent statement response of (Texas) not Involvedincomparison
to Pro Se Plaintiff attachedofficial document # 1 namely
77640 whichsaidCo-Defendant(s) “Joyce M. Guy and Edward McCray”
collectively hereinengagedinthe destructionof “physical evidence”of an
entire home whichwas completely destroyedbeing on

refusal toproduce to the Pro Se Plaintiff copies of saidrequired“property
deeds”for Lots NumberedOne and Two (1&2) in Block Number One Hundred
December 18th
2007- November13th
2009 10:22 amand continual admitting
Chief Defendant Antoine L. FreemanJ. D. “Attorney at Law”, hereinsaidCo-
Defendant(s) “Joyce M. Guy and Edward McCray”collectively herein
Continual betweenthe date of November 13th
2009 10:22 amthroughout
March30th
2015 refusal toproduce saidproperty deeds for Lots NumberedOne
and Two (1&2) in Block Number One HundredSeventy Two(172) of City of Port
intocivil suit in common law files before the JeffersonCounty Texas 58th
Judicial
District Court evenafter the 58th
Judicial District Court (Order) as describedin
Pro Se Plaintiff attachedDocument # 5 hereinOrder of the 58th
Judicial District
Court Cause No. A-180805 datedMay 10th
2010
Said Co-Defendant(s) “Joyce M. Guy and Edward McCray”collectively
hereininthe productionof said “property deeds”tothe dwelling locatedat Lots
Namely the property locatedat 448 DeQueenBlvd. inPort Arthur Texas.
Request Number 33.
said ProSe Plaintiff discovery request for “interrogatories”herein filedas ProSe
Plaintiff attached Document # 9 Defendant(s) response to“Interrogatories”
questions at number (12) and (14) are indeed“false, fictitiousandfraudulent”
statement of entry insaid Interrogators incomparisontoPro Se Plaintiff
attachedofficial document # 1 namely

77640
Request Number 34.
that you, conspire, hidden, scuttled, obstructed, conceal, keepsecrete, tuck
away, betweenthe dates of March14th
2008 throughout the Dates of October
14th
, 2009 ProSe Plaintiff attachedofficial document # 1 namely

77640 for the Behalf of the Co-Defendant(s) “Joyce M. Guy and Edward McCray”
herein.
Request Number 35.
2008 throughout the Dates of May 10th
2010 ProSe Plaintiff attachedofficial document # 1 namely
(“CDBG”) Hurricanes Katrina, Rita and Wilma inthe Gulf of Mexico2005
herein.
Request Number 36.

away, in the same “representationandpresentation”Beforethe Honorable U.S.
Hereinincontinual “defense”after your retainagainas counsel of record
in the file Defendant’s CollectiveOriginal Answer againinU.S. District Court for
1:10-CV-00055against the
Pro Se Plaintiff Louis Charles HamiltonII hereinand “you” Antoine L.
FreemanJ. D. “Attorney at Law”, being Defendant (also) inU.S. District Court for
1:10-CV-00055betweenthe dates of March14th
2008 throughout the Dates of
April 30th
2010 continual inthe same (RICO) enterprise “patternandpractices”
conspire, hidden, scuttled, obstructed, conceal, keepsecrete, tuck away, for the
continual legal behalf of the of the saidCo-Defendant(s) “Joyce M. Guy and
Edward McCray”herein now federal “subject matter”before the Honorable
U.S. Judge MarciaA. Crone and Honorable U.S. Magistrate KeithF. Giblin
Pro Se Plaintiff attachedofficial document # 1 namely
77640 for the continual legal Behalf of the said Co-Defendant(s) “Joyce M. Guy

and Edward McCray”herein April 30th
2010 andall Federal Court Proceeding
derive thereafter inthe continual conspire, hidden, scuttled, obstructed,
conceal, keepsecrete, tuck
Pro Se Plaintiff attachedofficial document #1 “Mechanic’s LIEN Contract
filedon June 9th
2009 SWMJConstructionInc., 525 N. Sam HoustonPkwy East,
Suite 600, Houston, Texas 77060 inconnectionwithaHousing Grant in excess of
$72,500.00 U.S Dollars
Request Number 37.
2008 throughout the Dates of May 10th
herein.
Request Number 38.

2008 throughout the Dates of March
30th
herein.
Request Number 39.
2008 throughout the Dates of October
14th
, 2009 ProSe Plaintiff attachedofficial document # 1 namely

hereinand “you” Chief Defendant Antoine L. FreemanJ. D. “Attorney at Law”,
hereinrefusedtofile a“Motionfor Withdrawal of Counsel”until November 13th
2009 10:22 amhour.
Request Number 40.
2008 throughout the Dates of December
11th
525 N. Sam HoustonPkwy East, Suite 600, Houston, Texas 77060in connection

hereinand “you” Chief Defendant Antoine L. FreemanJ. D. “Attorney at Law”,
hereinrefusedtofile a“Motion for Withdrawal of Counsel”until November 13th
2009 10:22 amhour.
Request Number 41.
that the saidCo-Defendant(s) “Joyce M. Guy and Edward McCray”hereinhaving
a “Mechanic’s LIEN Contract”filedon June 9th
2009 withSWMJConstruction
Inc., 525 N. Sam HoustonPkwy East, Suite 600, Houston, Texas 77060 in
connectionwitha Housing Grant inexcess of $72,500.00 U.S Dollars For Lots
77640 whichsaiddwelling, property locatedat 448 DeQueenBlvd. inPort
Arthur Texas 77640 is alsoinvolvedin a civil suit incommon law in the 58th
Judicial District Court of JeffersonCounty Texas since November 26th
2007
before said “Mechanic’s LIEN Contract”filedonJune 9th
2009 withSWMJ
ConstructionInc., was established, posted, date mark, and executedagainst said
77640.
Request Number 42.
connectionwitha Housing Grant inexcess of $72,500.00 U.S Dollars in
Connectionwith “Texas Department of Housing and Community affairs”Loan
No. 2727 File No. 1219-2102152 CFDA14.228 Community Development Block
Grant Program (“CDBG”) Hurricanes Katrina, Ritaand Wilma in the Gulf of
Mexico2005

Arthur Texas 77640 is alsoinvolvedina civil suit incommon law in the 58th
Judicial District Court of JeffersonCounty Texas since
November 26th
2007 before said “Mechanic’s LIEN Contract”filedonJune
9th
2009 withSWMJConstructionInc., was established, posted, date mark, and
executedagainst saidLots NumberedOne andTwo (1&2) in Block Number One
77640.
Request Number 43.
Connectionwith Federally DeclaredDisaster Funding under Department of
Defense Appropriations Act, 2006 CDBG Disaster Recovery Program
(Homeowner Assistance Program“HAP”)
November 26th
9th
77640.

Request Number 44.
Connectionwith
November 26th
2007 before said“Mechanic’s LIEN Contract”filedonJune
9th
77640.
Request Number 45.
Connectionwith (Sabine Pass RestorationProgram“SPRP”) Awarding Federal
Agency:UnitedStates Departmentof Housing and Urban Development TDHCA
Federal AwardNumber:B-06-DG-48-0002Federal AwardYear (Year of Award
from HUD to TDHCA):2006 TDHCA AwardYear:2007.

November 26th
9th
77640.
Request Number 46.
Pursuant to the provisions of Federal Rule of Civil Procedure 36, YOUmaking
same admissions of the following statements of fact’s inthe (year) of 2015 in
your defense of this current Complaint filedinU.S. Cause No. 1:14-CV-592 U.S.
District Court for the Districtof Texas, Beaumont DivisionJeffersonCounty,
Texas when you filedDefendant’s Original Answer againinU.S. District Court
for the District of Texas, Beaumont DivisionJeffersonCounty, Texas U.S. Docket
No. 1:10-CV-00055 against the ProSe Plaintiff Louis Charles HamiltonII herein
Magistrate KeithF. Giblinonyour behalf Chief Defendant Antoine L. FreemanJ.
D. “Attorney at Law”, hereinandthe Co-Defendant(s) “Joyce M. Guy and
Edward McCray collective legal behalf Admitting youare continual making the
same “representationandpresentation”
Magistrate KeithF. Giblin, in2010 (April) 30th
tobe exact and all defense derive
thereafter That you stating that on or about April 2nd
2008 and April 11, 2008
the continual false claims you were in possession, custody, andcontrol of Pro Se
Plaintiff Discovery request for Productionof Documents andRequest for
Disclosure inaccordance withthe
Texas Rules of Civil Procedures toCause No. A-180805ina civil suit inthe
58th
Judicial District Court of JeffersonCounty Texas and the official date your

claiming of such knowledge tobe that on or about April 2nd
2008 and April 11,
2008, tobe material factual, 100% the truthagainst Federal Penalty of perjury in
comparisonto Pro Se Plaintiff attachedDocument # 10 “The Official 58th
Judicial
District Court of JeffersonCounty Texas”, Case Ledger showing saiddiscovery of
Pro Se Plaintiff Louis Charles HamiltonII hereinDiscovery requestfor
Productionof Documents and Request for Disclosureinaccordance withthe
Texas Rules of Civil Procedures toCause No. A-180805 inacivil suit inthe
58th
Judicial District Court of JeffersonCounty Texas was in your Chief
Defendant Antoine L. FreemanJ. D. “Attorney at Law”, hereinlegal possession
Custody and Control since March14th
2008 andnot the dates of April 2nd
2008
and April 11, 2008 as you’re falsely claiming.
Request Number 47.
Texas when you filedDefendant’s Original Answer againinU.S. District Court
for the District of Texas, Beaumont DivisionJeffersonCounty, Texas U.S. Docket
No. 1:10-CV-00055 against the ProSe Plaintiff Louis Charles HamiltonII herein
Edward McCray collective legal behalf Admitting youare continual making the
same “representationandpresentation”
Magistrate KeithF. Giblin, in2010 (April) 30th
tobe exact and all defense derive
thereafter in2010 (April) 30th
after viewing
Pro Se Plaintiff attacheddocument # 10 namely Chief Defendant Antoine
L. FreemanJ. D. “Attorney at Law”, herein SubscribedandSworn “Verification”
datedthe 11th
day of September 2009tobe statements under oathtobe true
and correct the official date your claiming , in 2010 (April) 30th
tobe exact and
all defense derive thereafter 2010 (April) 30th

In U.S. Docket No. 1:10-CV-00055 against the ProSe Plaintiff Louis Charles
HamiltonII herein
Edward McCray collective legal behalf
presentation” indefense of suchknowledge tobe that on or about April 2nd
2008 and April 11, 2008, tobe material factual, 100% the truthagainst Federal
Penalty of perjury incomparison toPro Se Plaintiff attachedDocument #11
“The Official 58th
Judicial District Court of JeffersonCounty Texas”, Case
Ledger showing saiddiscovery of Pro Se Plaintiff Louis Charles HamiltonII herein
Discovery requestfor Productionof Documents, and Request for Disclosure in
accordance withthe
Texas Rules of Civil Procedures toCause No. A-180805 inacivil suit inthe
58th
Judicial District Court of JeffersonCounty Texas was in your Chief
Defendant Antoine L. FreemanJ. D. “Attorney at Law”, hereinlegal possession
Custody and Control since March14th
2008 andnot the dates of April 2nd
2008
and April 11, 2008 as you’re falsely claiming...
Request Number 48.
Texas before the
Honorable U.S. Magistrate Judge Zack Hawthorn against the Pro Se
Plaintiff Louis Charles HamiltonII herein on your behalf Chief Defendant
Antoine L. FreemanJ. D. “Attorney at Law”, hereinand the Co-Defendant(s)
“Joyce M. Guy and Edward McCray collective legal behalf Admitting youare
continual making the same “representationandpresentation” in2015 tobe
exact and all defense derive thereafter inthis currentComplaint filedinU.S.
Cause No. 1:14-CV-592that youChief Defendant Antoine L. FreemanJ. D.
“Attorney at Law”, herein

Continual stating that on or about April 2nd
2008 and April 11, 2008 the
continual false claims you were inpossession, custody, andcontrol of ProSe
Plaintiff Discovery request for Productionof Documents andRequest for
Disclosure inaccordance withthe
Texas Rules of Civil Procedures toCause No. A-180805ina civil suit inthe
58th
Judicial District Court of JeffersonCounty Texas and the official date your
claiming of such knowledge tobe that on or about April 2nd
2008 and April 11,
2008, tobe material factual, 100% the truthagainst Federal Penalty of perjury in
comparisonto Pro Se Plaintiff attachedDocument # 11
“The Official 58th
Judicial District Court of JeffersonCounty Texas”, Case
Ledger showing saiddiscovery of Pro Se Plaintiff Louis Charles HamiltonII herein
Discovery requestfor Productionof Documents and Request for Disclosurein
accordance withthe
Texas Rules of Civil Procedures 194.2, 197, and198, toCause No. A-
180805 inacivil suit in the 58th
was in your Chief Defendant Antoine L. FreemanJ. D. “Attorney at Law”, herein
legal possessionCustody andControl since March14th
2008 andnot the dates of
April 2nd
2008 and April 11, 2008 as you’re falsely claiming.
Request Number 49.
Texas before the
Honorable U.S. Magistrate Judge Zack Hawthorn against the Pro Se
Plaintiff Louis Charles HamiltonII herein on your behalf Chief Defendant
Antoine L. FreemanJ. D. “Attorney at Law”, hereindefense after the date of
December 3rd
2014 tobe exact and all defense derivethereafter inthis current
Complaint filedin U.S. Cause No. 1:14-CV-592that you
Chief Defendant Antoine L. FreemanJ. D. “Attorney at Law”, hereinafter
viewing ProSe Plaintiff attacheddocument # 10 namely Chief Defendant
Antoine L. FreemanJ. D. “Attorney at Law”, hereinSubscribedandSworn
“Verification”datedthe 11th
day of September 2009tobe statementsunder
oath to be true and correct the official date your claiming before the

REQUESTS FOR ADMISSION, SET TWO, To: Antoine L. Freeman J. D. Attorney at Law AND HIS COUNSEL OF RECORD U.S. Cause No. 1:14-CV-592

REQUESTS FOR ADMISSION, SET TWO, To: Antoine L. Freeman J. D. Attorney at Law AND HIS COUNSEL OF RECORD U.S. Cause No. 1:14-CV-592

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REQUESTS FOR ADMISSION, SET TWO, To: Antoine L. Freeman J. D. Attorney at Law AND HIS COUNSEL OF RECORD U.S. Cause No. 1:14-CV-592