In The United States District Court Defendant “Antoine L. Freeman J.D. (Attorney at Law)” Cause No. 1:14-CV-592 “First Set of Interrogatories”

In The United States District Court

For The Eastern Division of Texas

Beaumont Division

Louis Charles Hamilton II

Pro Se Plaintiff

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

Antoine L. Freeman J. D.

Defendant

Joyce M. Guy

Edward McCray

Co-Defendant(s)

To: Defendant “Antoine L. Freeman J.D. (Attorney at Law)” and His Counsel

of Record filed herein, Pro Se Plaintiff Louis Charles Hamilton II Propounded “First

Set” of Interrogatories.

Pursuant to the provisions of Federal Rule of Civil Procedure 33, it is hereby requested and demanded of Defendant “Antoine L. Freeman J.D. (Attorney at Law)” responds to this “First Set of Interrogatories” within 30 days after the service of the interrogatories.

A shorter or longer time may be directed by the court or, in the absence of such an order, agreed to in writing by the parties subject to Rule 29.

Answers and Objections.

(1) Each interrogatory shall be answered separately and fully in writing under oath, unless it is objected to, in which event the objecting party shall state the reasons for objection and shall answer to the extent the interrogatory is not objectionable.

http://www.ilnd.uscourts.gov/LEGAL/frcpweb/FRC00032.HTM

(2) The answers are to be signed by the person making them, and the objections signed by the attorney making them.

(3) The party upon whom the interrogatories have been served shall serve a copy of the answers, and objections if any, within 30 days after the service of the interrogatories.

A shorter or longer time may be directed by the court or, in the absence of such an order, agreed to in writing by the parties subject to Rule 29.

(4) All grounds for an objection to an interrogatory shall be stated with specificity.

Any ground not stated in a timely objection is waived unless the party's failure to object is excused by the court for good cause shown.

Interrogatories

(1)

Explain in full expert Attorney at Law details, and Supply in full details also any and all legal court documents, letters, faxes, text, memos, emails, in support from the date of December 18th 2007 throughout the dates of October 14th 2009 you

Defendant “Antoine L. Freeman, J.D. Texas Bar No. 24058299 herein was (Only) acting in the “legal capacitates” as a Attorney at Law to file a General Denial (Only) to reply in the Complaint made against Co-Defendant(s) Joyce M. Guy and Edward McCray( herein )

In a civil suit in the 58th Judicial District Court of Jefferson County Texas filed in Cause No. A-180805 that you were retain to for such services from said time frame of December 18th 2007 and still remaining (Acting) Attorney of record throughout the dates of October 14th 2009, up till the dates November 13th 2009 10:22 AM when you file a “Motion for Withdrawal” in cause No. A-180805

a. Explain in full detail just what was all of your legal duties as a Attorney of Law” you performed for the full behalf of the Co-Defendant(s) Joyce M. Guy and Edward McCray (herein) between the dates and time frame from December 18th 2007 when you filed your general denial and all of

http://www.ilnd.uscourts.gov/LEGAL/frcpweb/FRC00032.HTM

your legal duties you performed their after December 18th 2007 throughout the dates November 13th 2009 10:22 AM time frame when you file a “Motion for Withdrawal” in cause No. A-180805, describing all meeting, events, hearings you attended, Motions you filed, phone records and communications made thereof with Co-Defendant(s) Joyce M. Guy and Edward McCray in response to any court discovery documents Pro Se Plaintiff herein filed and mail you copies thereof.

b. Stating and explaining in full legally at what point in date and precise time in month and exact year was you legal services in the capacity of a Attorney of Law in and For The State of Texas did your fiduciary employment and responsibility to the 58th Judicial Court of Jefferson County Texas in all facts legally ended and your being legally discharged by the Co-Defendant(s) Joyce M. Guy and Edward McCray herein from acting as Attorney of record for a civil suit in the 58th Judicial District Court of Jefferson County Texas filed in Cause No. A-180805 between the dates of December 18th 2007 throughout the dates November 13th 2009

c. Provide a detail Month to Month account of each of your duties and billing hours you performed, to include your staff performed for the legal behalf of Co-Defendant(s) Joyce M. Guy and Edward McCray herein between the dates of December 18th 2007 throughout the dates November 13th 2009

And Supply in support of any and all legal court documents, letters, faxes, text, memos, emails, from the date of December 18th 2007 throughout the dates of November 13th 2009 providing proof in date and time of month and year your Attorney at Law Services ended for the Co-Defendant(s) Joyce M. Guy and Edward McCray herein.

(2)

Explain in full expert Attorney at Law details, after you filed your “General Denial” for the Co-Defendant(s) Joyce M. Guy and Edward McCray (herein) behalf to complaint Cause No. A-180805 in Jefferson County Texas

On the dates of December 18th 2007 how is it you did not filed a Motion for withdrawal immediately thereafter in December of 2007 after your service was (Only) contracted for the December 18th 2007 filing you claim was under contract

and retain for “monetary” but your still acting “Attorney of Record” throughout the dates November 13th 2009 some 1 year and 8 months later..?

(3)

Explain in full expert Attorney at Law details, after you filed your “General Denial” for the Co-Defendant(s) Joyce M. Guy and Edward McCray (herein) behalf to complaint Cause No. A-180805 in Jefferson County Texas Between the dates of December 18th 2007 what prevented you from filing a Motion for withdrawal immediately thereafter in the month of..?

a. December of 2007 b. January of 2008 c. February of 2008 d. March of 2008 e. April of 2008 f. May of 2008 g. June of 2008 h. July of 2008 i. August of 2008 j. September of 2008 k. October of 2008 l. November of 2008 m. December of 2008 n. January of 2009 o. February of 2009 p. March of 2009 q. April of 2009 r. May of 2009 s. June of 2009 t. July of 2009 u. August of 2009 v. September of 2009 w. October of 2009

(4)

Explain in full expert Attorney at Law details, after you filed your “General Denial” for the Co-Defendant(s) Joyce M. Guy and Edward McCray (herein) behalf collectively to complaint Cause No. A-180805 in Jefferson County Texas on the dates of December 18th 2007

As described by Document #1 attached herein being the official 58th Judicial District Court of Jefferson County Texas “Case Ledger” for Civil Cause No. A-180805

How is it you’re still acting live retaining “Attorney of record” …?

Until Judge Bob Wortham gave official Court approval for your motion to withdrawal from Co-Defendant(s) “Joyce M. Guy and Edward McCray collectively herein on December 11th 2009 exactly for a time frame of 1 year, 11 months and 11 days later active in civil suit in common law Docket No. A-180805 filed in Jefferson County Texas…?

(5)

Explain in full expert Attorney at Law details, after you filed your “General Denial” for the Co-Defendant(s) Joyce M. Guy and Edward McCray (herein) collectively behalf to complaint Cause No. A-180805 in Jefferson County Texas on the dates of December 18th 2007

And your claiming in Document # 2 attached herein “Your response to Pro Se Plaintiff Motion for sanction against you for violations of Rule 193.1 by failing to respond to Plaintiff’s discovery request

In your defense in attached Document # 2 herein as you claim, sworn and stated:

Defendant, Joyce Guy, retain the services of Antoine Freeman for the purpose of writing a general denial so as to avoid a default judgment being render against her.

Why..? Are you legally in the retain capacity as an acting “Attorney of record” for docket No. A-180805 while being still in full possession, custody and

legal control over Pro Se Plaintiff Discovery Request on “request for admission”, “Interrogatories”, and “Disclosure” and at the same time frame refusing to respond to any said discovery after the months of April of 2008..?

And then the same full possession, custody and legal control over Pro Se Plaintiff Discovery Request thereafter the months of;

a. May of 2008 b. June of 2008 c. July of 2008 d. August of 2008 e. September of 2008 f. October of 2008 g. November of 2008 h. December of 2008 i. January of 2009 j. February of 2009 k. March of 2009 l. April of 2009 m. May of 2009 n. June of 2009 o. July of 2009 p. August of 2009 q. September of 2009 r. October of 2009

(6)

Explain in full expert Attorney at Law details, after you filed your “General Denial” for the Co-Defendant(s) Joyce M. Guy and Edward McCray (herein) collectively behalf to complaint Cause No. A-180805 in Jefferson County Texas on the dates of December 18th 2007

And your claiming in Document # 2 attached herein “Your response to Pro Se Plaintiff Motion for sanction against you for violations of Rule 193.1 Texas Rules of Civil Procedure by failing to respond to Plaintiff’s discovery request during the months of March of 2008, April of 2008, May of 2008, June of 2008, July of 2008, August of 2008, September of 2008,

October of 2008, November of 2008, December of 2008, January of 2009, February of 2009, March of 2009, April of 2009, May of 2009, June of 2009, July of 2009, August of 2009, and September of 2009 you did not file a “timely response”



Explain Why..? Are you legally still in the “retain capacity” as an acting “Attorney of record” for docket No. A-180805 while in the time frame of being still in full possession, custody and legal control over Pro Se Plaintiff “Motion for Production of Documents dated August 12th 2009

Throughout the dates of October 12th 2009 some three months later while being still in full possession, custody and legal control, of said discovery request

With your retain “Attorney at Law” refusal to respond in a “timely fashion” to said Production for “property deeds, and production for all construction estimates for repairs caused by damages of Hurricane Rita, Humberto, and Ike to said dwelling..?

As being described in attached Document #1 attached herein being the official 58th Judicial District Court of Jefferson County Texas “Case Ledger”

Namely Pro Se Plaintiff required Production for “Property Deeds” to said dwelling for the property located at 448 DeQueen Blvd. in Port Arthur Texas. (Block 172, Lot 1-2)

And Production for all construction estimates for repairs caused by damages of Hurricane Rita, Humberto, and Ike to said dwelling described herein as being described in Pro Se Plaintiff attached Document # 3 herein

58th Judicial District “Court Order” for Production for “Property Deeds” to said dwelling for the property located at 448 DeQueen Blvd. in Port Arthur Texas. (Block 172, Lot 1-2)

And “Court Order” for Production for all construction estimates for repairs caused by damages of Hurricane Rita, Humberto, and Ike to said dwelling

(7)





Defendant, Joyce Guy, retain the services of Antoine Freeman for the purpose of writing a “general denial” so as to avoid a default judgment being render against her.

Explain Why..?

a. Are you legally still in the “retain capacity” as an acting “Attorney of record” for docket No. A-180805 and appearing in official “Attorney of Record” retain status before a “Live Court Hearing” on the date of August 28th 2009..?

When you’re being only retained for general denial filing for Co-Defendant(s) “Joyce M. Guy and Edward McCray collectively back on December 18th 2007..?

b. And Explain why..? You’re still being in retained “Attorney at Law” status before a “Live Court Hearing” on the date of September 11th 2009..?

When you’re being only retained for general denial filing for Co-Defendant(s) “Joyce M. Guy and Edward McCray collectively back on December 18th 2007..?

(8)

You” Attorney at Law Texas Bar No. 24058299 under retain services for the Co- Defendant Joyce M. Guy” and Edward McCray collectively herein which Co-Defendant “Joyce M. Guy” supply the following Answer to Pro Se Plaintiff Interrogatories in Document # 4 attached herein pursuant to Rule 197 of the Texas Rules of Civil Procedures

At Question: 10, 11, 12, 13, 14, 15, and 16. Which sworn and states as follows:

10. Where is the Funding for the New Home?

Answer: Federal Grant

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

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

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

Answer: $76,000.00 U.S. Dollars

13. How is the city of Port Arthur Involved?

Answer: Not involved

14. How is the State of Texas Involved?

Answer: Not Involved

15. How is the Federal Government involved?


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

Answer: No money paid by Co-Defendant

Then You” retain “Attorney at Law” and the Co- Defendant Joyce M. Guy” herein supply the following “false and fraudulent” Answer to Pro Se Plaintiff Interrogatories Document # 4 attached herein at question number 14



In comparison to Pro Se Plaintiff attached Document # 5 herein the “Jefferson County Real Estate Search Index” herein showing in factual details during this same time frame “Your” being acting Attorney of record cause No. A-180805 while in absolutely refusal to respond to any discovery request during the time frame of December 18th 2007 throughout September 30th 2009

The said “Property Deeds” for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas (Block 172, Lot 1-2) of the Co-Defendant(s) “Joyce M. Guy and Edward McCray herein collectively custody, control and legal possession

Was Legally Transfer to the “Texas Department of Housing & Community Affairs” on June 18th 2009 as described by “Jefferson County Real Estate Index” in attached document #5 herein

For a $76,000.00 U. S. Dollars Housing Grant. Instrument # 2009022762.

With a “Financing statement” in connection thereof Instrument # 2009022763 relating to the “Texas Department of Housing & Community Affairs”

But Your reply for the Co-Defendant(s)”Joyce M. Guy and Edward McCray collectively behalf is



15. How is the Federal Government involved?


When “Jefferson County Real Estate Search Index” in attached document #5 herein also showing at Instrument # 2013023794 a release dated July 22nd 2013 relating to the “Texas Department of Housing & Community Affairs”

And also Instrument # 2013023857 Terminations dated July 22nd 2013 relating to the “Texas Department of Housing & Community Affairs”

Which on April 22nd 2014 Co-Defendant(s) “Joyce M. Guy and Edward McCray herein collectively obtain the Property Deed for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas (Block 172, Lot 1-2)

Free and clear as described in Instrument # 2014012455 after legal transfer to the “Texas Department of Housing & Community Affairs” as fully legally described in “Jefferson County Real Estate Search Index” in attached Document #5 attached herein

Yet..? “Your acting Attorney of Record filing this reply to the Pro Se Plaintiff Interrogatories questions at 10, 11, and 12

10. Where is the Funding for the New Home?


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

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

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

Answer: $76,000.00 U.S. Dollars

Then explain why in Document # 5 attached herein

Showing legal records to factual legal documented claim in real life events and circumstances that the State of Texas had completely direct involvement, possession, custody and control over said dwelling located at 448 DeQueen Blvd. in Port Arthur Texas (Block 172, Lot 1-2)

But your retain “Attorney at Law” reply for the Co-Defendant(s)”Joyce M. Guy and Edward McCray” collectively behalf as is in interrogatories question at 14 Document # 4 attached herein



Please carefully explain in full expert Attorney at Law details, this major financial discrepancy detail involvement of a $76,000.00 U.S. Dollars Housing Grant

Between Documents # 5 the public records of “Jefferson County Real Estate search Index” showing the “State of Texas” direct involvement

And your retain “Attorney at Law” financial discrepancy detail reply for the Co-Defendant(s)”Joyce M. Guy and Edward McCray” collectively behalf as is in interrogatories question at 14..?

Being fully False fraudulent material sworn claims made against the “United States of America” involvement of a $76,000.00 U.S. Dollars Housing Grant gift for the Co-Defendant(s) ”Joyce M. Guy and Edward McCray” collectively behalf..?

For said dwelling located at 448 DeQueen Blvd. in Port Arthur Texas (Block 172, Lot 1-2)

Which was a party to a civil suit since November 26th 2007 Docket No. A-180805

(9)




And “Your” in full possession, custody and legal control over Pro Se Plaintiff Motion for Production of Documents dated August 12th 2009 and you did not file a “timely response” to the Production of said Property deeds and all records involving Hurricanes, Rita, Humberto, and Ike, contractor estimates, insurances records; and “Your in 1005 absolutely refused to file a immodestly motion for your withdrawal as claiming your (Only) duties was the filing of the General Denial as “Your” lingering on this civil action as acting “Attorney of Record for exactly December 18th 2007- December 11th 2009

Explain in full expert “Attorney at Law” details, why..? That said “Property”,

dwelling, and deeds thereof “for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas (Block 172, Lot 1-2)

Already being a physical issue of “material evidence” subject matter and

actual party thereof in a civil suit in Common law in the State of Texas

Since November 26th of 2007 for a “Breach of Construction Contract in excess of $10,800.00 U.S. Dollars while you’re still acting “Attorney of Record”

cause No A-180805

Throughout the time frame dates of December 18th 2007 throughout December 11th 2009

Legally end up in The “Texas Department of Housing & Community Affairs” being 1005 legally full possession, custody control and legal affairs surround the actual transfer on June 18th 2009

Then “deeds” release on July 22nd 2013 and then “deeds’ terminated on July 22nd 2013 said possession, custody and control of “Property Deeds, back into the possession, custody and legal control to the

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

On April 14th 2014 as described in Pro Se Plaintiff attached Document # 7 attached herein “Jefferson County Texas Property search Index” Instrument # 2014012455

When this “Property”, dwelling, and deeds thereof “already being a issue of

“material evidence” and actual party thereof in a Civil suit in Common law in the

State of Texas

Since November 26th of 2007 for a “Breach of Construction Contract in excess of $10,800.00 U.S. Dollars while you’re still acting Attorney of Record…..?

(10)




And “Your” in full possession, custody and legal control over Pro Se Plaintiff Motion for Production of Documents dated August 12th 2009 and you did not file a “timely response” to the Production of said Property deeds and all records involving Hurricanes, Rita, Humberto, and Ike,

Contractor estimates, insurances records; and “Your in 1005 absolutely refused to file a immodestly motion for your withdrawal as claiming your (Only) duties was the filing of the General Denial as “Your” lingering on this civil action as acting “Attorney of Record for exactly December 18th 2007- December 11th 2009

And said “Property”, dwelling, and deeds thereof “for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas (Block 172, Lot 1-2)

Already being a physical issue of “material evidence” subject matter and actual party thereof in a civil suit in Common law in the State of Texas

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

excess of $10,800.00 U.S. Dollars while you’re still acting “Attorney of Record” cause No A-180805

Throughout the time frame dates of December 18th 2007 throughout December 11th 2009

Legally end up in The “Texas Department of Housing & Community Affairs” being 100% legally full possession, custody, control and legal affairs thereof surround the actual transfer on June 18th 2009

Then said “deeds” release on July 22nd 2013 and then same said “deeds’ terminated on July 22nd 2013 said possession, custody and control of “Property Deeds, back into the possession, custody and legal control to the

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

collectively

On April 14th 2014 as described in Pro Se Plaintiff attached Document # 7 attached herein “Jefferson County Texas Property search Index” Instrument # 2014012455

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

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


excess of $10,800.00 U.S. Dollars involving Fraud surrounding Hurricanes “Rita, Humberto, and “Ike” as the Original Complaint A-180805,

U.S. Complaint and As being fully legally described before the

“Honorable Justice” in this U. S. Cause 1:2014-CV-592 herein now

(11)

Explain in full expert “Attorney at Law” details, Defendant “Antoine L. Freeman, J.D. Texas Bar No. 24058299 herein

Fully why that “Your” legally involved in this dishonest, deceitful quite

fraudulent bogus transfer of “property and deeds” thereof

And failing to disclosed “material facts” said “property and deeds thereof

was in the custody, possession and legal control of the “Texas Department of Housing & Community Affairs” as described in Pro Se Plaintiff attached Document

# 7 attached herein “Jefferson County Texas Property search Index” Instrument # 2014012455

While you’re still acting Attorney of Record in ongoing civil suit A-180805

58th Judicial District Court of Jefferson County Texas…..?

(12)

Further Explain in full expert “Attorney at Law” details, Defendant “Antoine L. Freeman, J.D. Texas Bar No. 24058299 herein

Fully why that “Your” being fully legally, and professional skilled “Attorney

at Law” aware of the facts that the Co-Defendant(s) “Joyce M. Guy and “Edward McCray” herein collectively being fully 100% involved, engaged in

this dishonest, deceitful quite fraudulent bogus transfer of “property and deeds”

thereof for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas (Block 172, Lot 1-2)

And “Your” failing to disclosed this “material facts” said “property and deeds thereof was in the full physical custody, possession, and legal control of the

“Texas Department of Housing & Community Affairs” for a $76,000.00 U.S. Dollars Housing Grant

As described in Pro Se Plaintiff attached Document # 7 attached herein “Jefferson County Texas Property search Index” Instrument # 2014012455

While you’re still acting Attorney of Record in this ongoing civil suit A-

180805 58th Judicial District Court of Jefferson County Texas dated November 26th 2007…..?

(13)

Explain in full expert Attorney at Law details, after you filed your “General Denial” for the Co-Defendant(s) Joyce M. Guy and Edward McCray” (herein) behalf collectively to complaint Cause No. A-180805 in Jefferson County Texas on the dates of December 18th 2007

And your claiming in Document # 2 attached herein “Your response to Pro Se Plaintiff Motion for sanction against you for violations of Rule 193.1 Texas Rules of Civil Procedure by failing to respond to Plaintiff’s discovery request during the months of

March of 2008, April of 2008, May of 2008, June of 2008, July of 2008, August of 2008, September of 2008,

October of 2008, November of 2008, December of 2008, January of 2009, February of 2009, March of 2009, April of 2009,

May of 2009, June of 2009, July of 2009, August of 2009, and September of 2009 you did not file a “timely response”

And “Your” only sworn duties as described in Document # 2 attached herein “Your” response to Pro Se Plaintiff Motion for sanction against you;

“You” stated “Your” said duties in the capacity as acting “Attorney of Record” cause No. A-180805 requires

“You” to only to file a “General Denial” on December 18th 2007..? As described in Document # 2 attached herein

Explain in full expert Attorney at Law details how is it physically possible, and “Why”..?

“Your” being legally “physically present” and present the performances thereof live “oral” arguments from your mouth, thoughts, and skills as a acting “Attorney of Record”

For the legal behalf and physical public interest of the Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein against the Pro Se Plaintiff “Louis Charles Hamilton II” herein

During an actual physical “Court Hearing” before Honorable Judge Bob Wortham of the 58th Judicial District Court of Jefferson County Texas in a civil suit in common law docket No. A-180805 date of August 28th 2009

When your “physically not official in being monetary retain” for such professional legal service in the capacity as acting “Attorney of Record” from the time frame date of December 18th 2007 to the exact date of the hearing August 28th 2009

Which “Your” stated and legally sworn to such claiming before “Judge Bob Wortham” on December 11th 2009 hearing date and as described in attached Document # 2 attached herein

“Your” response to Pro Se Plaintiff Motion for sanction against you: To avoid “actual physical sanctions” being levy against “You”

“You’re only “legal retain duties” was to simply filing a “General Denial” back in December 18th 2007..?

But “Your” providing professional skilled legal service in the capacity as acting “Attorney of Record”…? On August 28th 2009 open Court Hearing…? Why..?

Then Further Explain in full expert “Attorney at Law” details, How is it still humanly possible that the Defendant “Antoine L. Freeman, J.D. Texas Bar No. 24058299 herein

“Your” further physical in being legally in the same public position of providing continue “professional skilled legal service” in the same capacity as acting “Attorney of Record”…?

“Your” being legally “physically present” and present the performances thereof live “oral” arguments from your mouth, thoughts, and skills as a acting “Attorney of Record”

During an actual “second” physical “Court Hearing” before “Honorable Judge Bob Wortham” of the 58th Judicial District Court of Jefferson County Texas in a civil suit in common law docket No. A-180805 on September 11th 2009…?

When you’re claiming “Your only legal retain duties” was to simply filing a “General Denial” back in December 18th 2007..? Document # 2 attached herein

“Your” response to Pro Se Plaintiff Motion for sanction against you for violations of Rule 193.1 Texas Rules of Civil Procedure by failing to respond to Plaintiff’s discovery request during the months of March of 2008, April of 2008, May of 2008, June of 2008, July of 2008, August of 2008, September of 2008,

October of 2008, November of 2008, December of 2008, January of 2009, February of 2009, March of 2009, April of 2009, May of 2009, June of 2009, July of 2009, August of 2009, and September of 2009 you did not file a “timely response”.

While at the same time frame “Your” withholding out on all discovery to include the physical Production of said Property Deeds for said dwelling located at 448 DeQueen Blvd. in Port Arthur Texas (Block 172, Lot 1-2)

(A). subpart

Explaining continually completely & fully in the same patter and practices of “Your” quite professional skill “Attorney at Law” expert precise details how is it Defendant “Antoine L. Freeman, J.D. Texas Bar No. 24058299 herein in this Interrogatories question # 13 herein

“Your” still being quite further having official involvement in the legal public position of providing continue “professional skilled legal service” in the capacity as acting “Attorney of Record”…?

And actually appearing in (person) before “Honorable Judge Bob Wortham” of the 58th Judicial District Court of Jefferson County Texas once again in a civil suit in common law docket No. A-180805 on the hearing date of September 11th 2009…?

When your legal professional skilled “Attorney at Law” duties ended and expire back in December 18th 2007 after filing the said “General Denial”…” as claimed by “You”…?

While “mysteriously fraudulently” during this same “legal time frame”

Throughout the time frame dates now of December 18th 2007 of your filing a “General Denial” throughout September 11th 2009 “Your” official second “Attorney at Law” appearance for that hearing date …?

Said “Property”, dwelling, and deeds thereof “for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas (Block 172, Lot 1-2)

Already being a physical issue of “material evidence” subject matter and actual party thereof in a civil suit in Common law in the State of Texas


excess of $10,800.00 U.S. Dollars while you’re still acting in the official legal capacity as acting “Attorney of Record” for cause No A-180805

Property Deeds now physically being entertained as subject matter conflicting issue before the “Court” in a Motion for Production of Document(s) in “Your” possession since the date of August 12th 2009

Said “Property Deeds” now legally end up in the hand of the “Texas Department of Housing & Community Affairs” being 100% legally in full possession, custody, control, and legal affairs surround the actual transfer on June 18th 2009

Then “deeds” release on July 22nd 2013 and then “deeds’ terminated on July 22nd 2013 said possession, custody and control of “Property Deeds, back into the possession, custody and legal control to the

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

On April 14th 2014 as described in Pro Se Plaintiff attached Document # 7 attached herein “Jefferson County Texas Property search Index” Instrument # 2014012455.

And “Your” failing to fully disclosed this “material facts” said “property and deeds thereof was transfer in the full physical custody, possession, and legal

control of the “Texas Department of Housing & Community Affairs” for a $76,000.00 U.S. Dollars Housing Grant since June 6th 2009

As described in Pro Se Plaintiff attached Document # 7 attached herein “Jefferson County Texas Property search Index” Instrument # 2009022762

While you’re still acting Attorney of Record in this ongoing civil suit A-

180805 58th Judicial District Court of Jefferson County Texas dated November 26th 2007…..?

(14)


During the months of March of 2008, April of 2008, May of 2008, June of 2008, July of 2008, August of 2008, September of 2008,

October of 2008, November of 2008, December of 2008, January of 2009, February of 2009, March of 2009, April of 2009, May of 2009, June of 2009, July of 2009, August of 2009, and September of 2009

You did not file a “timely response” while having, custody, possession, and legal control over Pro Se Plaintiff Request for admission, interrogatories, and disclosure mail to you in accordance’s to “Texas Rules of Civil Procedure”.

Why did you in “factual real life time events and civil public circumstances” continue to hold on to all of said discovery requests Request for admission, interrogatories, and disclosure mail to you in accordance’s to

“Texas Rules of Civil Procedure” and simply return all said discovery back to sender (Pro Se Plaintiff) herein said legal documents and note saying you’re not the actual legal “Attorney of record

As “Your” claiming having knowledge of said discovery April of 2008, as described in Pro Se Plaintiff attached e Document # 2 attached herein



Explain fully Professional exactly What stop you completely from returning the said discovery request “legal documents” and all subject matter content contain therein back in the “United States Mailing system return to sender to Pro Se Plaintiff

Since “Your” not in any “shape or form” acting “Attorney of record” for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” During the time frame of December 18th 2007 throughout April of 2008,…?

And continue to fully precisely explain exactly What stop you completely from returning the said discovery request “legal documents” and all subject matter content contain therein back to Pro Se Plaintiff for each of the following exact months if you’re not acting “Attorney of Record during the months of …

a. May of 2008…? What stop you completely….? b. June of 2008…? What stop you completely….? c. July of 2008…? What stop you completely….? d. August of 2008…? What stop you completely….? e. September of 2008…? What stop you completely….? f. October of 2008…? What stop you completely….? g. November of 2008…? What stop you completely….? h. December of 2008…? What stop you completely….?

i. January of 2009…? What stop you completely….? j. February of 2009….? What stop you completely….? k. March of 2009….? What stop you completely….? l. April of 2009….? What stop you completely….? m. May of 2009….? What stop you completely….? n. June of 2009….? What stop you completely….? o. July of 2009….? What stop you completely….? p. August of 2009….? What stop you completely….? q. And September of 2009….? What stop you completely…?

As “Your” claiming having knowledge of said discovery during the month of April of 2008, as described in Pro Se Plaintiff attached Document # 2 attached herein

“Your” response to Pro Se Plaintiff Motion for sanction against you: To avoid “actual physical sanctions” being levy against “You”:


(15)


During the months of March of 2008, April of 2008, May of 2008, June of 2008, July of 2008, August of 2008, September of 2008,

October of 2008, November of 2008, December of 2008, January of 2009, February of 2009, March of 2009, April of 2009, May of 2009, June of 2009, July of 2009, August of 2009, and September of 2009

You did not file a “timely response” while having, custody, possession, and legal control over Pro Se Plaintiff Request for admission, interrogatories, and disclosure mail to you in accordance’s to “Texas Rules of Civil Procedure”.

Why did you in “factual real life time events and civil public circumstances” continue to hold on to all of said discovery requests Request for admission, interrogatories, and disclosure mail to you in accordance’s to

“Texas Rules of Civil Procedure” and simply return all said discovery back to sender (Pro Se Plaintiff) herein said legal documents and a simple note saying you’re not the actual legal “Attorney of record” for court docket No. A-180805

As “Your” claiming having knowledge of said discovery April of 2008, as described in Pro Se Plaintiff attached e Document # 2 attached herein



Explain fully Professional exactly What stop you completely from returning the said discovery request “legal documents” and all subject matter content contain therein back in the “United States Mailing system return to sender to Pro Se Plaintiff

And file “your” motion for withdrawal, and give some legal formal notice to the 58th Judicial District Court of Jefferson County Texas and the Pro Se Plaintiff herein

Since “Your” not in any “physical shape or form” acting “Attorney of record” for court docket No. A-180805 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf

During the time frame of December 18th 2007 throughout April of 2008, what stop you completely in the return of said discovery legal documents and filing notice to the court concerning your “Attorney for hire retain status” and notice of the same to the Pro se Plaintiff …?

And continue to fully precisely explain exactly What stop you completely from returning the said discovery request “legal documents” and all subject matter content contain therein back to Pro Se Plaintiff and filing notice to the court concerning your “Attorney for hire retain status” and notice of the same to the Pro se Plaintiff …? Explaining this in details for each of the following exact months if you’re not acting “Attorney of Record during the months of …

r. May of 2008…? What stop you completely….?

s. June of 2008…? What stop you completely….? t. July of 2008…? What stop you completely….? u. August of 2008…? What stop you completely….? v. September of 2008…? What stop you completely….? w. October of 2008…? What stop you completely….? x. November of 2008…? What stop you completely….? y. December of 2008…? What stop you completely….? z. January of 2009…? What stop you completely….? aa. February of 2009….? What stop you completely….? bb. March of 2009….? What stop you completely….? cc. April of 2009….? What stop you completely….? dd. May of 2009….? What stop you completely….? ee. June of 2009….? What stop you completely….? ff. July of 2009….? What stop you completely….? gg. August of 2009….? What stop you completely….? hh. And September of 2009….? What stop you completely…?

As “Your” claiming having knowledge of said discovery during the month of April of 2008, as described in Pro Se Plaintiff attached Document # 2 attached herein

“Your” response to Pro Se Plaintiff Motion for sanction against you: To avoid “actual physical sanctions” being levy against “You”:


(16)


As “Your” claiming having knowledge of said discovery during the month of April of 2008, as described in Pro Se Plaintiff attached Document # 2 attached herein with Co-Defendant “Joyce M. Guy” affidavit file in support thereof attached Document #6 herein also


As stated by “You” in attached Document #2 paragraph 2 and 3:

(2) Defendant, Joyce Guy, retain the services of Antoine Freeman for the purpose of writing a general denial as to avoid a default judgment being rendered against her.

(3) Plaintiff was informed of this fact when he visited the law office of Antoine L. Freeman on February 11th 2008

Fully explain Defendant “Antoine L. Freeman, J.D.” Texas Bar No. 24058299 herein in expert legal details…?

If “Your” really in “real life event and circumstances” completely informed Pro Se Plaintiff herein to his actual physical person at your law office no less ….?

The absolutely defined position that “Your” not in any “shape or physical form” the acting Attorney of record on or before February 11th 2008 for case No. A-180805…?

As being described by you in Document #2 herein as your claiming these additional further facts your only duties was for the December 18th 2007 legal services of filing said “General Denial” (only)…?

Why are you physically accepting Pro Se Discovery documents in the “United States Mailing system during the months of April 2008 …?

After the Pro Se Plaintiff physically visited your office on February 11 th 2008 request all of his Construction Company tools back and your actual position was a retain status of being completely

“Rude & Hostile that exact day of February 11th 2008 for your Co-Defendant(s) Joyce M. Guy and Edward McCray” legal behalf…?

Subpart (A)

While Defendant “Antoine L. Freeman, J.D.” Texas Bar No. 24058299 herein in expert legal details further explaining why was the 58th Judicial District Court of Jefferson County Texas fully official being also made aware on or before February

11th 2008 further facts of your only duties status was for the December 18 th 2007 legal services of filing said “General Denial” (only)

And “Your” filing an official “Motion for Your Withdrawal” on or before February 11th 2008 if this twisted “lie” before the “Honorable U.S. Justice”,

And notwithstanding The Pro Se Plaintiff herein is to be accepted as true..?

When elementary your actual physical “Attorney at Law” legal documented “Motion for your Withdrawal” from case No. A-180805 being not officially physically filed until November 13th 2009…?

Instead of on or long before February 11th 2008..? When Plaintiff made inquiries at your office…?

Subpart (B)

While Defendant “Antoine L. Freeman, J.D.” Texas Bar No. 24058299 herein in expert legal details further explaining why was the 58th Judicial District Court of Jefferson County Texas fully official being also made aware on or before February 11th 2008 further facts of your only “duties status” was for the December 18th 2007 legal services of filing said “General Denial” (only)

When you were “physically in all legal circumstances present before the 58th Judicial District Court of Jefferson County Texas “Live” court hearing dates of August 28th 2009

And then once again you were “physically in all legal circumstances present before the 58th Judicial District Court of Jefferson County Texas “Live” court hearing dates of September 11th 2009

But your claims in Document # 2 paragraph (3) Plaintiff was informed of this fact when he visited the law office of Antoine L. Freeman on February 11 th 2008 “That your only legal obligations was December 18th 2007 “General Denial” filing for the Co-Defendant(s) herein collectively behalf…?

Subpart (C)

While Defendant “Antoine L. Freeman, J.D.” Texas Bar No. 24058299 herein in expert legal details further explaining why are you physically still accepting Pro Se Discovery documents in the “United States Mailing system during the months of August 2009…? And not return to sender

Excepting on August 12th 2009 to be exact “Production of Document” for “among other things” namely copies of the actual “Property Deeds” for said dwelling located at 448 DeQueen Blvd. in Port Arthur Texas (Block 172, Lot 1-2) while “Your” in 100% status of being Completely refusal to turnover copies of said “Property Deeds”

All of which Being official “subject matter” before the 58th Judicial District Court of Jefferson County Texas if you’re not acting “Attorney of Record” as your claiming your duties ended long before February 11th 2008

As your stated this is the case to be of your Attorney for Hire legal services status to be to the Pro Se Plaintiff in person in your office no less…?

As physically being described in attached Document # 2 herein “Your” response to Pro Se Plaintiff Motion for sanction against you…?

To avoid “actual physical sanctions” being levy against “You”

(17)


As “Your” claiming having knowledge of said discovery during the month of April of 2008, as described in Pro Se Plaintiff attached Document # 2 attached herein with Co-Defendant “Joyce M. Guy” legal

“Affidavit” file in support thereof attached Document #6 herein also which states as follows:

“My name is Joyce Guy. I am at least 18 years of age and of sound mind. I am personally acquainted with the facts alleged herein.

“I, Joyce Guy, retained Antoine L. Freeman to draft and file a general denial on my behalf until sometime in August of 2009 when Mr. Freeman informed me that the Plaintiff secured a hearing with regards to this lawsuit.

Mr. Freeman informed me that the Plaintiff secured a hearing with regards to this lawsuit.

Mr. Freeman informed me between April 2nd 2008 and April 11th 2008 about Mr. Hamilton discovery request.

It was my decision and not Mr. Freeman’s decision not to respond to the discovery request of Mr. Hamilton

“Subscribed and Sworn on the 11th day of September 2009 (9/11)

Sabrina D Miguez Notary Public

Explain in full expert “Attorney at Law” details…? Defendant “Antoine L. Freeman, J.D. Texas Bar No. 24058299 herein

Why…? Are you still acting “Attorney of Record” after April 2nd 2008 and April 11th 2008 when Co-Defendant “Joyce M. Guy” herein informed “You” not to respond to Pro Se Plaintiff Discovery request…?

Subpart (A)

While Defendant “Antoine L. Freeman, J.D.” Texas Bar No. 24058299 herein in expert legal details further explaining…?

Why are you physically still legally in the acting “Attorney at Law” civil court position for cause No. A-180805 to not respond at all to any said discovery in your possession, custody and legal control there after the dates of April 2nd 2008 and April 11th 2008 and at the same time frame keeping all of this discovery under secret status under 100% absolutely concealment request

And the “direct orders” of the Co-Defendant “Joyce M. Guy” in violation of Rule 193.1 of the Texas Rules of Civil Procedure.

From the Time frame of April 2nd 2008 and April 11th 2008 throughout October 14th 2009 as described by attached Document # 4 herein “Defendant’s

Response to First Set of Interrogatories propounded by Plaintiff Louis Charles Hamilton II pursuant to rule 197 of the Texas Rules of Civil Procedure.

As further described by attached Document # 7 herein “Defendant’s Response to Request for Admissions of Plaintiff Louis Charles Hamilton II pursuant to rule 198 of the Texas Rules of Civil Procedure.

As further described by attached Document # 7 herein “Defendant’s Response to Request for Admissions of Plaintiff Louis Charles Hamilton II pursuant to rule 198 of the Texas Rules of Civil Procedure.

To include but not limited to Pro Se Plaintiff requested for disclosure Pursuant to Rule 194 of the Texas Rules of Civil Procedure.

With no “Motion for Your legal Withdrawal” in cause No. A-180805 thereafter being informed by Co-Defendant “Joyce M. Guy” herein she is not physically participating in such a required discovery request from the time frame period of April 2nd 2009 and April 11th 2008 throughout October 1st 2009…?

Subpart (B)

While Defendant “Antoine L. Freeman, J.D.” Texas Bar No. 24058299 herein in expert legal details further explaining…?

(Explain) Why you are physically present …? On Court hearing dates of “August” 28th 2009…?

While “Your” not respond at all to any said discovery in your full possession, custody and legal control there after the dates of April 2nd 2008 and April 11th 2008 as being fully described in Document # 6 attached herein namely Affidavit of Co-Defendant “Joyce M. Guy” Herein

And at the same “time frame” keeping all of this said discovery request of the Pro Se Plaintiff under secret status of 100% absolutely concealment request

And being the “direct orders” of the Co-Defendant “Joyce M. Guy” herein in violation of Rule 193.1 of the Texas Rules of Civil Procedure while “Your” acting Attorney of Record…?

From the Time frame of April 2nd 2008 and April 11th 2008 throughout October 14th 2009

As fully described by attached Document # 4 herein “Defendant’s Response to First Set of Interrogatories propounded by Plaintiff Louis Charles Hamilton II pursuant to rule 197 of the Texas Rules of Civil Procedure;

As further described by attached Document # 7 herein “Defendant’s Response to Request for Admissions of Plaintiff Louis Charles Hamilton II pursuant to rule 198 of the Texas Rules of Civil Procedure;

To include but not limited to Pro Se Plaintiff requested for disclosure Pursuant to Rule 194.2 of the Texas Rules of Civil Procedure.

With no “Motion for Your legal Withdrawal” in cause No. A-180805 thereafter being informed by Co-Defendant “Joyce M. Guy” herein

She is not 100% “physically participating” in such a required civil court of law discovery phase being presented throughout request time frame period of April 2nd 2008 and April 11th 2008 throughout October 1s t 2009…?

While “You’re Acting Attorney of Record”…?

Subpart (C)

And (Explain) once again why you are physically present On Court hearing dates of “September” 11th 2009…?

While “Your” not respond at all to any said discovery in your full possession, custody and legal control there after the dates of April 2nd 2008 and April 11th 2008 as being fully described in Document # 6 attached herein namely Affidavit of Co-Defendant “Joyce M. Guy” Herein

And at the same “time frame” keeping all of this said discovery request of the Pro Se Plaintiff under secret status of 100% absolutely concealment request

And being the “direct orders” of the Co-Defendant “Joyce M. Guy” herein in violation of Rule 193.1 of the Texas Rules of Civil Procedure while “Your” acting Attorney of Record…?

From the Time frame of April 2nd 2008 and April 11th 2008 throughout October 14th 2009

As fully described by attached Document # 4 herein “Defendant’s Response to First Set of Interrogatories propounded by Plaintiff Louis Charles Hamilton II pursuant to rule 197 of the Texas Rules of Civil Procedure;

As further described by attached Document # 7 herein “Defendant’s Response to Request for Admissions of Plaintiff Louis Charles Hamilton II pursuant to rule 198 of the Texas Rules of Civil Procedure;

To include but not limited to Pro Se Plaintiff requested for disclosure Pursuant to Rule 194.2 of the Texas Rules of Civil Procedure.

With no “Motion for Your legal Withdrawal” in cause No. A-180805 thereafter being informed by Co-Defendant “Joyce M. Guy” herein

She is not 100% “physically participating” in such a required civil court of law discovery phase being presented throughout request time frame period of April 2nd 2008 and April 11th 2008 throughout October 1s t 2009…?

While “You’re Acting Attorney of Record”…?

Subpart (D)

Further explaining in full expert “Attorney at Law” details, Defendant “Antoine L. Freeman, J.D. Texas Bar No. 24058299 herein how is it legally possible “Your” physically acting as “Attorney of record” …?

And “You’re” physically in all legal circumstances present before the 58th Judicial District Court of Jefferson County Texas “Live” court hearing dates of August 28th 2009 …?

And then once again you were “physically in all legal circumstances present before the 58th Judicial District Court of Jefferson County Texas “Live” court hearing dates of September 11th 2009…?

But not you’re not legally retained to be so in this legal position after December 18th 2007 …?

As fully claimed in the legal Document # 6 attached herein namely “Affidavit” of Co-Defendant “Joyce M. Guy” Herein

This states as follows:

“My name is Joyce Guy. I am at least 18 years of age and of sound mind. I am personally acquainted with the facts alleged herein.


Mr. Freeman informed me that the Plaintiff secured a hearing with regards to this lawsuit.

Mr. Freeman informed me between April 2nd 2008 and April 11th 2008 about Mr. Hamilton discovery request.

It was my decision and not Mr. Freeman’s decision not to respond to the discovery request of Mr. Hamilton

“Subscribed and Sworn on the 11th day of September 2009 (9/11)

Sabrina D Miguez Notary Public

And then “Your” officially public recorded evidences act of filing late response as fully described by attached Document # 4 herein

“Defendant’s Response to “First Set of Interrogatories” propounded by Plaintiff Louis Charles Hamilton II pursuant to rule 197 of the Texas Rules of Civil Procedure;

Dated October 14th 2009 which was in your legal custody, possession, and control since as claim by you and Co-Defendant “Joyce M. Guy” since April 2nd 2008 and April 11th 2008

And then “Your” officially public recorded evidences act of filing late response as fully further described by attached Document # 7 herein

“Defendant’s Response to “Request for Admissions” of Plaintiff Louis Charles Hamilton II pursuant to rule 198 of the Texas Rules of Civil Procedure; Dated October 14th 2009 which was in your legal custody, possession,

And physical control since as claim by you and Co-Defendant “Joyce M. Guy” since April 2nd 2008 and April 11th 2008

To include but not limited “Your” officially public recorded evidences act of filing late response to Pro Se Plaintiff “Request for disclosure” Pursuant to Rule 194.2 of the Texas Rules of Civil Procedure.

Dated October 14th 2009 which was in your legal custody, possession, and control since as claim by you and Co-Defendant “Joyce M. Guy” since April 2nd 2008 and April 11th 2008

Subpart (E)

Further expertly explaining in precise legal details Defendant “Antoine L. Freeman, J.D. Texas Bar No. 24058299 herein fully Why…? After April 2nd 2008 and April 11th 2008 when Co-Defendant “Joyce M. Guy” herein informed “You”

She is not 100% “physically participating” in such a required civil court of law discovery phase being presented by the Pro Se Plaintiff on April 2nd 2008 and April 11th 2008

As legally described in attached Document # 6 herein “Affidavit” of Co-Defendant “Joyce M. Guy”

Why…? “You” “Attorney at Law” Defendant herein did not file “Your” immediately official “Motion for your Withdrawal” …?

From cause No. A-180805 in the month of April 2008 there after April 2nd 2008 and April 11th 2008

If “Your” under retain for hire “Attorney at Law” orders/status to not “physically participating” in any such required Texas Rules of civil procedure court of law

Discovery phase being presented by the Pro Se Plaintiff Louis Charles Hamilton II herein for the time frame period of April 2nd 2008 and April 11th 2008 throughout October 1s t 2009…?

Subpart (F)

Further expertly explaining in precise legal careful details Defendant “Antoine L. Freeman, J.D.” Texas Bar No. 24058299 herein fully Why…?

Co-Defendant “Joyce M. Guy” clearly stated in Pro Se Plaintiff attached Document # 6 herein “Affidavit” of “Joyce Guy” stated as follows:


Explain why…? Are you informing your “non retain” for your legal services client(s) a/k/a Co-Defendant “Joyce M. Guy and Edward McCray” collectively herein

While all said discovery request being in your “actual physical” possession, custody and legal control thereof on or about April 2nd 2008 and April 11th 2008 as claimed by “You” and Co-Defendant(s)”Joyce M. Guy” collaborating “Affidavit” filed herein…?

However “Your” now informing Co-Defendant “Joyce M. Guy” in August of 2009 of a hearing Pro Se Plaintiff secured for September 11 th 2009 before the 58th Judicial District Court of Jefferson County Texas to advance now a official

“Motion to compel” you as acting “Attorney of Record” “Antoine L. Freeman, J.D. Texas Bar No. 24058299 for cause No. A-180805 to respond to all Discoveries of “First Set of Interrogatories” propounded by Plaintiff Louis Charles Hamilton II pursuant to rule 197 of the Texas Rules of Civil Procedure;

“Request for Admissions” of Plaintiff Louis Charles Hamilton II pursuant to rule 198 of the Texas Rules of Civil Procedure; and “Request for disclosure” Pursuant to Rule 194.2 of the Texas Rules of Civil Procedure.

When during this same time frame of April 2nd 2008 and April 11th 2008 throughout August of 2009 when Pro Se Plaintiff secured said September 11th 2009 hearing date for a Motion to compel before the

“Honorable Bob Wortham” of the 58th Judicial District Court of Jefferson County Texas for a official Motion to compel acting “Attorney of Record” Namely Skilled Chief Defendant “Antoine L. Freeman, J.D. Texas Bar No. 24058299 herein

As acting “Attorney of Record” to respond to discover request he having in his legal possession, custody and control over since back in April 2nd 2008 and April 11th 2008…?

Carefully Please Explain Legally Why…???

“You” did not file your official “Motion for withdrawal” as acting “Attorney of Record”…???

In this precise time frame of April 2nd 2008 and April 11th 2008 throughout September 11th 2009 hearing date …???

When you’re not even physically monetary retained by The Defendant(s) “Joyce M. Guy”….??? From the time frame of April 2nd 2008 and April 11th 2008 throughout September 11th 2009 hearing date …???

As also cleverly being described in Pro Se Plaintiff attached Document # 6 herein “Affidavit” of “Joyce Guy” and as also cleverly being described in Document # 2 attached herein

“Your” exact “fraudulent” response to Pro Se Plaintiff “Motion for Sanction” against you: To avoid “actual physical sanctions” being levy against “You”:

(18)

Explain in full expert “Attorney at Law” precise legal details, legal service in the capacity as acting “Attorney of Record” for Civil Suit in Common Law 58 th Judicial District Court of Jefferson County in and for the State of Texas Docket No. A-180805

Defendant “Antoine L. Freeman, J.D. Texas Bar No. 24058299 herein

As “Your” claiming in attached Document # 8 herein “Namely”; Your Motion for Withdrawal of Counsel, filed stamp dated November 13th 2009,

With “Your” attached “Certificate of Mailing Service in attached Document # 9 herein

And also with “Your” attached “Notice of Hearing” legally set for December 11th 2009 at 9:00 am hour

Before the 58th Judicial District Court of Jefferson County in and for the State of Texas

Docket No. A-180805 in attached Document # 10 herein

To discuss “among other official 58th court business things”

Your finally official filed “Motion for Withdrawal of Counsel”, filed stamp dated November 13th 2009 10:22 am hour stated as follows:

To The Honorable Judge of Said Court:

Now Comes Movant, Antoine L. Freeman J.D., Attorney for Defendants, Joyce Guy and Edward McCray, (hereinafter Defendants), and brings this Motion for withdrawal of Counsel, and in support thereof, shows the court the following:

I.

Good cause exists for withdrawal of Movant as counsel because Defendants have not complied with the terms of employment agreement with this attorney. Plaintiffs refuse to adhere to the terms of the employment agreement with this attorney.

II.

The setting and deadlines in this case are as follows: Motion for Sanction & Contempt on December 11th, 2009 @ 9:00 am (With Your Initials)

III.

This Motion is not sought for the purposes of delay.

IV.

A copy of this motion bearing the enclosed notice has been delivered to the last known addresses of the Defendants.

“Joyce Guy” 5050 7th street Port Arthur, Texas 77642

“Edward McCray” 5050 7th street Port Arthur, Texas 77642

V.

Defendants are hereby notified in writing of the right to object to this motion.

NOTICE

You are hereby notified that this motion for withdrawal of Counsel is set for hearing at the time and place set out below. You do not agree to this motion. If you wish to contest the withdrawal of Antoine L. Freeman, J.D. as your attorney, you should appear at the hearing.

If you do not oppose Antoine L. Freeman, J.D.’s withdrawal as your attorney, you may notify Antoine L. Freeman, J.D. in writing of your consent to this motion.

Wherefore, Premises Considered, Movant prays that the Court enters as order discharging Movant as attorney of record for Defendants, “Joyce Guy” and “Edward McCray”, and for such other and further relief that may be awarded at law or in equity.

Respectfully submitted, by “Antoine L. Freeman, J.D., Texas Bar No. 24058299, 3723 Gulfway Dr. Ste #104, Port Arthur, Texas 77642 (409) 293-1627, Fax (409) 983-7405

“Attorney for Defendants” Joyce Guy and Edward McCray

“First” and primary Chief Defendant “Antoine L. Freeman, J.D., Texas Bar No. 24058299 herein carefully, legally, in precise exact details explains…?

As described by you in paragraph (1) in Pro Se Plaintiff attached Document #8 attached herein stating:

“Good cause exists for withdrawal of Movant as counsel because Defendants have not complied with the terms of employment agreement with this attorney.

Plaintiffs refuse to adhere to the terms of the employment agreement with this attorney.”

Explaining in precise legal details fully how is it “physically possible” that the Pro Se Plaintiff namely (Louis Charles Hamilton II) herein being the

Plaintiffs whom refuse to adhere to the terms of the employment agreement..?

With this attorney? Namely (You)..?

When in all factual circumstances of “real life civil legal events” said Pro Se Plaintiff (Louis Charles Hamilton II) herein

Is the “complainant” bring forth the “civil action” docket No. A-180805 against the Co-Defendant “Joyce M. Guy and Edward McCray”

In an “Independent” Pro Se Plaintiff “legal” style format without “Your” retained”Attorney at Law” for hire legal services…?

And Pro Se Plaintiff Namely (Louis Charles Hamilton II) herein

Did not “Legally” in any physical monetary “shape or form” officially retain “Your” crooked (RICO) services in the “first place”… to represent the said Pro Se Plaintiff “Louis Charles Hamilton II” Herein in civil suit in “common law” within the 58th Judicial District Court of Jefferson County Texas Docket No. A-180805…?

And why…? Is the Pro Se Plaintiff being “further fraudulently” represented and “Identified” by “You” Chief (RICO) Defendant Antoine L. Freeman, J.D., Texas

Bar No. 24058299 in “Your” official filed “Motion for Withdrawal of Counsel”, filed stamp dated November 13th 2009 10:22 am hour. …?

As “Your” legal filed motion for your withdrawal of counsel before the “Honorable 58th Judicial District Court quite “among other things” completely represented and “Identified”

Very “fraudulently” the describing Pro Se Plaintiff “Louis Charles Hamilton II” herein in a “legal status state” of “Plaintiffs refuses to adhere to the terms of the employment agreement..?

In connection with “Attorney at Law” Chief (RICO) Defendant Antoine L. Freeman, J.D., Texas Bar No. 24058299 herein…?

As foolishly, stupidly and bogusly being described in Pro Se Plaintiff attached Document # 8…?

“Your” official filed “Motion for Withdrawal of Counsel”?

Subpart (A)

Further expertly explaining in precise legal careful details Defendant “Antoine L. Freeman, J.D.” Texas Bar No. 24058299 herein fully legally precisely how was the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein collectively…?

Exactly with supporting “physical documented” of proof and your “legally” precise details said Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein “Not officially” complying fully with, and acting in all accordance with all specified standards and terms of the employment agreement contract for your “Attorney at Law” legal services

For said civil in “common law” within the 58th Judicial District Court of Jefferson County Texas, Docket No. A-180805…?

During the exact precise month of November of 2009…?

Subpart (B)


Exactly with supporting “physical documented” of proof and your “legally” precise details said Co-Defendant(s) collectively complying fully with, and acting in accordance with all specified standards and terms of the employment agreement contract for your “Attorney at Law” legal services


During the exact precise month of December of 2007…?

Subpart (C)




During the exact precise month of January 2008.…?

Subpart (D)




During the exact precise month of Februarys of 2008…?

Subpart (E)




During the exact precise month of March of 2008…?

Subpart (F)




During the exact precise month of April of 2008…?

Subpart (G)




During the exact precise month of May of 2008…?

Subpart (H)




During the exact precise month of June of 2008…?

Subpart (I)




During the exact precise month of July of 2008…?

Subpart (J)




During the exact precise month of August of 2008…?

Subpart (K)




During the exact precise month of September of 2008…?

Subpart (L)




During the exact precise month of October of 2008…?

Subpart (M)




During the exact precise month of November of 2008…?

Subpart (N)




During the exact precise month of December of 2008…?

Subpart (O)




During the exact precise month of January of 2009…?

Subpart (P)




During the exact precise month of Februarys of 2009…?

Subpart (Q)




During the exact precise month of March of 2009…?

Subpart (R)




During the exact precise month of April of 2009…?

Subpart (S)




During the exact precise month of May of 2009…?

Subpart (T)




During the exact precise month of June of 2009…?

Subpart (U)




During the exact precise month of July of 2009…?

Subpart (V)




During the exact precise month of August of 2009…?

Subpart (W)




During the exact precise month of September of 2009…?

Subpart (X)




During the exact precise month of October of 2009…?

Subpart (Y)

Further expertly explaining in precise legal quite careful avoiding “Perjury” details…?

Defendant “Antoine L. Freeman, J.D.” Texas Bar No. 24058299 herein

Fully legally precisely how is possible it that the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein collectively…?

Having a physical “legal binding contract” for your “legal services” from the time frame of December 18th 2007 when you filed “Your” General Denial…?

Throughout the time frame until “You” finally official filed a “Motion for Withdrawal of Counsel”, filed stamp dated November 13th 2009 10:22 am hour…?

Being fully quite “Legally” described in Pro Se Plaintiff attached Document # 8 “Your Motion for withdrawal of counsel”

As stated legally by you as follows:

To The Honorable Judge of Said Court:

Now Comes Movant, Antoine L. Freeman J.D., Attorney for Defendants, Joyce Guy and Edward McCray, (hereinafter Defendants), and brings this Motion for withdrawal of Counsel, and in support thereof, shows the court the following:

I.

Good cause exists for withdrawal of Movant as counsel because Defendants have not complied with the terms of employment agreement with this attorney. Plaintiffs refuse to adhere to the terms of the employment agreement with this attorney.

II.

The setting and deadlines in this case are as follows: Motion for Sanction & Contempt on December 11th, 2009 @ 9:00 am (With Your Initials)

III.

This Motion is not sought for the purposes of delay.

IV.

A copy of this motion bearing the enclosed notice has been delivered to the last known addresses of the Defendants.

“Joyce Guy” 5050 7th street Port Arthur, Texas 77642

“Edward McCray” 5050 7th street Port Arthur, Texas 77642

V.

Defendants are hereby notified in writing of the right to object to this motion.

NOTICE

You are hereby notified that this motion for withdrawal of Counsel is set for hearing at the time and place set out below. You do not agree to this motion. If you wish to contest the withdrawal of Antoine L. Freeman, J.D. as your attorney, you should appear at the hearing.

If you do not oppose Antoine L. Freeman, J.D.’s withdrawal as your attorney, you may notify Antoine L. Freeman, J.D. in writing of your consent to this motion.

Wherefore, Premises Considered, Movant prays that the Court enters as order discharging Movant as attorney of record for Defendants, “Joyce Guy” and “Edward McCray”, and for such other and further relief that may be awarded at law or in equity.

Respectfully submitted, by “Antoine L. Freeman, J.D., Texas Bar No. 24058299, 3723 Gulfway Dr. Ste #104, Port Arthur, Texas 77642 (409) 293-1627, Fax (409) 983-7405

“Attorney for Defendants” Joyce Guy and Edward McCray

“When” oddly being described once again by “You” officially in Pro Se Plaintiff attached Document # 2 your fully legally claiming in said Document # 2 attached herein “Your response to Pro Se Plaintiff Motion for sanction against you for violations of Rule 193.1 by failing to respond to Plaintiff’s discovery request

In your defense in attached Document # 2 herein as you claim, sworn and stated in paragraph 1 and 2 stated as follows:

(1)

At the time of Plaintiffs discovery request Defendant’s Attorney had not been retain by Defendants to represent their interest with regards to this lawsuit.

(2)


Why legally…? Now in November of 2009 there is in factual circumstances surrounding a legal binding contract you’re claiming do in fact exist between Attorney/client namely Defendant “Antoine L. Freeman, J.D.” Texas Bar No. 24058299 herein and said Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein

As described in Pro Se Plaintiff attached Document # 8 herein namely “Your” Motion for withdrawal of counsel” fully stating among other things

Said Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein “Not officially” complying fully with, and acting in all accordance with all specified standards and terms of the employment agreement contract for your “Attorney at Law” legal services


During the exact precise day of the 13th during the month of November in the year of 2009…?

Which now legally “You” are seeking the 58th Judicial District Court Judge Bob Wortham “honest official approval” to terminate said contract… in December 11th 2009 Court Hearing…?

As you’re saying “officially” before the “Honorable Court” a contract do not exist at all between the time frame of December 18th 2007…?

Throughout the time frame you file said Response to Plaintiff’s Motion for sanctions against you on September 11th 2009…?

Between “You” Defendant (Attorney at Law) herein and said Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein…?

As you secure your official false, fraudulent bogus (RICO) Obstruction of Justice” representation before the “Honorable 58th Judicial District Judge Bob Wortham “Honorable Court” in regards to “among other things”

Your 100% “acting Attorney of Record” violation of Rule 193.1 of the Texas Rules of Civil Procedure regarding responds to discovery in a timely manner…?

But “Your” still at the same “time frame” legally claiming before the same Honorable 58th Judicial District Court Judge “Bob Wortham” in Pro Se Plaintiff attached Document # 2 herein “Your” response to Plaintiff’s Motion for sanctions against you

Your being 100% official stating that “no such legal binding Contract exists” at all, “Your (only) duties were the official filing of a “General Denial” on December 18th 2007…?

And “Your” having official just legal rights to not respond to all said discovery request of the Pro Se Plaintiff herein for this civil suit in common law being in your full legal possession, custody and control since March of 2008, April of 2008, May of 2008, June of 2008, July of 2008, August of 2008,

September of 2008, October of 2008, November of 2008, December of 2008, January of 2009, February of 2009, March of 2009, April of 2009, May of 2009, June of 2009, July of 2009,August of 2009, and September of 2009 against Texas Rules of Civil Procedures

When such a real Legal binding Contract does exist between you and The Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein collectively

From the exact time frame date of December 18th 2007 throughout December 11th 2009 when the court granted your withdrawal of counsel…? From said “Contract” between “You” and the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein collectively

As being further precisely legally being “officially” cleverly described in Pro Se Plaintiff attached Document # 8

“Your” very own “Motion for withdrawal as counsel” stating in November 13th 2009…? “Among other things”

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

“Have not complied with the “terms of employment agreement” with this attorney.”…? In the month of November of 2009…?

Subpart (Z)

Further expertly explaining in precise legal quite careful avoiding “Perjury” details…?

Chief Defendant “Antoine L. Freeman, J.D.” Texas Bar No. 24058299 herein

Fully legally precisely how is “legally 100% possible” it that the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein collectively…? During the months of

March of 2008, April of 2008, May of 2008, June of 2008, July of 2008, August of 2008,

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

Actually physically complied fully with all of the “terms and conditions of employment agreement” with this attorney.”…?

Namely “You” Defendant Antoine L. Freeman, J.D.” Texas Bar No. 24058299 herein …?

When while “Your” representing said Co-Defendant(s) herein collectively at the same time

“You” (Attorney at Law) never ever produce an “actual physical copy(s)” of said Property deeds for dwelling and the property located at 448 DeQueen Blvd. in Port Arthur Texas. (Block 172, Lot 1-2) as request and required in Pro Se Plaintiff Motion for Production of Document dated August 12th 2008…?

As being described such a motion exist for the production of said “Property deeds in Pro Se Plaintiff attached Document #10

The 58th Judicial District Court of Jefferson County Texas “Court Order” dated the 10th day of May 2010 in Compelling the physical Production of said “Property Deeds”…?

While fraudulently (RICO) also at this same “precise legal time frame” same

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

Being in the “Active physical” possession, custody and legal control of the “Texas Department of Housing & Community Affairs” During the same time frame of “June 18th 2009 throughout July 22nd 2013 as being described in Pro Se Plaintiff attached Document # 9 herein

The “Jefferson County Texas Property search Index” (Public Record).

While these same said “Property Deeds” for dwelling and the property located at 448 DeQueen Blvd. in Port Arthur Texas. (Block 172, Lot 1-2) of Co-Defendant(s) “Joyce M. Guy and Edward McCray herein collectively

Being official “subject matter” in a civil suit in common law since November 26th 2007 while you’re still acting “Attorney of Record…?

Throughout December 11th 2009…?

(19)

Explain in full expert “Attorney at Law” precise legal details, legal service in the capacity as acting “Attorney of Record” for Civil Suit in Common Law 58th

Judicial District Court of Jefferson County in and for the State of Texas Docket No. A-180805

Defendant “Antoine L. Freeman, J.D. Texas Bar No. 24058299 herein

“The Texas Disciplinary Rules of Professional Conduct” particularly relating to 8.04 Misconduct described as follows:

a) A lawyer shall not:

(1) Violate these rules, knowingly assist or induce another to do so, or do so through the acts of another, whether or not such violation occurred in the course of a client-lawyer relationship;

(2) Commit a serious crime or commit any other criminal act that reflects adversely on the lawyer's honesty, trustworthiness or fitness as a lawyer in other respects;

(3) engage in conduct involving dishonesty, fraud, deceit or misrepresentation;

(4) Engage in conduct constituting obstruction of justice;

“Explain…..? “Chief” Defendant “Antoine L. Freeman, J.D.” Attorney at Law Texas Bar No. 24058299 herein precisely why…?

When (I) Pro Se Plaintiff “Louis Charles Hamilton II” herein on the exact day of August 12th 2009 request for the Production of Document “namely” in the exact physical proof of “ownership” in the production of said property deeds for

dwelling and the property located at 448 DeQueen Blvd. in Port Arthur Texas. (Block 172, Lot 1-2)

And you’re fully aware at that exact moment in time of said Production of document request..?

“You” Defendant (Attorney at Law) did not come forth before the 58th Judicial District Court of Jefferson County Texas “Honorable Bob Wortham” in docket No. A-180805

And honestly first and foremost file a legal written notice to the “Honorable Court” ex-parte, or with notice served upon said Pro Se Plaintiff herein also

Saying in precise legal details your “Clients” a/k/a said Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein collectively illegally during the course

of your representation illegally Transfer the property deed” for the dwelling

located at 448 DeQueen Blvd. in Port Arthur Texas (Block 172, Lot 1-2)herein

On the exact dates of June 18th 2009 to “The Texas Department of Housing & Community Affairs as being described in Pro Se Plaintiff attached Document #

9“Jefferson County Real Estate Index” Instrument #2009022762 in Attached document #7 herein shown

And “You” are filing “You’re” immediately “Motion for withdrawal of

Counsel”,

So you’re not in any shape or physical form associated, and being a misused party to the ongoing current June 18th 2009 dishonesty, fraud, and deceit standing

before the 58th Judicial District Court of Jefferson County Texas

In an ongoing civil suit in common law since 2007 involving “You” Chief Defendant (Attorney at Law) and the Co-Defendant(s) herein “Joyce M. Guy and Edward McCray” collectively and the Property Deeds…?

When “The Texas Disciplinary Rules of Professional Conduct” particularly relating to 8.04 Misconduct described as follows:

a) A lawyer shall not:

(1) Violate these rules, knowingly assist or induce another to do so, or do so through the acts of another, whether or not such violation occurred in the course of a client-lawyer relationship;



And “Your” being directly legally, documented proof engaging in the

conduct involving dishonesty, fraud, deceit and concealment of said property deeds since August 12th 2009…?

And failing to disclosed this “material facts” said “property and deeds

thereof was in the custody, possession and legal control of the “Texas Department of Housing & Community Affairs” as described in Pro Se Plaintiff attached

Document # 9 attached herein “Jefferson County Texas Property search Index” Instrument # 2014012455

While you’re still acting Attorney of Record in ongoing civil suit A-180805

before the 58th Judicial District Court of Jefferson County Texas…..?

When “The Texas Disciplinary Rules of Professional Conduct” particularly relating to 8.04 Misconduct paragraph (2) and (3) clearly stating:



Subpart (A)

Further expertly explaining in precise legal careful details Defendant “Antoine L. Freeman, J.D.” Texas Bar No. 24058299 herein for the exact month of April of 2008…? Your having full possession, custody and legal control over said discovery request, of Request for admission, Interrogatories, and Disclosure Request Pursuant to Rule 194 of the Texas rules of Civil Procedure,

As you stated in Pro Se Plaintiff attached Document # 2 herein “Your response to Plaintiff Motion for sanctions against you for violation of Rule 193.1 of the Texas Rules of Civil Procedure regarding responding to discovery in a timely manner…?

Fully explaining why did you Defendant (Attorney at Law) come forth before the 58th Judicial District Court of Jefferson County Texas appearing in

person no less before the “Honorable Bob Wortham” in Docket No. A-180805 on the 11th day of September 2009 and completely “lie” and further supply false fabricated affidavits of Co-Defendant “Joyce M. Guy” herein filed as attached Document # 6 and further supply false fabricated “Motion for withdrawal” filed as attached Document #2 attached herein

And stated “You” are Not the “retain acting attorney of record” to defend the legal interest of the Co-Defendant(s) described collectively herein and there is no such binding contract for your legal services there after the 18th day of December 2007 when you was under contract to file said “General Denial”

And “Your” having official just legal rights standing to not respond to any and all said discovery request of the Pro Se Plaintiff herein for this civil suit in common law being in your full legal possession, custody and control since March of 2008, April of 2008, May of 2008, June of 2008, July of 2008, August of 2008,

September of 2008, October of 2008, November of 2008, December of 2008, January of 2009, February of 2009, March of 2009, April of 2009, May of 2009, June of 2009, July of 2009,August of 2009, and September of 2009 against Texas Rules of Civil Procedures

But you’re filing a “Motion for withdrawal of counsel” on November 13th

2009 as described by you in paragraph (1) in Pro Se Plaintiff attached Document # 8 attached herein stating:

“Good cause exists for withdrawal of Movant as counsel because Defendants have not complied with the terms of employment agreement with this attorney during the month of November 2009...?

When “The Texas Disciplinary Rules of Professional Conduct” particularly relating to 8.04 Misconduct paragraph (2) and (3) clearly stating you’re not to be:


But you’re physically chief Defendant “Antoine L. Freeman, J.D.” Texas Bar No. 24058299 herein bring forth false misrepresentation before the “Honorable Bob Wortham” in docket No. A-180805

On the 11th day of September 2009 regarding “Your” actual retain for hire

status throughout your full legal possession, custody and control since March of 2008, April of 2008, May of 2008, June of 2008, July of 2008, August of 2008,

September of 2008, October of 2008, November of 2008, December of 2008, January of 2009, February of 2009, March of 2009, April of 2009,

May of 2009, June of 2009, July of 2009, August of 2009, and September of 2009 against Texas Rules of Civil Procedures

When you’re physically being discharge as acting Attorney of record on December 11th 2009…? From said “Attorney for hire contract in connection with the Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein.

Subpart (B)

Further expertly continue explaining in precise legal careful details Defendant “Antoine L. Freeman, J.D.” Texas Bar No. 24058299 herein

When (I) Pro Se Plaintiff “Louis Charles Hamilton II” herein on the exact day of August 12th 2009 request for the Production of Document “namely” among other things in the exact physical proof of “ownership”

In the production of said property deeds for dwelling and the property located at 448 DeQueen Blvd. in Port Arthur Texas. (Block 172, Lot 1-2) and your fully aware at that exact moment in time of said Production of document request..

And you’re claiming in attached Document # 2 herein Your Response to Plaintiff motion for sanctions against “You” in paragraph 1 and 2

In your defense in attached Document # 2 herein as you claim, sworn and stated as follows:

“At the time of Plaintiffs discovery request Defendant’s Attorney had not been retain by Defendants to represent their interest with regards to this lawsuit.”

“Defendant, Joyce Guy, retain the services of Antoine Freeman for the purpose of writing a general denial so as to avoid a default judgment being render against her”.

Why …? Are you on the exact dates of August 28th 2009 “physically present”

before the “Honorable Bob Wortham” in same Docket No. A-180805 in the physical breathing acting “Attorney of Record” legal capacity presenting

“Oral Arguments” no less against the Pro Se Plaintiff (TRO) ‘Temporary

Restraining Order, order to show cause, motion for Guardian AD LITEM being described in

Pro Se Plaintiff attached Documents # 11 herein namely the 58th Judicial

District Court of Jefferson County Texas “Civil Docket Report” for cause A-180805 fully describing “among other things you “legally physically there” as

acting retain “Attorney of record” for the Co-Defendant(s) “Joyce M. Guy” and Edward McCray” collectively behalf…?

And you having no official “Motion for withdrawal of counsel” as being

described in Pro Se Plaintiff attached Document # 8 herein filed on November 13th 2009

When as already stated by “You” in attached Document # 2 herein Your Response to Plaintiff motion for sanctions against “You” in paragraph 1 and 2 as you legally claim, sworn and stated as follows:

“At the time of Plaintiffs discovery request Defendant’s Attorney had not been retain by Defendants to represent their interest with regards to this lawsuit.”

“Defendant, Joyce Guy, retain the services of Antoine Freeman for the purpose of writing a general denial so as to avoid a default judgment being render against her”

Which “You” directly “sworn” to these “material facts” on “December 11th 2009 being 100% adamantly “However” at the same time frame your actually acting attorney of record until “December 11th 2009 in the AM hour…?

When “The Texas Disciplinary Rules of Professional Conduct” particularly relating to 8.04 Misconduct paragraphs (3) clearly stating you’re not to be:


But your being at the same time frame physically dishonest, providing fraudulent documents to support the facts, as described in attached Documents #2, your response to motion for sanctions against you

And Document #6 herein “Affidavit” of Co-Defendant “Joyce M. Guy”

And Defendant (Attorney at Law) 100% directly misrepresentation “Live” actual deceit before the “Honorable Judge Bob Wortham” of the 58th Judicial District Court in Jefferson County Texas in same Docket No. A-180805

Stating “You” are not acting retain “attorney of record” after the filing of the

“General Denial” on December 18th 2007 as your physically saying all of this on December 11th 2009…?

But Pro Se Plaintiff attached Document # 11 herein namely the 58th Judicial

District Court of Jefferson County Texas “Civil Docket Report” for cause A-180805 having you acting Attorney of record

Fully 100% describing “among other things you “legally physically there” as acting retain “Attorney of record” for the Co-Defendant(s) “Joyce M. Guy” and Edward McCray” collectively behalf… on August 28th 2009 “Live Hearing”

date…?

As you’re deceiving the “Honorable Court” from August 28th 2009 “Live

Hearing” dates throughout the hearing date of December 11th 2009…?

As Pro Se Plaintiff attached Documents # 11 herein namely the 58th Judicial District Court of Jefferson County Texas “Civil Docket Report” for cause A-

180805 fully describing “among other things you “legally physically there”

As acting retain “Attorney of record” for the Co-Defendant(s) “Joyce M. Guy” and Edward McCray” collectively behalf

Is this not in direct violation…? Of The Texas Disciplinary Rules of Professional Conduct” particularly relating to

8.04 Misconduct paragraphs (3) clearly stating you’re not to be an Attorney:


(20)

The Constitution of the State of Texas

Article 16: "General Provisions" Contains miscellaneous provisions, including limits on interest rates, civil penalties for murder, and the punishment for bribery. Section 37 provides for the constitutional protection of the mechanic's lien. Section 50 provides for protection of a homestead against forced sale to pay debts, except for foreclosure on debts related to the homestead (mortgage, taxes, mechanic's liens, and home equity loans).

Explain why in detail…? Are you Chief Defendant “Antoine L. Freeman,

J.D.” Texas Bar No. 24058299 herein providing Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein full protection, and concealment of said “property deeds” from the Pro Se Plaintiff herein from December 18th 2007 – December 11th 2009 when you was removed as acting Attorney of Record…?

Providing the full “Attorney at Law” skilled protection, and concealment thereof said “property deeds” against the Pro Se Plaintiff “Louis Charles Hamilton II” herein opportunity in filing a “Mechanic’s lien” for said dwelling and the property located at 448 DeQueen Blvd. in Port Arthur Texas. (Block 172, Lot 1-2)

During the time exact time frame of “August 12th 2009 in the “actual concealment” of said “property deed” you engaged from that day well into 2015 Attorney at Law skilled protection, and concealment in the required Pro Se Plaintiff “Production of Document” for said “property deeds”

You 100% refused to respond to in a timely manner (30) days thereafter possession of said “Production of Document for said “property deeds” as claiming

legally before the 58th Judicial District Court of Jefferson county Texas “Your” not retain at all on August 12th 2009 to response to said Production of Property Deeds..?

But Defendant herein still acting as “Attorney of record” until December 11th 2009…?

While into the time frame of June 18th 2009- April 22nd 2014 when “Texas Department of Housing and Community affairs” ended having full possession, custody and legal control of said “Property Deeds”

As being described “legally” in Pro Se Plaintiff attached Document # 5 herein “Jefferson County Texas Search Index”

While “You” Defendant (Attorney at Law) did not “come forth” before the 58th Judicial District Court of Jefferson County Texas “Honorable Judge Bob Wortham” in Docket No. A-180805

And honestly “first and foremost” file a legal written notice to the “Honorable Court” being ex-parte, or with notice served upon said Pro Se Plaintiff “Louis Charles Hamilton II herein also

Saying in “precise legal details” your “Clients” a/k/a said Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein collectively during the course of your

representation illegally Transfer the property deed” for the dwelling located at 448

DeQueen Blvd. in Port Arthur Texas (Block 172, Lot 1-2)herein

On the exact dates of June 18th 2009 to “The Texas Department of Housing

& Community Affairs” as being described in Pro Se Plaintiff attached Document # 9“ herein Jefferson County Real Estate Index” Instrument #2009022762

And “You” are filing “You’re” immediately “Motion for withdrawal of

Counsel”,

So you’re Chief Defendant “Antoine L. Freeman, J.D.” Texas Bar No.

24058299 herein not in any “shape or physical form” associated, and being a misused party to the ongoing current June 18th 2009 dishonesty, fraud, and deceit standing before the 58th Judicial District Court of Jefferson County Texas

surrounding the said property deeds…?

In an ongoing “civil suit” in common law since 2007…? Involving “You” Chief Defendant (Attorney at Law) and the Co-Defendant(s) herein “Joyce M. Guy

and Edward McCray” collectively and the legal issues of subject matter surround

said “Property Deeds”…?

Being against “among other things” the Pro Se Plaintiff herein Constitutional rights of the State of Texas Article 16: Section 37 and Section 50

When “The Texas Disciplinary Rules of Professional Conduct” particularly relating to 8.04 Misconduct paragraph (2) and (3) clearly stating that you active “Attorney at Law” within the State of Texas prohibited from:



Which said “property deeds” for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein being in there possession, custody and legal

control at the start of this civil suit in common law

On November 26th 2007 for dwelling and the property located at 448 DeQueen Blvd. in Port Arthur Texas. (Block 172, Lot 1-2) – June 17th 2009

As said “property deeds is a party of and subject matter to a civil suit in common law since November 26th 2007 Docket No. A-180805 throughout January 21s t 2015

Notwithstanding at the “same time frame” quite fraudulently the “Texas Department of Housing and Community affairs” end up having full possession, custody and legal control over said “Property Deeds” from June 18th 2009 – July 22nd 2013…?

And as your acting “Attorney of record” since December 18th 2007 – December 11th 2009

Having full legal possession, custody and control since March of 2008, April of 2008, May of 2008, June of 2008, July of 2008, August of 2008,

September of 2008, October of 2008, November of 2008, December of 2008, January of 2009, February of 2009, March of 2009, April of 2009,

May of 2009, June of 2009, July of 2009, August of 2009, and September of 2009 over all discovery request of interrogatories, request for admission, and disclosure and your 100% in refusing to file a “timely response” thereof (30) days later claiming “Your” not acting “Attorney of record” between the time frame of December 18th 2007- November 13th 2009

As being described in Pro Se Plaintiff attached Document # 2 “Your” fraudulent response to Pro Se Plaintiff motion for sanctions against you.

When Pro Se Plaintiff attached Documents # 11 herein namely the official

58th Judicial District Court of Jefferson County Texas “Civil Docket Report” for

cause A-180805 fully describing “among other things” you “legally” acting as

“Attorney of record” from December 18th 2007- December 11th 2009

With additionally Pro Se Plaintiff Document #1 attached herein being the official 58th Judicial District Court of Jefferson County Texas “Case Ledger” for Civil Cause No. A-180805 also showing your acting retained “Attorney of record” between the time frame of December 18th 2007- December 11th 2009…?

(21)

Explain in full expert “Attorney at Law” details, and Supply in full details also any and all legal court documents, docket reports, court ledgers, letters, faxes, text, memos, emails, “filed motion for withdrawal of counsel” in support thereof from the exact date of December 18th 2007 throughout the exact dates of January 1s t 2008

Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” Bar No. 24058299 herein

Was not legally representing “material physical fact’s in the professional legal public capacity as a acting “Attorney at Law“ before Louis Charles Hamilton

II herein Namely said “Pro Se Plaintiff” herein in connection with one “Joyce M. Guy and Edward McCray” in Jefferson County Texas.

Namely exactly Antoine L. Freeman, J.D. “Attorney at Law” Texas Bar No. 24058299 (active) within the “State of Texas” was not providing such a physical representation and appearance thereof of as “Attorney at Law” services for the “legal behalf” and “retain interest” before an “Honorable Court of Law” in cause No. A-180805 filed in the Jefferson County Texas Courthouse

For their combine legal representation of said Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein in a format regarding “among other things”

Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” was not making Public Representation in the Profession as a “skilled counsel of law” against the Pro Se “Louis Charles Hamilton II” herein in a civil suit in the 58th Judicial District Court of Jefferson County Texas filed in Cause No. A-180805 being Defendant (Attorney at law)

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” Was not physically acting as “Attorney of Record” for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” and not accepting any legal court documents for their legal behalf of said Co-Defendant(s) collectively from said Pro Se Plaintiff herein from the “United States Mailing System

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” was not making any secluding court appearances,

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” was not involved in any “attorney/client” work product thereof, billing hours, invoices, banking records, tax records, and was not filing any legal counter motions, against said Pro Se Plaintiff “Louis Charles Hamilton II” herein

Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” was (Only) acting in the “legal capacitates” as a Attorney at Law to file a General Denial (Only) on December 18th 2007 to reply in the Complaint made against Co-Defendant(s) Joyce M. Guy and Edward McCray( herein ) and such services ended thereafter the exact date of December 18th 2007

In a civil suit in the 58th Judicial District Court of Jefferson County Texas filed in Cause No. A-180805 that you were retain to for such services legal to file a General Denial (Only) regarding a “Breach of Construction Contract” in excess of $10,800.00 U.S. Dollars as described by “You” Defendant (Attorney at Law) in attached Document # 2 herein

“Your” response to Pro Se Plaintiff Motion for Sanction against “You” Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” Bar No. 24058299 herein

Surrounding Pro Se Plaintiff claims of a chain of fraudulent events as a result of Hurricane Rita, Humberto and Ike for said dwelling and the property located at 448 DeQueen Blvd. in Port Arthur Texas. (Block 172, Lot 1-2) in connection with Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively.

Subpart (A)

Explain in full expert “Attorney at Law” details, and Supply in full details also any and all legal court documents, docket reports, court ledgers, letters, faxes, text, memos, emails, “filed motion for withdrawal of counsel” in support thereof from the exact date of January 30th 2008 throughout the exact dates of Feburary 1s t 2008


Was not legally representing “material physical fact’s in the professional legal public capacity as a acting “Attorney at Law“ before Louis Charles Hamilton II herein Namely said “Pro Se Plaintiff” herein in connection with one “Joyce M. Guy and Edward McCray” in Jefferson County Texas.











Subpart (B)

Explain in full expert “Attorney at Law” details, and Supply in full details also any and all legal court documents, docket reports, court ledgers, letters, faxes, text, memos, emails, “filed motion for withdrawal of counsel” in support thereof from the exact date of February 1s t 2008 throughout the exact dates of March 1s t 2008






In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” Was not physically acting as “Attorney of Record” for the Co-Defendant(s) “Joyce

M. Guy and Edward McCray” legal behalf” and not accepting any legal court documents for their legal behalf of said Co-Defendant(s) collectively from said Pro Se Plaintiff herein from the “United States Mailing System







Subpart (C)

Explain in full expert “Attorney at Law” details, and Supply in full details also any and all legal court documents, docket reports, court ledgers, letters,

faxes, text, memos, emails, “filed motion for withdrawal of counsel” in support thereof from the exact date of March 1s t 2008 throughout the exact dates of April 1s t 2008








In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” was not involved in any “attorney/client” work product thereof, billing hours,

invoices, banking records, tax records, and was not filing any legal counter motions, against said Pro Se Plaintiff “Louis Charles Hamilton II” herein





Subpart (D)

Explain in full expert “Attorney at Law” details, and Supply in full details also any and all legal court documents, docket reports, court ledgers, letters, faxes, text, memos, emails, “filed motion for withdrawal of counsel” in support thereof from the exact date of April 1s t 2008 throughout the exact dates of May1s t 2008














Subpart (E)

Explain in full expert “Attorney at Law” details, and Supply in full details also any and all legal court documents, docket reports, court ledgers, letters, faxes, text, memos, emails, “filed motion for withdrawal of counsel” in support thereof from the exact date of May 1s t 2008 throughout the exact dates of June 1s t 2008













Subpart (G)

Explain in full expert “Attorney at Law” details, and Supply in full details also any and all legal court documents, docket reports, court ledgers, letters, faxes, text, memos, emails, “filed motion for withdrawal of counsel” in support thereof from the exact date of June 1s t 2008 throughout the exact dates of July 1s t 2008













Subpart (H)

Explain in full expert “Attorney at Law” details, and Supply in full details also any and all legal court documents, docket reports, court ledgers, letters, faxes, text, memos, emails, “filed motion for withdrawal of counsel” in support thereof from the exact date of July 1s t 2008 throughout the exact dates of August 1s t 2008













Subpart (I)

Explain in full expert “Attorney at Law” details, and Supply in full details also any and all legal court documents, docket reports, court ledgers, letters, faxes, text, memos, emails, “filed motion for withdrawal of counsel” in support thereof from the exact date of August 1s t 2008 throughout the exact dates of September 1s t 2008









Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” was (Only) acting in the “legal capacitates” as a Attorney at Law to file a General Denial (Only) on December 18th 2007 to reply in the Complaint made against Co-

Defendant(s) Joyce M. Guy and Edward McCray( herein ) and such services ended thereafter the exact date of December 18th 2007




Subpart (J)

Explain in full expert “Attorney at Law” details, and Supply in full details also any and all legal court documents, docket reports, court ledgers, letters, faxes, text, memos, emails, “filed motion for withdrawal of counsel” in support thereof from the exact date of September 1s t 2008 throughout the exact dates of October 1s t 2008



Namely exactly Antoine L. Freeman, J.D. “Attorney at Law” Texas Bar No. 24058299 (active) within the “State of Texas” was not providing such a physical representation and appearance thereof of as “Attorney at Law” services for the

“legal behalf” and “retain interest” before an “Honorable Court of Law” in cause No. A-180805 filed in the Jefferson County Texas Courthouse










Subpart (K)

Explain in full expert “Attorney at Law” details, and Supply in full details also any and all legal court documents, docket reports, court ledgers, letters, faxes, text, memos, emails, “filed motion for withdrawal of counsel” in support thereof from the exact date of October 1s t 2008 throughout the exact dates of November 1s t 2008





Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” was not making Public Representation in the Profession as a “skilled counsel of law” against the Pro Se “Louis Charles Hamilton II” herein in a civil suit in the 58th

Judicial District Court of Jefferson County Texas filed in Cause No. A-180805 being Defendant (Attorney at law)








Subpart (L)

Explain in full expert “Attorney at Law” details, and Supply in full details also any and all legal court documents, docket reports, court ledgers, letters, faxes, text, memos, emails, “filed motion for withdrawal of counsel” in support thereof from the exact date of November 1s t 2008 throughout the exact dates of December 1s t 2008













Subpart (M)

Explain in full expert “Attorney at Law” details, and Supply in full details also any and all legal court documents, docket reports, court ledgers, letters, faxes, text, memos, emails, “filed motion for withdrawal of counsel” in support thereof from the exact date of December 1s t 2008 throughout the exact dates of January1s t 2009














Subpart (N)

Explain in full expert “Attorney at Law” details, and Supply in full details also any and all legal court documents, docket reports, court ledgers, letters, faxes, text, memos, emails, “filed motion for withdrawal of counsel” in support thereof from the exact date of January1st 2009 throughout the exact dates of February 1s t 2009













Subpart (O)

Explain in full expert “Attorney at Law” details, and Supply in full details also any and all legal court documents, docket reports, court ledgers, letters, faxes, text, memos, emails, “filed motion for withdrawal of counsel” in support thereof from the exact date of February 1s t 2009 throughout the exact dates of March 1s t 2009






In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” Was not physically acting as “Attorney of Record” for the Co-Defendant(s) “Joyce

M. Guy and Edward McCray” legal behalf” and not accepting any legal court documents for their legal behalf of said Co-Defendant(s) collectively from said Pro Se Plaintiff herein from the “United States Mailing System







Subpart (P)

Explain in full expert “Attorney at Law” details, and Supply in full details also any and all legal court documents, docket reports, court ledgers, letters, faxes, text, memos, emails, “filed motion for withdrawal of counsel” in support

thereof from the exact date of March 1s t 2009 throughout the exact dates of April 1s t 2009








In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” was not involved in any “attorney/client” work product thereof, billing hours,

invoices, banking records, tax records, and was not filing any legal counter motions, against said Pro Se Plaintiff “Louis Charles Hamilton II” herein





Subpart (Q)

Explain in full expert “Attorney at Law” details, and Supply in full details also any and all legal court documents, docket reports, court ledgers, letters, faxes, text, memos, emails, “filed motion for withdrawal of counsel” in support thereof from the exact date of April 1s t 2009 throughout the exact dates of May 1s t 2009










In a civil suit in the 58th Judicial District Court of Jefferson County Texas filed in Cause No. A-180805 that you were retain to for such services legal to file a General Denial (Only) regarding a “Breach of Construction Contract” in excess of

$10,800.00 U.S. Dollars as described by “You” Defendant (Attorney at Law) in attached Document # 2 herein



Subpart (R)

Explain in full expert “Attorney at Law” details, and Supply in full details also any and all legal court documents, docket reports, court ledgers, letters, faxes, text, memos, emails, “filed motion for withdrawal of counsel” in support thereof from the exact date of May 1s t 2009 throughout the exact dates of June 1s t 2009












Surrounding Pro Se Plaintiff claims of a chain of fraudulent events as a result of Hurricane Rita, Humberto and Ike for said dwelling and the property

located at 448 DeQueen Blvd. in Port Arthur Texas. (Block 172, Lot 1-2) in connection with Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively.

Subpart (S)

Explain in full expert “Attorney at Law” details, and Supply in full details also any and all legal court documents, docket reports, court ledgers, letters, faxes, text, memos, emails, “filed motion for withdrawal of counsel” in support thereof from the exact date of June 1s t 2009 throughout the exact dates of July1st 2009






In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” Was not physically acting as “Attorney of Record” for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” and not accepting any legal court

documents for their legal behalf of said Co-Defendant(s) collectively from said Pro Se Plaintiff herein from the “United States Mailing System







Subpart (T)

Explain in full expert “Attorney at Law” details, and Supply in full details also any and all legal court documents, docket reports, court ledgers, letters, faxes, text, memos, emails, “filed motion for withdrawal of counsel” in support thereof from the exact date of July1st 2009 throughout the exact dates of August 1s t 2009













Subpart (U)

Explain in full expert “Attorney at Law” details, and Supply in full details also any and all legal court documents, docket reports, court ledgers, letters, faxes, text, memos, emails, “filed motion for withdrawal of counsel” in support thereof from the exact date of August 1s t 2009 throughout the exact dates of September 1s t 2009



Namely exactly Antoine L. Freeman, J.D. “Attorney at Law” Texas Bar No. 24058299 (active) within the “State of Texas” was not providing such a physical

representation and appearance thereof of as “Attorney at Law” services for the “legal behalf” and “retain interest” before an “Honorable Court of Law” in cause No. A-180805 filed in the Jefferson County Texas Courthouse










Subpart (V)

Explain in full expert “Attorney at Law” details, and Supply in full details also any and all legal court documents, docket reports, court ledgers, letters, faxes, text, memos, emails, “filed motion for withdrawal of counsel” in support thereof from the exact date of September 1s t 2009 throughout the exact dates of October 1s t 2009





Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” was not making Public Representation in the Profession as a “skilled counsel of law” against the Pro Se “Louis Charles Hamilton II” herein in a civil suit in the 58th

Judicial District Court of Jefferson County Texas filed in Cause No. A-180805 being Defendant (Attorney at law)








Subpart (W)

Explain in full expert “Attorney at Law” details, and Supply in full details also any and all legal court documents, docket reports, court ledgers, letters, faxes, text, memos, emails, “filed motion for withdrawal of counsel” in support thereof from the exact date of October 1s t 2009 throughout the exact dates of November 1s t 2009













(22)

Explain in full expert “Attorney at Law” details, and Supply in full details also any and all legal court documents, docket reports, court ledgers, letters, faxes, text, memos, emails, “filed motions for withdrawal of counsel” all records in support thereof from the exact date of December 18th 2007 throughout the exact dates of January1s t 2008

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” Bar No. 24058299 herein

Was not legally representing any “material physical fact’s in the professional legal public capacity as a acting “Attorney at Law“ In and for the “Sate of Texas” Bar No. 24058299

Before the 58th Judicial District Court of Jefferson County Texas described herein thereafter

Namely said “Honorable Judge Bob Wortham”

Herein in connection with one “Joyce M. Guy and Edward McCray” hereafter Co-Defendant(s) collectively

In a civil suit in the 58th Judicial District Court of Jefferson County Texas filed in Cause No. A-180805 in Jefferson County Texas.

In that Namely exactly “Antoine L. Freeman, J.D. “Attorney at Law” Texas Bar No. 24058299” (active) within the “State of Texas” was not providing such any physical presentation, representation and appearance thereof as acting “Attorney at Record Law services” for the full skilled “legal behalf” and “retain interest” thereafter December 18th 2007 throughout January1st 2008

In a civil suit in the 58th Judicial District Court of Jefferson County Texas filed in Cause No. A-180805

Before an “Honorable Court of Law” in cause No. A-180805 filed in the Jefferson County Texas Courthouse November 26th 2007


In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein explaining he was not making Public Representation, presentation in the Profession as a “skilled counsel of law” Before the “Honorable Judge Bob Wortham, the “Honorable Judge Bob Wortham” staff namely “Ms. Sydney Moreau”, the Court reporters, and the court bailiff’s, thereafter December 18th 2007 throughout January1st 2008

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any Public Representation, presentation in the Profession as a “skilled counsel of law” Before The Jefferson County Clerk of Court “Lolita Ramos”,

And all (active) Deputy Clerks acting on behalf of said Jefferson County Clerk of Court “Lolita Ramos, involved in the records thereof, filed as Pro Se Plaintiff attached Document(s) # 1 and Documents # 11herein

Namely” the 58th Judicial District Court of Jefferson County Texas “Case Ledger” for Cause No. A-180805

Namely” the 58th Judicial District Court of Jefferson County Texas “Civil Docket report” for cause No. A-180805

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not physically acting as “Attorney of Record” before the 58th Judicial District Court of Jefferson County Texas for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” at no physical time frame other then retain filing services for December 18th 2007 “General Denial” paid services render (only).

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not filing any legal court documents for their legal behalf of said Co-Defendant(s) collectively through the “United States Mailing System” thereafter December 18th 2007 throughout January1st 2008

And forwarding such to the “Honorable Judge Bob Wortham, to the “Honorable Judge Bob Wortham” staff namely “Ms. Sydney Moreau”, to The Jefferson County Clerk of Court “Lolita Ramos”,




With direct Usage of the “United States Mailing System” surround civil court event thereafter December 18th 2007 throughout January1st 2008 for their legal behalf of said Co-Defendant(s) collectively through the “United States Mailing System”

Namely in that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not physically executing the usage of the “United States Mailing System” in the capacity of acting “Attorney of Record” thereafter December 18th 2007 throughout January1st 2008

For the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” at no physical time frame other then retain filing services for December 18 th 2007 “General Denial” paid services render (only).

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not physically involved with inner actions on live “court transcripts” with the 58th Court reporters thereafter December 18th 2007 throughout January1s t 2008 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not present before the 58th Judicial District Court of Jefferson County Texas bailiff’s, thereafter the time frame of December 18th 2007 throughout January1s t 2008

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation, presentation of material facts as acting “Attorney of record” Before the “Honorable Judge Bob Wortham”, thereafter the date of December 18th 2007 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation, presentation of material facts as acting “Attorney of record” before The “Honorable Judge Bob Wortham” staff namely “Ms. Sydney Moreau”, thereafter the Date of December 18th 2007

throughout January1s t 2008 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation, presentation of material facts as acting “Attorney of record” before the Jefferson County Clerk “Lolita Ramos”, record office of Jefferson County Texas thereafter the Date of December 18th 2007 throughout January1st 2008 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not involved in any “attorney/client”, work product thereof, and making such a presentations and representations of “material facts” as acting physically in the professional capacity of acting “Attorney of record”

Before the “Honorable Judge Bob Wortham”, against said Pro Se Plaintiff “Louis Charles Hamilton II” herein subject matter in complaint against the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” thereafter December 18th 2007 throughout January1st 2008 in cause No. A-180805

“Meaning” in that Chief Defendant “Antoine L. Freeman, J.D. “Attorney at Law” Texas Bar No240582299 was not in any shape or form involved in any “attorney/client”, work product thereof, “attorney/client” communications thereof,

And making such a physical presentations and representations of “material facts” as acting physically in the professional capacity of acting “Attorney of record”.

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was (Only) acting in the “legal capacitates” as a Attorney at Law to file a General Denial (Only) on December 18th 2007

To “simply” reply in the Complaint A-180805 made against Co-Defendant(s) “Joyce M. Guy and Edward McCray” ( Herein ) collectively and such “legal attorney at law retain services” ended thereafter the exact date of December 18th 2007

In a civil suit in the 58th Judicial District Court of Jefferson County Texas filed in Cause No. A-180805 that you Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” were legally retain for such legal services to file a General Denial (Only)

Regarding a “Breach of Construction Contract” in excess of $10,800.00 U.S. Dollars as described by “You” Defendant (Attorney at Law) your only being retain for services, and contract for all legal services thereof required for such professional legal services to file a simple “General Denial” (Only) on December 18th 2007

As described in Pro Se Plaintiff attached Document # 2 herein

“Your” response to Pro Se Plaintiff Motion for Sanction against “You” Chief Defendant “Antoine L. Freeman, J.D. “Attorney at Law” Texas Bar No. 24058299 herein describing your “legal attorney at law retain services” ended thereafter the exact date of December 18th 2007


Surrounding Pro Se Plaintiff claims of a chain of fraudulent events as a result of Hurricane Rita, Humberto and Ike for said dwelling and the property located at 448 DeQueen Blvd. in Port Arthur Texas. (Block 172, Lot 1-2) in connection with Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein.

Subpart (A)

Explain in full expert “Attorney at Law” details, and Supply in full details also any and all legal court documents, docket reports, court ledgers, letters, faxes, text, memos, emails, “filed motions for withdrawal of counsel” all records in support thereof from the exact date of January1st 2008 throughout the exact dates of February 1s t 2008







In that Namely exactly “Antoine L. Freeman, J.D. “Attorney at Law” Texas Bar No. 24058299” (active) within the “State of Texas” was not providing such any physical presentation, representation and appearance thereof as acting “Attorney at Record Law services” for the full skilled “legal behalf” and “retain interest” thereafter January1s t 2008 throughout the exact dates of February 1s t 2008




In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein explaining he was not making Public Representation, presentation in the Profession as a “skilled counsel of law” Before the “Honorable Judge Bob Wortham, the “Honorable Judge Bob Wortham” staff namely “Ms. Sydney Moreau”, the Court reporters, and the court bailiff’s, thereafter January1s t 2008 throughout the exact dates of February 1s t 2008





In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not physically acting as “Attorney of Record” before the 58 th Judicial District Court of Jefferson County Texas for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” at no physical time frame other then retain filing services for December 18th 2007 “General Denial” paid services render (only).

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not filing any legal court documents for their legal behalf of said Co-Defendant(s) collectively through the “United States Mailing System” thereafter January1s t 2008 throughout the exact dates of February 1s t 2008





With direct Usage of the “United States Mailing System” surround civil court event thereafter January1s t 2008 throughout the exact dates of February 1s t 2008 for their legal behalf of said Co-Defendant(s) collectively through the “United States Mailing System”

Namely in that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not physically executing the usage of the “United States Mailing System” in the capacity of acting “Attorney of Record” thereafter January1s t 2008 throughout the exact dates of February 1s t 2008


In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not physically involved with inner actions on live “court transcripts” with the 58th Court reporters thereafter January1s t 2008 throughout the exact dates of February 1s t 2008 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not present before the 58th Judicial District Court of Jefferson County Texas bailiff’s, thereafter the time frame of January1st 2008 throughout the exact dates of February 1s t 2008

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation, presentation of material facts as acting “Attorney of record” Before the “Honorable Judge Bob Wortham”, thereafter the date of January1s t 2008 throughout the exact dates of February 1s t 2008 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation, presentation of material facts as acting “Attorney of record” before The “Honorable Judge Bob Wortham” staff namely “Ms. Sydney Moreau”, thereafter the Date of January1s t 2008 throughout

the exact dates of February 1s t 2008 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation, presentation of material facts as acting “Attorney of record” before the Jefferson County Clerk “Lolita Ramos”, record office of Jefferson County Texas thereafter the Date of January1s t 2008 throughout the exact dates of February 1s t 2008 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805


Before the “Honorable Judge Bob Wortham”, against said Pro Se Plaintiff “Louis Charles Hamilton II” herein subject matter in complaint against the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” thereafter January1s t 2008 throughout the exact dates of February 1s t 2008 in cause No. A-180805











Subpart (B)

Continue Explain in full expert “Attorney at Law” details, and Supply in full details also any and all legal court documents, docket reports, court ledgers, letters, faxes, text, memos, emails, “filed motions for withdrawal of counsel” all records in support thereof from the exact date of February 1s t 2008 throughout the exact dates of March 1s t 2008







In that Namely exactly “Antoine L. Freeman, J.D. “Attorney at Law” Texas Bar No. 24058299” (active) within the “State of Texas” was not providing such any physical presentation, representation and appearance thereof as acting “Attorney at Record Law services” for the full skilled “legal behalf” and “retain interest” thereafter February 1s t 2008 throughout the exact dates of March 1s t 2008




In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein explaining he was not making Public Representation, presentation in the Profession as a “skilled counsel of law” Before the “Honorable Judge Bob Wortham, the “Honorable Judge Bob Wortham” staff namely “Ms. Sydney Moreau”, the Court reporters, and the court bailiff’s, thereafter February 1s t 2008 throughout the exact dates of March 1s t 2008






In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not filing any legal court documents for their legal behalf of said Co-Defendant(s) collectively through the “United States Mailing System” thereafter February 1s t 2008 throughout the exact dates of March 1s t 2008





With direct Usage of the “United States Mailing System” surround civil court event thereafter February 1s t 2008 throughout the exact dates of March 1s t 2008 for their legal behalf of said Co-Defendant(s) collectively through the “United States Mailing System”

Namely in that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not physically executing the usage of the “United States Mailing System” in the capacity of acting “Attorney of Record” thereafter February 1s t 2008 throughout the exact dates of March 1s t 2008


In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not physically involved with inner actions on live “court transcripts” with the 58th Court reporters thereafter February 1s t 2008 throughout the exact dates of March 1s t 2008 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not present before the 58th Judicial District Court of Jefferson County Texas bailiff’s, thereafter the time frame of February 1s t 2008 throughout the exact dates of March 1s t 2008

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation, presentation of material facts as acting “Attorney of record” Before the “Honorable Judge Bob Wortham”, thereafter the date of December 18th 2007 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation, presentation of material facts as acting “Attorney of record” before The “Honorable Judge Bob Wortham” staff namely “Ms. Sydney Moreau”, thereafter the Date of February 1s t 2008

throughout the exact dates of March 1s t 2008 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation, presentation of material facts as acting “Attorney of record” before the Jefferson County Clerk “Lolita Ramos”, record office of Jefferson County Texas thereafter the Date of February 1s t 2008 throughout the exact dates of March 1s t 2008 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805


Before the “Honorable Judge Bob Wortham”, against said Pro Se Plaintiff “Louis Charles Hamilton II” herein subject matter in complaint against the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” thereafter February 1s t 2008 throughout the exact dates of March 1s t 2008 in cause No. A-180805











Subpart (C)

Continue Explain in full expert “Attorney at Law” details, and Supply in full details also any and all legal court documents, docket reports, court ledgers, letters, faxes, text, memos, emails, “filed motions for withdrawal of counsel” all records in support thereof from the exact date of March 1s t 2008 throughout the exact dates of April 1s t 2008







In that Namely exactly “Antoine L. Freeman, J.D. “Attorney at Law” Texas Bar No. 24058299” (active) within the “State of Texas” was not providing such any physical presentation, representation and appearance thereof as acting “Attorney at Record Law services” for the full skilled “legal behalf” and “retain interest” thereafter March 1s t 2008 throughout the exact dates of April 1s t 2008




In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein explaining he was not making Public Representation, presentation in the Profession as a “skilled counsel of law” Before the “Honorable Judge Bob Wortham, the “Honorable Judge Bob Wortham” staff namely “Ms. Sydney Moreau”, the Court reporters, and the court bailiff’s, thereafter March 1s t 2008 throughout the exact dates of April 1s t 2008






In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not filing any legal court documents for their legal behalf of said Co-Defendant(s) collectively through the “United States Mailing System” thereafter March 1s t 2008 throughout the exact dates of April 1s t 2008





With direct Usage of the “United States Mailing System” surround civil court event thereafter March 1s t 2008 throughout the exact dates of April 1s t 2008 for their legal behalf of said Co-Defendant(s) collectively through the “United States Mailing System”

Namely in that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not physically executing the usage of the “United States Mailing System” in the capacity of acting “Attorney of Record” thereafter March 1s t 2008 throughout the exact dates of April 1s t 2008

For the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” at no physical time frame other then retain filing services for December 18th 2007 “General Denial” paid services render (only).

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not physically involved with inner actions on live “court transcripts” with the 58th Court reporters thereafter March 1s t 2008 throughout the exact dates of April 1s t 2008 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not present before the 58th Judicial District Court of Jefferson County Texas bailiff’s, thereafter the time frame of March 1s t 2008 throughout the exact dates of April 1s t 2008

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation, presentation of material facts as acting “Attorney of record” Before the “Honorable Judge Bob Wortham”, thereafter the date of March 1s t 2008 throughout the exact dates of April 1s t 2008 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation, presentation of material facts as acting “Attorney of record” before The “Honorable Judge Bob Wortham” staff namely “Ms. Sydney Moreau”, thereafter the Date of March 1s t 2008 throughout

the exact dates of April 1s t 2008 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation, presentation of material facts as acting “Attorney of record” before the Jefferson County Clerk “Lolita Ramos”, record office of Jefferson County Texas thereafter the Date of March 1s t 2008 throughout the exact dates of April 1s t 2008 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805


Before the “Honorable Judge Bob Wortham”, against said Pro Se Plaintiff “Louis Charles Hamilton II” herein subject matter in complaint against the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” thereafter March 1s t 2008 throughout the exact dates of April 1s t 2008 in cause No. A-180805











Subpart (D)

Explain in full expert “Attorney at Law” details, and Supply in full details also any and all legal court documents, docket reports, court ledgers, letters, faxes, text, memos, emails, “filed motions for withdrawal of counsel” all records in support thereof from the exact date of April 1s t 2008 throughout the exact dates of May 1s t 2008







In that Namely exactly “Antoine L. Freeman, J.D. “Attorney at Law” Texas Bar No. 24058299” (active) within the “State of Texas” was not providing such any physical presentation, representation and appearance thereof as acting “Attorney at Record Law services” for the full skilled “legal behalf” and “retain interest” thereafter April 1s t 2008 throughout the exact dates of May 1s t 2008




In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein explaining he was not making Public Representation, presentation in the Profession as a “skilled counsel of law” Before the “Honorable Judge Bob Wortham, the “Honorable Judge Bob Wortham” staff namely “Ms. Sydney Moreau”, the Court reporters, and the court bailiff’s, thereafter April 1s t 2008 throughout the exact dates of May 1s t 2008






In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not filing any legal court documents for their legal behalf of said Co-Defendant(s) collectively through the “United States Mailing System” thereafter April 1s t 2008 throughout the exact dates of May 1s t 2008





With direct Usage of the “United States Mailing System” surround civil court event thereafter April 1s t 2008 throughout the exact dates of May 1s t 2008 for their legal behalf of said Co-Defendant(s) collectively through the “United States Mailing System”

Namely in that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not physically executing the usage of the “United States Mailing System” in the capacity of acting “Attorney of Record” thereafter April 1s t 2008 throughout the exact dates of May 1s t 2008


In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not physically involved with inner actions on live “court transcripts” with the 58th Court reporters thereafter April 1s t 2008 throughout the exact dates of May 1s t 2008 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not present before the 58th Judicial District Court of Jefferson County Texas bailiff’s, thereafter the time frame of April 1s t 2008 throughout the exact dates of May 1s t 2008

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation, presentation of material facts as acting “Attorney of record” Before the “Honorable Judge Bob Wortham”, thereafter the date of April 1s t 2008 throughout the exact dates of May 1s t 2008 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation, presentation of material facts as acting “Attorney of record” before The “Honorable Judge Bob Wortham” staff namely “Ms. Sydney Moreau”, thereafter the Date of April 1s t 2008 throughout

the exact dates of May 1s t 2008 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation, presentation of material facts as acting “Attorney of record” before the Jefferson County Clerk “Lolita Ramos”, record office of Jefferson County Texas thereafter the Date of April 1s t 2008 throughout the exact dates of May 1s t 2008 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805


Before the “Honorable Judge Bob Wortham”, against said Pro Se Plaintiff “Louis Charles Hamilton II” herein subject matter in complaint against the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” thereafter April 1s t 2008 throughout the exact dates of May 1s t 2008 in cause No. A-180805











Subpart (E)

Explain in full expert “Attorney at Law” details, and Supply in full details also any and all legal court documents, docket reports, court ledgers, letters, faxes, text, memos, emails, “filed motions for withdrawal of counsel” all records in support thereof from the exact date of May 1s t 2008 throughout the exact dates of June 1s t 2008







In that Namely exactly “Antoine L. Freeman, J.D. “Attorney at Law” Texas Bar No. 24058299” (active) within the “State of Texas” was not providing such any physical presentation, representation and appearance thereof as acting “Attorney at Record Law services” for the full skilled “legal behalf” and “retain interest” thereafter May 1s t 2008 throughout the exact dates of Jun 1s t 2008




In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein explaining he was not making Public Representation, presentation in the Profession as a “skilled counsel of law” Before the “Honorable Judge Bob Wortham, the “Honorable Judge Bob Wortham” staff namely “Ms. Sydney Moreau”, the Court reporters, and the court bailiff’s, thereafter May 1s t 2008 throughout the exact dates of June 1s t 2008






In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not filing any legal court documents for their legal behalf of said Co-Defendant(s) collectively through the “United States Mailing System” thereafter May 1s t 2008 throughout the exact dates of June 1s t 2008





With direct Usage of the “United States Mailing System” surround civil court event thereafter May 1s t 2008 throughout the exact dates of June 1s t 2008 for their legal behalf of said Co-Defendant(s) collectively through the “United States Mailing System”

Namely in that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not physically executing the usage of the “United States Mailing System” in the capacity of acting “Attorney of Record” thereafter May 1s t 2008 throughout the exact dates of June 1s t 2008


In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not physically involved with inner actions on live “court transcripts” with the 58th Court reporters thereafter May 1s t 2008 throughout the exact dates of June 1s t 2008 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not present before the 58th Judicial District Court of Jefferson County Texas bailiff’s, thereafter the time frame of May 1s t 2008 throughout the exact dates of June 1s t 2008

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation, presentation of material facts as acting “Attorney of record” Before the “Honorable Judge Bob Wortham”, thereafter the date of May 1s t 2008 throughout the exact dates of June 1s t 2008 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation, presentation of material facts as acting “Attorney of record” before The “Honorable Judge Bob Wortham” staff namely “Ms. Sydney Moreau”, thereafter the Date of May 1s t 2008 throughout

the exact dates of JUne 1s t 2008 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation, presentation of material facts as acting “Attorney of record” before the Jefferson County Clerk “Lolita Ramos”, record office of Jefferson County Texas thereafter the Date of May 1s t 2008 throughout the exact dates of June 1s t 2008 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805


Before the “Honorable Judge Bob Wortham”, against said Pro Se Plaintiff “Louis Charles Hamilton II” herein subject matter in complaint against the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” thereafter May 1s t 2008 throughout the exact dates of June 1s t 2008 in cause No. A-180805











Subpart (F)

Explain in full expert “Attorney at Law” details, and Supply in full details also any and all legal court documents, docket reports, court ledgers, letters, faxes, text, memos, emails, “filed motions for withdrawal of counsel” all records in support thereof from the exact date of June 1s t 2008 throughout the exact dates of July 1s t 2008







In that Namely exactly “Antoine L. Freeman, J.D. “Attorney at Law” Texas Bar No. 24058299” (active) within the “State of Texas” was not providing such any physical presentation, representation and appearance thereof as acting “Attorney at Record Law services” for the full skilled “legal behalf” and “retain interest” thereafter June 1s t 2008 throughout the exact dates of July 1s t 2008




In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein explaining he was not making Public Representation, presentation in the Profession as a “skilled counsel of law” Before the “Honorable Judge Bob Wortham, the “Honorable Judge Bob Wortham” staff namely “Ms. Sydney Moreau”, the Court reporters, and the court bailiff’s, thereafter June 1s t 2008 throughout the exact dates of July 1s t 2008






In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not filing any legal court documents for their legal behalf of said Co-Defendant(s) collectively through the “United States Mailing System” thereafter June 1s t 2008 throughout the exact dates of July 1s t 2008





With direct Usage of the “United States Mailing System” surround civil court event thereafter June 1s t 2008 throughout the exact dates of July 1s t 2008 for their legal behalf of said Co-Defendant(s) collectively through the “United States Mailing System”

Namely in that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not physically executing the usage of the “United States Mailing System” in the capacity of acting “Attorney of Record” thereafter June 1s t 2008 throughout the exact dates of July 1s t 2008


In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not physically involved with inner actions on live “court transcripts” with the 58th Court reporters thereafter June 1s t 2008 throughout the exact dates of July 1s t 2008 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not present before the 58th Judicial District Court of Jefferson County Texas bailiff’s, thereafter the time frame of June 1s t 2008 throughout the exact dates of July 1s t 2008

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation, presentation of material facts as acting “Attorney of record” Before the “Honorable Judge Bob Wortham”, thereafter the date of June 1s t 2008 throughout the exact dates of July 1s t 2008 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation, presentation of material facts as acting “Attorney of record” before The “Honorable Judge Bob Wortham” staff namely “Ms. Sydney Moreau”, thereafter the Date of June 1s t 2008 throughout

the exact dates of July 1s t 2008 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation, presentation of material facts as acting “Attorney of record” before the Jefferson County Clerk “Lolita Ramos”, record office of Jefferson County Texas thereafter the Date of June 1s t 2008 throughout the exact dates of July 1s t 2008 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805


Before the “Honorable Judge Bob Wortham”, against said Pro Se Plaintiff “Louis Charles Hamilton II” herein subject matter in complaint against the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” thereafter June 1s t 2008 throughout the exact dates of July 1s t 2008 in cause No. A-180805











Subpart (G)

Explain in full expert “Attorney at Law” details, and Supply in full details also any and all legal court documents, docket reports, court ledgers, letters, faxes, text, memos, emails, “filed motions for withdrawal of counsel” all records in support thereof from the exact date of June 1s t 2008 throughout the exact dates of July 1s t 2008







In that Namely exactly “Antoine L. Freeman, J.D. “Attorney at Law” Texas Bar No. 24058299” (active) within the “State of Texas” was not providing such any physical presentation, representation and appearance thereof as acting “Attorney at Record Law services” for the full skilled “legal behalf” and “retain interest” thereafter June 1s t 2008 throughout the exact dates of July 1s t 2008




In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein explaining he was not making Public Representation, presentation in the Profession as a “skilled counsel of law” Before the “Honorable Judge Bob Wortham, the “Honorable Judge Bob Wortham” staff namely “Ms. Sydney Moreau”, the Court reporters, and the court bailiff’s, thereafter June 1s t 2008 throughout the exact dates of July 1s t 2008






In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not filing any legal court documents for their legal behalf of said Co-Defendant(s) collectively through the “United States Mailing System” thereafter June 1s t 2008 throughout the exact dates of July 1s t 2008





With direct Usage of the “United States Mailing System” surround civil court event thereafter June 1s t 2008 throughout the exact dates of July 1s t 2008 for their legal behalf of said Co-Defendant(s) collectively through the “United States Mailing System”

Namely in that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not physically executing the usage of the “United States Mailing System” in the capacity of acting “Attorney of Record” thereafter June 1s t 2008 throughout the exact dates of July 1s t 2008


In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not physically involved with inner actions on live “court transcripts” with the 58th Court reporters thereafter June 1s t 2008 throughout the exact dates of July 1s t 2008 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not present before the 58th Judicial District Court of Jefferson County Texas bailiff’s, thereafter the time frame of June 1s t 2008 throughout the exact dates of July 1s t 2008

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation, presentation of material facts as acting “Attorney of record” Before the “Honorable Judge Bob Wortham”, thereafter the date of June 1s t 2008 throughout the exact dates of July 1s t 2008 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation, presentation of material facts as acting “Attorney of record” before The “Honorable Judge Bob Wortham” staff namely “Ms. Sydney Moreau”, thereafter the Date of June 1s t 2008 throughout

the exact dates of July 1s t 2008 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation, presentation of material facts as acting “Attorney of record” before the Jefferson County Clerk “Lolita Ramos”, record office of Jefferson County Texas thereafter the Date of June 1s t 2008 throughout the exact dates of July 1s t 2008 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805


Before the “Honorable Judge Bob Wortham”, against said Pro Se Plaintiff “Louis Charles Hamilton II” herein subject matter in complaint against the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” thereafter June 1s t 2008 throughout the exact dates of July 1s t 2008 in cause No. A-180805











Subpart (H)

Explain in full expert “Attorney at Law” details, and Supply in full details also any and all legal court documents, docket reports, court ledgers, letters, faxes, text, memos, emails, “filed motions for withdrawal of counsel” all records in support thereof from the exact date of July 1s t 2008 throughout the exact dates of August 1s t 2008







In that Namely exactly “Antoine L. Freeman, J.D. “Attorney at Law” Texas Bar No. 24058299” (active) within the “State of Texas” was not providing such any physical presentation, representation and appearance thereof as acting “Attorney at Record Law services” for the full skilled “legal behalf” and “retain interest” thereafter July 1s t 2008 throughout the exact dates of August 1s t 2008




In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein explaining he was not making Public Representation, presentation in the Profession as a “skilled counsel of law” Before the “Honorable Judge Bob Wortham, the “Honorable Judge Bob Wortham” staff namely “Ms. Sydney Moreau”, the Court reporters, and the court bailiff’s, thereafter July 1s t 2008 throughout the exact dates of August 1s t 2008






In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not filing any legal court documents for their legal behalf of said Co-Defendant(s) collectively through the “United States Mailing System” thereafter July 1s t 2008 throughout the exact dates of August 1s t 2008





With direct Usage of the “United States Mailing System” surround civil court event thereafter July 1s t 2008 throughout the exact dates of August 1s t 2008 for their legal behalf of said Co-Defendant(s) collectively through the “United States Mailing System”

Namely in that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not physically executing the usage of the “United States Mailing System” in the capacity of acting “Attorney of Record” thereafter July 1s t 2008 throughout the exact dates of August 1s t 2008


In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not physically involved with inner actions on live “court transcripts” with the 58th Court reporters thereafter July 1s t 2008 throughout the exact dates of August 1s t 2008 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not present before the 58th Judicial District Court of Jefferson County Texas bailiff’s, thereafter the time frame of July 1s t 2008 throughout the exact dates of August 1s t 2008

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation, presentation of material facts as acting “Attorney of record” Before the “Honorable Judge Bob Wortham”, thereafter the date of July 1s t 2008 throughout the exact dates of August 1s t 2008 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation, presentation of material facts as acting “Attorney of record” before The “Honorable Judge Bob Wortham” staff namely “Ms. Sydney Moreau”, thereafter the Date of July 1s t 2008 throughout the

exact dates of August 1s t 2008 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation, presentation of material facts as acting “Attorney of record” before the Jefferson County Clerk “Lolita Ramos”, record office of Jefferson County Texas thereafter the Date of July 1s t 2008 throughout the exact dates of August 1s t 2008 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805


Before the “Honorable Judge Bob Wortham”, against said Pro Se Plaintiff “Louis Charles Hamilton II” herein subject matter in complaint against the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” thereafter July 1s t 2008 throughout the exact dates of August 1s t 2008 in cause No. A-180805











Subpart (I)

Explain in full expert “Attorney at Law” details, and Supply in full details also any and all legal court documents, docket reports, court ledgers, letters, faxes, text, memos, emails, “filed motions for withdrawal of counsel” all records in support thereof from the exact date of August 1s t 2008 throughout the exact dates of September 1s t 2008







In that Namely exactly “Antoine L. Freeman, J.D. “Attorney at Law” Texas Bar No. 24058299” (active) within the “State of Texas” was not providing such any physical presentation, representation and appearance thereof as acting “Attorney at Record Law services” for the full skilled “legal behalf” and “retain interest” thereafter August 1s t 2008 throughout the exact dates of September 1s t 2008




In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein explaining he was not making Public Representation, presentation in the Profession as a “skilled counsel of law” Before the “Honorable Judge Bob Wortham, the “Honorable Judge Bob Wortham” staff namely “Ms. Sydney Moreau”, the Court reporters, and the court bailiff’s, thereafter August 1s t 2008 throughout the exact dates of September 1s t 2008






In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not filing any legal court documents for their legal behalf of said Co-Defendant(s) collectively through the “United States Mailing System” thereafter August 1s t 2008 throughout the exact dates of September 1s t 2008





With direct Usage of the “United States Mailing System” surround civil court event thereafter June 1s t 2008 throughout the exact dates of August 1s t 2008 throughout the exact dates of September 1s t 2008 for their legal behalf of said Co-Defendant(s) collectively through the “United States Mailing System”

Namely in that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not physically executing the usage of the “United States Mailing System” in the capacity of acting “Attorney of Record” thereafter August 1s t 2008 throughout the exact dates of September 1s t 2008


In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not physically involved with inner actions on live “court transcripts” with the 58th Court reporters thereafter August 1s t 2008 throughout the exact dates of September 1s t 2008 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not present before the 58th Judicial District Court of Jefferson County Texas bailiff’s, thereafter the time frame of August 1s t 2008 throughout the exact dates of September 1s t 2008

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation, presentation of material facts as acting “Attorney of record” Before the “Honorable Judge Bob Wortham”, thereafter the date of August 1s t 2008 throughout the exact dates of September 1s t 2008 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation, presentation of material facts as acting “Attorney of record” before The “Honorable Judge Bob Wortham” staff namely “Ms. Sydney Moreau”, thereafter the Date of August 1s t 2008 throughout

the exact dates of September 1s t 2008 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation, presentation of material facts as acting “Attorney of record” before the Jefferson County Clerk “Lolita Ramos”, record office of Jefferson County Texas thereafter the Date of August 1s t 2008 throughout the exact dates of September 1s t 2008 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805


Before the “Honorable Judge Bob Wortham”, against said Pro Se Plaintiff “Louis Charles Hamilton II” herein subject matter in complaint against the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” thereafter August 1s t 2008 throughout the exact dates of September 1s t 2008 in cause No. A-180805











Subpart (J)

















In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not physically acting as “Attorney of Record” before the 58th Judicial District Court of Jefferson County Texas for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” at no physical time frame other then retain filing services for December 18th 2007 “General Denial” paid services render (only).



























Subpart (K)












































Subpart (L)

Explain in full expert “Attorney at Law” details, and Supply in full details also any and all legal court documents, docket reports, court ledgers, letters, faxes, text, memos, emails, “filed motions for withdrawal of counsel” all records in support thereof from the exact date of September 1s t 2008 throughout the exact dates of October 1s t 2008







In that Namely exactly “Antoine L. Freeman, J.D. “Attorney at Law” Texas Bar No. 24058299” (active) within the “State of Texas” was not providing such any physical presentation, representation and appearance thereof as acting “Attorney at Record Law services” for the full skilled “legal behalf” and “retain interest” thereafter September 1s t 2008 throughout the exact dates of October 1s t 2008




In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein explaining he was not making Public Representation, presentation in the Profession as a “skilled counsel of law” Before the “Honorable Judge Bob Wortham, the “Honorable Judge Bob Wortham” staff namely “Ms. Sydney Moreau”, the Court reporters, and the court bailiff’s, thereafter September 1s t 2008 throughout the exact dates of October 1s t 2008






In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not filing any legal court documents for their legal behalf of said Co-Defendant(s) collectively through the “United States Mailing System” thereafter September 1s t 2008 throughout the exact dates of October 1s t 2008





With direct Usage of the “United States Mailing System” surround civil court event thereafter June 1s t 2008 throughout the exact dates of August 1s t 2008 throughout the exact dates of September 1s t 2008 throughout the exact dates of October 1s t 2008 for their legal behalf of said Co-Defendant(s) collectively through the “United States Mailing System”

Namely in that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not physically executing the usage of the “United States Mailing System” in the capacity of acting “Attorney of Record” thereafter September 1s t 2008 throughout the exact dates of October 1s t 2008




In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation, presentation of material facts as acting “Attorney of record” Before the “Honorable Judge Bob Wortham”, thereafter the date of September 1s t 2008 throughout the exact dates of October 1s t 2008 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation, presentation of material facts as acting “Attorney of record” before The “Honorable Judge Bob Wortham” staff

namely “Ms. Sydney Moreau”, thereafter the Date of September 1s t 2008 throughout the exact dates of October 1s t 2008 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation, presentation of material facts as acting “Attorney of record” before the Jefferson County Clerk “Lolita Ramos”, record office of Jefferson County Texas thereafter the Date of September 1s t 2008 throughout the exact dates of October 1s t 2008 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805


Before the “Honorable Judge Bob Wortham”, against said Pro Se Plaintiff “Louis Charles Hamilton II” herein subject matter in complaint against the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” thereafter September 1s t 2008 throughout the exact dates of October 1s t 2008 in cause No. A-180805











(M)

Explain in full expert “Attorney at Law” details, and Supply in full details also any and all legal court documents, docket reports, court ledgers, letters, faxes, text, memos, emails, “filed motions for withdrawal of counsel” all records in support thereof from the exact date of October 1s t 2008 throughout the exact dates of November 1s t 2008







In that Namely exactly “Antoine L. Freeman, J.D. “Attorney at Law” Texas Bar No. 24058299” (active) within the “State of Texas” was not providing such any physical presentation, representation and appearance thereof as acting “Attorney at Record Law services” for the full skilled “legal behalf” and “retain interest” thereafter October 1s t 2008 throughout the exact dates of November 1s t 2008




In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein explaining he was not making Public Representation, presentation in the Profession as a “skilled counsel of law” Before the “Honorable Judge Bob Wortham, the “Honorable Judge Bob Wortham” staff namely “Ms. Sydney Moreau”, the Court reporters, and the court bailiff’s, thereafter October 1s t 2008 throughout the exact dates of November 1s t 2008






In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not filing any legal court documents for their legal behalf of said Co-Defendant(s) collectively through the “United States Mailing System” thereafter October 1s t 2008 throughout the exact dates of November 1s t 2008





With direct Usage of the “United States Mailing System” surround civil court event thereafter June 1s t 2008 throughout the exact dates of October 1s t 2008 throughout the exact dates of November 1s t 2008 for their legal behalf of said Co-Defendant(s) collectively through the “United States Mailing System”

Namely in that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not physically executing the usage of the “United States Mailing System” in the capacity of acting “Attorney of Record” thereafter October 1s t 2008 throughout the exact dates of November 1s t 2008



In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not present before the 58th Judicial District Court of Jefferson County Texas bailiff’s, thereafter the time frame of October 1s t 2008 throughout the exact dates of November 1s t 2008

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation, presentation of material facts as acting “Attorney of record” Before the “Honorable Judge Bob Wortham”, thereafter the date of October 1s t 2008 throughout the exact dates of November 1s t 2008 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation, presentation of material facts as acting “Attorney of record” before The “Honorable Judge Bob Wortham” staff namely “Ms. Sydney Moreau”, thereafter the Date of October 1s t 2008

throughout the exact dates of November 1s t 2008 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation, presentation of material facts as acting “Attorney of record” before the Jefferson County Clerk “Lolita Ramos”, record office of Jefferson County Texas thereafter the Date of October 1s t 2008 throughout the exact dates of November 1s t 2008 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805


Before the “Honorable Judge Bob Wortham”, against said Pro Se Plaintiff “Louis Charles Hamilton II” herein subject matter in complaint against the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” thereafter October 1s t 2008 throughout the exact dates of November 1s t 2008 in cause No. A-180805











Subpart (N)

Explain in full expert “Attorney at Law” details, and Supply in full details also any and all legal court documents, docket reports, court ledgers, letters, faxes, text, memos, emails, “filed motions for withdrawal of counsel” all records in support thereof from the exact date of November 1s t 2008 throughout the exact dates of December 1s t 2008







In that Namely exactly “Antoine L. Freeman, J.D. “Attorney at Law” Texas Bar No. 24058299” (active) within the “State of Texas” was not providing such any physical presentation, representation and appearance thereof as acting “Attorney at Record Law services” for the full skilled “legal behalf” and “retain interest” thereafter November 1s t 2008 throughout the exact dates of December 1s t 2008




In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein explaining he was not making Public Representation, presentation in the Profession as a “skilled counsel of law” Before the “Honorable Judge Bob Wortham, the “Honorable Judge Bob Wortham” staff namely “Ms. Sydney Moreau”, the Court reporters, and the court bailiff’s, thereafter November 1s t 2008 throughout the exact dates of December 1s t 2008






In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not filing any legal court documents for their legal behalf of said Co-Defendant(s) collectively through the “United States Mailing System” thereafter November 1s t 2008 throughout the exact dates of December 1s t 2008





With direct Usage of the “United States Mailing System” surround civil court event thereafter November 1s t 2008 throughout the exact dates of December 1s t 2008 for their legal behalf of said Co-Defendant(s) collectively through the “United States Mailing System”

Namely in that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not physically executing the usage of the “United States Mailing System” in the capacity of acting “Attorney of Record” thereafter November 1s t 2008 throughout the exact dates of December 1s t 2008



In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not present before the 58th Judicial District Court of Jefferson County Texas bailiff’s, thereafter the time frame of November 1s t 2008 throughout the exact dates of December 1s t 2008

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation, presentation of material facts as acting “Attorney of record” Before the “Honorable Judge Bob Wortham”, thereafter the date of November 1s t 2008 throughout the exact dates of December 1s t 2008 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation, presentation of material facts as acting “Attorney of record” before The “Honorable Judge Bob Wortham” staff namely “Ms. Sydney Moreau”, thereafter the Date of November 1s t 2008

throughout the exact dates of December 1s t 2008 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation, presentation of material facts as acting “Attorney of record” before the Jefferson County Clerk “Lolita Ramos”, record office of Jefferson County Texas thereafter the Date of November 1s t 2008 throughout the exact dates of December 1s t 2008 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805


Before the “Honorable Judge Bob Wortham”, against said Pro Se Plaintiff “Louis Charles Hamilton II” herein subject matter in complaint against the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” thereafter November 1s t 2008 throughout the exact dates of December 1s t 2008 in cause No. A-180805











Subpart (O)

Explain in full expert “Attorney at Law” details, and Supply in full details also any and all legal court documents, docket reports, court ledgers, letters, faxes, text, memos, emails, “filed motions for withdrawal of counsel” all records in support thereof from the exact date of December 1s t 2008 throughout the exact dates of January 1s t 2009







In that Namely exactly “Antoine L. Freeman, J.D. “Attorney at Law” Texas Bar No. 24058299” (active) within the “State of Texas” was not providing such any physical presentation, representation and appearance thereof as acting “Attorney at Record Law services” for the full skilled “legal behalf” and “retain interest” thereafter December 1s t 2008 throughout the exact dates of January 1s t 2009




In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein explaining he was not making Public Representation, presentation in the Profession as a “skilled counsel of law” Before the “Honorable Judge Bob Wortham, the “Honorable Judge Bob Wortham” staff namely “Ms. Sydney Moreau”, the Court reporters, and the court bailiff’s, thereafter December 1s t 2008 throughout the exact dates of January 1s t 2009






In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not filing any legal court documents for their legal behalf of said Co-Defendant(s) collectively through the “United States Mailing System” thereafter December 1s t 2008 throughout the exact dates of January 1s t 2009





With direct Usage of the “United States Mailing System” surround civil court event thereafter December 1s t 2008 throughout the exact dates of January 1s t 2009 for their legal behalf of said Co-Defendant(s) collectively through the “United States Mailing System”

Namely in that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not physically executing the usage of the “United States Mailing System” in the capacity of acting “Attorney of Record” thereafter December 1s t 2008 throughout the exact dates of January 1s t 2009


In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not physically involved with inner actions on live “court transcripts” with the 58th Court reporters thereafter December 1s t 2008 throughout the exact dates of January 1s t 2009 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not present before the 58th Judicial District Court of Jefferson County Texas bailiff’s, thereafter the time frame of December 1s t 2008 throughout the exact dates of January 1s t 2009

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation, presentation of material facts as acting “Attorney of record” Before the “Honorable Judge Bob Wortham”, thereafter the date of December 1s t 2008 throughout the exact dates of January 1s t 2009 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation, presentation of material facts as acting “Attorney of record” before The “Honorable Judge Bob Wortham” staff namely “Ms. Sydney Moreau”, thereafter the Date of December 1s t 2008

throughout the exact dates of January 1s t 2009 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation, presentation of material facts as acting “Attorney of record” before the Jefferson County Clerk “Lolita Ramos”, record office of Jefferson County Texas thereafter the Date of December 1s t 2008 throughout the exact dates of January 1s t 2009 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805


Before the “Honorable Judge Bob Wortham”, against said Pro Se Plaintiff “Louis Charles Hamilton II” herein subject matter in complaint against the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” thereafter December 1s t 2008 throughout the exact dates of January 1s t 2009 in cause No. A-180805











Subpart (P)

Explain in full expert “Attorney at Law” details, and Supply in full details also any and all legal court documents, docket reports, court ledgers, letters, faxes, text, memos, emails, “filed motions for withdrawal of counsel” all records in support thereof from the exact date of January 1s t 2009 throughout the exact dates of February 1s t 2009







In that Namely exactly “Antoine L. Freeman, J.D. “Attorney at Law” Texas Bar No. 24058299” (active) within the “State of Texas” was not providing such any physical presentation, representation and appearance thereof as acting “Attorney at Record Law services” for the full skilled “legal behalf” and “retain interest” thereafter January 1s t 2009 throughout the exact dates of February 1s t 2009




In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein explaining he was not making Public Representation, presentation in the Profession as a “skilled counsel of law” Before the “Honorable Judge Bob Wortham, the “Honorable Judge Bob Wortham” staff namely “Ms. Sydney Moreau”, the Court reporters, and the court bailiff’s, thereafter January 1s t 2009 throughout the exact dates of February 1s t 2009






In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not filing any legal court documents for their legal behalf of said Co-Defendant(s) collectively through the “United States Mailing System” thereafter January 1s t 2009 throughout the exact dates of February 1s t 2009





With direct Usage of the “United States Mailing System” surround civil court event thereafter January 1s t 2009 throughout the exact dates of February 1st 2009 for their legal behalf of said Co-Defendant(s) collectively through the “United States Mailing System”

Namely in that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not physically executing the usage of the “United States Mailing System” in the capacity of acting “Attorney of Record” thereafter January 1s t 2009 throughout the exact dates of February 1s t 2009


In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not physically involved with inner actions on live “court transcripts” with the 58th Court reporters thereafter January 1s t 2009 throughout the exact dates of February 1s t 2009 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not present before the 58th Judicial District Court of Jefferson County Texas bailiff’s, thereafter the time frame of January 1s t 2009 throughout the exact dates of February 1s t 2009

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation, presentation of material facts as acting “Attorney of record” Before the “Honorable Judge Bob Wortham”, thereafter the date of January 1s t 2009 throughout the exact dates of February 1s t 2009 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation, presentation of material facts as acting “Attorney of record” before The “Honorable Judge Bob Wortham” staff namely “Ms. Sydney Moreau”, thereafter the Date of January 1s t 2009 throughout

the exact dates of February 1s t 2009 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation, presentation of material facts as acting “Attorney of record” before the Jefferson County Clerk “Lolita Ramos”, record office of Jefferson County Texas thereafter the Date of January 1s t 2009 throughout the exact dates of February 1s t 2009 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805


Before the “Honorable Judge Bob Wortham”, against said Pro Se Plaintiff “Louis Charles Hamilton II” herein subject matter in complaint against the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” thereafter January 1s t 2009 throughout the exact dates of February 1s t 2009 in cause No. A-180805











Subpart (Q)

Explain in full expert “Attorney at Law” details, and Supply in full details also any and all legal court documents, docket reports, court ledgers, letters, faxes, text, memos, emails, “filed motions for withdrawal of counsel” all records in support thereof from the exact date of February 1s t 2009 throughout the exact dates of March 1s t 2009







In that Namely exactly “Antoine L. Freeman, J.D. “Attorney at Law” Texas Bar No. 24058299” (active) within the “State of Texas” was not providing such any physical presentation, representation and appearance thereof as acting “Attorney at Record Law services” for the full skilled “legal behalf” and “retain interest” thereafter February 1s t 2009 throughout the exact dates of March 1s t 2009




In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein explaining he was not making Public Representation, presentation in the Profession as a “skilled counsel of law” Before the “Honorable Judge Bob Wortham, the “Honorable Judge Bob Wortham” staff namely “Ms. Sydney Moreau”, the Court reporters, and the court bailiff’s, thereafter February 1s t 2009 throughout the exact dates of March 1s t 2009






In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not filing any legal court documents for their legal behalf of said Co-Defendant(s) collectively through the “United States Mailing System” thereafter February 1s t 2009 throughout the exact dates of March 1s t 2009





With direct Usage of the “United States Mailing System” surround civil court event thereafter February 1s t 2009 throughout the exact dates of March 1s t 2009 for their legal behalf of said Co-Defendant(s) collectively through the “United States Mailing System”

Namely in that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not physically executing the usage of the “United States Mailing System” in the capacity of acting “Attorney of Record” thereafter February 1s t 2009 throughout the exact dates of March 1s t 2009


In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not physically involved with inner actions on live “court transcripts” with the 58th Court reporters thereafter February 1s t 2009 throughout the exact dates of March 1s t 2009 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not present before the 58th Judicial District Court of Jefferson County Texas bailiff’s, thereafter the time frame of February 1s t 2009 throughout the exact dates of March 1s t 2009

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation, presentation of material facts as acting “Attorney of record” Before the “Honorable Judge Bob Wortham”, thereafter the date of February 1s t 2009 throughout the exact dates of March 1s t 2009 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation, presentation of material facts as acting “Attorney of record” before The “Honorable Judge Bob Wortham” staff namely “Ms. Sydney Moreau”, thereafter the Date of February 1s t 2009

throughout the exact dates of March 1s t 2009 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation, presentation of material facts as acting “Attorney of record” before the Jefferson County Clerk “Lolita Ramos”, record office of Jefferson County Texas thereafter the Date of January 1s t 2009 throughout the exact dates of of February 1s t 2009 throughout the exact dates of March 1s t 2009 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805


Before the “Honorable Judge Bob Wortham”, against said Pro Se Plaintiff “Louis Charles Hamilton II” herein subject matter in complaint against the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” thereafter of February 1s t 2009 throughout the exact dates of March 1s t 2009 in cause No. A-180805











Subpart (R)

Explain in full expert “Attorney at Law” details, and Supply in full details also any and all legal court documents, docket reports, court ledgers, letters, faxes, text, memos, emails, “filed motions for withdrawal of counsel” all records in support thereof from the exact date of March 1s t 2009 throughout the exact dates of April 1s t 2009







In that Namely exactly “Antoine L. Freeman, J.D. “Attorney at Law” Texas Bar No. 24058299” (active) within the “State of Texas” was not providing such any physical presentation, representation and appearance thereof as acting “Attorney at Record Law services” for the full skilled “legal behalf” and “retain interest” thereafter March 1s t 2009 throughout the exact dates of April 1s t 2009




In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein explaining he was not making Public Representation, presentation in the Profession as a “skilled counsel of law” Before the “Honorable Judge Bob Wortham, the “Honorable Judge Bob Wortham” staff namely

“Ms. Sydney Moreau”, the Court reporters, and the court bailiff’s, thereafter March 1s t 2009 throughout the exact dates of April 1s t 2009






In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not filing any legal court documents for their legal behalf of said Co-Defendant(s) collectively through the “United States Mailing System” thereafter March 1s t 2009 throughout the exact dates of April 1s t 2009





With direct Usage of the “United States Mailing System” surround civil court event thereafter March 1s t 2009 throughout the exact dates of April 1s t 2009 for their legal behalf of said Co-Defendant(s) collectively through the “United States Mailing System”

Namely in that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not physically executing the usage of the “United States Mailing System” in the capacity of acting “Attorney of Record” thereafter March 1s t 2009 throughout the exact dates of April 1s t 2009


In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not physically involved with inner actions on live “court transcripts” with the 58th Court reporters thereafter March 1s t 2009 throughout the exact dates of April 1s t 2009 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not present before the 58th Judicial District Court of Jefferson County Texas bailiff’s, thereafter the time frame of March 1s t 2009 throughout the exact dates of April 1s t 2009

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation, presentation of material facts as acting “Attorney of record” Before the “Honorable Judge Bob Wortham”, thereafter the date of March 1s t 2009 throughout the exact dates of April 1s t 2009 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation, presentation of material facts as acting “Attorney of record” before The “Honorable Judge Bob Wortham” staff namely “Ms. Sydney Moreau”, thereafter the Date of March 1s t 2009 throughout

the exact dates of April 1s t 2009 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation, presentation of material facts as acting “Attorney of record” before the Jefferson County Clerk “Lolita Ramos”, record office of Jefferson County Texas thereafter the Date of March 1s t 2009 throughout the exact dates of April 1s t 2009 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805


Before the “Honorable Judge Bob Wortham”, against said Pro Se Plaintiff “Louis Charles Hamilton II” herein subject matter in complaint against the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” thereafter of March 1s t 2009 throughout the exact dates of April 1s t 2009 in cause No. A-180805











Subpart (S)

Explain in full expert “Attorney at Law” details, and Supply in full details also any and all legal court documents, docket reports, court ledgers, letters, faxes, text, memos, emails, “filed motions for withdrawal of counsel” all records in support thereof from the exact date of April 1s t 2009 throughout the exact dates of May 1s t 2009







In that Namely exactly “Antoine L. Freeman, J.D. “Attorney at Law” Texas Bar No. 24058299” (active) within the “State of Texas” was not providing such any physical presentation, representation and appearance thereof as acting “Attorney at Record Law services” for the full skilled “legal behalf” and “retain interest” thereafter April 1s t 2009 throughout the exact dates of May 1s t 2009




In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein explaining he was not making Public Representation, presentation in the Profession as a “skilled counsel of law” Before the “Honorable Judge Bob Wortham, the “Honorable Judge Bob Wortham” staff namely “Ms. Sydney Moreau”, the Court reporters, and the court bailiff’s, thereafter April 1s t 2009 throughout the exact dates of May 1s t 2009






In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not filing any legal court documents for their legal behalf of said Co-Defendant(s) collectively through the “United States Mailing System” thereafter April 1s t 2009 throughout the exact dates of May 1s t 2009





With direct Usage of the “United States Mailing System” surround civil court event thereafter April 1s t 2009 throughout the exact dates of May 1s t 2009 for their legal behalf of said Co-Defendant(s) collectively through the “United States Mailing System”

Namely in that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not physically executing the usage of the “United States Mailing System” in the capacity of acting “Attorney of Record” thereafter April 1s t 2009 throughout the exact dates of May 1s t 2009


In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not physically involved with inner actions on live “court transcripts” with the 58th Court reporters thereafter April 1s t 2009 throughout the exact dates of May 1s t 2009 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not present before the 58th Judicial District Court of Jefferson County Texas bailiff’s, thereafter the time frame of April 1s t 2009 throughout the exact dates of May 1s t 2009

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation, presentation of material facts as acting “Attorney of record” Before the “Honorable Judge Bob Wortham”, thereafter the date of April 1s t 2009 throughout the exact dates of May 1s t 2009 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation, presentation of material facts as acting “Attorney of record” before The “Honorable Judge Bob Wortham” staff namely “Ms. Sydney Moreau”, thereafter the Date of April 1s t 2009 throughout

the exact dates of May 1s t 2009 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation, presentation of material facts as acting “Attorney of record” before the Jefferson County Clerk “Lolita Ramos”, record office of Jefferson County Texas thereafter the Date of April 1s t 2009 throughout the exact dates of May 1s t 2009 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805


Before the “Honorable Judge Bob Wortham”, against said Pro Se Plaintiff “Louis Charles Hamilton II” herein subject matter in complaint against the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” thereafter of April 1s t 2009 throughout the exact dates of May 1s t 2009 in cause No. A-180805











Subpart (T)

Explain in full expert “Attorney at Law” details, and Supply in full details also any and all legal court documents, docket reports, court ledgers, letters, faxes, text, memos, emails, “filed motions for withdrawal of counsel” all records in support thereof from the exact date of May 1s t 2009 throughout the exact dates of June 1s t 2009







In that Namely exactly “Antoine L. Freeman, J.D. “Attorney at Law” Texas Bar No. 24058299” (active) within the “State of Texas” was not providing such any physical presentation, representation and appearance thereof as acting “Attorney at Record Law services” for the full skilled “legal behalf” and “retain interest” thereafter May 1s t 2009 throughout the exact dates of June 1s t 2009




In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein explaining he was not making Public Representation, presentation in the Profession as a “skilled counsel of law” Before the “Honorable Judge Bob Wortham, the “Honorable Judge Bob Wortham” staff namely “Ms. Sydney Moreau”, the Court reporters, and the court bailiff’s, thereafter May 1s t 2009 throughout the exact dates of June 1s t 2009






In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not filing any legal court documents for their legal behalf of said Co-Defendant(s) collectively through the “United States Mailing System” thereafter May 1s t 2009 throughout the exact dates of June 1s t 2009





With direct Usage of the “United States Mailing System” surround civil court event thereafter May 1s t 2009 throughout the exact dates of June 1s t 2009 for their legal behalf of said Co-Defendant(s) collectively through the “United States Mailing System”

Namely in that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not physically executing the usage of the “United States Mailing System” in the capacity of acting “Attorney of Record” thereafter May 1s t 2009 throughout the exact dates of June 1s t 2009


In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not physically involved with inner actions on live “court transcripts” with the 58th Court reporters thereafter May 1s t 2009 throughout the exact dates of June 1s t 2009 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not present before the 58th Judicial District Court of Jefferson County Texas bailiff’s, thereafter the time frame of May 1s t 2009 throughout the exact dates of June 1s t 2009 In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation, presentation of material facts as acting “Attorney of record” Before the “Honorable Judge Bob Wortham”, thereafter the date of May 1s t 2009 throughout the exact dates of June 1s t 2009 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation, presentation of material facts as acting “Attorney of record” before The “Honorable Judge Bob Wortham” staff namely “Ms. Sydney Moreau”, thereafter the Date of May 1s t 2009 throughout the exact dates of June 1s t 2009 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation, presentation of material facts as acting “Attorney of record” before the Jefferson County Clerk “Lolita Ramos”, record office of Jefferson County Texas thereafter the Date of May 1s t 2009 throughout the exact dates of June 1s t 2009 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805


Before the “Honorable Judge Bob Wortham”, against said Pro Se Plaintiff “Louis Charles Hamilton II” herein subject matter in complaint against the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” thereafter May 1s t 2009 throughout the exact dates of June 1s t 2009 in cause No. A-180805











Subpart (U)

Explain in full expert “Attorney at Law” details, and Supply in full details also any and all legal court documents, docket reports, court ledgers, letters, faxes, text, memos, emails, “filed motions for withdrawal of counsel” all records in support thereof from the exact date of June 1s t 2009 throughout July 1s t 2009 In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” Bar No. 24058299 herein






In that Namely exactly “Antoine L. Freeman, J.D. “Attorney at Law” Texas Bar No. 24058299” (active) within the “State of Texas” was not providing such any physical presentation, representation and appearance thereof as acting “Attorney at Record Law services” for the full skilled “legal behalf” and “retain interest” June 1s t 2009 throughout July 1s t 2009 In a civil suit in the 58th Judicial District Court of Jefferson County Texas filed in Cause No. A-180805



In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein explaining he was not making Public Representation, presentation in the Profession as a “skilled counsel of law” Before the “Honorable Judge Bob Wortham, the “Honorable Judge Bob Wortham” staff namely “Ms. Sydney Moreau”, the Court reporters, and the court bailiff’s, thereafter June 1s t 2009 throughout July 1s t 2009 In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any Public Representation, presentation in the Profession as a “skilled counsel of law” Before The Jefferson County Clerk of Court “Lolita Ramos”,





In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not filing any legal court documents for their legal behalf of said Co-Defendant(s) collectively through the “United States Mailing System” thereafter June 1s t 2009 throughout July 1s t 2009





With direct Usage of the “United States Mailing System” surround civil court event thereafter June 1s t 2009 throughout July 1s t 2009 for their legal behalf of said Co-Defendant(s) collectively through the “United States Mailing System”

Namely in that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not physically executing the usage of the “United States Mailing System” in the capacity of acting “Attorney of Record” thereafter June 1s t 2009 throughout July 1s t 2009 For the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” at no physical time frame other then retain filing services for December 18th 2007 “General Denial” paid services render (only).

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not physically involved with inner actions on live “court transcripts”

with the 58th Court reporters thereafter June 1s t 2009 throughout July 1s t 2009 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not present before the 58th Judicial District Court of Jefferson County Texas bailiff’s, thereafter the time frame of June 1s t 2009 throughout July 1s t 2009

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation, presentation of material facts as acting “Attorney of record” Before the “Honorable Judge Bob Wortham”, thereafter the date of June 1s t 2009 throughout July 1s t 2009 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation, presentation of material facts as acting “Attorney of record” before The “Honorable Judge Bob Wortham” staff namely “Ms. Sydney Moreau”, thereafter the Date of June 1s t 2009 throughout July 1s t 2009 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation, presentation of material facts as acting “Attorney of record” before the Jefferson County Clerk “Lolita Ramos”, record office of Jefferson County Texas thereafter the Date of June 1s t 2009 throughout July 1s t 2009 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805


Before the “Honorable Judge Bob Wortham”, against said Pro Se Plaintiff “Louis Charles Hamilton II” herein subject matter in complaint against the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” thereafter June 1s t 2009 throughout July 1s t 2009 in cause No. A-180805











Subpart (V)

Explain in full expert “Attorney at Law” details, and Supply in full details also any and all legal court documents, docket reports, court ledgers, letters, faxes, text, memos, emails, “filed motions for withdrawal of counsel” all records in support thereof from the exact date of July 1s t 2009 throughout the exact dates of August 1s t 2009







In that Namely exactly “Antoine L. Freeman, J.D. “Attorney at Law” Texas Bar No. 24058299” (active) within the “State of Texas” was not providing such any physical presentation, representation and appearance thereof as acting “Attorney at Record Law services” for the full skilled “legal behalf” and “retain interest” thereafter July 1s t 2009 throughout the exact dates of August 1s t 2009




In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein explaining he was not making Public Representation, presentation in the Profession as a “skilled counsel of law” Before the “Honorable Judge Bob Wortham, the “Honorable Judge Bob Wortham” staff namely “Ms. Sydney Moreau”, the Court reporters, and the court bailiff’s, thereafter July 1s t 2009 throughout the exact dates of August 1s t 2009






In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not filing any legal court documents for their legal behalf of said Co-Defendant(s) collectively through the “United States Mailing System” thereafter July 1s t 2009 throughout the exact dates of August 1s t 2009





With direct Usage of the “United States Mailing System” surround civil court event thereafter February 1s t 2009 throughout the exact dates of July 1s t 2009 throughout the exact dates of August 1s t 2009 for their legal behalf of said Co-Defendant(s) collectively through the “United States Mailing System”

Namely in that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not physically executing the usage of the “United States Mailing System” in the capacity of acting “Attorney of Record” thereafter July 1s t 2009 throughout the exact dates of August 1s t 2009


In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not physically involved with inner actions on live “court transcripts” with the 58th Court reporters thereafter July 1s t 2009 throughout the exact dates of August 1s t 2009 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not present before the 58th Judicial District Court of Jefferson County Texas bailiff’s, thereafter the time frame of July 1s t 2009 throughout the exact dates of August 1s t 2009

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation, presentation of material facts as acting “Attorney of record” Before the “Honorable Judge Bob Wortham”, thereafter the date of July 1s t 2009 throughout the exact dates of August 1s t 2009 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation, presentation of material facts as acting “Attorney of record” before The “Honorable Judge Bob Wortham” staff namely “Ms. Sydney Moreau”, thereafter the Date of July 1s t 2009 throughout the exact dates of August 1s t 2009 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation, presentation of material facts as acting “Attorney of record” before the Jefferson County Clerk “Lolita Ramos”, record office of Jefferson County Texas thereafter the Date of July 1s t 2009 throughout the exact dates of August 1s t 2009 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805


Before the “Honorable Judge Bob Wortham”, against said Pro Se Plaintiff “Louis Charles Hamilton II” herein subject matter in complaint against the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” thereafter of July 1s t 2009 throughout the exact dates of August 1s t 2009 in cause No. A-180805

“Meaning” in that Chief Defendant “Antoine L. Freeman, J.D. “Attorney at Law” Texas Bar No240582299 was not in any shape or form involved in any

“attorney/client”, work product thereof, “attorney/client” communications thereof,









Surrounding Pro Se Plaintiff claims of a chain of fraudulent events as a result of Hurricane Rita, Humberto and Ike for said dwelling and the property

located at 448 DeQueen Blvd. in Port Arthur Texas. (Block 172, Lot 1-2) in connection with Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein.

Subpart (W)


















In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not filing any legal court documents for their legal behalf of said Co-

Defendant(s) collectively through the “United States Mailing System” thereafter August 1s t 2009 throughout the exact dates of September 1s t 2009





With direct Usage of the “United States Mailing System” surround civil court event thereafter August 1s t 2009 throughout the exact dates of September 1s t 2009 for their legal behalf of said Co-Defendant(s) collectively through the “United States Mailing System”




In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not present before the 58th Judicial District Court of Jefferson County

Texas bailiff’s, thereafter the time frame of August 1s t 2009 throughout the exact dates of September 1s t 2009


In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation, presentation of material facts as acting “Attorney of record” before The “Honorable Judge Bob Wortham” staff namely “Ms. Sydney Moreau”, thereafter the Date of August 1s t 2009 throughout the exact dates of September 1s t 2009 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805



Before the “Honorable Judge Bob Wortham”, against said Pro Se Plaintiff “Louis Charles Hamilton II” herein subject matter in complaint against the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” thereafter of August 1s t 2009 throughout the exact dates of September 1s t 2009 in cause No. A-180805











Subpart (X)

Explain in full expert “Attorney at Law” details, and Supply in full details also any and all legal court documents, docket reports, court ledgers, letters, faxes, text, memos, emails, “filed motions for withdrawal of counsel” all records in support thereof from the exact date of September 1s t 2009 throughout the exact dates of October 1s t 2009







In that Namely exactly “Antoine L. Freeman, J.D. “Attorney at Law” Texas Bar No. 24058299” (active) within the “State of Texas” was not providing such any physical presentation, representation and appearance thereof as acting “Attorney at Record Law services” for the full skilled “legal behalf” and “retain interest” thereafter September 1s t 2009 throughout the exact dates of October 1s t 2009




In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein explaining he was not making Public Representation, presentation in the Profession as a “skilled counsel of law” Before the “Honorable Judge Bob Wortham, the “Honorable Judge Bob Wortham” staff namely “Ms. Sydney Moreau”, the Court reporters, and the court bailiff’s, thereafter September 1s t 2009 throughout the exact dates of October 1s t 2009






In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not filing any legal court documents for their legal behalf of said Co-Defendant(s) collectively through the “United States Mailing System” thereafter September 1s t 2009 throughout the exact dates of October 1s t 2009





With direct Usage of the “United States Mailing System” surround civil court event thereafter September 1s t 2009 throughout the exact dates of October 1s t 2009 for their legal behalf of said Co-Defendant(s) collectively through the “United States Mailing System”

Namely in that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not physically executing the usage of the “United States Mailing System” in the capacity of acting “Attorney of Record” thereafter September 1s t 2009 throughout the exact dates of October 1s t 2009


In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not physically involved with inner actions on live “court transcripts” with the 58th Court reporters thereafter September 1s t 2009 throughout the exact dates of October 1s t 2009 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not present before the 58th Judicial District Court of Jefferson County Texas bailiff’s, thereafter the time frame of September 1s t 2009 throughout the exact dates of October 1s t 2009

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation, presentation of material facts as acting “Attorney of record” Before the “Honorable Judge Bob Wortham”, thereafter the date of September 1s t 2009 throughout the exact dates of October 1s t 2009 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation, presentation of material facts as acting “Attorney of record” before The “Honorable Judge Bob Wortham” staff namely “Ms. Sydney Moreau”, thereafter the Date of September 1s t 2009 throughout the exact dates of October 1s t 2009 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation, presentation of material facts as acting “Attorney of record” before the Jefferson County Clerk “Lolita Ramos”, record office of Jefferson County Texas thereafter the Date of September 1s t 2009 throughout the exact dates of October 1s t 2009 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805


Before the “Honorable Judge Bob Wortham”, against said Pro Se Plaintiff “Louis Charles Hamilton II” herein subject matter in complaint against the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” thereafter of September 1s t 2009 throughout the exact dates of October 1s t 2009 in cause No. A-180805











Subpart (Y)

Explain in full expert “Attorney at Law” details, and Supply in full details also any and all legal court documents, docket reports, court ledgers, letters, faxes, text, memos, emails, “filed motions for withdrawal of counsel” all records in support thereof from the exact date of October 1s t 2009 throughout the exact dates of November 11s t 2009







In that Namely exactly “Antoine L. Freeman, J.D. “Attorney at Law” Texas Bar No. 24058299” (active) within the “State of Texas” was not providing such any physical presentation, representation and appearance thereof as acting “Attorney at Record Law services” for the full skilled “legal behalf” and “retain interest” thereafter October 1s t 2009 throughout the exact dates of November 11s t 2009




In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein explaining he was not making Public Representation, presentation in the Profession as a “skilled counsel of law” Before the “Honorable Judge Bob Wortham, the “Honorable Judge Bob Wortham” staff namely “Ms. Sydney Moreau”, the Court reporters, and the court bailiff’s, thereafter October 1s t 2009 throughout the exact dates of November 11s t 2009






In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not filing any legal court documents for their legal behalf of said Co-Defendant(s) collectively through the “United States Mailing System” thereafter October 1s t 2009 throughout the exact dates of November 11s t 2009





With direct Usage of the “United States Mailing System” surround civil court event thereafter October 1s t 2009 throughout the exact dates of November 11s t 2009 for their legal behalf of said Co-Defendant(s) collectively through the “United States Mailing System”

Namely in that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not physically executing the usage of the “United States Mailing System” in the capacity of acting “Attorney of Record” thereafter October 1s t 2009 throughout the exact dates of November 11s t 2009


In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not physically involved with inner actions on live “court transcripts” with the 58th Court reporters thereafter October 1s t 2009 throughout the exact dates of November 11s t 2009 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not present before the 58th Judicial District Court of Jefferson County Texas bailiff’s, thereafter the time frame of September 1s t 2009 throughout the exact dates of October 1s t 2009

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation, presentation of material facts as acting “Attorney of record” Before the “Honorable Judge Bob Wortham”, thereafter the date of October 1s t 2009 throughout the exact dates of November 11s t 2009 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation, presentation of material facts as acting “Attorney of record” before The “Honorable Judge Bob Wortham” staff namely “Ms. Sydney Moreau”, thereafter the Date of October 1s t 2009 throughout the exact dates of November 11s t 2009 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805

In that Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” herein was not making any representation, presentation of material facts as acting “Attorney of record” before the Jefferson County Clerk “Lolita Ramos”, record office of Jefferson County Texas thereafter the Date of October 1s t 2009 throughout the exact dates of November 11s t 2009 for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” in cause No. A-180805


Before the “Honorable Judge Bob Wortham”, against said Pro Se Plaintiff “Louis Charles Hamilton II” herein subject matter in complaint against the Co-Defendant(s) “Joyce M. Guy and Edward McCray” legal behalf” thereafter of October 1s t 2009 throughout the exact dates of November 11s t 2009 in cause No. A-180805











(23)

Explain in full expert “Attorney at Law” details, Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” Bar No. 24058299 herein do you contend fully even at the door steps of facing U.S. Federal penalties for “perjury” that your clients “Joyce M. Guy and Edward McCary” herein collectively Namely being “Co-Defendant(s)

Were “physically legally” acting as their own counsel of record for their very own collectively “legal civil interest behalf” appearing as such in their own “Pro Se” persons excluding “Your” Attorney at Law skilled representation appearing before the 58th Judicial District Court of Jefferson County Texas in a civil suit in common law docket No A-180805 being filed November 26th 2007

Namely in that term of appearing in their own person/persons as Pro Se thereafter the date of December 18th 2007

Namely in that term of Pro Se, Pro se legal representation (/ˌproʊ ̍ siː/ or /ˌproʊ ̍ seɪ/) means advocating on one's own behalf before a court, rather than being represented by a lawyer

In that “You” Chief Defendant (Attorney at Law) herein as an official officer of the Court in and for the State of Texas fully, legally, honestly 100% contend and appearing now before the “Honorable Justice Magistrate Judge ”

Namely the “Honorable Zack Hawthorn” being a U.S. Magistrate Judge of the United States District Court for the Eastern District of Texas, Beaumont Division, in U.S. Docket Cause No. 1:14-CV-592 herein

In that “You” Chief Defendant (Attorney at Law) herein affirm, state, and

supplied such attached sworn affidavit statement thereof your “material facts”, circumstances, and real life time events that said

“Co-Defendant(s) “Joyce M. Guy and Edward McCary” herein collectively represented the civil suit in common law docket No A-180805 filed November 26th 2007 thereafter the exact date of December 18th 2007 your describing of you and your physical person legally being discharged of law duties in the capacity as acting legal counsel of record in cause No A-180805

http://en.wikipedia.org/wiki/Help:IPA_for_English


http://en.wikipedia.org/wiki/Help:IPA_for_English#Key
















As also described by you in Pro Se Plaintiff attached Document # 2 attached herein “namely”, “Your response” to Pro Se Plaintiff motion for sanctions against you being “Chief Defendant” (Attorney at Law) herein with your filing a supporting “Affidavit” of Co-Defendant “Joyce M. Guy” herein in support thereof as Pro Se Plaintiff attached such Affidavit being Document # 6 herein

As “Co-Defendant(s) “Joyce M. Guy and Edward McCary” herein collectively “Appeared” official before the 58th Judicial District Court of Jefferson County Texas in a civil suit in common law docket No A-180805

As “Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein collectively “Appeared” before The “Honorable Judge Bob Wortham” in a legal format as described now by you and contentions herein as Pro Se counsel fully acting as such for their very own “legal interest” against the said Pro Se Plaintiff Louis Charles Hamilton II herein from the exact “time frame dates” of December 19th 2007 throughout December 11th 2009…?

(24)

If your answer is 100% yes.., to Pro Se Plaintiff “interrogatories question” at # 23 herein, then please “Chief Defendant” (Attorney at Law) Texas Bar No. 24058299 herein

Fully identify all facts, circumstances, legal events, dates, documents, and witnesses that fully legal support your honestly 100% contention that the “Co-Defendant(s) “Joyce M. Guy and Edward McCray” described herein collectively did in all facts and legal circumstances, events and real life person/persons physically “Appeared” acting as Pro Se

To include but not limited to “namely” “Chief Defendant” (Attorney at Law) Texas Bar No. 24058299 herein your honestly 100% contention in that the “Co-Defendant(s) “Joyce M. Guy and Edward McCray” described herein appearing acting as Pro Se on hearing dates of August 28th 2009, before Judge Bob Wortham, and Court Reporter, “Anita Becker” and you’re not acting as legal counsel of record on said hearing dates of August 28th 2009

To include but not limited to “namely” “Chief Defendant” (Attorney at Law) Texas Bar No. 24058299 herein your honestly 100% contention in that the “Co-Defendant(s) “Joyce M. Guy and Edward McCray” described herein appearing

acting as Pro Se on said hearing dates of September 11th 2009, before Judge Bob Wortham, and Court Reporter, “Anita Becker” and you’re not acting as legal counsel of record on said hearing dates of September 11th 2009

As the Pro Se Plaintiff Louis Charles Hamilton II herein surly shall present such legal honest evidence and findings legally supplied by you “namely” your being “Chief Defendant” (Attorney at Law) Texas Bar No 24058299 herein appearing before the “Honorable Justice Magistrate” of the United States District Court in U.S. Docket Cause No. 1:14-CV-592

And Pro Se Plaintiff Louis Charles Hamilton II herein appearing for his own legal behalf before the “Honorable U.S. Justice” and as such “Louis Charles Hamilton II surly shall withdraw the U.S. Complaint made against You “Chief Defendant (Attorney at Law) Texas Bar No 24058299” herein and no longer waist valuable Judicial Court Time in this U.S. Docket Cause No. 1:14-CV-592

*However take real legal notice to this * “Chief Defendant (Attorney at Law) Texas Bar No 24058299” herein

This is fully based in that your “contentions” is “Stated, Sworn, and Affirm, and 100% absolutely honest in all appearance being described before The U.S. “Honorable Justice” in that:

A. You fully identify all facts circumstances, dates and events that support your contention.

B. You fully identify all documents that support your facts, circumstances, dates, and events of your contention. And

C. You fully identify all witnesses that support all facts circumstances, dates and events of your honest contention.

Thereafter the exact date of December 18th 2007 your describing of legally being physically in a state of actual discharged of “legal duties” in the capacity as acting legal counsel of record, in cause No. A-180805 between the exact dates of December 18th 2007 throughout the exact date of December 10th 2009

As described in Pro Se Plaintiff attached Document # 2 herein “Your response” to motion for sanctions against you with supporting “Affidavit” of Co-Defendant “Joyce M. Guy” in support thereof “namely” Pro Se Plaintiff attached Document # 2 herein

Your absolute solid “set” in concrete, stone, chisel ink you “Chief Defendant” (Attorney at Law) herein “legally entertaining” such that your “contentions” before a “Federal Court of Law” is that one Co-Defendant(s) “Joyce M. Guy and Edward McCary” herein collectively “Appeared” active before the 58th Judicial District Court of Jefferson County Texas

In a civil suit in common law in docket No A-180805 and appearing as such before The “Honorable Judge Bob Wortham” in a legal format as acting “Live” Pro Se Defendant(s) being one “Joyce M. Guy and Edward McCray” collectively herein fully engage as such under the term as Pro Se counsel for their very own “legal civil courtroom interest”

In a “Breach of Construction Contract” Complaint filed in connection with the dwelling and the property located at 448 DeQueen Blvd. in Port Arthur Texas. (Block 172, Lot 1-2)

Your absolute contentions as saying such legal terms of a legal Pro Se Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein collectively acting physically in a “court of law” within Texas State Court

Appearing as such against the same said Pro Se Plaintiff Louis Charles Hamilton II herein from the exact time frame dates of “December 19th 2007 throughout the exact date of December 11th 2009” for there on legal interest…?

*Please see legal definition for Pro Se *

“Chief Defendant” (Attorney at Law) Texas Bar No 24058299” herein and or his own acting “Attorney or Record” for this U.S. Docket Cause No. 1:14-CV-592

herein

Before you even collectively commence, to entertain any foolish legal thoughts thereof to falsely begin to supply any “Stated, Sworn, and Affirm, “further fraudulent answers” of facts, events, circumstances, dates and witnesses thereof to this “Interrogatories” question at # 23 and # 24 herein.

(25)

Explain in full expert “Attorney at Law” details, Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” Bar No. 24058299 herein do you contend fully even at the door steps of facing U.S. Federal penalties for “perjury” that

In a civil suit in common law in docket No A-180805, in the 58th Judicial District Court of Jefferson County Texas your absolute solid “set” in concrete, stone, chisel ink you

“Chief Defendant” (Attorney at Law) herein “legally entertaining” such that your “contentions” before a “Federal Court of Law” is that one Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein collectively in ongoing active civil suit before the 58th Judicial District Court of Jefferson County Texas in January of 2015

Further explaining in Affirm, Sworn, and stated legal details dates, with supporting documents, exhibits, witnesses, and real life time fact of events and circumstances from the exact date of December 18th 2007 throughout the exact dates of November 13th 2009 10:22 AM

Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” Bar No. 24058299 herein was not acting;

In that term Attorney - n. an agent or someone authorized to act for another a person who has been qualified by a state or federal court to provide legal services, including appearing in court.

In that term Attorney of Record - n. the attorney who has appeared in court and/or signed pleadings or other forms on behalf of a client.

The lawyer remains the attorney of record until some other attorney or the client substitutes for him/her,

He/she is allowed by the court to withdraw, or after the case is closed.

In that term Attorney's Fee - n. The payment for legal services, hourly charge, and flat fee for the performance of a particular service some mixture of hourly and contingent fee or other combination.

A "retainer" is a down payment on fees, often required by the attorney in order to make sure he or she is not left holding the bag for work performed, or at least as a good faith indication that the client is serious and can afford the services.

In the term Attorney's Work Product - n. written materials, charts, notes of conversations and investigations, and other materials directed toward preparation of a case or other legal representation.

In the term Attorney-Client Privilege - n. the requirement that an attorney may not reveal communications, conversations and letters between himself/ herself and his/her client, under the theory that a person should be able to speak freely and honestly with his/her attorney without fear of future revelation.

In the term Defense - n. a general term for the effort of an attorney representing a defendant during trial and in pre-trial maneuvers to defeat the party suing, to counter, defeat or remove all or a part of the contentions of the plaintiff.

As described in Pro Se Plaintiff attached Document # 2 herein “Your” response to Pro Se Plaintiff Motion for Sanction against “You” Chief Defendant “Antoine L. Freeman, J.D. Texas “Attorney at Law” Bar No. 24058299 herein

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

By, _______________________________

Louis Charles Hamilton II

Pro Se Plaintiff

P.O. Box 17524

Sugar Land Texas 77496

In The United States District Court Defendant “Antoine L. Freeman J.D. (Attorney at Law)” Cause No. 1:14-CV-592 “First Set of Interrogatories”

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