To Defendant “Antoine L. Freeman J.D. (Attorney at Law), Pro Se Plaintiff “Louis Charles Hamilton II” herein propounding party REQUESTS FOR ADMISSION, SET ONE To: Antoine L. Freeman J. D. Attorney at Law AND HIS COUNSEL OF RECORD: Pursuant to the provisions of Federal Rule of Civil Procedure 36, it is hereby requested and demanded of Defendant Antoine L. Freeman J. D. (hereinafter “YOU” or “YOUR”), that YOU make admissions of the following statements of fact which are materially pertinent to Plaintiff claims hereto in accordance with Rule 36, Under which rule of procedure this request for admissions is made, thereby answering the following facts in the above-entitled and number cause, and that such answers be sworn to and filed promptly in the office of the District Clerk Where this cause is pending and a copy delivered to the writer within thirty (30) days from the serving of this request upon you. Otherwise, each of the matter of which an admission is requested and demanded shall be deemed admitted by you in accordance with Rule 36 of the Federal Rules of Civil Procedure. Request for Admission Truth of Facts

1. In The United States DistrictCourt
For The Eastern Division of Texas
Beaumont Division
Louis Charles Hamilton II
Pro Se Plaintiff
Vs. CauseNo. 1:14-CV-592
Antoine L. Freeman J. D.
Defendant
Joyce M. Guy
Edward McCray
Co-Defendant(s)
To Defendant “Antoine L. Freeman J.D. (Attorney at Law), Pro Se Plaintiff
“Louis Charles Hamilton II” herein propounding party
REQUESTSFORADMISSION,SETONE
To: Antoine L. Freeman J. D. Attorney at Law AND HIS COUNSEL OF RECORD:
Pursuantto the provisions of Federal Rule of Civil Procedure36, it is hereby
requested and demanded of Defendant
Antoine L. Freeman J. D. (hereinafter “YOU” or “YOUR”), that YOUmake
admissions of the following statements of fact which are materially pertinent to
Plaintiff claims hereto in accordancewith Rule 36,
Under which rule of procedurethis requestfor admissions is made, thereby
answering the following facts in the above-entitled and number cause, and that
such answers besworn to and filed promptly in the office of the District Clerk

2. Where this causeis pending and a copy delivered to the writer within thirty
(30) days fromthe serving of this request upon you.
Otherwise, each of the matter of which an admission is requested and
demanded shall be deemed admitted by you in accordancewith Rule 36 of the
Federal Rules of Civil Procedure.
Request for Admission
Truth of Facts
Admit that the following facts are true:
Request Number 1.
Admit: that you made legal claim Co-Defendant(s) JoyceM. Guy and
Edward McCray herein (Only) retain the legal services of Antoine L. Freeman J.D.
(Attorney at Law) for the purposeof
(Only) writing a general denial so as to avoid a default judgment being
rendered against(Them) in a civil suit in the 58th
Judicial District Court of Jefferson
County Texas filed in Cause No. A-180805, By Pro SePlaintiff herein.
Request Number 2.
Admit: That You on December 18th
2007 filed for Co-Defendant(s) JoyceM.
Guy and Edward McCray herein your “legal General Denial” to Complaint made by
Pro Se Plaintiff herein to Cause No. A-180805
In a civil suitin the 58th
Judicial District Courtof Jefferson County Texas.
Request Number 3.
Admit: That you on November 13th
2009 10:22 amfiled with “Lolita
Ramos”, Clerk, and District Courtof Jefferson County, Texas
A Motion for to Withdrawalof CounselfromCo-Defendant(s) JoyceM. Guy
and Edward McCray herein exactly 1 year, 10 months and 13 days of simply being
“financially retain” to file a simple “Legal General Denial” to Cause No. A-180805
on December 18th
2007 and this was you’reonly “Legal Duties” and “Fiduciary

3. Obligations” as acting retain” Counsel of Record “for the Co-Defendant(s) Joyce
M. Guy and Edward McCray herein
in the entire “Legal ongoing civil suitin common law” time frameof 1 year,
10 months and 13 days filed in the 58th
JudicialDistrict Court of Jefferson County
Texas before the HonorableBob Wortham.
Request Number 4.
Admit: That you on or about April 2nd
2008 and April11, 2008 you
were in possession, custody, and controlof Pro Se Plaintiff Discovery requestfor
Interrogatories, Requestof Admission, and Request for Disclosurein accordance
with the Texas Rules of Civil Procedures 194.2, 197, and 198, to CauseNo. A-
180805 in a civil suit in the 58th
Judicial DistrictCourt of Jefferson County Texas.
Request Number 5.
Admit: that you did not file a “Motion for withdrawalof Counsel” fromthe
Co-Defendant(s) JoyceM. Guy and Edward McCray herein “Between” the dates of
December 18th
2007 your claimof filing your “General Denial”(Only) to causeNo.
A-180805 to thedate of April 2nd
2008 and April11, 2008, after being in
possession, custody, and control over Pro Se Plaintiff Discovery request for
Interrogatories, Requestfor Admission, and Request for Disclosurein accordance
with the Texas Rules of Civil Procedures 194.2, 197, and 198, during this time
frame “You” did not file a “Motion for withdrawalof Counsel to cause No. A-
180805
Request Number 6.
Admit: that you after being in full possession, custody, and legal control
over Pro Se Plaintiff Discovery requestfor Interrogatories, Requestof Admission,
and Request for Disclosurein accordancewith the Texas Rules of Civil Procedures
194.2, 197, and 198, fromthedates of April 2nd
2008 and April11, 2008,
throughoutOctober 14th
2009 during this time frameof (1) year and (5) months
“You” did not file a “Motion for withdrawalof Counselto causeNo. A-180805

4. Request Number 7.
Admit: that “You” being in full possession, custody, and legalcontrol over
Pro Se Plaintiff Discovery request for Interrogatories, Requestfor Admission, and
Request for Disclosurein accordancewith the Texas Rules of Civil Procedures
194.2, 197, and 198, “Between” the dates of April 2nd
2008 and April11, 2008,
throughoutthe dates of October 14th
2009 during this time frame of (1) year and
(5) months and counting days
“You” finally filed a “Certificate of Mailing Service” on or about October 14th
2009 to cause No. A-180805to reply to said Discovery request of Interrogatories,
Request for Admission, and Request for Disclosure that the Pro Se Plaintiff herein
Mail to “You” between the dates of April 2nd
2008 and April 11th
, of 2008 in a Civil
Suit in Common Law within the State of Texas.
Request Number 8.
Admit: That “You” being in full possession, custody, and legal control over
Pro Se Plaintiff Discovery Requestfor Interrogatories, Requestfor Admission, and
Request for Disclosurein accordancewith the Texas Rules of Civil Procedures
194.2, 197, and 198,
“Between” the dates of April 2nd
2008 and April 11, 2008, throughoutthe
dates of April 2nd
2009 and April11th
2009 “You” for a time frame of (1) exact year
during this said time frameof being in full possession, custody, and legal control
over said Pro Se Plaintiff Discovery request for Interrogatories, Requestfor
Admission, and Request for Disclosure
“You” did not even reply at all to any of the Pro Se Plaintiff Discovery legal
request for Interrogatories, Requestof Admission, and Request for Disclosurethat
was mailed to you in accordancewith the Texas Rules of Civil Procedures 194.2,
197, and 198, in causeNo. A-180805 filed in the 58th
Judicial District Courtof
Jefferson County Texas
Request Number 9.

5. Admit: “You” did not file a “Motion for withdrawalof Counsel” to causeNo.
A-180805 between thedates of April 2nd
2008 and April11, 2008, throughoutthe
dates of April 2nd
2009 and April11th
2009 (1) exactyear “Your” being in full
possession, custody, and legal control over Pro Se Plaintiff Discovery requestfor
Interrogatories, Requestof Admission, and Request for Disclosurein accordance
with the Texas Rules of Civil Procedures 194.2, 197, and 198,.
Request Number 10.
Admit: “You” did not file a “Motion for withdrawalof Counsel” to causeNo.
A-180805, Between the dates of April 2nd
2009 and April11th
2009 while“Your” in
full possession, custody, and legalcontrol over Pro Se Plaintiff Discovery request
for Interrogatories, Requestof Admission, and Request for Disclosurein
accordancewith the Texas Rules of Civil Procedures 194.2,197, and 198,
“Throughout” the dates of October 14th
2009 some(6) months during this
additional time frame dates
“Your” in full possession, custody, and legal controlover Pro Se Plaintiff
Discovery requestfor Interrogatories, Requestof Admission, and Request for
Disclosurein accordancewith the Texas Rules of Civil Procedures 194.2, 197, and
198, .
Request Number 11.
Admit: Between” the dates of April 2nd
2008 and April11, 2008, “Your” in
full possession, custody, and legalcontrol over Pro Se Plaintiff Discovery request
for Interrogatories, Requestof Admission, and Request for Disclosurein
accordancewith the Texas Rules of Civil Procedures 194.2,197, and 198,
“You” werelegally required to file a reply of some sorts (30) days thereafter
Pro Se Plaintiff herein made such a Discovery request upon “You” for a legal
responseand reply to Interrogatories, Requestof Admission, and Request for
Disclosurein accordancewith the Texas Rules of Civil Procedures 194.2, 197, and
198,. On or about the dates of April 2nd
2008 and April11th
, 2008.

6. Request Number 11.
Admit: that “You” in causeNo. A-180805 “Between” thedates of April 2nd
2008 and April 11, 2008, throughoutthedates of October 14th
2009 “Your” in full
possession, custody, and legal control over Pro Se Plaintiff Discovery requestfor
Interrogatories, Requestof Admission, and Request for Disclosurein accordance
with the Texas Rules of Civil Procedures 194.2, 197, and 198,
“You” never informed the HonorableJudge “Bob Wortham” of the 58th
Judicial DistrictCourt of Jefferson County Texas
“Your” being in complete refusal to file a legal responseand reply to any
of the Interrogatories, Requestof Admission, and Request for DisclosurePro Se
Plaintiff mailed to “You” on the dates of April 2nd
2008 and April11, 2008, in
accordancewith the Texas Rules of Civil Procedures 194.2,197, and 198, in cause
No. A-180805.
Request Number 12.
Admit: “You” never informed the Honorable Judge “Bob Wortham” of the
58th
Judicial DistrictCourt of Jefferson County Texas between the time frame
dates of April 2nd
2008 and April11, 2008, throughoutthedates of April 2nd
2009
and April 11th
2009 (1) exactyear
“Your” being in full possession, custody, and legal control over Pro Se
Plaintiff Discovery requestfor Interrogatories, Requestof Admission, and Request
for Disclosurein accordancewith the Texas Rules of Civil Procedures 194.2, 197,
and 198,.
“Your” being in complete refusal to file a legal responseand reply to any
of the Interrogatories, Requestof Admission, and Request for DisclosurePro Se
Plaintiff mailed to “You” on the dates of April 2nd
2008 and April11, 2008, in
accordancewith the Texas Rules of Civil Procedures 194.2,197, and 198, in cause
No. A-180805for the“Legal behalf” of Co-Defendant(s) JoyceM. Guy and Edward
McCray herein.

7. Request Number 13.
Admit: “You” did not request a longer extension of time fromthe Pro Se
Plaintiff herein and agree upon in writing to reply to said “Discovery Requestof
Interrogatories, Requestof Admission, and Request for DisclosurePro Se Plaintiff
mailed to
“You” on the dates of April 2nd
2008 and April11, 2008, in accordancewith
the Texas Rules of Civil Procedures 194.2,197, and 198, (30) Days after Serviceof
said discovery requestin cause No. A-180805for the“Legal behalf” of Co-
Defendant(s) JoyceM. Guy and Edward McCray herein.
Request Number 14.
Admit: “You” did not request a longer extension of time fromthe 58th
Judicial DistrictCourt Judge “Bob Wortham” in order to obtain a Court Order of
“approval” of the HonorableCourt in “Your” being granted a longer extension of
time to reply to all of the said Discovery Requestof Interrogatories, Requestof
Admission, and Request for DisclosurePro Se Plaintiff mailed to
“You” on the dates of April 2nd
2008 and April11, 2008, in accordancewith
the Texas Rules of Civil Procedures 194.2,197, and 198,
(30) Days after Serviceof said discovery requestin causeNo. A-
180805 on thedates being described herein April 2nd
2008 and April11th
2008 for the “Legal behalf” of Co-Defendant(s) JoyceM. Guy and Edward
McCray herein.
Request Number 15.
Admit: “You” did not give the 58th
Judicial DistrictCourt Judge “Bob
Wortham” any Written, or Verbal notice, cellular phone or office phone
communication, memo, documents or emails transmission of any type, fax, text,

8. between the dates of April2nd
2008 and April 11, 2008, throughoutthedates of
October 14th
2009
“Your” being granted a longer extension of time to reply to all of the said
Discovery Requestof Interrogatories, Requestof Admission, and Request for
DisclosurePro Se Plaintiff mailed to “You” on the dates of April 2nd
2008 and April
11, 2008, in accordancewith the Texas Rules of Civil Procedures 194.2, 197, and
198,
“Your” were being in full possession, custody, and legal controlover Pro Se
Plaintiff said “Discovery requests” in causeNo. A-180805 on the dates being
described herein April 2nd
2008 and April11th
2008 for the “Legal behalf” of Co-
Defendant(s) JoyceM. Guy and Edward McCray herein.
Request Number 16.
Admit: “You” did not give the 58th
Judicial DistrictCourt Judge “Bob
Wortham” or his office clerk or any staff member of the 58th
Judicial Court any
Written form, or Verbalnotice of somesort, cellular phonecall or office phone
communication of any type, memos, documents or emails transmission of any
type, faxes, text, between the dates of December 18th
2007 throughoutthedates
of April 2nd
2008 and April11, 2008
“You” wanted to file a Motion for withdrawalin cause No. A-180805from
being acting Attorney of Record on the behalf of Co-Defendant(s) JoyceM. Guy
and Edward McCray herein.
Request Number 17.
Admit: “You” did not give the 58th
Judicial DistrictCourt Judge “Bob
Wortham” or his office clerk or any staff member of the 58th
Judicial Court any
Written form, or Verbalnotice of some sort, cellular phonecall or office phone
communication of any type, memos, documents or emails transmission of any
type, faxes, text, between the dates of April 2nd
2008 and April11, 2008
throughoutthe dates of October 14th
2009

9. “You” wanted to file a Motion for withdrawalin cause No. A-180805from
being acting Attorney of Record on the behalf of Co-Defendant(s) JoyceM. Guy
and Edward McCray herein.
Request Number 18.
Admit: “You” filed before58th
Judicial District CourtJudge “Bob Wortham”
A Responseto Plaintiff Motion for Sanctions against you with “Your” Affidavit
attached signed and dated September 11th
2009. For notreplying to any of the
Pro Se Plaintiff Discovery requestbetween the dates of April 2nd
2008 and April
11, 2008 throughout October 13th
2009 in causeNo. A-180805
Request Number 19.
Admit: “You” stated before the HonorableCourt in your ResponseMotion
for Sanctions document dated September 11th
2009, “You” being retain by Co-
Defendant JoyceM. Guy herein for purposeof (Only) writing a general denial so
as to avoid a default judgmentbeing rendered against which you filed in
December of 2007 in responseto the complaint cause No. A-180805
Request Number 20.
Admit: “You” did in fact legally representCo-Defendant(s) JoyceM. Guy
and Edward McCray as acting Attorney of Record in cause No. A-180805other
then justsimply filing a General Denial between the dates of December 18th
2007
throughoutthe dates of October 14th
2009.
Request Number 21.
Admit: “You” did in fact legally representCo-Defendant(s) JoyceM. Guy
and Edward McCray as acting Attorney of Record in cause No. A-180805during a
hearing held on the 28th
day of August2009 beforethe HonorableJudge Bob
Wortham
Request Number 22.

10. Admit: “You” did in fact legally representCo-Defendant(s) JoyceM. Guy
and Edward McCray as acting Attorney of Record in cause No. A-180805other
then justsimply filing a General Denial between the dates of December 18th
2007
and filed your certificate of mailing service and responseto said discovery request
on the 14th
day of October 2009 to Plaintiff said “Discovery Requestof
Interrogatories, Requestof Admission, and Request for DisclosurePro Se Plaintiff
mailed to
“You” on the dates of April 2nd
2008 and April11, 2008, in accordancewith
the Texas Rules of Civil Procedures 194.2,197, and 198, for the“Legal behalf” of
Co-Defendant(s) JoyceM. Guy and Edward McCray herein.
Request Number 23.
Admit: “You” fully fail and flat out refuse to reply to any of said discovery
request of Interrogatories, Requestof Admission, and Request for DisclosurePro
Se Plaintiff mailed to
“You” on the dates of April 2nd
2008 and April11, 2008, in accordancewith
the Texas Rules of Civil Procedures 194.2,197, and 198, for the“Legal behalf” of
Co-Defendant(s) JoyceM. Guy and Edward McCray herein after (30) Days after
Service of said discovery requestin causeNo. A-180805 had expired for the “Legal
behalf” of Co-Defendant(s) JoyceM. Guy and Edward McCray herein.
Request Number 24.
Admit: “You” were retain by Co-Defendant(s) JoyceM. Guy and
Edward McCray to not reply to any discovery requestof the Pro Se Plaintiff
herein cause No. A-180805 requestof Interrogatories,Requestof
Admission, and Request for Disclosure in the time framedates of April 2nd
2008 and April 11, 2008 throughoutApril2nd
2009 and April11, 2009
Request Number 25.
Admit: “You” were retain by Co-Defendant(s) JoyceM. Guy and
Edward McCray to not reply to any discovery requestof the Pro Se Plaintiff
herein cause No. A-180805 requestof Interrogatories,Requestof

11. Admission, and Request for Disclosurein the time framedates of April 2nd
2008 and April 11, 2008 throughoutSeptember 1st
2009
Request Number 26.
Admit: “You” claim were retain by Co-Defendant(s) JoyceM. Guy and
Edward McCray simply to the Attorney at Law duties of filing a General
Denial between the dates of December 18th
2007 butwas acting Attorney
of Record throughoutthe dates of November 13th
2009.
Request Number 27.
Admit: “You” were retained by Co-Defendant(s) JoyceM. Guy and
Edward McCray to hide all of the discovery phaseof this civil cause No. A-
180805 fromthePro Se Plaintiff and the 58th
Judicial DistrictCourt of
Jefferson County Texas and Not allowed Pro Se Plaintiff any legal access at
all to said discovery requestof Interrogatories, Requestof Admission, and
Request for DisclosurePro Se Plaintiff mailed to
“You” on the dates of April 2nd
2008 and April11, 2008, in
accordancewith the Texas Rules of Civil Procedures 194.2,197, and 198,
for the “Legal behalf” of Co-Defendant(s) JoyceM. Guy and Edward McCray
between the dates of April2nd
2008 and April 11, 2008 throughoutthe
dates of September 1st
2009.
Request Number 28.
Admit: “You” Attorney at Law were retained by Co-Defendant(s)
Joyce M. Guy and Edward McCray in December of 2007 for causeNo. A-
180805 in the 58th
Judicial DistrictCourt of Jefferson County Texas
Request Number 29.

12. Admit: “You” Attorney at Law were retained by Co-Defendant(s)
Joyce M. Guy and Edward McCray in January of 2008 causeNo. A-180805 in
the 58th
Judicial DistrictCourt of Jefferson County Texas
Request Number 30.
Admit: “You” Attorney at Law were retained by Co-Defendant(s)
Joyce M. Guy and Edward McCray in February of 2008 causeNo. A-180805
in the 58th
Judicial DistrictCourt of Jefferson County Texas
Request Number 31.
Admit: “You” Attorney at Law were retained by Co-Defendant(s)
Joyce M. Guy and Edward McCray in March of 2008 causeNo. A-
180805 in the 58th
Judicial DistrictCourt of Jefferson County Texas
Request Number 32.
Admit: “You” Attorney at Law were retained by Co-Defendant(s)
Joyce M. Guy and Edward McCray in April of 2008 causeNo. A-
180805 in the 58th
Judicial DistrictCourt of Jefferson County Texas.
Request Number 33.
Admit: “You” Attorney at Law were retained by Co-Defendant(s)
Joyce M. Guy and Edward McCray in May of 2008 causeNo. A-
180805 in the 58th
Judicial DistrictCourt of Jefferson County Texas.
Request Number 34.

13. Admit: “You” Attorney at Law were retained by Co-Defendant(s)
Joyce M. Guy and Edward McCray in June of 2008 causeNo. A-
180805 in the 58th
Judicial DistrictCourt of Jefferson County Texas.
Request Number 35.
Admit: “You” Attorney at Law were retained by Co-Defendant(s)
Joyce M. Guy and Edward McCray in July of 2008 causeNo. A-180805
in the 58th
Judicial DistrictCourt of Jefferson County Texas.
Request Number 36.
Admit: “You” Attorney at Law were retained by Co-Defendant(s)
Joyce M. Guy and Edward McCray in Augustof 2008 causeNo. A-
180805 in the 58th
Judicial DistrictCourt of Jefferson County Texas.
Request Number 37.
Admit: “You” Attorney at Law were retained by Co-Defendant(s)
Joyce M. Guy and Edward McCray in September of 2008 causeNo. A-
180805 in the 58th
Judicial DistrictCourt of Jefferson County Texas.
Request Number 38.
Admit: “You” Attorney at Law were retained by Co-Defendant(s)
Joyce M. Guy and Edward McCray in October of 2008 causeNo. A-180805
in the 58th
Judicial DistrictCourt of Jefferson County Texas.
Request Number 39.
Admit: “You” Attorney at Law were retained by Co-Defendant(s)
Joyce M. Guy and Edward McCray in November of 2008 causeNo. A-
180805 in the 58th
Judicial DistrictCourt of Jefferson County Texas.

14. Request Number 40.
Admit: “You” Attorney at Law were retained by Co-Defendant(s)
Joyce M. Guy and Edward McCray in December of 2008 causeNo. A-180805
in the 58th
Judicial DistrictCourt of Jefferson County Texas.
Request Number 41.
Admit: “You” Attorney at Law were retained by Co-Defendant(s)
Joyce M. Guy and Edward McCray in January of 2009 causeNo. A-180805 in
the 58th
Judicial DistrictCourt of Jefferson County Texas.
Request Number 42.
Admit: “You” Attorney at Law were retained by Co-Defendant(s)
Joyce M. Guy and Edward McCray in February of 2009 causeNo. A-180805
in the 58th
Judicial DistrictCourt of Jefferson County Texas.
Request Number 43.
Admit: “You” Attorney at Law were retained by Co-Defendant(s)
Joyce M. Guy and Edward McCray in March of 2009 causeNo. A-180805 in
the 58th
Judicial DistrictCourt of Jefferson County Texas.
Request Number 44.
Admit: “You” Attorney at Law were retained by Co-Defendant(s)
Joyce M. Guy and Edward McCray in April of 2009 causeNo. A-180805in
the 58th
Judicial DistrictCourt of Jefferson County Texas.
Request Number 45.

15. Admit: “You” Attorney at Law were retained by Co-Defendant(s)
Joyce M. Guy and Edward McCray in May of 2009 causeNo. A-180805 in
the 58th
Judicial DistrictCourt of Jefferson County Texas.
Request Number 46.
Admit: “You” Attorney at Law were retained by Co-Defendant(s)
Joyce M. Guy and Edward McCray in June of 2009 causeNo. A-180805in
the 58th
Judicial DistrictCourt of Jefferson County Texas.
Request Number 47.
Admit: “You” Attorney at Law were retained by Co-Defendant(s)
Joyce M. Guy and Edward McCray in July of 2009 causeNo. A-180805 in the
58th
Judicial DistrictCourt of Jefferson County Texas.
Request Number 48.
Admit: “You” Attorney at Law were retained by Co-Defendant(s)
Joyce M. Guy and Edward McCray in Augustof 2009 causeNo. A-180805in
the 58th
Judicial DistrictCourt of Jefferson County Texas.
Request Number 49.
Admit: “You” Attorney at Law were retained by Co-Defendant(s)
Joyce M. Guy and Edward McCray in September of 2009 causeNo. A-
180805 in the 58th
Judicial DistrictCourt of Jefferson County Texas.
Request Number 50.
Admit: “You” Attorney at Law were retained by Co-Defendant(s)
Joyce M. Guy and Edward McCray in October of 2009 causeNo. A-180805
in the 58th
Judicial DistrictCourt of Jefferson County Texas.

16. Request Number 51.
Admit: “You” Attorney at Law were retained by Co-Defendant(s)
Joyce M. Guy and Edward McCray in May of 2008 causeNo. A-180805 in
the 58th
Judicial DistrictCourt of Jefferson County Texas to Keep all of Pro
Se Plaintiff Discovery requestof Interrogatories, Requestof Admission, and
Request for Disclosuresecretfiling away fromthe HonorableCourtrecords
and you simply not reply at all.
Request Number 52.
Admit: “You” Attorney at Law were retained by Co-Defendant(s)
Joyce M. Guy and Edward McCray in June of 2008 causeNo. A-180805in
the 58th
Judicial DistrictCourt of Jefferson County Texas to Keep all of Pro
Se Plaintiff Discovery requestof Interrogatories, Requestof Admission, and
Request for Disclosuresecret filing away fromthe HonorableCourtrecords
and you simply not reply at all..
Request Number 53.
Admit: “You” Attorney at Law were retained by Co-Defendant(s)
Joyce M. Guy and Edward McCray in July of 2008 causeNo. A-180805 in the
58th
Judicial DistrictCourt of Jefferson County Texas to Keep all of Pro Se
Plaintiff Discovery requestof Interrogatories, Requestof Admission, and
Request for Disclosuresecretfiling away fromthe HonorableCourtrecords
and you simply not reply at all..
Request Number 54.
Admit: “You” Attorney at Law were retained by Co-Defendant(s)
Joyce M. Guy and Edward McCray in Augustof 2008 causeNo. A-180805in
the 58th
Judicial DistrictCourt of Jefferson County Texas to Keep all of Pro
Se Plaintiff Discovery requestof Interrogatories, Requestof Admission, and
Request for Disclosuresecretfiling away fromthe HonorableCourtrecords
and you simply not reply at all..

17. Request Number 55.
Admit: “You” Attorney at Law were retained by Co-Defendant(s)
Joyce M. Guy and Edward McCray in September of 2008 causeNo. A-
180805 in the 58th
Judicial DistrictCourt of Jefferson County Texas to Keep
all of Pro Se Plaintiff Discovery requestof Interrogatories, Requestof
Admission, and Request for Disclosuresecretfiling away fromthe
HonorableCourt records and you simply not reply at all..
Request Number 56.
Admit: “You” Attorney at Law were retained by Co-Defendant(s)
Joyce M. Guy and Edward McCray in October of 2008 causeNo. A-180805
in the 58th
Judicial DistrictCourt of Jefferson County Texas to Keep all of Pro
Se Plaintiff Discovery requestof Interrogatories, Requestof Admission, and
Request for Disclosuresecretfiling away fromthe HonorableCourtrecords
and you simply not reply at all.
Request Number 57.
Admit: “You” Attorney at Law were retained by Co-Defendant(s)
Joyce M. Guy and Edward McCray in November of 2008 causeNo. A-
180805 in the 58th
Judicial DistrictCourt of Jefferson County Texas to Keep
all of Pro Se Plaintiff Discovery requestof Interrogatories, Requestof
Admission, and Request for Disclosuresecretfiling away fromthe
HonorableCourt records and you simply not reply at all.
Request Number 58.
Admit: “You” Attorney at Law were retained by Co-Defendant(s)
Joyce M. Guy and Edward McCray in December of 2008 causeNo. A-180805
in the 58th
Judicial DistrictCourt of Jefferson County Texas to Keep all of Pro
Se Plaintiff Discovery requestof Interrogatories, Requestof Admission, and
Request for Disclosuresecretfiling away fromthe HonorableCourtrecords
and you simply not reply at all.

18. Request Number 59.
Admit: “You” Attorney at Law were retained by Co-Defendant(s)
Joyce M. Guy and Edward McCray in January of 2009 causeNo. A-180805 in
the 58th
Judicial DistrictCourt of Jefferson County Texas to Keep all of Pro
Se Plaintiff Discovery requestof Interrogatories, Requestof Admission, and
Request for Disclosuresecretfiling away fromthe HonorableCourtrecords
and you simply not reply at all.
Request Number 60.
Admit: “You” Attorney at Law were retained by Co-Defendant(s)
Joyce M. Guy and Edward McCray in February of 2009 causeNo. A-180805
in the 58th
Judicial DistrictCourt of Jefferson County Texas to Keep all of Pro
Se Plaintiff Discovery requestof Interrogatories, Requestof Admission, and
Request for Disclosuresecretfiling away fromthe HonorableCourtrecords
and you simply not reply at all.
Request Number 61.
Admit: “You” Attorney at Law were retained by Co-Defendant(s)
Joyce M. Guy and Edward McCray in March of 2009 causeNo. A-180805 in
the 58th
Judicial DistrictCourt of Jefferson County Texas to Keep all of Pro
Se Plaintiff Discovery requestof Interrogatories, Requestof Admission, and
Request for Disclosuresecretfiling away fromthe HonorableCourtrecords
and you simply not reply at all.
Request Number 62.
Admit: “You” Attorney at Law were retained by Co-Defendant(s)
Joyce M. Guy and Edward McCray in April of 2009 causeNo. A-180805in
the 58th
Judicial DistrictCourt of Jefferson County Texas to Keep all of Pro
Se Plaintiff Discovery requestof Interrogatories, Requestof Admission, and
Request for Disclosuresecretfiling away fromthe HonorableCourtrecords
and you simply not reply at all.

19. Request Number 63.
Admit: “You” Attorney at Law were retained by Co-Defendant(s)
Joyce M. Guy and Edward McCray in May of 2009 causeNo. A-180805 in
the 58th
Judicial DistrictCourt of Jefferson County Texas to Keep all of Pro
Se Plaintiff Discovery requestof Interrogatories, Requestof Admission, and
Request for Disclosuresecretfiling away fromthe HonorableCourtrecords
and you simply not reply at all.
Request Number 64.
Admit: “You” Attorney at Law were retained by Co-Defendant(s)
Joyce M. Guy and Edward McCray in June of 2009 causeNo. A-180805in
the 58th
Judicial DistrictCourt of Jefferson County Texas to Keep all of Pro
Se Plaintiff Discovery requestof Interrogatories, Requestof Admission, and
Request for Disclosuresecretfiling away fromthe HonorableCourtrecords
and you simply not reply at all.
Request Number 65.
Admit: “You” Attorney at Law were retained by Co-Defendant(s)
Joyce M. Guy and Edward McCray in July of 2009 causeNo. A-180805 in the
58th
Judicial DistrictCourt of Jefferson County Texas to Keep all of Pro Se
Plaintiff Discovery requestof Interrogatories, Requestof Admission, and
Request for Disclosuresecretfiling away fromthe HonorableCourtrecords
and you simply not reply at all.
Request Number 66.
Admit: “You” Attorney at Law were retained by Co-Defendant(s)
Joyce M. Guy and Edward McCray in Augustof 2009 causeNo. A-180805in
the 58th
Judicial DistrictCourt of Jefferson County Texas to Keep all of Pro
Se Plaintiff Discovery requestof Interrogatories, Requestof Admission, and
Request for Disclosuresecretfiling away fromthe HonorableCourtrecords
and you simply not reply at all.

20. Request Number 67.
Admit: “You” Attorney at Law were retained by Co-Defendant(s)
Joyce M. Guy and Edward McCray in September of 2009 causeNo. A-
180805 in the 58th
Judicial DistrictCourt of Jefferson County Texas to Keep
all of Pro Se Plaintiff Discovery requestof Interrogatories, Requestof
Admission, and Request for Disclosuresecretfiling away fromthe
HonorableCourt records and you simply not reply at all.
Request Number 68.
Admit: “You” Attorney at Law Knew you was acting “Attorney of
Record in April and May of 2008 causeNo. A-180805 in the 58th
Judicial
District Courtof Jefferson County Texas and did not file a “Motion for
Withdrawalin April and May of 2008
Request Number 69.
Admit: “You” Attorney at Law Knew you was acting “Attorney of
Record in June of 2008 causeNo. A-180805 in the 58th
Judicial DistrictCourt
of Jefferson County Texas and did not file a “Motion for Withdrawalin June
of 2008
Request Number 70.
Admit: “You” Attorney at Law Knew you was acting “Attorney of
Record in July of 2008 causeNo. A-180805in the 58th
Judicial District Court
of Jefferson County Texas and did not file a “Motion for Withdrawalin July
of 2008
Request Number 71.
Admit: “You” Attorney at Law Knew you was acting “Attorney of
Record in Augustof 2008 causeNo. A-180805 in the 58th
Judicial District

21. Court of Jefferson County Texas and did not file a “Motion for Withdrawal
in Augustof 2008
Request Number 72.
Admit: “You” Attorney at Law Knew you was acting “Attorney of
Record in September of 2008 causeNo. A-180805 in the 58th
Judicial
District Courtof Jefferson County Texas and did not file a “Motion for
Withdrawalin September of 2008
Request Number 73.
Admit: “You” Attorney at Law Knew you was acting “Attorney of
Record in October of 2008 causeNo. A-180805 in the 58th
Judicial District
Court of Jefferson County Texas and did not file a “Motion for Withdrawal
in October of 2008
Request Number 74.
Admit: “You” Attorney at Law Knew you was acting “Attorney of
Record in November of 2008 causeNo. A-180805 in the 58th
Judicial District
Court of Jefferson County Texas and did not file a “Motion for Withdrawal
in November of 2008
Request Number 75.
Admit: “You” Attorney at Law Knew you was acting “Attorney of
Record in December of 2008 causeNo. A-180805in the 58th
Judicial District
Court of Jefferson County Texas and did not file a “Motion for Withdrawal
in December of 2008
Request Number 76.

22. Admit: “You” Attorney at Law Knew you was acting “Attorney of
Record in January of 2009 causeNo. A-180805in the 58th
Judicial District
Court of Jefferson County Texas and did not file a “Motion for Withdrawal
in January of 2009
Request Number 77.
Admit: “You” Attorney at Law Knew you was acting “Attorney of
Record in February of 2009 causeNo. A-180805 in the 58th
Judicial District
Court of Jefferson County Texas and did not file a “Motion for Withdrawal
in February of 2009
Request Number 78.
Admit: “You” Attorney at Law Knew you was acting “Attorney of
Record in March of 2009 causeNo. A-180805 in the 58th
Judicial District
Court of Jefferson County Texas and did not file a “Motion for Withdrawal
in March of 2009
Request Number 79.
Admit: “You” Attorney at Law Knew you was acting “Attorney of
Record in April of 2009 causeNo. A-180805 in the 58th
Judicial DistrictCourt
of Jefferson County Texas and did not file a “Motion for Withdrawalin April
of 2009
Request Number 80.
Admit: “You” Attorney at Law Knew you was acting “Attorney of
Record in May of 2009 causeNo. A-180805in the 58th
Judicial District Court
of Jefferson County Texas and did not file a “Motion for Withdrawalin May
of 2009
Request Number 81.

23. Admit: “You” Attorney at Law Knew you was acting “Attorney of
Record in June of 2009 causeNo. A-180805 in the 58th
Judicial DistrictCourt
of Jefferson County Texas and did not file a “Motion for Withdrawalin June
of 2009
Request Number 82.
Admit: “You” Attorney at Law Knew you was acting “Attorney of
Record in July of 2009 causeNo. A-180805in the 58th
Judicial District Court
of Jefferson County Texas and did not file a “Motion for Withdrawalin July
of 2009
Request Number 83.
Admit: “You” Attorney at Law Knew you was acting “Attorney of
Record in Augustof 2009 causeNo. A-180805 in the 58th
Judicial District
Court of Jefferson County Texas and did not file a “Motion for Withdrawal
in Augustof 2009
Request Number 84.
Admit: “You” Attorney at Law Knew you was acting “Attorney of
Record in September of 2009 causeNo. A-180805 in the 58th
Judicial
District Courtof Jefferson County Texas and did not file a “Motion for
Withdrawalin September of 2009
Request Number 84.
Admit: “You” Attorney at Law Knew you was acting “Attorney of
Record in October of 2009 causeNo. A-180805 in the 58th
Judicial District
Court of Jefferson County Texas and did not file a “Motion for Withdrawal
in October of 2009
Request Number 85.

24. Admit: “You” Attorney at Law Knew you was acting “Attorney of
Record in November of 2009 causeNo. A-180805 in the 58th
Judicial District
Court of Jefferson County Texas and did in Facts and Circumstances file a
“Motion for Withdrawal” as Attorney of record for the behalf of the Co-
Defendant(s) JoyceM. Guy and Edward McCray herein on November 13th
2009 @ 10:22 AMin the Judicial District “Clerk of Court Office” of Jefferson
County Texas.
Request Number 86.
Admit: “You” Attorney at Law Knew you was acting “Attorney of
Record in December of 2007 causeNo. A-180805in the 58th
Judicial District
Court of Jefferson County Texas and did not file a “Motion for Withdrawal
throughoutthe dates of March of 2007 as Attorney of record for the behalf
of the Co-Defendant(s) JoyceM. Guy and Edward McCray herein.
Request Number 87.
Admit: “You” Attorney at Law was retained by Co-Defendant(s)
Joyce. M. Guy and Edward McCray herein cause No. A-180805 and “You”
Attorney at Law appear beforea hearing at the 58th
Judicial District Courtof
Jefferson County Texas on September 11th
, 2009 beforetheHonorable Bob
Worthamand your Clients Co-Defendant(s) Joyce. M. Guy and Edward
McCray herein
Were through “You” wereorder to respond to Pro Se Plaintiff
Discovery requestof Interrogatories, Requestof Admission, and Request
for Disclosure“You” held in your possession, custodyand legal control since
dates of April 2nd
2008 and April11, 2008, that“You” refused to respond to
throughoutthe dates of September 11th
, 2009 atthis hearing before the
HonorableBob Wortham
Request Number 88.
Admit: “You” Attorney at Law was retained by Co-Defendant(s)
Joyce. M. Guy and Edward McCray herein cause No. A-180805 and “You”
Attorney at Law appear beforea hearing at the 58th
Judicial District Courtof

25. Jefferson County Texas on August28th
, 2009 beforetheHonorable Bob
Worthamand your Clients Co-Defendant(s) Joyce. M. Guy and Edward
McCray herein was required to respond to a Motion Pro Se Plaintiff filed
namely a (TRO) Temporary Restraining Order AgainstCo-Defendant“Joyce
M. Guy” herein
Request Number 89.
Admit: “You” Attorney at Law was retained by Co-Defendant(s)
Joyce. M. Guy and Edward McCray herein cause No. A-180805 and “You”
Attorney at Law appear beforea hearing at the 58th
Judicial District Courtof
Jefferson County Texas on August28th
, 2009 beforetheHonorable Bob
Wortham
And your Clients Co-Defendant(s) Joyce. M. Guy and Edward McCray
herein was required to respond to a Motion Pro Se Plaintiff filed namely a
Motion for a Guardian over “Norma Guy” Natural Mother to Co-Defendant
Joyce M. Guy whomhad power of Attorney of said “Mother”.
Request Number 90.
Admit: “You” Attorney at Law was retained by Co-Defendant(s)
Joyce. M. Guy and Edward McCray herein cause No. A-180805 and had in
your full possession, custody and legalcontrol discovery requestof
Interrogatories, Requestof Admission, and Request for DisclosurePro Se
Plaintiff mailed to “You” on the dates of April 2nd
2008 and April11, 2008,
and did not respond to any of said discovery request
When “You” Attorney at Law appear before a hearing at the 58th
Judicial DistrictCourt of Jefferson County Texas on August28th
, 2009 before
the HonorableBob Worthamand your Clients Co-Defendant(s) Joyce. M.
Guy and Edward McCray herein
Was required to respond to a Motion Pro Se Plaintiff filed namely a
Motion for a Guardian over “Norma Guy” Natural Mother to Co-Defendant
Joyce M. Guy whomhad power of Attorney of said “Mother” and “You” did

26. not respond to discovery requestof Interrogatories, Requestfor Admission,
and Request for Disclosureon August28th
, 2009.
Request Number 91.
Admit: “You” Attorney at Law was retained by Co-Defendant(s)
Joyce. M. Guy and Edward McCray herein cause No. A-180805 and had in
your full possession, custody and legalcontrol discovery requestof
Interrogatories, Requestof Admission, and Request for DisclosurePro Se
Plaintiff mailed to “You” on the dates of April 2nd
2008 and April11, 2008
and that
“You” refused to respond to any formal legal reply of somesorts to
said discovery requestand “You” attended two Hearing before the
HonorableBob Wortham 58th
Judicial District Courtof Jefferson County
Texas on dates of August28th
, 2009 and September 11th
, 2009 whilestill
not responding to said discovery requestof Interrogatories, Requestof
Admission, and Request for DisclosurePro Se Plaintiff mailed to “You” on
the dates of April 2nd
2008 and April11, 2008.
Request Number 92.
Admit: “You” Attorney at Law was retained by Co-Defendant(s)
Joyce. M. Guy and Edward McCray herein cause No. A-180805 atthe old
mailing address 448 DeQueen blvd. in PortArthur Texas in December of
2007 and “You” having known Co-Defendant(s) lastknown address to be
5050 east7th
street in PortArthur Texas77642 in the year 2009 up to
November 13th
of 2009
“Your” knowing full well of this change of mailing address and Co-
Defendant(s) Joyce. M. Guy and Edward McCray living at a different
location other then 448 DeQueen Blvd. in Port Arthur Texas while this civil
suit still ongoing in the 58th
Judicial DistrictCourt of Jefferson County
Texas..
Request Number 93.

27. Admit: “You” Attorney at Law was retained by Co-Defendant(s)
Joyce. M. Guy and Edward McCray herein cause No. A-180805 atthe old
mailing address 448 DeQueen blvd. in PortArthur Texas in December of
2007 and having full knowledge that the old home was being completely
disassembled down to the ground and a “New Home” being replaced in
2009 at the old mailing address 448 DeQueen blvd. in PortArthur Texas
And that is why “Your” having full knowledgeof Co-Defendant(s)
Joyce. M. Guy and Edward McCray herein cause No. A-180805 and thatis
why “You” are having known Co-Defendant(s) Joyce. M. Guy and Edward
McCray last known address to be 5050 east7th
street in PortArthur
Texas77642 in the year 2009 up to November 13th
of 2009.
Request Number 94.
Admit: “You” Attorney at Law was retained by Co-Defendant(s)
Joyce. M. Guy and Edward McCray herein cause No. A-180805 atthe old
mailing address 448 DeQueen blvd. in PortArthur Texas 77640 in
December of 2007 and mailed to Co-Defendant(s) Joyce. M. Guy and
Edward McCray herein ”Your” Motion for withdrawal“You” filed on
November 13th
2009 whereby “You” mailed
“Your” Motion for withdrawalto 5050 east7th
street in Port Arthur
Texas 77642 whereby your having fullknowledgeof Co-Defendant(s) last
known address to be at 5050 east7th
street in Port Arthur Texas 77642
thereafter the knowledgeof Co-Defendant(s) Joyce. M. Guy and Edward
McCray herein living in the dwelling located at 448 DeQueen blvd. in Port
Arthur Texas 77640.
Request Number 95.
Admit: “You” Attorney at Law was not going to mail a copy of “Your”
Motion for withdrawalto the dwelling located at 448 DeQueen blvd. in Port
Arthur Texas 77640 on or about November 13th
of 2009 you filed in
Jefferson County Clerk of CourtOffice knowingly thatthe dwelling located

28. at 448 DeQueen blvd. in Port Arthur Texas no longer exist, and Construction
of a New Home had commence in the year of 2009 for the Co-Defendant(s)
Joyce. M. Guy and Edward McCray herein.
Request Number 96.
Admit: “You” Attorney at Law was retained by Co-Defendant(s)
Joyce. M. Guy and Edward McCray herein cause No. A-180805 on or about
December 18th
2007 and did “You” did not filed a Motion for withdrawalon
or aboutJune 18th
2009 when Co-Defendant(s)Joyce. M. Guy and Edward
McCray herein transfer property dwelling located at 448 DeQueen blvd. in
PortArthur Texas to “The Department of Housing & Community Affairs” for
a “New Home” during the same time frame “You” Attorney at Law was
retained by Co-Defendant(s) Joyce. M. Guy and Edward McCray herein
causeNo. A-180805
And “You” had in your full possession, custody and legal control
discovery requestof Interrogatories, Requestof Admission, and Request for
DisclosurePro Se Plaintiff mailed to “You” on the dates of April 2nd
2008
and April 11, 2008, and “You” did not respond to any of said discovery
request until on or about October 14th
2009
Request Number 97.
Admit: “You” Attorney at Law was retained by Co-Defendant(s)
Joyce. M. Guy and Edward McCray herein cause No. A-180805 on or about
December 18th
2007 and”You” did not filed a Motion for withdrawalon or
about June 18th
2009 when Co-Defendant(s) Joyce. M. Guy and Edward
McCray herein filed with The County Clerk office in Jefferson County Texas
“
“Financing Statement” in connection with “The Departmentof
Housing & Community Affairs” for a “New Home” during the same time
frame “You” Attorney at Law was retained by Co-Defendant(s) Joyce. M.
Guy and Edward McCray herein causeNo. A-180805

29. And “You” had in “Your” full possession, custodyand legal control
discovery requestof Interrogatories, Requestof Admission, and Request for
DisclosurePro Se Plaintiff mailed to “You” on the dates of April 2nd
2008
and April 11, 2008, and “You” did not respond to any of said discovery
request until on or about October 14th
2009.
Request Number 98.
Admit: “You” Attorney at Law was retained by Co-Defendant(s)
Joyce. M. Guy and Edward McCray herein cause No. A-180805 on or about
December 18th
2007 and did not filed a Motion for withdrawalon or about
June 18th
2009 when Co-Defendant(s) Joyce. M. Guy and Edward McCray
herein had a
“Mechanics Lien” filed against them by “SWMJ Construction Inc.”
filed with The County Clerk office in Jefferson County Texas “or about June
18th
2009 during thesame time frame “You” Attorney at Law was retained
by Co-Defendant(s) Joyce. M. Guy and Edward McCray herein causeNo. A-
180805
And “You” had in “Your” full possession, custodyand legal control
discovery request of Interrogatories, Requestfor Admission, and Request
for DisclosurePro Se Plaintiff mailed to “You” on the dates of April 2nd
2008
and April 11, 2008, and “You” did not respond to any of said discovery
request until on or about October 14th
2009.
Request Number 99.
Admit: “You” Attorney at Law was retained by Co-Defendant(s)
Joyce. M. Guy and Edward McCray herein cause No. A-180805 on or about
December 18th
2007 as was requested to comply to Texas rules of Civil
Procedures 30 days later with a responseto Pro Se Plaintiff Discovery
request “You” had in your full possession, custody and legal control, said
discovery requestof Interrogatories, Requestof Admission, and Request for
DisclosurePro Se Plaintiff mailed to “You” on the dates of April 2nd
2008
and April 11, 2008, and
“You” did not respond to any of said discovery request(30) days later
as required and demanded but until in the time frame of on or about

30. October 14th
2009 when your responseto Discovery Requestin Civil No. A-
180805
Some (1) year and (6) months plus days later as “You” was requested
complying with Texas rules of Civil Procedures, 194.2., 197, and 198.
Request of Interrogatories, Requestof Admission, and Request for
Disclosure
Request Number 100.
Admit: “You” Attorney at Law was retained by Co-Defendant(s)
Joyce. M. Guy and Edward McCray herein cause No. A-180805 on or about
December 18th
2007 you filed a General Denial and on November 13th
2009
at 10:22 am “You” filed a Motion to Withdrawalas Counsel fromCo-
Defendant(s) herein “Joyce M. Guy and Edward McCray Civil No. A-180805
filed in The Jefferson County 58th
Judicial District Courtin Jefferson County
Texas.
Request Number 101.
Admit: Texas Rules of Civil Procedures 194.2. (Plaintiff) “Requestfor
Disclosure” requiremailed to you on the dates of April 2nd
2008 and April
11, 2008“You” to respond to on behalf of Co-Defendant(s) Joyce. M. Guy
and Edward McCray herein causeNo. A-180805 (30) days thereafter mailing
of serviceupon “You” to so reply
Request Number 102.
Admit: Texas Rules of Civil Procedures 197 (Plaintiff)
“Interrogatories” mailed to “You” ” on the dates of April 2nd
2008 and April
11, 2008 require“You” to respond to on behalf of Co-Defendant(s) Joyce.
M. Guy and Edward McCray herein causeNo. A-180805 (30) days thereafter
mailing of service upon “You” to so reply
Request Number 103.
Admit: Texas Rules of Civil Procedures 198 (Plaintiff)
“Interrogatories” mailed to “You” ” on the dates of April 2nd
2008 and April
11, 2008 require“You” to respond to on behalf of Co-Defendant(s) Joyce.

31. M. Guy and Edward McCray herein causeNo. A-180805 (30) days thereafter
mailing of service upon “You” to so reply
Request Number 104.
Admit: “You” Attorney at Law are partly “Responsiblefor the
damages suffered by Pro Se Plaintiff herein.
Request Number 105.
Admit: “You” Attorney at Law are fully “Responsiblefor the damages
suffered by Pro Se Plaintiff herein.
Request Number 106.
Admit: “You” Attorney at Law do not have any defenses to the claims
against you contained in Pro Se Plaintiff’s Complaint
Request Number 107.
Admit: “You” Attorney at Law that none of the denials contained in
your answer to Pro Se Plaintiff’s Complaint have any Merit.
Request Number 108.
Admit: “You” Attorney at Law that you signed the “responseto
Plaintiff’s Motion for Sanctions attached as document#1 herein
Request Number 109.
Admit: “You” Attorney at Law that you signed the “Motion for
Withdrawalof Counsel” On November 13th
, 2009 filed at 10:22 am
Jefferson County Texas, CourthouseClerk of CourtOffice attached as
document #2 attached herein
Request Number 110.
Admit: “You” Attorney at Law that “You” supplied Co-Defendant(s)
“JoyceM. Guy” and Edward McCray last known addresses to be that of
5050 east7th
street in PortArthur Texas 77642 in November 13th
2009 on

32. the attached document #2 herein containing “Your” signature. “Motion for
Withdrawalof Counsel” On November 13th, 2009 filed at 10:22 am
Jefferson County Texas, CourthouseClerk of CourtOffice
Request Number 111.
Admit: “You” Attorney at Law that “You did not file a
“Motion for Withdrawalof Counsel” attached as document #2 herein
until November 13th, 2009 filed at 10:22 amJefferson County Texas,
CourthouseClerk of Court Officeand that you were legally retain as
Attorney of Law Texas Bar. No. 24058299 to attended (2) courthearing
before the 58th
Judicial District Courtin Jefferson County Texas for the legal
behalf of Co-Defendant(s) Joyce. M. Guy and Edward McCray herein cause
No. A-180805on the dates of “August28th
2009 and September 11th
2009
Request Number 112.
Admit: “You” Attorney at Law that “You” signed the “Responseto
FirstSet of Interrogatories of Plaintiff Louis Charles Hamilton II on October
14th
2009 attached document #3 herein containing “Your” signature, that
“You” Attorney at Law had in “Your” legal possession, custody and control
on the dates of April 2nd
2008 and April11, 2008.
Request Number 113.
Admit: “You” Attorney at Law that “You” signed the “Responseto
Request for Admissions of Plaintiff Louis Charles Hamilton II on October 14th
2009 attached document#4 herein containing “Your” signature, that “You”
Attorney at Law had in “Your” legal possession, custody and controlon the
dates of April 2nd
2008 and April11, 2008.
Request Number 114.
Admit: “You” Attorney at Law that “You” were “monetary retain” to
file a General Denial on December 18th
2007 and that you were legally
retained as Attorney of Law Texas Bar. No. 24058299 to attended (2) court

33. hearing beforethe 58th
Judicial DistrictCourt in Jefferson County Texas for
the legal behalf of Co-Defendant(s) Joyce. M. Guy and Edward McCray
herein cause No. A-180805 on the dates of “August28th
2009 and
September 11th
2009
But “You” was “monetary retain” to keep also all discovery request
phaseof request of Interrogatories, Requestfor Admission, and Request for
Disclosureyou had in your possession, custody and legal control
“Absolutely Secret”, Private, and not to be a partof the Pro Se Plaintiff
herein ongoing civil court proceeding against Co-Defendant(s) Joyce. M.
Guy and Edward McCray herein while “Your” being acting Attorney of
record for cause No. A-180805filed in the Jefferson County Texas
Courthouse
Request Number 115.
Admit: “You” Attorney at Law that you were “monetary retain” to file
a “General Denial” on December 18th
2007 for theCo-Defendant(s) Joyce.
M. Guy and Edward McCray herein then “You” Attorney at Law
Were monetary retain as legal counsel“once again” on August28th
2009 to attend a Court hearing same cause No. A-180805 filed in the
Jefferson County Texas Courthousefor the Co-Defendant(s) Joyce. M. Guy
and Edward McCray herein then
“You” Attorney at Law were retained “another once” as legal
counselagain on September 11th
2009 to attend another separatecourt
hearing in the samecause No. A-180805 filed in the Jefferson County Texas
Courthouse
But “You” Attorney at Law at no time framebetween the dates of
April 2nd
2008 and April11, 2008, throughoutSeptember 14th
2009 was
monetary retain by the Co-Defendant(s) Joyce. M. Guy and Edward McCray
herein
To file and respond to any of the Pro Se Plaintiff Discovery request
“You” had in your full possession, custodyand legal control, said discovery
request of Interrogatories, Requestof Admission, and Request for
DisclosurePro Se Plaintiff mailed to

34. “You” on the dates of April 2nd
2008 and April11th
2008 for thesame
causeNo. A-180805 filed in the Jefferson County Texas Courthouse.
Request Number 116.
Admit: “You” Attorney at Law that “You” were “monetary retain” to
file a General Denial on December 18th
2007 and that you were legally
retained once again at some point as acting Attorney of Law Texas Bar. No.
24058299 to prepareand be ready to attended (2) court hearing before the
58th
Judicial DistrictCourt in Jefferson County Texas for the legal behalf of
Co-Defendant(s) Joyce. M. Guy and Edward McCray herein cause No. A-
180805 on thedates of “August28th
2009 and September 11th
2009
And during this sametime frame of your retain services on
September 2nd
of 2009 before“Your” September 11th
2009 hearing No. A-
180805 thatrequired “You” to producePro Se Plaintiff said discovery
request on behalf of Co-Defendant(s) JoyceM. Guy and Edward McCray
herein
Pro Se Plaintiff herein filed on September 2nd
of 2009 “inquiry,
investigation, and complaint” #21883 with the “State of Texas, Department
of Aging and Disability Services” regarding GNG Service Company of Co-
Defendant “JoyceM. Guy” herein in violation of Health and Safety Code
Chapter 142 by
Co-Defendant“Joyce M. Guy” herein engaging in home health or
personalassistanceservices, which includes hands-on personalcare; by
representing to the public that Co-Defendant“JoyceM. Guy” herein is a
provider of home health, or personalassistanceservices which includes
hands-on personalcarefor “Pay”
Co-Defendant“Joyce M. Guy” herein never having a HCSSA license
and immediately cease providing home health services without said HCSSA
licensed attached document #5 and # 6 herein dated December 1st
, 2009
and January 7th
2010
Request Number 117.

35. Admit: “You” Attorney at Law that “You” were fully awareduring the
time frame of December 18th
2007 throughout“Your” being acting
Attorney of record until November 13th
2009 your being awarePro Se
Plaintiff was making “inquiry, investigation, and discovery requests into the
past history of your “Clients” Co-Defendant(s) “JoyceM. Guy and Edward
McCray” herein.
Request Number 118.
Admit: “You” Attorney at Law that “You” signed the “Responseto
FirstSet of Interrogatories of Plaintiff Louis Charles Hamilton II on October
14th
2009 attached document #3 herein containing “Your” signature, that
“You” did not forward said discovery requestback to the Pro Se Plaintiff
herein their after (60) days of said discovery requestbeing in your full legal
possession, custody, and legal control on or about the dates of April 2nd
2008 and April 11, 2008.
Request Number 119.
Admit: “You” Attorney at Law that “You” signed the “Request for
Admission of Plaintiff Louis Charles Hamilton II on October 14th
2009
attached document #2 herein containing “Your” signature,
That “You” did not forward said discovery requestback to the Pro Se
Plaintiff herein their after (60) days of said discovery requestbeing in your
full legal possession, custody,and legal control on or about the dates of
April 2nd
2008 and April11, 2008.
Request Number 120.
Admit: “You” Attorney at Law that “You” signed the “Responseto
FirstSet of Interrogatories of Plaintiff Louis Charles Hamilton II on October
14th
2009 attached document #3 herein containing “Your” signature, that
“You” did not forward all of said legal discovery request“docketNo.
A-180805” being in “Your” full legal possession, custody,and legal control
on or about the dates of April2nd
2008 and April 11, 2008

36. Being forward (30) to (60) days thereafter to any other Law Officeor
Attorney(s) other then “Yourself” for the “Legal Behalf of the Co-
Defendant(s) JoyceM. Guy and Edward McCray herein ongoing Civil Suit in
Common Law.
Request Number 121.
Admit: “You” Attorney at Law that “You” signed the “Request for
Admission of Plaintiff Louis Charles Hamilton II on October 14th
2009
attached document #2 herein containing “Your” signature,
“You” did not forward all of said legal discovery request“docketNo.
A-180805” being in “Your” full legal possession, custody,and legal control
on or about the dates of April2nd
2008 and April 11, 2008
Being Forward (30) to (60) days thereafter to any other Law Officeor
Attorney(s) other then “Yourself” for the “Legal Behalf of the Co-
Defendant(s) JoyceM. Guy and Edward McCray herein ongoing Civil Suit in
Common Law.
Request Number 122.
Admit: “You” Attorney at Law that “You” received and had in “Your”
possession, custody, and legal control fromPro Se Plaintiff “Louis Charles
Hamilton II” herein a “Motion for Production of Document(s) dated August
12th
2009” on the certificate of mailing services for the same cause No. A-
180805 filed in the Jefferson County Texas Courthouse
Said Motion for Production of Document(s) requested “among other
things” copies of the Property Deeds of the dwelling of 448 DeQueen Blvd.
in Port Arthur Texas.
That’s being in the possession, custody and legal controlof the Co-
Defendant(s) “JoyceM. Guy and Edward McCray” herein
Request Number 123.
Admit: “You” Attorney at Law that “You” received and had in “Your”
possession, custody, and legal control fromPro Se Plaintiff “Louis Charles

37. Hamilton II” herein a “Motion for Production of Document(s) dated August
12th
2009” on the certificate of mailing services for the same cause No. A-
180805 filed in the Jefferson County Texas Courthouse and
“You” Attorney at Law was retain to attended a hearing on August
28th
2009 (16) days later after “Your” receiving a “Motion for Production of
Document(s) dated August12th
2009” for theBehalf of the Co-Defendant(s)
“JoyceM. Guy and Edward McCray” herein
While The Interrogatories, Requestof Admission, and Request for
DisclosurePro Se Plaintiff mailed to “You” on the dates of April 2nd
2008
and April 11, 2008, in accordancewith the Texas Rules of Civil Procedures
194.2, 197, and 198, in causeNo. A-180805 “You” Attorney atLaw refused
to respond and that on the date of “August12th
2009”
And “You” Attorney at Law did not file any Motion for withdrawalon
“August12th
2009 fromcauseNo. A-180805filed in the Jefferson County
Texas Courthouse.
Request Number 124.
Admit: “You” Attorney at Law that “You” knew from the Co-
Defendant(s) “JoyceM. Guy and Edward McCray” herein
That the “Property Deed of the dwelling of 448 DeQueen Blvd. in
PortArthur Texas. Pro Se Plaintiff sent“You” herein a “Motion for
Production of Document(s) dated August12th
2009 for said “Property
Deeds that’s being in the possession, custody and legal control of the Co-
Defendant(s) “JoyceM. Guy and Edward McCray” herein
During this sametime frame “Your” being acting Attorney of record
causeNo. A-180805 filed in the Jefferson County Texas Courthouse said
“Property Deeds” was Legally Transfer to the Texas Department of Housing
& Community Affairs on June 18th
2009 as described by “Jefferson County
Real Estate Indexin attached document #7 herein
Request Number 125.

38. Admit: “You” Attorney at Law that “You” refused to respond to any
of Pro Se Plaintiff “Motion for Production of Document(s) dated August12th
2009” on the certificate of mailing services for the same causeNo. A-
180805 filed in the Jefferson County Texas Courthouse(30) days thereafter
serviceupon
“You” for the behalf of the Co-Defendant(s) “JoyceM. Guy and
Edward McCray” herein and “You” did not file a Motion for withdrawalon
September 9th
2009 whilebeing in the possession, custody and legal control
Pro Se Plaintiff “Motion for Production of Document(s) dated August12th
2009”
Request Number 126.
Admit: “You” Attorney at Law that “You” refused to respond to any
of Pro Se Plaintiff “Motion for Production of Document(s) dated August12th
2009” on the certificate of mailing services for the same causeNo. A-
180805 filed in the Jefferson County Texas Courthouse(30) days thereafter
serviceupon “You” for the behalf of the Co-Defendant(s) “JoyceM. Guy
and Edward McCray” herein
And “You” however in facts was retain to attend a hearing on the
date of August28th
2009 services for thesame cause No. A-180805 in the
capacity as Attorney of Record some (16) days after services of “Motion for
Production of Document(s) dated August12th
2009” on the certificate of
mailing services being in “Your” Possession, custody, and Control
Which “You” during this same “Time Frame” However were
personally presentfor on the dates of August28th
2009 hearing thereafter
While “You” already 100% being in full refusalto respond to any Pro
Se Plaintiff herein discovery requestin “Your” full possession, custodyand
legal control, discovery requestof Interrogatories, Requestof Admission,
and Request for DisclosurePro Se Plaintiff mailed to “You” on the dates of
April 2nd
2008 and April11, 2008 the pastyear.
Request Number 127.

39. Admit: “You” Attorney at Law that “You” refused to respond to any
of Pro Se Plaintiff “Motion for Production of Document(s) dated August12th
2009” on the certificate of mailing services for the same causeNo. A-
180805 filed in the Jefferson County Texas Courthouse(30) days thereafter
serviceupon “You” for the behalf of the Co-Defendant(s) “JoyceM. Guy
and Edward McCray” herein
And “You” however in facts was retain to attend a hearing on the
date of September 11th
2009 services for thesame causeNo. A-180805 in
the capacity as Attorney of Record some(16) days after services of “Motion
for Production of Document(s) dated August12th
2009” on thecertificate of
mailing services being in “Your” Possession, custody, and Control
Which “You” were during this “same time frame” personally present
for one said hearing on the dates of September 11th
2009 hearing
thereafter
While “You” already being in 100% fullrefusalto respond to any Pro
Se Plaintiff herein discovery requestin “Your” full possession, custodyand
legal control, discovery requestof Interrogatories, Requestof Admission,
and Request for DisclosurePro Se Plaintiff mailed to “You” on the dates of
April 2nd
2008 and April11, 2008 the pastyear.
Request Number 128.
Admit: “You” Attorney at Law that “Jefferson County Real Estate
Index” Instrument#2009022762 in Attached document #7 herein shown
the Legal Transfer of the property deed of the Co-Defendant(s) herein Joyce
M. Guy and Edward McCray” dwelling located at 448 DeQueen Blvd. in Port
Arthur Texas herein on the dates of June 18th
2009 to “The Texas
Department of Housing & Community Affairs
While Which “Your” in full refusalto respond to Pro Se Plaintiff
“Motion for Production of Document(s) dated August12th
2009”on the
certificate of mailing services for the samecause No. A-180805 filed in the
Jefferson County Texas Courthouse(30) days thereafter serviceupon “You”
for the behalf of the Co-Defendant(s) “JoyceM. Guy and Edward McCray”
herein copies of such “Property Deeds” ”

40. For the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas
being already complained of in a among other causeof action “Breach of
Contract dispute” in a civil suit in common law beforethe 58th
Judicial
District Courtof Jefferson County Texas causeNo. A-180805.
Request Number 129.
Admit: “You” Attorney at Law that “You” having in “Your” full
possession, custody and legalcontrol, over Pro Se Plaintiff herein “Motion
to Compel” Co-Defendant(s) “JoyceM. Guy and Edward McCray” herein
with mailing service date executed on September 9th
2009 samecauseNo.
A-180805
While “You” already being in 100% full refusalto respond to any Pro
Se Plaintiff herein discovery requestin “Your” full possession, custodyand
legal control, discovery requestof Interrogatories, Requestof Admission,
and Request for DisclosurePro Se Plaintiff mailed to “You” on the dates of
April 2nd
2008 and April11, 2008 the pastyear same cause No. A-180805,
While “You” were already during this “same time frame” personally
present for one said hearing on the dates of September 11th
2009 hearing
thereafter same causeNo. A-180805
While “You” were already during this “same time frame” personally
present for one said hearing on the dates of August28th
2009 hearing
thereafter not filing a “Motion for withdrawal” samecause No. A-180805
While “You” were already during this “same time frame” ” refused to
respond to any of Pro Se Plaintiff “Motion for Production of Document(s)
dated August12th
2009” on the certificate of mailing services for the same
causeNo. A-180805 filed in the Jefferson County Texas Courthouse(30)
days thereafter serviceupon
“You” for the behalf of the Co-Defendant(s) “JoyceM. Guy and
Edward McCray” herein to Produceamong other things copies of Property
deed for the dwelling located at 448 DeQueen Blvd. in PortArthur Texas
(Lot) 1-2 blk. 172 (PortArthur Texas) same causeNo. A-180805

41. While “You” Attorney at Law refusalto file “Your” “Motion for “Your”
withdrawalon or before next 58th
Judicial DistrictCourt in Jefferson County
Texas hearing on the dates set for September 11th
2009 samecauseNo. A-
180805.
While “You” did personally appeared as acting Attorney of Record for
same causeNo. A-180805 on thedates of September 11th
2009.
But “Your” never replying to or responding to any such discovery
request soughtby the Pro Se Plaintiff herein as described herein “Request
for Admission” # 129.
Request Number 130.
Admit: “You” Attorney at Law that “You” knew Texas rules of Civil
Procedures 196. Govern “Motion for Production of Documents” require
“You” to respond to (30) days thereafter serviceupon you such a Motion
for Production of Documents.
Request Number 131.
Admit: “You” Attorney at Law that “You” knew Texas rules of Civil
Procedures 196. Govern “Motion for Production of Documents” require
“You” to respond to (30) days thereafter serviceupon you for such a
Motion for Production of Documents and “You” Attorney at law refuseto
respond (30) days thereafter serviceupon you on dates of Service of
mailing date August12th
2009.
Request Number 132.
Admit: “You” Attorney at Law that “You” knew Texas rules of Civil
Procedures 196. Govern “Motion for Production of Documents” require
“You” to respond to (30) days thereafter serviceupon you for such a
Motion for Production of Documents and
“You” Attorney at law refuseto respond (30) days thereafter service
upon you on dates of Service of mailing date August12th
2009 for said
Production copies of “Property Deeds” for the dwelling located at 448

42. DeQueen Blvd. in PortArthur Texas (Lot) 1-2 blk. 172 (PortArthur Texas)
same causeNo. A-180805
But “Your” in 100% refusalto File a simple Motion for “Your”
withdrawalof Counselfor the behalf of the Co-Defendant(s) “JoyceM. Guy
and Edward McCray” herein during the time frame dates of August12th
2009.
Request Number 133.
Admit: “You” Attorney at Law that “Your” Legal Expert in the capacity
of “Attorney at Law” specialties skills “among other things” are described
expert in Criminal Defense, “Fraud”, Insuranceand PersonalInjuryattwo
legal law firms locations in Jefferson County, PortArthur Texas
Request Number 134.
Admit: “You” Attorney at Law that “Your” reply in your responseto
Pro Se Plaintiff motion for sanctions dated the 11th
day of September 2009
you state of having any knowledgeof “Required Pro Se Plaintiff discovery
request for admissions, interrogatories and Disclosureon or about the
dates of April 2nd
2008 and April11, 2008 as described in Document# 1
attached herein.
Request Number 135.
Admit: “You” Attorney at Law that on Document# 1 containing your
correctTexas Bar No. 24058299
Request Number 136.
Admit: “You” Attorney at Law that on Document# 8 58th
Judicial
District Courtof Jefferson County Texas “CaseLedger” that on March 14th
2008 is the correct “actual date” your having full knowledgeof Required
Pro Se Plaintiff discovery requestfor admissions, interrogatories and
Disclosurefor causeNo. A-180805

43. Request Number 137.
Admit: “You” Attorney at Law that “Your” reply in your responseto
Pro Se Plaintiff motion for sanctions dated the 11th
day of September 2009
Document # 1 herein
You state of having any knowledgeof “Required Pro Se Plaintiff
discovery requestfor admissions, interrogatories and Disclosureon or
about the dates of April 2nd
2008 and April11, 2008 as described in
Document # 1 attached herein
And this is not-correctand completely a false statement made by
“you” “Attorney at Law” in regards to the correct dates of “Your” having
knowledgeof Pro Se Plaintiff discovery requestfor admissions,
interrogatories and Disclosure
And the correct date is March 14th
2008 “Your” having actual
knowledgeof “Required Pro Se Plaintiff discovery requestfor admissions,
interrogatories and Disclosureas described in Document # 8 herein 58th
Judicial DistrictCourt of Jefferson County Texas “Case Ledger”
Request Number 138.
Admit: “You” Attorney at Law that is “Your” signatureon Document
# 9 attached herein “Your” Affidavitin Supportof your reply to Pro Se
Plaintiff Motion for sanctions dated 11th
day of September 2009 and
Document # 9 contain a false verification on oath of “Your” sworn
statement made by “you”
And “Your” having actual knowledge of “Required Pro Se Plaintiff
discovery requestfor admissions, interrogatories and Disclosureas
described in Document# 8 herein 58th
Judicial DistrictCourt of Jefferson
County Texas “Case Ledger”
Request Number 139.
Admit: “You” Attorney at Law that “Your” Affidavitin supportof
your reply to Pro Se Plaintiff “Motion for Sanctions” againstyou Document

44. #9 herein with false statement made by “You” was Placed in the United
States Mail and Publically Mailed to the Pro Se Plaintiff herein at P.O. Box
342 PortArthur Texas 77640
Request Number 140.
Admit: You” Attorney at Law that “Your” Affidavit in supportof your
reply to Pro Se Plaintiff “Motion for Sanctions” againstyou Document #9
herein with false statement made by “You” was Placed in the United States
Mail and Publically Mailed to Co -Defendant(s) “JoyceM. Guy and Edward
McCray” collectively herein CauseNo. A-180805
Request Number 141.
Admit: You” Attorney at Law that “Your” Affidavit in supportof your
reply to Pro Se Plaintiff “Motion for Sanctions” againstyou Document #9
herein with false statement made by “You” was Placed in the United States
Mail and Publically Mailed to The Jefferson County Texas Court House
“Clerk of District Court” for causeNo. A-180805
Request Number 142.
Admit: You” Attorney at Law that “Your” Affidavit in supportof your
reply to Pro Se Plaintiff “Motion for Sanctions” againstyou Document #9
herein with false statement made by “You” was Placed in the United States
Mail and Publically Mailed to The Jefferson County Texas Court House
“Clerk of District Court” for causeNo. A-180805
And was electronically computer filed in Document# 8 herein 58th
Judicial DistrictCourt of Jefferson County Texas “Case Ledger” and Court
Records for cause No. A-180805
Request Number 143.
Admit: “You” Attorney at Law that “Your” reply/respond to Pro Se
Plaintiff “Motion for Sanctions” against you Document #1 herein with false
statement made by “You” was Placed in the United States Mail and
Publically Mailed to the Pro Se Plaintiff herein at P.O. Box 342 PortArthur
Texas 77640

45. Request Number 144.
Admit: “You” Attorney at Law that “Your” reply/respond to Pro Se
Plaintiff “Motion for Sanctions” against you Document #1 herein with false
statement made by “You” was Placed in the United States Mail and
Publically Mailed to Co -Defendant(s) “JoyceM. Guy and Edward McCray”
collectively herein CauseNo. A-180805
Request Number 145.
Admit: “You” Attorney at Law that “Your” reply/respond to Pro Se
Plaintiff “Motion for Sanctions” against you Document #1 herein with false
statement made by “You” was Placed in the United States Mail and
Publically Mailed to The Jefferson County Texas Court House“Clerk of
District Court” for cause No. A-180805
Request Number 146.
Admit: “You” Attorney at Law that “Your” reply/respond to Pro Se
Plaintiff “Motion for Sanctions” against you Document #1 herein with false
statement made by “You” was Placed in the United States Mail and
Publically Mailed to The Jefferson County Texas Court House“Clerk of
District Court” for cause No. A-180805
And was electronically computer filed in Document# 8 herein 58th
Judicial DistrictCourt of Jefferson County Texas “Case Ledger”
Request Number 147.
Admit: “You” Attorney at Law that “Your” Affidavitin supportof
your reply to Pro Se Plaintiff “Motion for Sanctions” againstyou Document
#9 herein with false statement made by “You” was Placed in the United
States Mail and Publically Mailed to the Pro Se Plaintiff herein at P.O. Box
342 PortArthur Texas 77640
During this sametime frame “Your” being acting Attorney of record
causeNo. A-180805 filed in the Jefferson County Texas Courthousesaid
“Property Deeds” for the dwelling located at 448 DeQueen Blvd. in Port

46. Arthur Texas of the Co-Defendant(s) “JoyceM. Guy and Edward McCray
herein
Was Legally Transfer to the Texas Department of Housing &
Community Affairs on June 18th
2009 as described by “Jefferson County
Real Estate Indexin attached document #7 herein for a $76,000.00 U. S.
Dollars Housing Grant
Request Number 148.
Admit: You” Attorney at Law that “Your” Affidavit in supportof your
reply to Pro Se Plaintiff “Motion for Sanctions” againstyou Document #9
herein with false statement made by “You” was Placed in the United States
Mail and Publically Mailed to Co -Defendant(s) “JoyceM. Guy and Edward
McCray” collectively herein CauseNo. A-180805
During this sametime frame “Your” being acting Attorney of record
causeNo. A-180805 filed in the Jefferson County Texas Courthousesaid
“Property Deeds” ” for the dwelling located at 448 DeQueen Blvd. in Port
Arthur Texas of the Co-Defendant(s) “JoyceM. Guy and Edward McCray
herein
Was Legally Transfer to the Texas Department of Housing &
Community Affairs on June 18th
2009 as described by “Jefferson County
Real Estate Indexin attached document #7 herein for a $76,000.00 U. S.
Dollars Housing Grant
Request Number 149.
Admit: You” Attorney at Law that “Your” Affidavit in supportof your
reply to Pro Se Plaintiff “Motion for Sanctions” againstyou Document #9
herein with false statement made by “You” was Placed in the United States
Mail and Publically Mailed to The Jefferson County Texas Court House
“Clerk of District Court” for causeNo. A-180805
During this sametime frame “Your” being acting Attorney of record
causeNo. A-180805 filed in the Jefferson County Texas Courthousesaid
“Property Deeds” ” for the dwelling located at 448 DeQueen Blvd. in Port

47. Arthur Texas of the Co-Defendant(s) “JoyceM. Guy and Edward McCray
herein
Was Legally Transfer to the Texas Department of Housing &
Community Affairs on June 18th
2009 as described by “Jefferson County
Real Estate Indexin attached document #7 herein for a $76,000.00 U. S.
Dollars Housing Grant
Request Number 150.
Admit: You” Attorney at Law that “Your” Affidavit in supportof your
reply to Pro Se Plaintiff “Motion for Sanctions” againstyou Document #9
herein with false statement made by “You” was Placed in the United States
Mail and Publically Mailed to The Jefferson County Texas Court House
“Clerk of District Court” for causeNo. A-180805
And was electronically computer filed in Document# 8 herein 58th
Judicial DistrictCourt of Jefferson County Texas “Case Ledger” and Court
Records for cause No. A-180805
During this sametime frame “Your” being acting Attorney of record
causeNo. A-180805 filed in the Jefferson County Texas Courthousesaid
“Property Deeds” ” for the dwelling located at 448 DeQueen Blvd. in Port
Arthur Texas of the Co-Defendant(s) “JoyceM. Guy and Edward McCray
herein
Was Legally Transfer to the Texas Department of Housing &
Community Affairs on June 18th
2009 as described by “Jefferson County
Real Estate Indexin attached document #7 herein for a $76,000.00 U. S.
Dollars Housing Grant
Request Number 151.
Admit: “You” Attorney at Law that “Your” reply/respond to Pro Se
Plaintiff “Motion for Sanctions” against you Document #1 herein with false
statement made by “You” was Placed in the United States Mail and
Publically Mailed to the Pro Se Plaintiff herein at P.O. Box 342 PortArthur
Texas 77640

48. During this sametime frame “Your” being acting Attorney of record
causeNo. A-180805 filed in the Jefferson County Texas Courthousesaid
“Property Deeds” ” for the dwelling located at 448 DeQueen Blvd. in Port
Arthur Texas of the Co-Defendant(s) “JoyceM. Guy and Edward McCray
herein
Was Legally Transfer to the Texas Department of Housing &
Community Affairs on June 18th
2009 as described by “Jefferson County
Real Estate Indexin attached document #7 herein for a $76,000.00 U. S.
Dollars Housing Grant
Request Number 152.
Admit: “You” Attorney at Law that “Your” reply/respond to Pro Se
Plaintiff “Motion for Sanctions” against you Document #1 herein with false
statement made by “You” was Placed in the United States Mail and
Publically Mailed to Co -Defendant(s) “JoyceM. Guy and Edward McCray”
collectively herein CauseNo. A-180805
During this sametime frame “Your” being acting Attorney of record
causeNo. A-180805 filed in the Jefferson County Texas Courthousesaid
“Property Deeds” ” for the dwelling located at 448 DeQueen Blvd. in Port
Arthur Texas of the Co-Defendant(s) “JoyceM. Guy and Edward McCray
herein
Was Legally Transfer to the Texas Department of Housing &
Community Affairs on June 18th
2009 as described by “Jefferson County
Real Estate Indexin attached document #7 herein for a $76,000.00 U. S.
Dollars Housing Grant
Request Number 153.
Admit: “You” Attorney at Law that “Your” reply/respond to Pro Se
Plaintiff “Motion for Sanctions” against you Document #1 herein with false
statement made by “You” was Placed in the United States Mail and
Publically Mailed to The Jefferson County Texas Court House“Clerk of
District Court” for cause No. A-180805

49. During this sametime frame “Your” being acting Attorney of record
causeNo. A-180805 filed in the Jefferson County Texas Courthousesaid
“Property Deeds” ” for the dwelling located at 448 DeQueen Blvd. in Port
Arthur Texas of the Co-Defendant(s) “JoyceM. Guy and Edward McCray
herein
Was Legally Transfer to the Texas Department of Housing &
Community Affairs on June 18th
2009 as described by “Jefferson County
Real Estate Indexin attached document #7 herein for a $76,000.00 U. S.
Dollars Housing Grant
Request Number 154.
Admit: “You” Attorney at Law that “Your” reply/respond to Pro Se
Plaintiff “Motion for Sanctions” against you Document #1 herein with false
statement made by “You” was Placed in the United States Mail and
Publically Mailed to The Jefferson County Texas Court House“Clerk of
District Court” for cause No. A-180805 by “You”
And was electronically computer filed in Document# 8 herein 58th
Judicial DistrictCourt of Jefferson County Texas “Case Ledger”
During this sametime frame “Your” being acting Attorney of record
causeNo. A-180805 filed in the Jefferson County Texas Courthousesaid
“Property Deeds” ” for the dwelling located at 448 DeQueen Blvd. in Port
Arthur Texas of the Co-Defendant(s) “JoyceM. Guy and Edward McCray
herein
Was Legally Transfer to the Texas Department of Housing &
Community Affairs on June 18th
2009 as described by “Jefferson County
Real Estate Indexin attached document #7 herein for a $76,000.00 U. S.
Dollars Housing Grant
Request Number 155.
Admit: “You” Attorney at Law that “You” filed Co-Defendant“Joyce
M. Guy “ herein “Affidavit in Support” of “Your” responsereply to Pro Se
Plaintiff Motion for Sanctions againstyou Dated September 11th
2009
attached document # 10 herein

50. Request Number 156.
Admit: “You” Attorney at Law that on Document# 10 herein Co-
Defendant “JoyceM. Guy” herein “Sworn AffidavitStatement States among
other things “being personally acquainted with the facts alleged”, Retained
Defendant (You) to draft and file a general denial on Co-DefendantBehalf.
Co-Defendantdid not retain (You) to represent (Co-Defendant)
beyond drafting and filing a general denial on my behalf until sometime in
Augustof 2009 when (You) informed me that Pro Se Plaintiff secured a
hearing with regards to this lawsuit (A-180805)
(You) informed (Co-Defendant) between April2nd
2008 and April 11th
2008 aboutPro Se Plaintiff discovery request
Itwas (Co-Defendant) decision and not (You) not to respond to the
discovery requestof Pro Se Plaintiff.
Request Number 157.
Admit: You having full legal “Attorney at Law” knowledgeof
Required Pro Se Plaintiff discovery requestfor admissions, interrogatories
and Disclosurefor causeNo. A-180805 as Co-Defendant“JoyceM. Guy”
and “You” corroboratethe same facts in refusalto respond to discovery for
over a full year in document#1 and document # 10 attached herein
Request Number 158.
Admit: “You” Attorney at Law that “You” drafted Co-Defendant
“JoyceM. Guy” herein “Affidavit” dated September 11th
2009 for “Your”
own Defense responsereply to Pro Se Plaintiff Motion for Sanctions against
“You” dated September 11th
2009 attached
In “Your” responseto Pro Se Plaintiff motion for sanctions dated the
11th
day of September 2009 Document# 1 herein

51. You state of having any knowledgeof “Required Pro Se Plaintiff
discovery requestfor admissions, interrogatories and Disclosureon or
about the dates of April 2nd
2008 and April11, 2008 as described in
Document # 1 attached herein having any knowledgeof “Required Pro Se
Plaintiff discovery requestfor admissions, interrogatories and Disclosureon
or aboutthe dates of April 2nd
2008 and April11, 2008 and as described in
Document # 10 attached herein
And further Admit this is not-correctand completely a false
statement made by “you” “Attorney at Law” and made by your client being
Co-Defendant“Joyce M. Guy” herein in regards to the correct dates of
“Your” both legally having knowledgeof Pro Se Plaintiff discovery request
for admissions, interrogatories and Disclosure
And the correct date is March 14th
2008 “Your” having actual
knowledgeof “Required Pro Se Plaintiff discovery requestfor admissions,
interrogatories and Disclosureas described in Document # 8 herein 58th
Judicial DistrictCourt of Jefferson County Texas “Case Ledger”
Request Number 159.
Admit: “You” Attorney at Law that “Your” Affidavitin supportof
your reply to Pro Se Plaintiff “Motion for Sanctions” againstyou Document
#9 herein and your responseto Pro Se Plaintiff Motion for sanctions against
“You” Document# 1 herein and Co-Defendant “JoyceM. Guy” “Affidavit in
supportof “You” document # 10 herein
Contain false statement made by “You” and Co-Defendant“JoyceM.
Guy having any knowledgeof “Required Pro Se Plaintiff discovery request
for admissions, interrogatories and Disclosureon or about the dates of April
2nd
2008 and April11, 2008 and as described in Document#1 and #10
attached herein
And further Admit all three documents #1, #9 and #10 was Placed in
the United States Mail and Publically Mailed to the Pro Se Plaintiff herein at
P.O. Box 342 Port Arthur Texas 77640 by “You”
Request Number 160.

52. Admit: “You” Attorney at Law that “Your” Affidavitin supportof
your reply to Pro Se Plaintiff “Motion for Sanctions” againstyou Document
#9 herein and your responseto Pro Se Plaintiff Motion for sanctions against
“You” Document# 1 herein and Co-Defendant “JoyceM. Guy” “Affidavitin
supportof “You” document # 10 herein
Contain false statement made by “You” and Co-Defendant“JoyceM.
Guy having any knowledgeof “Required Pro Se Plaintiff discovery request
for admissions, interrogatories and Disclosureon or about the dates of April
2nd
2008 and April11, 2008 and as described in Document#1 and #10
attached herein
And further admit all three documents #1, #9 and #10 was Placed in
the United States Mail and Publically Mailed to Co -Defendant(s) “JoyceM.
Guy and Edward McCray” collectively herein CauseNo. A-180805
Request Number 161.
Admit: “You” Attorney at Law that “Your” Affidavitin supportof
your reply to Pro Se Plaintiff “Motion for Sanctions” againstyou Document
#9 herein and your responseto Pro Se Plaintiff Motion for sanctions against
“You” Document# 1 herein and Co-Defendant “JoyceM. Guy” “Affidavitin
supportof “You” document # 10 herein
Contain false statement made by “You” and Co-Defendant“JoyceM.
Guy having any knowledgeof “Required Pro Se Plaintiff discovery request
for admissions, interrogatories and Disclosureon or about the dates of April
2nd
2008 and April11, 2008 and as described in Document#1 and #10
attached herein
And further Admit all three documents #1, #9 and #10 was Placed in
the United States Mail and Publically Mailed to The Jefferson County Texas
Court House“Clerk of District Court” for cause No. A-180805
Request Number 162.
Admit: “You” Attorney at Law that “Your” Affidavitin supportof
your reply to Pro Se Plaintiff “Motion for Sanctions” againstyou Document
#9 herein and your responseto Pro Se Plaintiff Motion for sanctions against

53. “You” Document# 1 herein and Co-Defendant “JoyceM. Guy” “Affidavit in
supportof “You” document # 10 herein
Contain false statement made by “You” and Co-Defendant“JoyceM.
Guy having any knowledgeof “Required Pro Se Plaintiff discovery request
for admissions, interrogatories and Disclosureon or about the dates of April
2nd
2008 and April11, 2008 and as described in Document#1 and #10
attached herein
And further Admit all three documents #1, #9 and #10 was Placed in
the United States Mail and
Publically Mailed to The Jefferson County Texas Court House“Clerk
of DistrictCourt” for causeNo. A-180805
And was electronically computer filed in Document# 8 herein 58th
Judicial DistrictCourt of Jefferson County Texas “Case Ledger” and Court
Records for cause No. A-180805
Request Number 163.
“You” Attorney at Law that “Your” Affidavit in supportof your reply
to Pro Se Plaintiff “Motion for Sanctions” againstyou Document#9 herein
and your responseto Pro Se Plaintiff Motion for sanctions against “You”
Document # 1 herein and Co-Defendant“JoyceM. Guy” “Affidavit in
supportof “You” document # 10 herein
Contain false statement made by “You” and Co-Defendant“JoyceM.
Guy having any knowledgeof “Required Pro Se Plaintiff discovery request
for admissions, interrogatories and Disclosureon or about the dates of April
2nd
2008 and April11, 2008 and as described in Document#1 and #10
attached herein
And further Admit all three documents #1, #9 and #10 was Placed in
the United States Mail and
Publically Mailed to The Jefferson County Texas Court House“Clerk
of DistrictCourt” for causeNo. A-180805

54. And was electronically computer filed in Document# 8 herein 58th
Judicial DistrictCourt of Jefferson County Texas “Case Ledger” and Court
Records for cause No. A-180805
During this sametime frame “Your” being acting Attorney of record
causeNo. A-180805 filed in the Jefferson County Texas Courthousesaid
“Property Deeds” for the dwelling located at 448 DeQueen Blvd. in Port
Arthur Texas of the Co-Defendant(s) “JoyceM. Guy and Edward McCray
herein
Was Legally Transfer to the Texas Department of Housing &
Community Affairs on June 18th
2009 as described by “Jefferson County
Real Estate Indexin attached document #7 herein for a $76,000.00 U. S.
Dollars Housing Grant.
Request Number 164.
Admit: You” Attorney at Law that Co- DefendantJoyce M. Guy”
herein supply the following Answer to Pro Se Plaintiff Interrogatories
Document # 11 attached herein pursuantto Rule 197 of the Texas Rules of
Civil Procedures at Question: 10, 11, 12, 13, 14, 15, and 16.
10. Where is the Funding for the New Home?
Answer: FederalGrant
11. What are the terms and conditions of any contract in regards to
the new home?
Answer: FederalGovernmentbuilt home free of chargeDefendant
must remain in home for at least 3 years.
12. What is the entire costof the construction for the new home?
Answer: $76,000.00 U.S. Dollars
13. How is the city of Port Arthur Involved?
Answer: Not involved

55. 14. How is the State of Texas Involved?
Answer: Not Involved
15. How is the Federal Government involved?
Answer: FederalGrant
16. How much money did the Co-Defendantactually paid for the new
home construction?
Answer: No money paid by Co-Defendant
Request Number 165.
Admit: You” Attorney at Law that Co- DefendantJoyce M. Guy”
herein supply the following “false and fraudulent” Answer to Pro Se
Plaintiff Interrogatories Document# 11 attached herein at question
number 14
14. How is the State of Texas Involved?
Answer: Not Involved
In comparison to Pro Se Plaintiff attached Document # 7 here in
showing during this sametime frame “Your” being acting Attorney of
record cause No. A-180805
said “Property Deeds” for the dwelling located at 448 DeQueen Blvd.
in Port Arthur Texas of the Co-Defendant(s) “JoyceM. Guy and Edward
McCray herein collectively custody, controland legal possession
Was Legally Transfer to the Texas Department of Housing &
Community Affairs on June 18th
2009 as described by “Jefferson County
Real Estate Indexin attached document #7 herein for a $76,000.00 U. S.
Dollars Housing Grant. Instrument# 2009022762.
Request Number 166.

56. And further Admit that Documents #11 that Co- Defendant JoyceM.
Guy” herein supply the following “false and fraudulent” Answer to Pro Se
Plaintiff Interrogatories was Placed in the United States Mail and
Publically Mailed to the Jefferson County Texas CourtHouse“Clerk of
District Court” for cause No. A-180805
And was electronically computer filed in Document# 8 herein 58th
Judicial DistrictCourt of Jefferson County Texas “Case Ledger” and Court
Records for cause No. A-180805
Request Number 167.
And further Admit that Documents #11 that Co- Defendant JoyceM.
Guy” herein supply the following “false and fraudulent” Answer to Pro Se
Plaintiff Interrogatories was Placed in the United States Mail and
Publically Mailed to the Jefferson County Texas CourtHouse“Clerk of
District Court” for cause No. A-180805
And was electronically computer filed in Document# 8 herein 58th
Judicial DistrictCourt of Jefferson County Texas “Case Ledger” and Court
Records for cause No. A-180805
And was Placed in the United States Mail and publically mailed to the
Pro Se Plaintiff herein.
Request Number 168.
And further Admit that Documents #11 that Co- Defendant JoyceM.
Guy” herein supply the following “false and fraudulent” Answer to Pro Se
Plaintiff Interrogatories was Placed in the United States Mail and
Publically Mailed to the Jefferson County Texas CourtHouse“Clerk of
District Court” for cause No. A-180805

57. And was electronically computer filed in Document# 8 herein 58th
Judicial DistrictCourt of Jefferson County Texas “Case Ledger” and Court
Records for cause No. A-180805
And was Placed in the United States Mail and publically mailed to the
Pro Se Plaintiff herein.
During this sametime frame “Your” being acting Attorney of record
causeNo. A-180805 filed in the Jefferson County Texas Courthousesaid
“Property Deeds” ” for the dwelling located at 448 DeQueen Blvd. in Port
Arthur Texas of the Co-Defendant(s) “JoyceM. Guy and Edward McCray
herein
Was Legally Transfer to the Texas Department of Housing &
Community Affairs on June 18th
2009 as described by “Jefferson County
Real Estate Indexin attached document #7 herein for a $76,000.00 U. S.
Dollars Housing Grant
Request Number 169.
Admit: You” Attorney at Law that “You” and Co-Defendant “JoyceM.
Guy” herein supply “Your” response to the following Answer to Pro Se
Plaintiff Interrogatories Document# 11 attached herein pursuantto Rule
197 of the Texas Rules of Civil Procedures at Question: 10, 11, 12, 13, 14,
15, and 16. In October 14th
2009
During this sametime frame “Your” being acting Attorney of record
causeNo. A-180805 filed in the Jefferson County Texas Courthousesaid
“Property Deeds” ” for the dwelling located at 448 DeQueen Blvd. in Port
Arthur Texas of the Co-Defendant(s) “JoyceM. Guy and Edward McCray
herein being a Party to a $10,800.00U.S. Dollars “Breach of Construction
Contract dispute said dwelling
Was “Already Completely Legally Transfer” to the Texas Department
of Housing & Community Affairs on June 18th
2009
As described by “Jefferson County Real Estate Indexin attached
document #7 herein for a $76,000.00 U. S. Dollars Housing Grant

58. Request Number 170.
And further Admit that Documents #11 attached herein that Co-
Defendant JoyceM. Guy” herein supply “falseand fraudulent” Answer to
Pro Se Plaintiff Interrogatories atquestion # 14 was legally requested by
Pro Se Plaintiff herein on March 14th
2008 but
“You” did not submit Co- Defendant Joyce M. Guy” herein supplied
“false and fraudulent” Answer until October 14th
2009 againstRule 197 of
the Texas Rules of Civil Procedures (30) days limitin filing a timely response
to Pro Se Plaintiff herein.
Being an actual year later “Your” finally forward actual“false and
fraudulent” answers of Co- DefendantJoyce M. Guy” Interrogatories at
question # 14 herein attached Document # 11 herein Legally “You” placed
in the United States Mail and Publically Mailed to The Jefferson County
Texas Court House“Clerk of District Court” for cause No. A-180805
And was electronically computer filed in Document# 8 herein 58th
Judicial DistrictCourt of Jefferson County Texas “Case Ledger”
And Copies
Request Number 171.
And further Admit that Documents #11 attached herein that Co-
Defendant JoyceM. Guy” herein supply “falseand fraudulent” Answer to
Pro Se Plaintiff Interrogatories atquestion # 14 which was legally requested
by Pro Se Plaintiff herein on March 14th
2008 but
“You” did not submit Co- Defendant Joyce M. Guy” herein supplied
“false and fraudulent” Answer until October 14th
2009 againstRule 197 of
the Texas Rules of Civil Procedures (30) days limitin filing a timely response
to Pro Se Plaintiff herein.
Being an actual year later “You’re” finally forward actual“false and
fraudulent” answers of Co- DefendantJoyce M. Guy” Interrogatories at
question # 14 herein attached Documents # 11 herein

59. Legally “You” placed said Interrogatories response in the United
States Mail and Publically Mailed to The Jefferson County Texas Court
House“Clerk of District Court” for causeNo. A-180805
And this Document# 11 was electronically computer filed in
Document # 8 herein 58th
Judicial DistrictCourt of Jefferson County Texas
“Case Ledger” and Court Records thereof
And Copies of such “false and fraudulent” Answer to Pro Se Plaintiff
Interrogatories being actual “false and fraudulent” answers of Co-
Defendant JoyceM. Guy” Interrogatories atquestion # 14 herein attached
Document # 11 herein Legally
“You” placed this legal Document in the United States Mail and
publically mailed also to the Pro Se Plaintiff mailing address at P.O. Box 342
in Port Arthur Texas 77640
Request Number 172.
Admit: You” Attorney at Law that “You” Drafted the Court Order Judge Bob
Worthamgave his approval on, placed his signatureupon said “Court
Order” issued in “Your” favor on December 11th
2009 which said 58th
Judicial DistrictCourt Order of Jefferson County Texas was electronically
computer filed in Document # 8 herein 58th
Judicial District Court of
Jefferson County Texas “CaseLedger” and all CourtRecords thereof
For “Your” Withdrawalas “Attorney of Record”
Cause No. A-180805 as described in attached Document# 12 herein 58th
Judicial DistrictCourt of Jefferson County Texas “Docket Report”
Request Number 173.
Admit: You” Attorney at Law that these “Chain of Events” are “True” of
“Your” attend a hearing held on the date of December 11th
2009 for “Your”
Withdrawalas acting “Attorney of Record” as “Your” being Acting Attorney
of Record since December 18th
2007 –December 11th
2009 1 year, 11
months and 11 days your officially active attorney of record in

60. Cause No. A-180805 as described in attached Document# 12 herein 58th
Judicial DistrictCourt of Jefferson County Texas “Docket Report”
With a “Court Order” on file of approvalof “Your withdrawalfromCo-
Defendant(s) “JoyceM. Guy and Edward McCray” collectively fromcause
No. A-180805
And as described in attached Document # 8 herein 58th
Judicial District
Court of Jefferson County Texas “Case Ledger”
And “Your” Affidavitin supportof “Your” reply to Pro Se Plaintiff “Motion
for Sanctions” against “You” Document #9 herein contain with false
statement made by “You” of “Your” having only knowledgeof “Required
Pro Se Plaintiff discovery requestfor admissions, interrogatories and
Disclosureon or about the dates of April 2nd
2008 and April11, 2008
Which “You” already had Placed in the United States Mail and Publically
Mailed to The Jefferson County Texas CourtHouse“Clerk of DistrictCourt”
for cause No. A-180805
And this documentwas electronically computer filed in Document #
8 herein 58th
Judicial DistrictCourt of Jefferson County Texas “CaseLedger”
and The Court Records for cause No. A-180805
During this sametime frame “Your” being acting Attorney of record
for cause No. A-180805 filed in the Jefferson County Texas Courthouse
The said “Property Deeds” a issue” for the dwelling located at 448
DeQueen Blvd. in PortArthur Texas of the Co-Defendant(s) “JoyceM. Guy
and Edward McCray herein
Was already legally Completely Transfer to the Texas Department of
Housing & Community Affairs on the date of June 18th
2009 as described by
“Jefferson County Real Estate Index” in attached document#7 herein for a
$76,000.00U. S. Dollars Housing Grant