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

In The United States District Court

For The Eastern Division of Texas

Beaumont Division

Louis Charles Hamilton II

Pro Se Plaintiff

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

Antoine L. Freeman J. D.

Defendant

Joyce M. Guy

Edward McCray

Co-Defendant(s)

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

“Louis Charles Hamilton II” herein propounding party

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

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

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

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

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

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

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

Request for Admission Truth of Facts

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

Admit that you Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, was acting “Attorney of record” between the exact date of December 18th 2007- June 9th 2009 when document #1 attached herein was filed with the Jefferson County Texas Clerk office

namely “Mechanic’s LIEN Contract filed on June 9th 2009 SWMJ Construction Inc., 525 N. Sam Houston Pkwy East, Suite 600, Houston, Texas 77060 in connection with a Housing Grant in excess of $72,500.00 U.S Dollars

“Texas Department of Housing and Community affairs” Loan No. 2727 File

No. 1219-2102152 CFDA 14.228 Community Development Block Grant Program (“CDBG”) Hurricanes Katrina, Rita and Wilma in the Gulf of Mexico 2005

Federally Declared Disaster Funding under Department of Defense

Appropriations Act, 2006 CDBG Disaster Recovery Program (Homeowner Assistance Program “HAP”)

Or (Sabine Pass Restoration Program “SPRP”) Awarding Federal Agency:

United States Department of Housing and Urban Development TDHCA Federal Award Number: B-06-DG-48-0002 Federal Award Year (Year of Award from HUD to TDHCA): 2006 TDHCA Award Year: 2007

For the property located at 448Dequeen Blvd. in Port Arthur Texas 77640 which you was acting counsel for Co-Defendant(s) Joyce M. Guy and Edward McCray in a civil suit in the 58th Judicial District Court of Jefferson County Texas

docket No. A-180805 involving a breach of a $10,800 U.S. Dollars construction contract with the described Pro Se Plaintiff herein. Request Number 2.

Admit that you Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein was acting in the monetary retain capacity as “Attorney of record” on the exact date of August 28th 2009 as described in document #2 attached herein Jefferson County Texas “Civil Docket” for A-180805 in which

Pro Se Plaintiff filed a (TRO) for the full legal protection of the Co-Defendant “Joyce M. Guy”, “Mother”

Namely Norma M. Guy and the property located at 5050east 7th Street in Port Arthur Texas Lot Number (10) in Block Number (4) of Lakeview addition, to the City of Port Arthur, Jefferson County, Texas

As Pro Se Plaintiff filed legal document and made claims before the Honorable Jude” Bob Wortham” of the 58 Judicial District Court of Jefferson County Texas for primary allegations of monetary fraud and scheme advantages during “Hurricane “Rita”, “Ike” and “Humberto ”

Scheme of things related to Construction storm damages, derive thereof in connection, with Co-Defendant “Joyce M. Guy” and the Pro Se Plaintiff herein and the property at 5050 east 7th street Repair for Hurricane Storm Roofing damages. Request Number 3.

Admit that you Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein was (Not) monetary retain “Attorney of record” on the exact date of August 28th 2009 as described in document #2 attached herein Jefferson County Texas “Civil Docket” for A-180805 in which

Pro Se Plaintiff filed a (TRO) for the full legal protection of the Co-Defendant “Joyce M. Guy”, “Mother”

Namely Norma M. Guy and the property located at5050east 7th Street in Port Arthur Texas Lot Number (10) in Block Number (4) of Lakeview addition, to the City of Port Arthur, Jefferson County, Texas

As Pro Se Plaintiff filed legal document and made claims before the Honorable Jude” Bob Wortham” of the 58 Judicial District Court of Jefferson

County Texas for primary allegations of monetary fraud and scheme advantages during “Hurricane “Rita”, “Ike” and “Humberto ”

Scheme of things related to Construction storm damages; derive thereof in connection, with Co-Defendant “Joyce M. Guy” and the Pro Se Plaintiff herein and the property at 5050 east 7th street needing Repair for Hurricane Storm Roofing damages. Which a Court hearing was held on the 28th day of August 2009 Request Number 4.

Admit that Pro Se Plaintiff Louis Charles Hamilton II herein Subpoena Witness namely Allen Guy”, Brother to Co-Defendant “Joyce M. Guy” before the Honorable Jude” Bob Wortham” of the 58 Judicial District Court of Jefferson County Texas as duly under oath said witness was under “direct examination” of the Pro Se Plaintiff “Louis Charles Hamilton II”

For primary allegations and subject matter of monetary fraud and scheme advantages during “Hurricane “Rita”, “Ike” and “Humberto”

Scheme of things related to Construction storm damages derive thereof in connection, with Co-Defendant “Joyce M. Guy” and the Pro Se Plaintiff herein and the property at 5050 east 7th street needing Repair for Hurricane Storm Roofing damages.

Which a Court hearing was held on the 28th day of August 2009. Request Number 5.

Admit that you Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein did in a capacity of a Attorney cross-examination said Subpoena Witness namely Allen Guy”, Brother to Co-Defendant “Joyce M. Guy” appearing before the Honorable Jude” Bob Wortham” of the 58 Judicial District Court of Jefferson County Texas after duly under oath said witness was under “direct examination” of the Pro Se Plaintiff “Louis Charles Hamilton II”

For primary allegations and subject matter of monetary fraud and scheme advantages during “Hurricane “Rita”, “Ike” and “Humberto”

Scheme of things related to Construction storm damages derive thereof in connection, with Co-Defendant “Joyce M. Guy” and the Pro Se Plaintiff herein and the property at 5050 east 7th street needing Repair for Hurricane Storm Roofing damages.

Which a Court hearing was held on the 28th day of August 2009.

Request Number 6.

Admit that you Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein did physically make the representation and presentation of cross-examination said Subpoena Witness namely Allen Guy”, Brother to Co-Defendant “Joyce M. Guy” before the

Honorable Jude” Bob Wortham” of the 58 Judicial District Court of Jefferson County Texas as duly under oath said witness …

But your were not monetary legally retain for such legal services of a Court hearing which was held on the 28th day of August 2009

As described by you in attached document #3 “Response to Motion for Sanctions” in which your claiming your retain legal service was filing a “General Denial” on December 18th 2007 (only) in Civil Docket No. A-180805.

Request Number 7.

Admit that you Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein having elicited an agreement in which Co-Defendant “Joyce M. Guy” and said Subpoena Witness namely Allen Guy”, Brother to Co-Defendant “Joyce M. Guy” appearing before the

Honorable Jude” Bob Wortham” of the 58 Judicial District Court of Jefferson County Texas as duly under oath said witness …agree with Co-Defendant “Joyce M. Guy” to out of their own financial pockets fix said home roofing damages

Located at 5050 east 7th street after the “private home owner insurance moneys” for the interest of Norma M. Guy” home having already being spent/squander up by Co-Defendant “Joyce M. Guy”. Request Number 8.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein provided cover up legal services before the 58th Judicial District of Jefferson County Texas for conspire in “Falsification of “Material facts” that Co-Defendant “Joyce M. Guy” and said Subpoena Witness namely Allen Guy”, Brother to Co-

Defendant “Joyce M. Guy” Was to out of their own financial pockets fix said home roofing damages

Located at 5050 east 7th street after the “private home owner insurance moneys” for the interest of Norma M. Guy” (Mother) home having already being spent/squander up by Co-Defendant “Joyce M. Guy” thereafter your cover up legal services before the 58th Judicial District Court on August 28th 2009 hearing date Co-Defendant “Joyce M. Guy” legally transfer once again another property to

“Texas Department of Housing and Community affairs” Loan No. 5866 file No. 1219-2355082 CFDA 14.228 Community Development Block Grant Program (“CDBG”) Hurricanes Katrina, Rita and Wilma in the Gulf of Mexico 2005

Federally Declared Disaster Funding under Department of Defense Appropriations Act, 2006 CDBG Disaster Recovery Program (Homeowner Assistance Program “HAP”)

Or (Sabine Pass Restoration Program “SPRP”) Awarding Federal Agency: United States Department of Housing and Urban Development TDHCA Federal Award Number: B-06-DG-48-0002 Federal Award Year

(Year of Award from HUD to TDHCA): 2006 TDHCA Award Year: 2007 To obtain on May 28th 2010 in excess of $54,839.31 U.S. Dollars

“Construction Grant” for the property located at 5050 east 7 th street in Port Arthur Texas

As described herein Pro Se Plaintiff attached document #4 Mechanics’s Lien, Contract Loan No. 5866, File # 1219-2355082

Request Number 9.

Admit that you Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein was never physically present and not monetary legally retain for such legal services of a Court hearing which was held on the 28th day of August 2009 before the

Honorable Bob Wortham, in 58th Judicial District Court of Jefferson County Texas for the legal behalf of the Co-Defendant(s) Joyce M. Guy and Edward McCray as described by you in attached herein document # 3“Response to

Motion for Sanctions” in which your claiming your retain legal service was filing a “General Denial” only on December 18th 2007 in Civil Docket No. A-180805. Request Number 10.

Admit that you Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein refusal to respond to all of the Pro Se Plaintiff discovery request your having in your legal, possession, custody and control mailed to you since the exact time date of March 14th 2008 –

And such Pro Se Plaintiff discovery request in your legal, possession, custody and control throughout August 28th 2009 hearing date as your in continual refusal to reply/response to said discovery request

And further admitting “You” were not monetary legally retain for such

legal services of a Court appearance at a hearing which was held on the 28th day of August 2009 before the

Honorable Bob Wortham, in 58th Judicial District Court of Jefferson County Texas for the legal behalf of the Co-Defendant(s) Joyce M. Guy and Edward McCray

As described by you in attached herein document # 3“Response to Motion for Sanctions” in which your claiming your retain legal service was filing a “General Denial” only on December 18th 2007 in Civil Docket No. A-180805 and all such legal services of you Chief Defendant Antoine L. Freeman J. D. “Attorney at Law” fully retain ended there after December 18th 2007

While you Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”,

herein admit continual refusal to respond to all of the Pro Se Plaintiff discovery request your having in your legal, possession, custody, and control being legally mailed to you in the exact time frame of March 14th 2008

As your continual admit in same “Attorney at Law” refusal to

reply/response to said discovery request throughout the 58th Judicial District Court of Jefferson County Texas hearing date on the 28th day of August 2009 which you was in fact present before the Honorable Court.

Request Number 11.

Admit that you Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein refusal to respond to all of the Pro Se Plaintiff discovery request your having in your legal, possession, custody and control mailed to you since the exact time date of March 14th 2008 –

And such Pro Se Plaintiff discovery request in your legal, possession, custody and control throughout September 11th 2009 hearing date as your in continual refusal to reply/response to said discovery request

To provided actual “obstruction of justice” cover up legal services before the 58th Judicial District of Jefferson County Texas “Honorable Bob Wortham” for conspire in “Falsification of all “Material facts” and Subject matter that Co-Defendant “Joyce M. Guy” and Edward McCray” collectively on June 9th 2009 when document #1 attached herein was filed with the Jefferson County Texas Clerk office








For the property located at 448Dequeen Blvd. in Port Arthur Texas

77640 which you was acting counsel for Co-Defendant(s) Joyce M. Guy and

Edward McCray in a civil suit in the 58th Judicial District Court of Jefferson

County Texas docket No. A-180805 involving a breach of a

$10,800 U.S. Dollars construction contract with the described Pro Se

Plaintiff herein which you Chief Defendant Antoine L. Freeman J. D. “Attorney at

Law”, herein furtherance admitting “Your” legally having Pro Se Plaintiff request

for said production of document for “property deeds” for the For the property

located at 448Dequeen Blvd. in Port Arthur Texas 77640

Which you Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”,

herein was acting legal counsel on behalf of for Co-Defendant(s) Joyce M. Guy

and Edward McCray in your (3) combine continual refusal to produce said

“property deeds” Lots Numbered One and Two (1&2) in Block Number One

Hundred Seventy Two (172) of City of Port Arthur in Jefferson County, Texas

From the exact date of March 14th 2008 throughout March 30th 2015

On or before an upcoming evidentiary hearing held on March 30th at

10:00 a.m. before

“Honorable Justice” United States Magistrate Judge Zack Hawthorn at the

Jack Brooks Federal Building, Beaumont Texas

In which said “Property Deeds” still outstanding in said production having

never been having been produce, and filed in Civil Suit in Common Law in the

58th Judicial District Court of Jefferson County Texas. Even after “Court Orders”

being obtain in such a production.

Request Number 12.

Admit that you Chief Defendant Antoine L. Freeman J. D. “Attorney at

Law”, herein Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”,


and Edward McCray in your

(3) Combine continual refusal to produce said “property deeds” Lots

Numbered One and Two (1&2) in Block Number One Hundred Seventy Two

(172) of City of Port Arthur in Jefferson County, Texas

From the exact date of March 14th 2008 throughout November 13th 2009

Request Number 13.

Admit that you Chief Defendant Antoine L. Freeman J. D. “Attorney at

Law”, herein Admit that you Chief Defendant Antoine L. Freeman J. D. “Attorney

at Law”, herein Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”,


and Edward McCray in your

(3) Combine continual refusal to produce said “property deeds” Lots

Numbered One and Two (1&2) in Block Number One Hundred Seventy Two

(172) of City of Port Arthur in Jefferson County, Texas

From the exact date of March 14th 2008 throughout February 19th 2015 9:00 am which a hearing was held for “Contempt of Court” of the 58 th Judicial District Court of Jefferson County Texas for said production of

“Property deeds”, among other documents being refusal in this continual obstruction of justice and hiding, obscuring, and failing to produce said “property deeds”

Lots Numbered One and Two (1&2) in Block Number One Hundred Seventy Two (172) of City of Port Arthur in Jefferson County, Texas which is subject matter in civil suit in common law A-180805 Request Number 14.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein that request for admission question (7) and (11) above combine having a monetary value in Connection with

United States Department of Housing and Urban Development TDHCA Federal Award

Federally Declared Disaster Funding in further connection directly with the “Texas Department of Housing and Community affairs” in excess of

$127,339.31 U.S. Dollars.

Request Number 15.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein after your refusal to comply with Texas Rules of Civil Procedure for the civil legal interest of the Co-Defendant(s) “Joyce M. Guy and Edward McCray

In which you had in your legal, possession, custody and Control, between the actual dates of March 14th 2008 throughout October 14th 2009

Said Pro Se Plaintiff Louis Charles Hamilton II herein Discovery request for

“among other things” Property Deeds to Lots Numbered One and Two (1&2) in Block Number One Hundred Seventy Two (172) of City of Port Arthur in Jefferson County, Texas

And said Pro Se Plaintiff Louis Charles Hamilton II herein Discovery

request for among other things all construction estimates for repairs in relationship to damages caused by Hurricane Rita, Humberto, and Ike

This is a continual subject matter in civil suit in common law docket No. A-

180805 well into March of 2015 That you Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”,

herein provided Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively Protection in such said failure in the production of the Property Deeds and

All construction estimates for repairs in relationship to damages caused

by Hurricane Rita, Humberto, and Ike to the property located Lots Numbered One and Two (1&2) in Block Number One Hundred Seventy Two (172) of City of Port Arthur in Jefferson County, Texas

Admitting further that as of March 30th 2015 said Co-Defendant(s) “Joyce

M. Guy and Edward McCray” collectively herein have Not filed the actual copies of said “Property Deeds” to Lots Numbered One and Two (1&2) in Block Number One Hundred Seventy Two (172) of City of Port Arthur in Jefferson County, Texas,

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

herein have not filed all construction estimates for repairs in relationship to damages caused by Hurricane Rita, Humberto, and Ike

As required in the files of cause No. A-180805 in the Jefferson County 58th

Judicial District Court As required by lawful Court Order of the 58th Judicial District as dated the

10th Day of May 2010 described in attached document # 5 herein 58th Judicial District Court of Jefferson County Texas official “Court Order”.

Request Number 16. Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein

after your refusal to comply with “Texas Rules of Civil Procedure” in which you had in your legal, possession, custody and actual physical Control, between the actual dates of March 14th 2008 throughout October 14th 2009

Said Pro Se Plaintiff Louis Charles Hamilton II herein Discovery request for



request for among other things all construction estimates for repairs in relationship to damages caused by Hurricane Rita, Humberto, and Ike

Which is a continual subject matter in civil suit in common law A-180805

in March of 2015 That you Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”,

herein provided Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively Protection, obstruction, hindrance, and hiding in such said production of the Property Deeds

Further provided Protection, obstruction, hindrance, and hiding in such

said all construction estimates for repairs in relationship to damages caused by Hurricane Rita, Humberto, and Ike

Admitting further that as of April 30th 2010 when you Chief Defendant

Antoine L. Freeman J. D. “Attorney at Law”, herein represented Co-Defendant(s)

“Joyce M. Guy and Edward McCray” collectively in the U.S. District Court for the District of Texas, Beaumont Division Jefferson County, Texas Docket No. 1:10-CV-005 before the Honorable U.S. Judge Marcia A. Crone and Honorable U.S. Magistrate Keith F. Giblin

As Described in attached document # 6 herein “Defendant’s Original Answer in U.S. District Court No. 1:10-CV-00055 being “You” & Joyce M. Guy and Edward McCray collectively

Admitting further said Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein still have Not “officially filed” said Property Deeds to Lots Numbered One and Two (1&2) in Block Number One Hundred Seventy Two (172) of City of Port Arthur in Jefferson County, Texas,

And have not “officially” filed all construction estimates for repairs in relationship to damages caused by Hurricane Rita, Humberto, and Ike to the “property” located at 448 DeQueen Blvd. in Port Arthur Texas

As required in the files of cause No. A-180805 in the Jefferson County 58th

Judicial District Court As required by lawful Court Order of the 58th Judicial District as dated 10th

Day of May 2010 in attached document # 5 herein 58th Judicial District Court of Jefferson County Texas official “Court Order” and no such filing has occurred on April 30th 2010

After Your Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein represented Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively in the U.S. District Court for the District of Texas, Beaumont Division Jefferson County, Texas Docket No. 1:10-CV-00055

Before the Honorable U.S. Judge Marcia A. Crone and Honorable U.S. Magistrate Keith F. Giblin April 30th 2010 as described in attached document


between the actual dates of March 14th 2008 throughout October 14th 2009 Said Pro Se Plaintiff Louis Charles Hamilton II herein Discovery request for



request for among other things all construction estimates for repairs in relationship to damages caused by Hurricane Rita, Humberto, and Ike having not been produced before the 58th Judicial District Court of Jefferson County Texas in civil docket No. A-180805


between the actual dates of March 14th 2008 throughout April 30th 2010 Said Pro Se Plaintiff Louis Charles Hamilton II herein Discovery request for


And said Pro Se Plaintiff Louis Charles Hamilton II herein Discovery request for among other things all construction estimates for repairs in relationship to damages caused by Hurricane Rita, Humberto, and Ike having not been produced before the 58th Judicial District Court of Jefferson County Texas in civil docket No. A-180805.


between the actual dates of March 14th 2008 throughout March 30th 2015 Said Pro Se Plaintiff Louis Charles Hamilton II herein Discovery request for


And said Pro Se Plaintiff Louis Charles Hamilton II herein Discovery request for among other things all construction estimates for repairs in relationship to damages caused by Hurricane Rita, Humberto, and Ike having not been produced before the 58th Judicial District Court of Jefferson County Texas in civil docket No. A-180805.

Request Number 20.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein between the actual dates of December 18th 2007 throughout April 30th 2010 you physically represented Co-Defendant(s) Joyce M. Guy and Edward McCray collectively in Jefferson County Judicial District Court Docket No. A-180805 before the Honorable Bob Wortham

And you physically represented Co-Defendant(s) Joyce M. Guy and Edward McCray collectively herein again in U.S. District Court for the District of Texas, Beaumont Division Jefferson County, Texas U.S. Docket No. 1:10-CV-00055 against the Pro Se Plaintiff Louis Charles Hamilton II herein

Before the Honorable U.S. Judge Marcia A. Crone and Honorable U.S. Magistrate Keith F. Giblin

And Said Pro Se Plaintiff Louis Charles Hamilton II herein Discovery request for “among other things” Property Deeds to Lots Numbered One and Two (1&2) in Block Number One Hundred Seventy Two (172) of City of Port Arthur in Jefferson County, Texas


request for among other things all construction estimates for repairs in relationship to damages caused by Hurricane Rita, Humberto, and Ike “having not been produced” and filed before the

58th Judicial District Court of Jefferson County Texas as of March 30th 2015

Which you Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein had in your legal, possession, custody and Control, between the actual dates of March 14th 2008 throughout October 14th 2009

Said Pro Se Plaintiff Louis Charles Hamilton II herein Discovery request for “among other things” Property Deeds to Lots Numbered One and Two (1&2) in Block Number One Hundred Seventy Two (172) of City of Port Arthur in Jefferson County, Texas

And said Pro Se Plaintiff Louis Charles Hamilton II herein Discovery request for among other things all construction estimates for repairs in relationship to damages caused by Hurricane Rita, Humberto, and Ike

This is a continual subject matter in civil suit in common law A-180805 in March of 2015 in Jefferson County Texas Judicial District.

Request Number 21.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein between the actual dates of December 18th 2007 throughout April 30th 2010 you physically represented Co-Defendant(s) Joyce M. Guy and Edward McCray collectively in Jefferson County Judicial District Court Docket No. A-180805 before the Honorable Bob Wortham

And you physically represented Co-Defendant(s) Joyce M. Guy and Edward McCray collectively herein again in U.S. District Court for the District of Texas, Beaumont Division Jefferson County, Texas U.S. Docket No. 1:10-CV-00055 on April 30th 2010 against the Pro Se Plaintiff Louis Charles Hamilton II herein

Before the Honorable U.S. Judge Marcia A. Crone and Honorable U.S.

Magistrate Keith F. Giblin and Said Pro Se Plaintiff Louis Charles Hamilton II herein Discovery request for “among other things” said “Property Deeds” to Lots Numbered One and Two (1&2) in Block Number One Hundred Seventy Two (172) of City of Port Arthur in Jefferson County, Texas

And said Pro Se Plaintiff Louis Charles Hamilton II herein Discovery request for among other things all construction estimates for repairs in relationship to damages caused by Hurricane Rita, Humberto, and Ike having not been produced before the 58th Judicial District Court of Jefferson County Texas

Further admitting that Co-Defendant(s) Joyce M. Guy and Edward McCray collectively herein transfer said “Property Deeds” to Lots Numbered One and Two (1&2) in Block Number One Hundred Seventy Two (172) of City of Port Arthur in Jefferson County, Texas on June 9th 2009 when document #1 attached herein was filed with the Jefferson County Texas Clerk office








For the property located at 448Dequeen Blvd. in Port Arthur Texas 77640 which you was acting counsel for Co-Defendant(s) Joyce M. Guy and Edward McCray in a civil suit in the 58th Judicial District Court of Jefferson County Texas docket No. A-180805 involving a breach of a $10,800 U.S. Dollars construction contract with the described Pro Se Plaintiff herein between the dates of December 18th 2007 throughout

December 11th 2009 at 9:00 am hour when you set a notice of hearing for your “Motion for Withdrawal” as described in Pro Se Plaintiff attached document # 7 “Notice of Hearing” with your attorney at Law “signature”

Further admitting “you” Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein also your acting counsel for Co-Defendant(s) Joyce M. Guy and Edward McCray in a civil suit in the U.S. District Court for the District of Texas, Beaumont Division Jefferson County, Texas U.S. Docket No. 1:10-CV-00055 in April 30th 2010.


between the actual dates of December 18th 2007 throughout April 30th 2010 you physically represented Co-Defendant(s) Joyce M. Guy and Edward McCray collectively in Jefferson County Judicial District Court Docket No. A-180805 before the Honorable Bob Wortham



Magistrate Keith F. Giblin and Said Pro Se Plaintiff Louis Charles Hamilton II herein Discovery request for “among other things” Property Deeds to Lots

Numbered One and Two (1&2) in Block Number One Hundred Seventy Two (172) of City of Port Arthur in Jefferson County, Texas


request for among other things all construction estimates for repairs in relationship to damages caused by Hurricane Rita, Humberto, and Ike “having not been produced before the 58th Judicial District Court of Jefferson County Texas as of March 30th 2015 further admitting that

Co-Defendant(s) Joyce M. Guy and Edward McCray collectively on June 9th 2009 when document #1 attached herein was filed with the Jefferson County Texas Clerk office








For the property located at 448 DeQueen Blvd. in Port Arthur Texas 77640 which you was acting counsel for Co-Defendant(s) Joyce M. Guy and Edward McCray in a civil suit in the 58th Judicial District Court of Jefferson County Texas docket No. A-180805 involving a breach of a $10,800 U.S. Dollars construction contract with the described Pro Se Plaintiff herein

Further admitting “you” Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein also acting counsel for Co-Defendant(s) Joyce M. Guy and Edward McCray collectively in a civil suit in the in U.S. District Court for the

District of Texas, Beaumont Division Jefferson County, Texas U.S. Docket No. 1:10-CV-00055 during the time frame of December 18th 2007 throughout the time frame of April 30th 2010

When Co-Defendant(s) Joyce M. Guy herein after said Pro Se Plaintiff Louis Charles Hamilton II herein filed a (TRO) on August 12th 2009 in civil suit in common law docket No. A-180805for the full legal protection of the Co-Defendant “Joyce M. Guy”, “Mother”

Namely Norma M. Guy and the property located at5050east 7 th Street in Port Arthur Texas Lot Number (10) in Block Number (4) of Lakeview addition, to the City of Port Arthur, Jefferson County, Texas

As Pro Se Plaintiff filed legal document and made claims before the Honorable Jude” Bob Wortham” of the 58 Judicial District Court of Jefferson County Texas on August 28th 2009 before the “Honorable Court” for primary allegations of monetary fraud and scheme advantages during “Hurricane “Rita”, “Ike” and “Humberto ”

Scheme of things related to Construction storm damages, derive thereof

in connection, with Co-Defendant “Joyce M. Guy” herein and the property at 5050 east 7th street Repair for Hurricane Storm Roofing damages,

Admitting further “you” Chief Defendant Antoine L. Freeman J. D.

“Attorney at Law”, herein that said Co-Defendant “Joyce M. Guy” herein legally transfer once again another property to

“Texas Department of Housing and Community affairs” Loan No. 5866 file No. 1219-2355082 CFDA 14.228 Community Development Block Grant Program (“CDBG”) Hurricanes Katrina, Rita and Wilma in the Gulf of Mexico 2005




“Construction Grant” for the property located at 5050 east 7 th street in Port

Arthur Texas as described herein Pro Se Plaintiff attached document #4 Mechanic’s Lien, Contract Loan No. 5866, File # 1219-2355082

And as further described in Pro Se Plaintiff attached document # 7 “Specific Power of Attorney” relating to real Property for the behalf of Norma Guy (the “Principal”), of 5050 7th street Jefferson County, Texas

Hereby appoint “Joyce Guy” of 448 DeQueen Blvd. in Jefferson County

Texas as Agent, (Attorney in Fact) after Pro Se Plaintiff filed legal document and made claims before the Honorable Jude” Bob Wortham” of the 58 Judicial District Court of Jefferson County Texas on August 28 th 2009 before the “Honorable Court” for primary allegations of monetary fraud and scheme advantages during “Hurricane “Rita”, “Ike” and “Humberto ”


in connection, with Co-Defendant “Joyce M. Guy” herein and the property at 5050 east 7th street Repair for Hurricane Storm Roofing damages,

Admitting further “you” Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein that combines housing grants for having a monetary value in Connection with



$127,339.31 U.S. Dollars. Request Number 22. Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein

between the actual dates of March 14th 2008 throughout April 30th 2010 you physically represented Co-Defendant(s) Joyce M. Guy and Edward McCray collectively in Jefferson County Judicial District Court Docket No. A-180805 before the Honorable Bob Wortham


Before the Honorable U.S. Judge Marcia A. Crone and Honorable U.S. Magistrate Keith F. Giblin and Said Pro Se Plaintiff Louis Charles Hamilton II herein Discovery request for “among other things” Property Deeds to Lots Numbered One and Two (1&2) in Block Number One Hundred Seventy Two (172) of City of Port Arthur in Jefferson County, Texas


request for among other things all construction estimates for repairs in relationship to damages caused by Hurricane Rita, Humberto, and Ike having not been produced before the 58th Judicial District Court of Jefferson County Texas that

Co-Defendant(s) Joyce M. Guy and Edward McCray collectively on June 9th 2009 when document #1 attached herein was filed with the Jefferson County Texas Clerk office








For the property located at 448Dequeen Blvd. in Port Arthur Texas 77640 which you was acting counsel for Co-Defendant(s) Joyce M. Guy and Edward McCray in a civil suit in the 58th Judicial District Court of Jefferson County Texas docket No. A-180805 involving a breach of a $10,800 U.S. Dollars construction contract with the described Pro Se Plaintiff herein

Further admitting “you” Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein also acting counsel for Co-Defendant(s) Joyce M. Guy and Edward McCray collectively in a civil suit in the in U.S. District Court for the District of Texas, Beaumont Division Jefferson County, Texas U.S. Docket No. 1:10-CV-00055 during the time frame of December 18th 2007 throughout the time frame of April 30th 2010

When Co-Defendant(s) Joyce M. Guy herein after said Pro Se Plaintiff filed

a (TRO) on August 12th 2009 for the full legal protection of the Co-Defendant “Joyce M. Guy”, “Mother”

Namely Norma M. Guy and the property located at5050east 7 th Street in Port Arthur Texas Lot Number (10) in Block Number (4) of Lakeview addition, to the City of Port Arthur, Jefferson County, Texas

As Pro Se Plaintiff filed legal document and made claims before the Honorable Jude” Bob Wortham” of the 58 Judicial District Court of Jefferson County Texas for primary allegations of monetary fraud and scheme advantages during “Hurricane “Rita”, “Ike” and “Humberto ”


in connection, with Co-Defendant “Joyce M. Guy” herein and the property at 5050 east 7th street Repair for Hurricane Storm Roofing damages admitting further said Co-Defendant “Joyce M. Guy” herein legally transfer once again another property to

“Texas Department of Housing and Community affairs” Loan No. 5866 file





“Construction Grant” for the property located at 5050 east 7 th street in Port

Arthur Texas as described herein Pro Se Plaintiff attached document #4 Mechanic’s Lien, Contract Loan No. 5866, File # 1219-2355082

And as further described in Pro Se Plaintiff attached document # 7 “Specific Power of Attorney” relating to real Property for the behalf of Norma Guy (the “Principal”), of 5050 7th street Jefferson County, Texas

Hereby appoint “Joyce Guy” of 448 DeQueen Blvd. in Jefferson County

Texas as Agent, (Attorney in Fact) and the property located at5050east 7th Street in Port Arthur Texas Lot Number (10) in Block Number (4) of Lakeview addition, to the City of Port Arthur, Jefferson County, Texas combine housing grants having a monetary value in Connection with



$127,339.31 U.S. Dollars While further admitting “you” Chief Defendant Antoine L. Freeman J. D.

“Attorney at Law”, herein also acting counsel for Co-Defendant(s) Joyce M. Guy and Edward McCray collectively legal behalf before the 58th Judicial District Court of Jefferson County Texas in a

Live hearing before the “Honorable Bob Wortham” on hearing dates of August 28th, 2009 and before the “Honorable Bob Wortham” hearing on dates of September 11th, 2009 which you

Chief Defendant Antoine L. Freeman J. D. “Attorney at Law” herein provided physical “Oral Arguments” before the “Honorable Court” against said Pro Se Plaintiff Louis Charles Hamilton II herein while “your” still claiming

Chief Defendant Antoine L. Freeman J. D. “Attorney at Law” herein that

you was never being in the physical capacity as the acting “attorney of record” for the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein legal behalf between the time frame of December 19th 2007 throughout September 11th 2009 in civil suit in common law docket No. A-180805

As described in Pro Se attached Document # 3 herein “Your” response to Motion for sanctions against you “Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein dated September 11th 2009.


between the actual dates of November 13th 2009 10:22 am hour you physically filed “Motion for Withdrawal of Counsel” namely Pro Se Plaintiff “Louis Charles Hamilton II” attached Document # 8 as stated by “you”

Chief Defendant” herein in paragraph IV: A copy of this motion bearing the enclosed notice has been delivered to the last known addresses of Defendants. Joyce Guy 5050 7th street Port Arthur. Texas 77642, and Edward McCray 5050 7th street Port Arthur, Texas 77642

While you furtherance Admitting Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein between the actual dates of December 18th 2007 throughout at some point date of November 13th 2009 10:22 am hour

Co-Defendant(s) “Joyce M. Guy and Edward McCray” was in fact living on Lots Numbered One and Two (1&2) in Block Number One Hundred Seventy Two (172) of City of Port Arthur in Jefferson County, Texas namely 448 DeQueen Blvd. in Port Arthur Texas 77640 which is the primary address of said Co-Defendant(s) collectively herein when you

“Chief Defendant” herein was retaining for your “Attorney at law” legal services in civil suit in common law docket No. A-180805 which the property 448 DeQueen Blvd. in Port Arthur Texas 77640 is involved in a breach of Construction Contract civil matter before the 58th Judicial District Court of Jefferson County, Texas.


between the actual dates of November 13th 2009 10:22 am hour you physically filed “Motion for Withdrawal of Counsel” as stated by “you”


“Your” having full legal knowledge that Lots Numbered One and Two (1&2) in Block Number One Hundred Seventy Two (172) of City of Port Arthur in Jefferson County, Texas

Namely the property located at 448 DeQueen Blvd. in Port Arthur Texas 77640 which is the primary “physical evidence” and “physical address” of said Co-Defendant(s) collectively herein which both “physical evidence” and “physical home” was completely destroyed in connection with namely

“Mechanic’s LIEN Contract filed on June 9th 2009 SWMJ Construction Inc.,

525 N. Sam Houston Pkwy East, Suite 600, Houston, Texas 77060 in connection with a Housing Grant in excess of $72,500.00 U.S Dollars







For the property located at 448Dequeen Blvd. in Port Arthur Texas 77640 which you between the exact time frame of December 18th 2007 throughout actual date of November 13th 2009 10:22 am hour until you physically filed “Motion for Withdrawal of Counsel” was acting counsel for Co-Defendant(s) Joyce M. Guy and Edward McCray in a civil suit in the

58th Judicial District Court of Jefferson County Texas docket No. A-180805 involving a breach of a $10,800 U.S. Dollars construction contract with the described Pro Se Plaintiff herein.

Request Number 25.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein

between the actual dates of December 18th 2007 throughout actual date of November 13th 2009 10:22 am hour when you physically filed “Motion for

Withdrawal of Counsel” you in this said time frame was acting counsel for Co-Defendant(s) Joyce M. Guy and Edward McCray in a civil suit in the

58th Judicial District Court of Jefferson County Texas docket No. A-180805 involving a breach of a $10,800 U.S. Dollars construction contract with the described Pro Se Plaintiff herein admitting furtherance’s

Said Co-Defendant(s) Joyce M. Guy and Edward McCray collectively engaged in the destruction of physical evidence of a entire home which was completely destroyed being on

Lots Numbered One and Two (1&2) in Block Number One Hundred Seventy Two (172) of City of Port Arthur in Jefferson County, Texas

Namely the property located at 448 DeQueen Blvd. in Port Arthur Texas 77640 which is the primary “physical evidence” and “physical address” of said Co-Defendant(s) collectively herein as described in Pro Se Plaintiff attached Document # 1 namely

“Mechanic’s LIEN Contract filed on June 9th 2009 SWMJ Construction Inc., 525 N. Sam Houston Pkwy East, Suite 600, Houston, Texas 77060 in connection with a Housing Grant in excess of $72,500.00 U.S Dollars







For the property located at 448Dequeen Blvd. in Port Arthur Texas

77640.

Request Number 26.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein between the actual dates of December 18th 2007 throughout actual date of November 13th 2009 10:22 am hour you physically filed “Motion for Withdrawal of Counsel” you was acting counsel for Co-Defendant(s) Joyce M. Guy and Edward McCray legal behalf in a civil suit in the

58th Judicial District Court of Jefferson County Texas docket No. A-180805 involving a breach of a $10,800 U.S. Dollars construction contract with the described Pro Se Plaintiff herein.


between the actual dates of March 14th 2008 – throughout actual date of November 13th 2009 10:22 am hour Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein refusal to respond to all of the Pro Se Plaintiff discovery request your having in your legal, possession, custody and control mailed to you since the exact time date of March 14th 2008 – on behalf of said Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein while “you”

Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein furtherance’s admitting said Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein engaged in the destruction of “physical evidence” of an entire home which was completely destroyed being on


Namely the property located at 448 DeQueen Blvd. in Port Arthur Texas 77640 which is the primary “physical evidence” and “physical address” of said Co-Defendant(s) collectively herein and furtherance’s admitting said

Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein refusal to produce to the Pro Se Plaintiff copies of said property deeds for Lots Numbered One and Two (1&2) in Block Number One Hundred Seventy Two (172) of City of Port Arthur in Jefferson County, Texas

Namely the property located at 448 DeQueen Blvd. in Port Arthur Texas 77640 while you’re still acting “attorney of record” between the actual dates of December 18th 2007- November 13th 2009 10:22 am

With “you” Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein in full possession, custody and legal control over of said Pro Se Plaintiff

herein “request for production of property deeds” for Lots Numbered One and Two (1&2) in Block Number One Hundred Seventy Two (172) of City of Port Arthur in Jefferson County, Texas

Namely the property located at 448 DeQueen Blvd. in Port Arthur Texas 77640 in Your” Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein physical custody, possession and legal control between the actual dates of March 14th 2008 – November 13th 2009 10:22 am hour.


between the actual dates of December 18th 2007 throughout actual date of April 30th 2010 when you filed Defendant’s Original Answer again in U.S. District Court for the District of Texas, Beaumont Division Jefferson County, Texas U.S. Docket No. 1:10-CV-00055 against the Pro Se Plaintiff Louis Charles Hamilton II herein


Magistrate Keith F. Giblin your Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein “your” having full knowledge that between the actual dates of November 13th 2009 10:22 am hour you physically filed “Motion for Withdrawal of Counsel” as stated by “you”


“Your” having full legal knowledge that on Lots Numbered One and Two (1&2) in Block Number One Hundred Seventy Two (172) of City of Port Arthur in Jefferson County, Texas

Namely the property located at 448 DeQueen Blvd. in Port Arthur Texas 77640 which is the primary “physical evidence” and “physical address” of said Co-Defendant(s) collectively herein which is both “physical evidence” and “physical home” was completely destroyed in connection with namely








United States Department of Housing and Urban Development TDHCA Federal Award Number: B-06-DG-48-0002 Federal Award Year (Year of Award from HUD to TDHCA): 2006 TDHCA Award Year: 2007.


between the actual dates of December 18th 2007 throughout actual date of April 30th 2010 when you filed Defendant’s Original Answer again in U.S. District Court for the District of Texas, Beaumont Division Jefferson County, Texas U.S. Docket No. 1:10-CV-00055 against the Pro Se Plaintiff Louis Charles Hamilton II herein


Magistrate Keith F. Giblin Admitting Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”,

herein refusal to respond to all of the Pro Se Plaintiff discovery request your having in your legal, possession, custody and control mailed to you since the exact time date of March 14th 2008 – on behalf of said

Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein until you Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein responded to all said discovery request on October 14 th, 2009 at which during this time frame of March 14th 2008 October 14th, 2009

“Your” having full legal knowledge that on Lots Numbered One and Two (1&2) in Block Number One Hundred Seventy Two (172) of City of Port Arthur in Jefferson County, Texas

Namely the property located at 448 DeQueen Blvd. in Port Arthur Texas 77640 which is the primary “physical evidence” and “physical address” of said Co-Defendant(s) collectively herein which is both “physical evidence” and “physical home” was completely destroyed in connection with namely









As physically described by you Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein in Pro Se Plaintiff attached Document # 9 Defendant(s) response to “Interrogatories” dated October 14 th, 2009 said property being under a Federal Grant namely Interrogatories herein pursuant to Rule 197 of the Texas Rules of Civil Procedures at Question: 10, 11, 12, 13, 14, 15, and 16.

Request Number 30.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein being in full possession, custody and legal control over said Pro Se Plaintiff herein “request for production of property deeds” for Lots Numbered One and Two (1&2) in Block Number One Hundred Seventy Two (172) of City of Port Arthur in Jefferson County, Texas

Namely the property located at 448 DeQueen Blvd. in Port Arthur Texas 77640 in Your” Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”,

herein physical custody, possession and legal control between the actual dates of March 14th 2008 and such “request for production of property deeds” for Lots Numbered One and Two (1&2) in Block Number One Hundred Seventy Two (172) of City of Port Arthur in Jefferson County, Texas

Namely the property located at 448 DeQueen Blvd. in Port Arthur Texas 77640 having not been produced to the Pro Se Plaintiff or the 58 th Judicial District Court of Jefferson County Texas throughout actual date of April 30th 2010 when you filed Defendant’s Original Answer again in U.S. District Court for the District of Texas, Beaumont Division Jefferson County, Texas U.S. Docket No. 1:10-CV-00055 against the Pro Se Plaintiff Louis Charles Hamilton II herein


Magistrate Keith F. Giblin Namely the property located at 448 DeQueen Blvd. in Port Arthur Texas 77640 which is the primary “physical evidence” and “physical address” of said Co-Defendant(s) collectively herein which is both “physical evidence” and “physical home” your furtherance’s admitting

Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein the primary “physical evidence” and “physical home on said address” of said Co-Defendant(s) collectively herein was completely destroyed in connection with namely









As your furtherance’s admitting physically being described by you Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein in Pro Se Plaintiff attached Document # 9 Defendant(s) response to “Interrogatories” dated October 14th, 2009

Stating said property being under a Federal Grant namely Interrogatories questions herein pursuant to Rule 197 of the Texas Rules of Civil Procedures at Question: 10, 11, 12, 13, 14, 15, and 16.

Request Number 31.


being in full possession, custody and legal control over said Pro Se Plaintiff discovery request for “interrogatories” herein filed as Pro Se Plaintiff attached Document # 9 Defendant(s) response to “Interrogatories” dated October 14 th, 2009 in “Your” physical possession between the actual dates of March 14th 2008 throughout the Dates of October 14th, 2009 and your admitting furtherance

Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein in

defense after your retain counsel of record filed Defendant’s Collective Original Answer again in U.S. District Court for the District of Texas, Beaumont Division Jefferson County, Texas U.S. Docket No. 1:10-CV-00055 against the Pro Se Plaintiff Louis Charles Hamilton II herein and “you” Antoine L. Freeman J. D. “Attorney at Law”, being Defendant (also) in U.S. District Court for the District of Texas, Beaumont Division Jefferson County, Texas U.S. Docket No. 1:10-CV-00055


Admitting furtherance Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein against penalty of perjury Before the Honorable U.S. Judge Marcia A. Crone and Honorable U.S. Magistrate Keith F. Giblin

Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein admitting when question (12) was asked “what is the entire cost of the construction for the new home..? And you Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein and on behalf of Co-Defendant(s) collectively supply the responded of $76,000

Admitting you are continual making the same “representation and presentation” Before the Honorable U.S. Judge Marcia A. Crone and Honorable

U.S. Magistrate Keith F. Giblin of the Question under Federal Rules of Civil Procedure in Your Answer to Interrogatories herein (now) to still be that of the false and fraudulent statement response of $76,000 in comparison to Pro Se Plaintiff attached official document # 1 namely


“Texas Department of Housing and Community affairs” Loan No. 2727 File No. 1219-2102152 CFDA 14.228 Community Development Block Grant Program (“CDBG”) Hurricanes Katrina, Rita and Wilma in the Gulf of Mexico 2005


Or (Sabine Pass Restoration Program “SPRP”) Awarding Federal Agency: United States Department of Housing and Urban Development TDHCA Federal Award Number: B-06-DG-48-0002 Federal Award Year (Year of Award from HUD to TDHCA): 2006 TDHCA Award Year: 2007.

For Lots Numbered One and Two (1&2) in Block Number One Hundred Seventy Two (172) of City of Port Arthur in Jefferson County, Texas

Namely the property located at 448 DeQueen Blvd. in Port Arthur Texas 77640 which said Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein engaged in the destruction of “physical evidence” of an entire home which was completely destroyed being on



Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein refusal to produce to the Pro Se Plaintiff copies of said required “property deeds” for Lots Numbered One and Two (1&2) in Block Number One Hundred Seventy Two (172) of City of Port Arthur in Jefferson County, Texas

Namely the property located at 448 DeQueen Blvd. in Port Arthur Texas 77640 while you’re still acting “attorney of record” between the actual dates of December 18th 2007- November 13th 2009 10:22 am and continual admitting Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein said Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein

Continual between the date of November 13th 2009 10:22 am throughout March 30th 2015 refusal to produce said property deeds for Lots Numbered One and Two (1&2) in Block Number One Hundred Seventy Two (172) of City of Port Arthur in Jefferson County, Texas

Namely the property located at 448 DeQueen Blvd. in Port Arthur Texas into civil suit in common law files before the Jefferson County Texas 58 th Judicial District Court even after the 58th Judicial District Court (Order) as described in Pro Se Plaintiff attached Document # 5 herein Order of the 58th Judicial District Court Cause No. A-180805 dated May 10th 2010

Said Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein in the production of said “property deeds” to the dwelling located at Lots Numbered One and Two (1&2) in Block Number One Hundred Seventy Two (172) of City of Port Arthur in Jefferson County, Texas

Namely the property located at 448 DeQueen Blvd. in Port Arthur Texas.


being in full possession, custody and legal control over said Pro Se Plaintiff discovery request for “interrogatories” herein filed as Pro Se Plaintiff attached Document # 9 Defendant(s) response to “Interrogatories” dated October 14 th, 2009 in “Your” physical possession between the actual dates of March 14th 2008 throughout the Dates of October 14th, 2009 and your admitting furtherance

Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein in defense after your retain counsel of record filed Defendant’s Collective Original Answer again in

U.S. District Court for the District of Texas, Beaumont Division Jefferson County, Texas U.S. Docket No. 1:10-CV-00055 against the Pro Se Plaintiff Louis Charles Hamilton II herein and “you” Antoine L. Freeman J. D. “Attorney at Law”, being Defendant (also) in U.S. District Court for the District of Texas, Beaumont Division Jefferson County, Texas U.S. Docket No. 1:10-CV-00055


Admitting furtherance Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein against penalty of perjury Before the Honorable U.S. Judge Marcia A. Crone and Honorable U.S. Magistrate Keith F. Giblin

Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein admitting when question (14) was asked

“How is the state of Texas Involved..? And you Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”,

herein and on behalf of Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein collectively supply the responded of “Not involved

Admitting you are continual making the same “representation and presentation” Before the Honorable U.S. Judge Marcia A. Crone and Honorable U.S. Magistrate Keith F. Giblin of the Question under Federal Rules of Civil Procedure in Your Answer to Interrogatories herein (now) to still be that of the false and fraudulent statement response of (Texas) not Involved in comparison to Pro Se Plaintiff attached official document # 1 namely







Namely the property located at 448 DeQueen Blvd. in Port Arthur Texas 77640 which said Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein engaged in the destruction of “physical evidence” of an entire home which was completely destroyed being on



Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein refusal to produce to the Pro Se Plaintiff copies of said required “property deeds” for Lots Numbered One and Two (1&2) in Block Number One Hundred Seventy Two (172) of City of Port Arthur in Jefferson County, Texas

Namely the property located at 448 DeQueen Blvd. in Port Arthur Texas 77640 while you’re still acting “attorney of record” between the actual dates of December 18th 2007- November 13th 2009 10:22 am and continual admitting Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein said Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein

Continual between the date of November 13th 2009 10:22 am throughout March 30th 2015 refusal to produce said property deeds for Lots Numbered One and Two (1&2) in Block Number One Hundred Seventy Two (172) of City of Port Arthur in Jefferson County, Texas

Namely the property located at 448 DeQueen Blvd. in Port Arthur Texas into civil suit in common law files before the Jefferson County Texas 58 th Judicial District Court even after the 58th Judicial District Court (Order) as described in Pro Se Plaintiff attached Document # 5 herein Order of the 58 th Judicial District Court Cause No. A-180805 dated May 10th 2010

Said Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein in the production of said “property deeds” to the dwelling located at Lots Numbered One and Two (1&2) in Block Number One Hundred Seventy Two (172) of City of Port Arthur in Jefferson County, Texas

Namely the property located at 448 DeQueen Blvd. in Port Arthur Texas. Request Number 33.


said Pro Se Plaintiff discovery request for “interrogatories” herein filed as Pro Se Plaintiff attached Document # 9 Defendant(s) response to “Interrogatories” questions at number (12) and (14) are indeed “false, fictitious and fraudulent” statement of entry in said Interrogators in comparison to Pro Se Plaintiff attached official document # 1 namely






Namely the property located at 448 DeQueen Blvd. in Port Arthur Texas 77640

Request Number 34.


that you, conspire, hidden, scuttled, obstructed, conceal, keep secrete, tuck away, between the dates of March 14th 2008 throughout the Dates of October 14th, 2009 Pro Se Plaintiff attached official document # 1 namely





Or (Sabine Pass Restoration Program “SPRP”) Awarding Federal Agency: United States Department of Housing and Urban Development TDHCA Federal

Award Number: B-06-DG-48-0002 Federal Award Year (Year of Award from HUD to TDHCA): 2006 TDHCA Award Year: 2007.


Namely the property located at 448 DeQueen Blvd. in Port Arthur Texas 77640 for the Behalf of the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein.

Request Number 35.


that you, conspire, hidden, scuttled, obstructed, conceal, keep secrete, tuck away, between the dates of March 14th 2008 throughout the Dates of May 10th 2010 Pro Se Plaintiff attached official document # 1 namely








Request Number 36.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein that you, conspire, hidden, scuttled, obstructed, conceal, keep secrete, tuck away, in the same “representation and presentation” Before the Honorable U.S. Judge Marcia A. Crone and Honorable U.S. Magistrate Keith F. Giblin

Herein in continual “defense” after your retain again as counsel of record in the file Defendant’s Collective Original Answer again in U.S. District Court for the District of Texas, Beaumont Division Jefferson County, Texas U.S. Docket No. 1:10-CV-00055 against the

Pro Se Plaintiff Louis Charles Hamilton II herein and “you” Antoine L. Freeman J. D. “Attorney at Law”, being Defendant (also) in U.S. District Court for the District of Texas, Beaumont Division Jefferson County, Texas U.S. Docket No. 1:10-CV-00055 between the dates of March 14th 2008 throughout the Dates of April 30th 2010 continual in the same (RICO) enterprise “pattern and practices” conspire, hidden, scuttled, obstructed, conceal, keep secrete, tuck away, for the continual legal behalf of the of the said Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein now federal “subject matter” before the Honorable U.S. Judge Marcia A. Crone and Honorable U.S. Magistrate Keith F. Giblin

Pro Se Plaintiff attached official document # 1 namely “Mechanic’s LIEN Contract filed on June 9th 2009 SWMJ Construction Inc.,






Namely the property located at 448 DeQueen Blvd. in Port Arthur Texas 77640 for the continual legal Behalf of the said Co-Defendant(s) “Joyce M. Guy

and Edward McCray” herein April 30th 2010 and all Federal Court Proceeding derive thereafter in the continual conspire, hidden, scuttled, obstructed, conceal, keep secrete, tuck

Pro Se Plaintiff attached official document # 1 “Mechanic’s LIEN Contract filed on June 9th 2009 SWMJ Construction Inc., 525 N. Sam Houston Pkwy East, Suite 600, Houston, Texas 77060 in connection with a Housing Grant in excess of $72,500.00 U.S Dollars


that you, conspire, hidden, scuttled, obstructed, conceal, keep secrete, tuck away, between the dates of March 14th 2008 throughout the Dates of May 10th 2010 Pro Se Plaintiff attached official document # 1 namely








Request Number 38.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein that you, conspire, hidden, scuttled, obstructed, conceal, keep secrete, tuck away, between the dates of March 14th 2008 throughout the Dates of March 30th 2015 Pro Se Plaintiff attached official document # 1 namely








Request Number 39.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein that you, conspire, hidden, scuttled, obstructed, conceal, keep secrete, tuck away, between the dates of March 14th 2008 throughout the Dates of October 14th, 2009 Pro Se Plaintiff attached official document # 1 namely







Namely the property located at 448 DeQueen Blvd. in Port Arthur Texas 77640 for the Behalf of the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein and “you” Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein refused to file a “Motion for Withdrawal of Counsel” until November 13th 2009 10:22 am hour.

Request Number 40.


that you, conspire, hidden, scuttled, obstructed, conceal, keep secrete, tuck away, between the dates of March 14th 2008 throughout the Dates of December 11th 2009 Pro Se Plaintiff attached official document # 1 namely







Namely the property located at 448 DeQueen Blvd. in Port Arthur Texas 77640 for the Behalf of the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein and “you” Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein refused to file a “Motion for Withdrawal of Counsel” until November 13th 2009 10:22 am hour.

Request Number 41.


that the said Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein having a “Mechanic’s LIEN Contract” filed on June 9th 2009 with SWMJ Construction Inc., 525 N. Sam Houston Pkwy East, Suite 600, Houston, Texas 77060 in connection with a Housing Grant in excess of $72,500.00 U.S Dollars For Lots Numbered One and Two (1&2) in Block Number One Hundred Seventy Two (172) of City of Port Arthur in Jefferson County, Texas

Namely the property located at 448 DeQueen Blvd. in Port Arthur Texas 77640 which said dwelling, property located at 448 DeQueen Blvd. in Port Arthur Texas 77640 is also involved in a civil suit in common law in the 58th Judicial District Court of Jefferson County Texas since November 26 th 2007 before said “Mechanic’s LIEN Contract” filed on June 9th 2009 with SWMJ Construction Inc., was established, posted, date mark, and executed against said Lots Numbered One and Two (1&2) in Block Number One Hundred Seventy Two (172) of City of Port Arthur in Jefferson County, Texas

Namely the property located at 448 DeQueen Blvd. in Port Arthur Texas 77640.

Request Number 42.


that the said Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein having a “Mechanic’s LIEN Contract” filed on June 9th 2009 with SWMJ Construction Inc., 525 N. Sam Houston Pkwy East, Suite 600, Houston, Texas 77060 in connection with a Housing Grant in excess of $72,500.00 U.S Dollars in Connection with “Texas Department of Housing and Community affairs” Loan No. 2727 File No. 1219-2102152 CFDA 14.228 Community Development Block Grant Program (“CDBG”) Hurricanes Katrina, Rita and Wilma in the Gulf of Mexico 2005


Namely the property located at 448 DeQueen Blvd. in Port Arthur Texas 77640 which said dwelling, property located at 448 DeQueen Blvd. in Port Arthur Texas 77640 is also involved in a civil suit in common law in the 58 th Judicial District Court of Jefferson County Texas since

November 26th 2007 before said “Mechanic’s LIEN Contract” filed on June 9th 2009 with SWMJ Construction Inc., was established, posted, date mark, and executed against said Lots Numbered One and Two (1&2) in Block Number One Hundred Seventy Two (172) of City of Port Arthur in Jefferson County, Texas



that the said Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein having a “Mechanic’s LIEN Contract” filed on June 9th 2009 with SWMJ Construction Inc., 525 N. Sam Houston Pkwy East, Suite 600, Houston, Texas 77060 in connection with a Housing Grant in excess of $72,500.00 U.S Dollars in Connection with Federally Declared Disaster Funding under Department of Defense Appropriations Act, 2006 CDBG Disaster Recovery Program (Homeowner Assistance Program “HAP”)


Namely the property located at 448 DeQueen Blvd. in Port Arthur Texas 77640 which said dwelling, property located at 448 DeQueen Blvd. in Port Arthur Texas 77640 is also involved in a civil suit in common law in the 58th Judicial District Court of Jefferson County Texas since



Request Number 44.


that the said Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein having a “Mechanic’s LIEN Contract” filed on June 9th 2009 with SWMJ Construction Inc., 525 N. Sam Houston Pkwy East, Suite 600, Houston, Texas 77060 in connection with a Housing Grant in excess of $72,500.00 U.S Dollars in Connection with







that the said Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein having a “Mechanic’s LIEN Contract” filed on June 9th 2009 with SWMJ Construction Inc., 525 N. Sam Houston Pkwy East, Suite 600, Houston, Texas 77060 in connection with a Housing Grant in excess of $72,500.00 U.S Dollars in Connection with (Sabine Pass Restoration Program “SPRP”) Awarding Federal Agency: United States Department of Housing and Urban Development TDHCA Federal Award Number: B-06-DG-48-0002 Federal Award Year (Year of Award from HUD to TDHCA): 2006 TDHCA Award Year: 2007.






Pursuant to the provisions of Federal Rule of Civil Procedure 36, YOU making same admissions of the following statements of fact’s in the (year) of 2015 in your defense of this current Complaint filed in U.S. Cause No. 1:14-CV-592 U.S. District Court for the District of Texas, Beaumont Division Jefferson County, Texas when you filed Defendant’s Original Answer again in U.S. District Court for the District of Texas, Beaumont Division Jefferson County, Texas U.S. Docket No. 1:10-CV-00055 against the Pro Se Plaintiff Louis Charles Hamilton II herein


Magistrate Keith F. Giblin on your behalf Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein and the Co-Defendant(s) “Joyce M. Guy and Edward McCray collective legal behalf Admitting you are continual making the same “representation and presentation”

Before the Honorable U.S. Judge Marcia A. Crone and Honorable U.S. Magistrate Keith F. Giblin, in 2010 (April) 30th to be exact and all defense derive thereafter That you stating that on or about April 2nd 2008 and April 11, 2008 the continual false claims you were in possession, custody, and control of Pro Se Plaintiff Discovery request for Production of Documents and Request for Disclosure in accordance with the

Texas Rules of Civil Procedures to Cause No. A-180805 in a civil suit in the 58th Judicial District Court of Jefferson County Texas and the official date your

claiming of such knowledge to be that on or about April 2nd 2008 and April 11, 2008, to be material factual, 100% the truth against Federal Penalty of perjury in comparison to Pro Se Plaintiff attached Document # 10 “The Official 58 th Judicial District Court of Jefferson County Texas”, Case Ledger showing said discovery of Pro Se Plaintiff Louis Charles Hamilton II herein Discovery request for Production of Documents and Request for Disclosure in accordance with the

Texas Rules of Civil Procedures to Cause No. A-180805 in a civil suit in the 58th Judicial District Court of Jefferson County Texas was in your Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein legal possession Custody and Control since March 14th 2008 and not the dates of April 2nd 2008 and April 11, 2008 as you’re falsely claiming.


Pursuant to the provisions of Federal Rule of Civil Procedure 36, YOU making same admissions of the following statements of fact’s in the (year) of 2015 in your defense of this current Complaint filed in U.S. Cause No. 1:14-CV-592 U.S. District Court for the District of Texas, Beaumont Division Jefferson County, Texas when you filed Defendant’s Original Answer again in U.S. District Court for the District of Texas, Beaumont Division Jefferson County, Texas U.S. Docket No. 1:10-CV-00055 against the Pro Se Plaintiff Louis Charles Hamilton II herein



Before the Honorable U.S. Judge Marcia A. Crone and Honorable U.S. Magistrate Keith F. Giblin, in 2010 (April) 30th to be exact and all defense derive thereafter in 2010 (April) 30th after viewing

Pro Se Plaintiff attached document # 10 namely Chief Defendant Antoine

L. Freeman J. D. “Attorney at Law”, herein Subscribed and Sworn “Verification” dated the 11th day of September 2009 to be statements under oath to be true and correct the official date your claiming , in 2010 (April) 30 th to be exact and all defense derive thereafter 2010 (April) 30th

In U.S. Docket No. 1:10-CV-00055 against the Pro Se Plaintiff Louis Charles Hamilton II herein

Before the Honorable U.S. Judge Marcia A. Crone and Honorable U.S. Magistrate Keith F. Giblin on your behalf Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein and the Co-Defendant(s) “Joyce M. Guy and Edward McCray collective legal behalf

Admitting you are continual making the same “representation and presentation” in defense of such knowledge to be that on or about April 2nd 2008 and April 11, 2008, to be material factual, 100% the truth against Federal Penalty of perjury in comparison to Pro Se Plaintiff attached Document # 11

“The Official 58th Judicial District Court of Jefferson County Texas”, Case Ledger showing said discovery of Pro Se Plaintiff Louis Charles Hamilton II herein Discovery request for Production of Documents, and Request for Disclosure in accordance with the

Texas Rules of Civil Procedures to Cause No. A-180805 in a civil suit in the 58th Judicial District Court of Jefferson County Texas was in your Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein legal possession Custody and Control since March 14th 2008 and not the dates of April 2nd 2008 and April 11, 2008 as you’re falsely claiming...


Pursuant to the provisions of Federal Rule of Civil Procedure 36, YOU making same admissions of the following statements of fact’s in the (year) of 2015 in your defense of this current Complaint filed in U.S. Cause No. 1:14-CV-592 U.S. District Court for the District of Texas, Beaumont Division Jefferson County, Texas before the

Honorable U.S. Magistrate Judge Zack Hawthorn against the Pro Se Plaintiff Louis Charles Hamilton II herein on your behalf Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein and the Co-Defendant(s) “Joyce M. Guy and Edward McCray collective legal behalf Admitting you are continual making the same “representation and presentation” in 2015 to be exact and all defense derive thereafter in this current Complaint filed in U.S. Cause No. 1:14-CV-592 that you Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein

Continual stating that on or about April 2nd 2008 and April 11, 2008 the continual false claims you were in possession, custody, and control of Pro Se Plaintiff Discovery request for Production of Documents and Request for Disclosure in accordance with the

Texas Rules of Civil Procedures to Cause No. A-180805 in a civil suit in the 58th Judicial District Court of Jefferson County Texas and the official date your claiming of such knowledge to be that on or about April 2nd 2008 and April 11, 2008, to be material factual, 100% the truth against Federal Penalty of perjury in comparison to Pro Se Plaintiff attached Document # 11

“The Official 58th Judicial District Court of Jefferson County Texas”, Case Ledger showing said discovery of Pro Se Plaintiff Louis Charles Hamilton II herein Discovery request for Production of Documents and Request for Disclosure in accordance with the

Texas Rules of Civil Procedures 194.2, 197, and 198, to Cause No. A-180805 in a civil suit in the 58th Judicial District Court of Jefferson County Texas was in your Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein legal possession Custody and Control since March 14 th 2008 and not the dates of April 2nd 2008 and April 11, 2008 as you’re falsely claiming.



Honorable U.S. Magistrate Judge Zack Hawthorn against the Pro Se Plaintiff Louis Charles Hamilton II herein on your behalf Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein defense after the date of December 3rd 2014 to be exact and all defense derive thereafter in this current Complaint filed in U.S. Cause No. 1:14-CV-592 that you

Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein after viewing Pro Se Plaintiff attached document # 10 namely Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein Subscribed and Sworn “Verification” dated the 11th day of September 2009 to be statements under oath to be true and correct the official date your claiming before the

Honorable U.S. Magistrate Judge Zack Hawthorn against the Pro Se Plaintiff Louis Charles Hamilton II herein

Continual stating that on or about April 2nd 2008 and April 11, 2008 the continual false claims you were in possession, custody, and control of Pro Se Plaintiff Discovery request for Production of Documents and Request for Disclosure in accordance with the

Texas Rules of Civil Procedures to Cause No. A-180805 in a civil suit in the 58th Judicial District Court of Jefferson County Texas and the official date your claiming of such knowledge to be that on or about April 2nd 2008 and April 11, 2008, to be material factual, 100% the truth against Federal Penalty of perjury in comparison to Pro Se Plaintiff attached Document # 11





Honorable U.S. Magistrate Judge Zack Hawthorn against the Pro Se Plaintiff Louis Charles Hamilton II herein on your behalf Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein admit that you did not file a “Motion for withdrawal of Counsel” from the Co-Defendant(s) Joyce M. Guy and Edward McCray civil action herein “Between” the dates of December 18th 2007 in your claim of filing your “General Denial” (Only) to cause No. A-180805 throughout the date of April 2nd 2008 and April 11, 2008, after “You” Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein being in

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

And Request for Disclosure in accordance with the Texas Rules of Civil Procedures during this time frame “You” did not file a “Motion for withdrawal of Counsel to cause No. A-180805.


when you filed Defendant’s Original Answer again in U.S. District Court for the District of Texas, Beaumont Division Jefferson County, Texas U.S. Docket No. 1:10-CV-00055 against the Pro Se Plaintiff Louis Charles Hamilton II herein



Before the Honorable U.S. Judge Marcia A. Crone and Honorable U.S. Magistrate Keith F. Giblin, in 2010 (April) 30th to be exact and all defense derive thereafter in 2010 (April) 30th

“Between” the dates of March 14th 2008, throughout the dates of October 14th 2009 “Your” in full possession, custody, and legal control over Pro Se Plaintiff Motion for Production of Documents, and Request for Disclosure in accordance with the Texas Rules of Civil Procedures

“You” admitting in your defense in 2010 (April) 30 th to be exact and all

defense derive thereafter in 2010 (April) 30 th in U.S. Docket No. 1:10-CV-00055

against the Pro Se Plaintiff Louis Charles Hamilton II herein

You Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein

admitting you did in facts and circumstances fully informed the Honorable Judge

“Bob Wortham” of the 58th Judicial District Court of Jefferson County Texas

“Your” being in complete refusal per your Co-Defendant(s)/ (Clients)

“Joyce M. Guy and Edward McCray collective request and directions to not file

any legal response and reply to any of the Production of Documents, and

Request for Disclosure Pro Se Plaintiff mailed to “You” on the dates of March

14th 2008 in accordance with the Texas Rules of Civil Procedures in cause No. A-

180805 throughout October 14th 2009 and You Chief Defendant Antoine L.

Freeman J. D. “Attorney at Law”, herein furtherance’s admitting you did in facts

and circumstances fully informed the Honorable Judge “Bob Wortham” of the

58th Judicial District Court of Jefferson County Texas you’re not acting Attorney

of Record between the dates of March 14th 2008 .




Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein after viewing Pro Se Plaintiff attached document # 11“The Official 58th Judicial District Court of Jefferson County Texas”, Case Ledger showing said discovery of Pro Se Plaintiff Louis Charles Hamilton II herein Discovery request for Production of Documents and Request for Disclosure in accordance with the



Pursuant to the provisions of Federal Rule of Civil Procedure 36, YOU making same admissions of the following statements of fact’s in the (year) of 2015 in your defense of this current Complaint filed in U.S. Cause No. 1:14-CV-592 U.S.

District Court for the District of Texas, Beaumont Division Jefferson County, Texas before the


Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein after viewing Pro Se Plaintiff attached document # 11“The Official 58th Judicial District Court of Jefferson County Texas”, Case Ledger showing said discovery of Pro Se Plaintiff Louis Charles Hamilton II herein Discovery request for Production of Documents and Request for Disclosure in accordance with the




Honorable U.S. Magistrate Judge Zack Hawthorn against the Pro Se Plaintiff Louis Charles Hamilton II herein on your behalf Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein defense after the date of

December 3rd 2014 to be exact and all defense derive thereafter in this current Complaint filed in U.S. Cause No. 1:14-CV-592 that you when you filed Defendant’s Original Answer again in U.S. District Court for the District of Texas, Beaumont Division Jefferson County, Texas U.S. Docket No. 1:10-CV-00055 against the Pro Se Plaintiff Louis Charles Hamilton II herein


Magistrate Keith F. Giblin on your behalf Chief Defendant Antoine L. Freeman J.

D. “Attorney at Law”, herein and the Co-Defendant(s) “Joyce M. Guy and Edward McCray collective legal behalf Admitting you are continual making the same “representation and presentation”

Before the Honorable U.S. Judge Marcia A. Crone and Honorable U.S. Magistrate Keith F. Giblin, in 2010 (April) 30th to be exact and all continual defense derive thereafter in 2010 (April) 30 th

Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein after viewing Pro Se Plaintiff attached document # 11“The Official 58 th Judicial District Court of Jefferson County Texas”, Case Ledger showing said discovery of Pro Se Plaintiff Louis Charles Hamilton II herein Discovery request for Production of Documents and Request for Disclosure in accordance with the

Texas Rules of Civil Procedures to Cause No. A-180805 in a civil suit in the 58th Judicial District Court of Jefferson County Texas was in your Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein legal possession Custody and Control since March 14th 2008 and your furtherance’s admitting not the dates of April 2nd 2008 and April 11, 2008 as your falsely claiming in Pro Se Plaintiff attached Document # 3 “Your Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein response to motion for sanctions against you dated September 11th 2009

Request Number 55.




December 3rd 2014 to be exact and all defense derive thereafter in this current Complaint filed in U.S. Cause No. 1:14-CV-592 that you when you filed Defendant’s Original Answer again in U.S. District Court for the District of Texas, Beaumont Division Jefferson County, Texas U.S. Docket No. 1:10-CV-00055 against the Pro Se Plaintiff Louis Charles Hamilton II herein

Before the Honorable U.S. Judge Marcia A. Crone and Honorable U.S. Magistrate Keith F. Giblin on your behalf Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein and the Co-Defendant(s) “Joyce M. Guy and Edward McCray collective legal behalf Admitting you are continual making the same “representation and presentation”

Before the Honorable U.S. Judge Marcia A. Crone and Honorable U.S. Magistrate Keith F. Giblin, in 2010 (April) 30th to be exact and all continual defense derive thereafter in 2010 (April) 30 th

Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein “You” did file a request for a longer extension of time herein furtherance’s admitting you did in facts and circumstances fully informed the Honorable Judge “Bob Wortham” of the 58th Judicial District Court of Jefferson County Texas you needing the extra time to reply to said “Discovery Request of Interrogatories, Request of Admission, Motion for Production of Documents and Request for Disclosure Pro Se Plaintiff mailed to “You” on the start dates of March 14 th 2008 and your herein furtherance’s admitting you did in facts and circumstances fully informed the Honorable Judge “Bob Wortham” between the actual dates of March 14th 2008 throughout October 12th 2009.

Request Number 56.




December 3rd 2014 to be exact and all defense derive thereafter in this current Complaint filed in U.S. Cause No. 1:14-CV-592 that you

Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein “You” did file a request for a longer extension of time herein furtherance’s admitting you did in facts and circumstances fully informed the Honorable Judge “Bob Wortham” of the 58th Judicial District Court of Jefferson County Texas you behalf Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein

needing the extra time to reply to said “Discovery Request of Interrogatories, Request of Admission,

Motion for Production of Documents and Request for Disclosure Pro Se Plaintiff mailed to “You” on the start dates of March 14th 2008 and your herein furtherance’s admitting you did in facts and circumstances fully informed the Honorable Judge “Bob Wortham” between the actual dates of March 14 th 2008 throughout October 12th 2009.




Admitting Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein that Co- Defendant Joyce M. Guy” herein supply the following Answer to Pro Se Plaintiff Interrogatories Document # 9 attached herein pursuant to Rule 197 of the Texas Rules of Civil Procedures at Question: 10, 11, 12, 13, 14, 15, and 16.

10. Where is the Funding for the New Home?

Answer: Federal Grant

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

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

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

Answer: $76,000.00 U.S. Dollars

13. How is the city of Port Arthur Involved?

Answer: Not involved

14. How is the State of Texas Involved?

Answer: Not Involved

15. How is the Federal Government involved?

Answer: Federal Grant

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

Answer: No money paid by Co-Defendant

And furtherance admitting Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, you never even took the “simple time” to legally factually discovery and obtain from the Co-Defendant(s) “Joyce M. Guy and Edward McCray correct material facts as described by

Pro Se Plaintiff attached document #1 herein which was filed with the Jefferson County Texas Clerk office




Or (Sabine Pass Restoration Program “SPRP”) Awarding Federal Agency: United States Department of Housing and Urban Development TDHCA Federal Award Number: B-06-DG-48-0002 Federal Award Year (Year of Award from HUD to TDHCA): 2006 TDHCA Award Year: 2007

For the property located at 448Dequeen Blvd. in Port Arthur Texas 77640 which you was acting counsel for Co-Defendant(s) Joyce M. Guy and Edward McCray in a civil suit in the

58th Judicial District Court of Jefferson County Texas docket No. A-180805 involving a breach of a $10,800 U.S. Dollars construction contract with the

described Pro Se Plaintiff herein before Chief Defendant Antoine L. Freeman J. D. “Attorney at Law” herein filing false and fraudulent material facts concerning

Interrogatories pursuant to Rule 197 of the Texas Rules of Civil Procedures at Question: 12,

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


Which the correct answer is $72,500.00 U.S Dollars as described in Pro Se Plaintiff attached document # 1 herein namely



Furtherance Before you Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, furtherance filing additional “false and fraudulent material facts” concerning Interrogatories pursuant to Rule 197 of the Texas Rules of Civil Procedures at Question: 14.

How is the State of Texas Involved?


Which the correct answer is “Texas Department of Housing and Community affairs” Loan No. 2727

File No. 1219-2102152 CFDA 14.228 Community Development Block Grant Program (“CDBG”) Hurricanes Katrina, Rita and Wilma in the Gulf of Mexico 2005 is involved

As described “legally” in Pro Se Plaintiff attached document # 1 herein namely


“Texas Department of Housing and Community affairs” Loan No. 2727 File No. 1219-2102152 CFDA 14.228 Community Development Block Grant Program (“CDBG”) Hurricanes Katrina, Rita and Wilma in the Gulf of Mexico 2005.


in your defense of this current Complaint filed in U.S. Cause No. 1:14-CV-592 U.S. District Court for the District of Texas, Beaumont Division Jefferson County, Texas before the


Admitting Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein that Co- Defendant Joyce M. Guy” pursuant to

18 U.S.C. § 1001: US Code - Section 1001: Statements or entries generally

(a) Except as otherwise provided in this section, whoever, in any matter within the jurisdiction of the executive, legislative, or judicial branch of the Government of the United States,

Co- Defendant Joyce M. Guy knowingly and willfully - (1) falsifies, conceals, or covers up by any trick, scheme, or device a material fact;

(2) Makes any materially false, fictitious, or fraudulent statement or representation; or

(3) Makes or uses any false writing or document knowing the same to contain any materially false, fictitious, or fraudulent statement or entry;

In connection with all court records of the 58th Judicial District Court of Jefferson County Texas, Interrogatories pursuant to Rule 197 of the Texas Rules of Civil Procedures at Question: 12,

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


Furtherance admitting Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein Co- Defendant Joyce M. Guy knowingly and willfully –

(1) Falsifies, conceals, or covers up by any trick, scheme, or device a material fact;



In connection with all court records of the 58th Judicial District Court of Jefferson County Texas, Interrogatories pursuant to Rule 197 of the Texas Rules of Civil Procedures at Question: 14

Being additional “false, fictitious, and fraudulent material facts” concerning Interrogatories pursuant to Rule 197 of the Texas Rules of Civil Procedures at Question: 14.

How is the State of Texas Involved?





Admitting Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein that you were fully aware on March 14th 2008, Pro Se Plaintiff herein request production of copies of property deeds for Lots Numbered One and Two (1&2) in Block Number One Hundred Seventy Two (172) of City of Port Arthur in Jefferson County, Texas

Namely the property located at 448 DeQueen Blvd. in Port Arthur Texas 77640 which said dwelling, property located at 448 DeQueen Blvd. in Port

Arthur Texas 77640 is also involved in a civil suit in common law in the 58 th Judicial District Court of Jefferson County Texas docket No. A-180805 since

November 26th 2007 as such request production of copies of property deeds as being legally described in Pro Se Plaintiff attached document # 12 Namely Plaintiff Motion for Production of Document(s) filed in the District Court of Jefferson County Texas “time stamp” March 14th 2008 1:48 pm hour.

And you have not produce such copies of said “property deeds between the dates of March 14th 2008 throughout October 14th 2009.




Admitting Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein that you were fully aware on or after March 14th 2008, Pro Se Plaintiff herein request Pursuant to rule 194, within thirty (30) days of Service of this request your are requested to disclosed the information or material described in Rule 194.2

As being legally described in Pro Se Plaintiff attached document # 13 herein Namely Plaintiff “request for disclosure” filed in the District Court of Jefferson County Texas “time stamp” March 14th 2008 1:48 pm hour

And you Chief Defendant Antoine L. Freeman J. D. “Attorney at Law” herein have not produced such requested to disclose between the dates of March 14th 2008 1:48 pm hour throughout October 14th 2009.

Request Number 61. Admitting Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”,

herein that you were fully aware on March 14th 2008, Pro Se Plaintiff herein request production of copies of property deeds for Lots Numbered One and Two (1&2) in Block Number One Hundred Seventy Two (172) of City of Port Arthur in Jefferson County, Texas

Namely the property located at 448 DeQueen Blvd. in Port Arthur Texas 77640 which said dwelling, property located at 448 DeQueen Blvd. in Port Arthur Texas 77640 is also involved in a civil suit in common law in the 58 th Judicial District Court of Jefferson County Texas docket No. A-180805 since


And Co- Defendant “Joyce M. Guy” and “Edward McCray” herein collectively having not filed Pro Se Plaintiff attached document # 14

Namely “General Warranty Deed” for Lots Numbered One and Two (1&2) in Block Number One Hundred Seventy Two (172) of City of Port Arthur in Jefferson County, Texas

Namely the property deeds for dwelling and Property located at 448 DeQueen Blvd. in Port Arthur Texas


filed Pro Se Plaintiff attached document # 14 Namely “General Warranty Deed” for Lots Numbered One and Two (1&2)

in Block Number One Hundred Seventy Two (172) of City of Port Arthur in Jefferson County, Texas

Namely the “property deeds” for dwelling and Property located at 448 DeQueen Blvd. in Port Arthur Texas that you were fully aware on March 14th 2008, Pro Se Plaintiff herein request production of copies of said “property deeds” for Lots Numbered One and Two (1&2) in Block Number One Hundred Seventy Two (172) of City of Port Arthur in Jefferson County, Texas

Namely the property located at 448 DeQueen Blvd. in Port Arthur Texas 77640 which said dwelling, property located at 448 DeQueen Blvd. in Port Arthur Texas 77640 is also involved in a civil suit in common law in the

58th Judicial District Court of Jefferson County Texas docket No. A-180805 since


And you have not produce such copies of said “property deeds” between the dates of March 14th 2008 throughout October 14th 2009 as being described in Pro Se Plaintiff attached document # 14 Namely “General Warranty Deed” for Lots Numbered One and Two (1&2) in Block Number One Hundred Seventy Two (172) of City of Port Arthur in Jefferson County, Texas

Namely the “property deeds” for dwelling and Property located at 448 DeQueen Blvd. in Port Arthur Texas.


filed Pro Se Plaintiff attached document # 14 Namely “General Warranty Deed” for Lots Numbered One and Two (1&2)

in Block Number One Hundred Seventy Two (172) of City of Port Arthur in Jefferson County, Texas

Namely the “property deeds” for dwelling and Property located at 448 DeQueen Blvd. in Port Arthur Texas that you were fully aware on March 14th 2008, throughout June 9th 2009 when document #1 attached herein was filed with the Jefferson County Texas Clerk office








For the property located at 448Dequeen Blvd. in Port Arthur Texas 77640 which you was acting counsel for Co-Defendant(s) Joyce M. Guy and Edward McCray in a civil suit in the 58th Judicial District Court of Jefferson County Texas docket No. A-180805 involving a breach of a $10,800 U.S. Dollars construction contract with the described Pro Se Plaintiff herein.

Request Number 64.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein filed Pro Se Plaintiff attached document # 14


Namely the “property deeds” for dwelling and Property located at 448 DeQueen Blvd. in Port Arthur Texas was kept secret, concealed, hidden, tuck away, put out of sight, throughout June 9th 2009 by “you” Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, for the legal collective behalf of the Co-Defendant(s) “Joyce M. Guy and Edward McCray” providing “General Warranty Deed” protection against the Pro Se Plaintiff civil suit in common law “civil rights” of “Texas Constitution Article 16 Section 37 “Protection of Mechanic’s Lien” and Section 50 therein

Admitting furtherance’s when document #1 attached herein was transfer and legally filed with the Jefferson County Texas Clerk office





For the property located at 448Dequeen Blvd. in Port Arthur Texas 77640 which you was acting counsel for Co-Defendant(s) Joyce M. Guy and Edward McCray in a civil suit in the 58th Judicial District Court of Jefferson County Texas docket No. A-180805 involving a breach of a $10,800 U.S. Dollars construction contract with the described Pro Se Plaintiff herein.


is in direct Violations of Chapter 96 of Title 18, United State Code: (RICO) Racketeering Influences Corruption Organization, Title 18 U.S.C. § 1341, 1343

And 1349 “Mail and Wire Fraud”, section 1028(relating to fraud and

related activity in connection with identification documents), and

Section 1503(relating to obstruction of justice) in connection with the Pro

Se Plaintiff and all records, affidavits, court records, transcripts, files and

documents, as described legally fully herein from March 14th 2008 1:48 pm hour

Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein kept

secret, concealed, hidden, tuck away, fully put out of sight, throughout June 9th

2009 by “you” Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, for

the legal collective behalf of the Co-Defendant(s) “Joyce M. Guy and Edward

McCray” providing

“General Warranty Deed” protection against the Pro Se Plaintiff civil suit in common law “civil rights” of “Texas Constitution Article 16 Section 37 “Protection of Mechanic’s Lien” and Section 50 therein Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein have not produce such copies of said “property deeds” between the dates of March 14th 2008 throughout October 14th 2009.


March 14th 2008 1:48 pm hour while your acting attorney of record throughout June 9th 2009 is approximately (1) year, (2) Months and (23) days Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein is in direct

Violations of Chapter 96 of Title 18, United State Code: (RICO) Racketeering Influences Corruption Organization, Section 1503(relating to obstruction of justice) in connection with the Pro Se Plaintiff on March 14th 2008 1:48 pm hour, Pro Se Plaintiff Louis Charles Hamilton II herein request production of copies of said “property deeds” from

Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein for Lots Numbered One and Two (1&2) in Block Number One Hundred Seventy Two (172) of City of Port Arthur in Jefferson County, Texas


58th Judicial District Court of Jefferson County Texas docket No. A-180805 since November 26th 2007 with Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein.

Request Number 67.

Admitting Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein that Co- Defendant “Joyce M. Guy” herein supply the following Answer to Pro Se Plaintiff Interrogatories Document # 9 attached herein pursuant to Rule 197 of the Texas Rules of Civil Procedures at Question: (11)

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

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

Request Number 68.

Admitting Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein “you” from the time frame of March 14th 2008 1:48 pm hour while your acting attorney of record and continual being said acting attorney of record continual making the same “representation and presentation”

Before the Honorable U.S. Judge Marcia A. Crone and Honorable U.S. Magistrate Keith F. Giblin, in 2010 (April) 30th to be exact and all defense derive thereafter in 2010 (April) 30th

throughout April 22nd 2014 is approximately the time frame Chief

Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein conspire in ‘obstruction of justice” with Co- Defendant “Joyce M. Guy and Edward McCray” collectively herein admitting to continual kept secret, concealed, hidden, tuck away, fully put out of sight, Pro Se Plaintiff attached document # 14


Namely the “property deeds” for dwelling and Property located at 448 DeQueen Blvd. in Port Arthur Texas in order that the Co- Defendant “Joyce M. Guy and Edward McCray” collectively herein fully comply under all the terms and conditions of any contract in regards to the new home being said

Federal Government built home “free of charge” Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein must remain in home for at least 3 years while furtherance’s admitting the old home being “physical material evidence in said suit in common law in the

58th Judicial District Court of Jefferson County Texas docket No. A-180805 since November 26th 2007 with Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein fully forever destroyed.

Request Number 69.

Admitting Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”,

herein “you” from the time frame of March 14th 2008 1:48 pm hour while your “acting attorney of record” and continual being said “acting attorney of record” continual making the same “representation and presentation”

Before the Honorable U.S. Judge Marcia A. Crone and Honorable U.S. Magistrate Keith F. Giblin, in 2010 (April) 30th to be exact and all defense derive thereafter in 2010 (April) 30th for the legal behalf of the Co-Defendant(s) Defendant “Joyce M. Guy and Edward McCray” collectively herein

Continual Admitting Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein that you were fully aware on or after March 14th 2008, Pro Se Plaintiff herein request Pursuant to Texas rule of civil procedure 196, within thirty (30) days of Service of this request your are requested to disclosed the information or material described in Rule 196

As being legally described in Pro Se Plaintiff attached document # 12 herein Namely Plaintiff “Motion for Production of Document” filed in the District Court of Jefferson County Texas “time stamp” March 14 th 2008 1:48 pm hour for

Co-Defendant(s) Joyce M. Guy and Edward McCray shall produce copies of deeds, property deeds or any other such physical document in Co-Defendants’ possession, custody or control that shows actual ownership of the property of the dwelling located at 448 DeQueen Blvd., Port Arthur, Texas.

And Co-Defendant(s) Joyce M. Guy and Edward McCray shall produce

copies of any and all construction estimates for repairs in Defendants’ possession, custody or control in relationship to the damage caused by Hurricanes Rita, Humberto and Ike to the property located at 448 DeQueen Blvd. in Port Arthur, Texas

And you Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”

herein have not produced such requested to disclose between the dates of March 14th 2008 1:48 pm hour throughout October 14th 2009.

And you Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”

herein furtherance’s admitting on September 11th 2009 between the time frame “time stamp” March 14th 2008 1:48 pm hour throughout October 14th 2009 you withheld said discovery request being all such as described in “Request for Admission” (67) herein

Admitting in that on September 11th 2009 Chief Defendant Antoine L. Freeman J. D. “Attorney at Law” herein used the “United States Postal System” on the exact date the 11th day of September 2009 as described in Pro Se Plaintiff attached document # 3 herein Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein

“Response to Motion for sanctions” and Pro Se Plaintiff attached document # 10 herein Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein “Sworn statement under oath” to target Pro Se Plaintiff “Louis Charles Hamilton II” herein in a

“Mail and Wire Fraud” scheme of things on the exact date the 11th day of September 2009 involving a civil suit in common law in the 58th Judicial District Court of Jefferson County Texas Docket No. A-180805

In that Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein admit after viewing Pro Se Plaintiff attached document # 10 namely Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein “Subscribed and Sworn” legal documented “Verification” dated the 11th day of September 2009 to be statements under oath to be true and correct

All said fraudulent, false material facts, as described by Pro Se Plaintiff in document # 3 attached herein Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein “Response to Motion for sanctions”

Namely the official date your falsely claiming of such “firsthand knowledge” of any of the Pro Se Plaintiff herein required discovery request for copies of deeds, property deeds or any other such physical document in Co-Defendants’ possession, custody or control that shows actual ownership of the property of the dwelling located at 448 DeQueen Blvd., Port Arthur, Texas.

And Co-Defendant(s) Joyce M. Guy and Edward McCray herein through counsel of record namely Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein shall produce copies of any and all construction estimates for repairs in Defendants’ possession, custody or control in relationship to the damage caused by

Hurricanes Rita, Humberto and Ike to the property located at 448 DeQueen Blvd. in Port Arthur, Texas to be that on or about April 2nd 2008 and April 11, 2008, your falsely claiming of such “firsthand knowledge” of any of the Pro Se Plaintiff herein required discovery request to be material factual, 100% the truth against Federal Penalty of perjury in comparison to Pro Se Plaintiff attached Document # 11



Request Number 70.

Admitting Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein “you” from the time frame of March 14th 2008 1:48 pm hour while your acting attorney of record and continual being said acting attorney of record continual making the same “representation and presentation”

Before the Honorable U.S. Judge Marcia A. Crone and Honorable U.S. Magistrate Keith F. Giblin, in 2010 (April) 30th to be exact and all defense derive thereafter in 2010 (April) 30th for the legal behalf of the Co-Defendant(s) Defendant “Joyce M. Guy and Edward McCray” collectively herein

Continual Admitting Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein that you were fully aware on or after March 14th 2008, Pro Se Plaintiff herein request Pursuant to Texas rule of civil procedure Pro Se Plaintiff Discovery request for Interrogatories, Request of Admission, and Request for Disclosure in accordance with the

Texas Rules of Civil Procedures 194.2, 197, and 198, Being required to be produced within thirty (30) days of Service of this request your are requested to disclosed the information or material

And you Chief Defendant Antoine L. Freeman J. D. “Attorney at Law” herein admitting “you” have not produced such requested to disclose between the dates of March 14th 2008 1:48 pm hour throughout October 12th 2009

And you Chief Defendant Antoine L. Freeman J. D. “Attorney at Law” herein withheld all said “discovery request” to fully “target” Pro Se Plaintiff “Louis Charles Hamilton II” herein in a

“Mail and Wire Fraud” scheme of things on the exact date the March 14th 2008 1:48 pm hour throughout October 12th 2009 involving a civil suit in common law in the 58th Judicial District Court of Jefferson County Texas Docket No. A-180805

In that Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein admit “you”, used the “United States Postal System” “Mail and Wire Fraud” scheme of things to concealed, obstructed, kept secret, tuck away, hidden, scuttle for the legal behalf of the Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein all said “subject matter” contain in the described Discovery request for Interrogatories, Request of Admission, and Request for Disclosure in accordance with the Texas Rules of Civil Procedures 194.2, 197, and 198,.

And admitting this such “obstruction of justice” of the 58 th Judicial District

Court of Jefferson County to continual concealed, obstructed, kept secret, tuck

away, hidden, scuttle for the legal behalf of the Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein all said “subject matter” contain in the described Discovery request for Interrogatories, Request of Admission, and Request for Disclosure in accordance with the Texas Rules of Civil Procedures 194.2, 197, and 198,. Was facilitated in the Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein full legal usage of the “United States Postal System” Between the exact dates of March 14th 2008 1:48 pm hour throughout October 14th 2009.

Request Number 71.

Admitting Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein “you” from the time exact time frame of November 13th 2009 Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein fully legally usage of the “United States Postal System” to serve on Pro Se Plaintiff by execution of certified mail, return receipt requested on (Pro Se) Plaintiff at P.O. Box 342, Port Arthur, Texas 77640

“Your” Motion for Withdrawal of Counsel of Chief Defendant Antoine L.

Freeman J. D. “Attorney at Law” herein while Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein continual admitting to having not produced such requested to disclose between the dates of

March 14th 2008 1:48 pm hour throughout October 14th 2009 in that you withheld said all “discovery request” to “target” Pro Se Plaintiff “Louis Charles Hamilton II” herein in a “Mail and Wire Fraud” scheme of things on the exact date the March 14th 2008 1:48 pm hour throughout October 14th 2009 involving a civil suit in common law in the 58th Judicial District Court of Jefferson County Texas Docket No. A-180805”

To concealed, obstructed, kept secret, tuck away, hidden, scuttle for the legal behalf of the Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein all said “subject matter” contain in the described Discovery request for Interrogatories, Request of Admission, and Request for Disclosure in accordance with the Texas Rules of Civil Procedures 194.2, 197, and 198,.

Request Number 72.

Admitting Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein “you” from the time exact time frame of April 30th 2010 you are continual making the same “representation and presentation” Before the Honorable U.S. Judge Marcia A. Crone and Honorable U.S. Magistrate Keith F. Giblin

To continual herein fully legally usage of the “United States Postal System” “Mail and Wire Fraud” scheme of things to continual concealed, obstructed, kept secret, tuck away, hidden, scuttle for the legal behalf of the Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein all said “subject matter” contain in the described Discovery request for Interrogatories, Request of Admission, and Request for Disclosure in accordance with the Texas Rules of Civil Procedures 194.2, 197, and 198,.

That Co-Defendant(s) Joyce M. Guy and Edward McCray shall produce

copies of deeds, property deeds or any other such physical document in Co-Defendants’ possession, custody or control that shows actual ownership of the property of the dwelling located at 448 DeQueen Blvd., Port Arthur, Texas.

And that Co-Defendant(s) Joyce M. Guy and Edward McCray shall produce

copies of any and all construction estimates for repairs in Defendants’ possession, custody or control in relationship to the damage caused by Hurricanes Rita, Humberto and Ike to the property located at 448 DeQueen Blvd. in Port Arthur, Texas

While Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein continual having not produced such requested to disclose between the dates of

March 14th 2008 1:48 pm hour throughout October 14th 2009 in that you withheld said all “discovery request” to “target” Pro Se Plaintiff “Louis Charles Hamilton II” herein in a “Mail and Wire Fraud” scheme of things in the usage of the United States Postal system on the exact time frame dates of March 14th 2008 1:48 pm hour throughout October 14th 2009 involving a civil suit in common law in the 58th Judicial District Court of Jefferson County Texas Docket No. A-180805”


fully legally intend to continual usage of the “United States Postal System” in a

“Mail and Wire Fraud” scheme of things against “The United States District Court For The Eastern Division of Texas, Beaumont Division” from the time exact time frame of April 30th 2010 and all defense derive thereafter

In that you Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein are continual making the same fraudulent, false, fictitious “Representation and Presentation” Before the Honorable U.S. Judge Marcia A. Crone and Honorable U.S. Magistrate Keith F. Giblin U.S. Docket No. 1:10-CV-00055 against the Pro Se Plaintiff Louis Charles Hamilton II herein

All said fraudulent, false material facts, as described by Pro Se Plaintiff in document # 3 attached herein Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein “Response to Motion for sanctions” in that “You” was only retain to file a

“General Denial” only on December 18th 2007 and from the time frame of March 14th 2008 1:48 pm hour throughout November 13th 2009 10:22 am hour “You” herein Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein was not the acting ‘attorney of record”, did not attend any hearing on August 28th, 2009 and September 11th 2009.


fully legally intend to “continual usage” of the “United States Postal System” in a “Mail and Wire Fraud” scheme of things against “The United States District Court For The Eastern Division of Texas, Beaumont Division” from the time exact time frame of December 3rd 2014 and all defense derive thereafter

In that you Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein are continual making the same fraudulent, false, fictitious “Representation and Presentation” Before the

Honorable U.S. Magistrate Judge Zack Hawthorn U.S. Docket No. 1:14-CV-00592 against the Pro Se Plaintiff Louis Charles Hamilton II herein

All said fraudulent, false material facts, as described by Pro Se Plaintiff in document # 3 attached herein Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein “Response to Motion for sanctions” in that “You” was only retain to file a

“General Denial” only on December 18th 2007 and from the time frame of March 14th 2008 1:48 pm hour throughout November 13th 2009 10:22 am hour “You” herein Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”,

herein was not in any legal capacity the acting ‘attorney of record”, did not attend any hearing on August 28th, 2009 and September 11th 2009. In a civil suit in common law in the Jefferson County Texas 58th Judicial District Court Docket No. A-180805


fully legally intend to “continual usage” of the “United States Postal System” in a “Mail and Wire Fraud” scheme of things against “The United States District Court For The Eastern Division of Texas, Beaumont Division” from the time exact time frame of December 3rd 2014 and all defense derive thereafter Before the


In that you Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein are continual fully legally usage of the “United States Postal System” in a “Mail and Wire Fraud” scheme of things to continual concealed, obstructed, kept secret, tuck away, hidden, scuttle for the legal behalf of the Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein all said “subject matter” contain in the described Discovery request for Interrogatories, Request of Admission, and Request for Disclosure in accordance with the Texas Rules of Civil Procedures 194.2, 197, and 198,.

In That Co-Defendant(s) Joyce M. Guy and Edward McCray shall produce copies of deeds, property deeds or any other such physical document in Co-Defendants’ possession, custody or control that shows actual ownership of the property of the dwelling located at 448 DeQueen Blvd., Port Arthur, Texas.

And in that Co-Defendant(s) Joyce M. Guy and Edward McCray shall produce copies of any and all construction estimates for repairs in Defendants’ possession, custody or control in relationship to the damage caused by Hurricanes Rita, Humberto and Ike to the property located at 448 DeQueen Blvd. in Port Arthur, Texas


fully legally intend to “continual usage” of the “United States Postal System” in a “Mail and Wire Fraud” scheme of things against “The United States District

Court For The Eastern Division of Texas, Beaumont Division” from the time exact time frame of December 3rd 2014 and all defense derive thereafter Before the


In that you Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”,

herein are continual fully legally usage of the “United States Postal System” in a “Mail and Wire Fraud” scheme of things to continual concealed, obstructed, kept secret, tuck away, hidden, scuttle for the legal behalf of the Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein copies of said required “property deeds” for Lots Numbered One and Two (1&2) in Block Number One Hundred Seventy Two (172) of City of Port Arthur in Jefferson County, Texas

Namely the property located at 448 DeQueen Blvd. in Port Arthur Texas 77640 as described in Pro Se Plaintiff attached document # 14 “General Warranty Deed” of the Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein


after viewing Pro Se Plaintiff attached document # 10 namely Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein Subscribed and Sworn “Verification” dated the 11th day of September 2009 to be statements under oath to be true and correct In that you Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein did usage of the “United States Postal System” to forward Subscribed and Sworn “Verification” dated the 11th day of September 2009 to the 58th Judicial District Court of Jefferson County Texas,

And in that you Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein did usage of the “United States Postal System” to forward said Subscribed and Sworn “Verification” dated the 11th day of September 2009 to the Pro Se Plaintiff by execution of certified mail, return receipt requested on (Pro Se) Plaintiff at P.O. Box 342, Port Arthur, Texas 77640

Request Number 78.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein In that you fully legally usage of the “United States Postal System” in a “Mail and Wire Fraud” scheme of things to continual concealed, obstructed, kept secret, tuck away, hidden, scuttle for the legal behalf of the Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein all said “subject matter” contain in the described Discovery request for Interrogatories, Request of Admission, from the time frame dates of March 14th 2008 1:48 pm hour throughout October 14th 2009

In which on October 14th 2009 Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein while in legal possession, custody and control of Discovery request for Interrogatories, Request of Admission, since March 14th 2008 1:48 pm hour finally did make effort to Response/reply to the Pro Se Plaintiff by execution of certified mail, return receipt requested on (Pro Se) Plaintiff at P.O. Box 342, Port Arthur, Texas 77640 as this was legally usage of the “United States Postal System” on the exact date of October 14th 2009

Request Number 79.

Admitting Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein “you” from the time frame of March 14th 2008 1:48 pm hour while your acting attorney of record and continual making the same “representation and presentation”

Before the Honorable U.S. Judge Marcia A. Crone and Honorable U.S. Magistrate Keith F. Giblin, in 2010 (April) 30th to be exact said acting attorney of record and all defense derive thereafter in 2010 (April) 30th for the legal behalf of the Co-Defendant(s) Defendant “Joyce M. Guy and Edward McCray” collectively herein

U.S. Docket No. 1:10-CV-00055 against the Pro Se Plaintiff Louis Charles Hamilton II herein You fully legally continual in the usage of the “United States Postal System” in a “Mail and Wire Fraud” scheme of things defense against “The United States District Court For The Eastern Division of Texas Beaumont Division” to continual concealed, obstructed, kept secret, tuck away, hidden, scuttle for the legal behalf of the Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein said “property deeds” Namely “General Warranty Deed” for Lots Numbered One and Two (1&2) in Block Number One Hundred Seventy Two (172) of City of Port Arthur in Jefferson County, Texas

Namely the “property deeds” for dwelling and Property located at 448 DeQueen Blvd. in Port Arthur Texas.

Request Number 80.


herein “you” from the time frame of March 14th 2008 1:48 pm hour while your acting attorney of record and continual making the same “representation and presentation”


U.S. Docket No. 1:10-CV-00055 against the Pro Se Plaintiff Louis Charles Hamilton II herein You fully legally continual in the usage of the “United States Postal System” in a “Mail and Wire Fraud” scheme of things defense against “The United States District Court For The Eastern Division of Texas Beaumont Division” to continual concealed, obstructed, kept secret, tuck away, hidden, scuttle for the legal behalf of the Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein said “property deeds” Namely “General Warranty Deed” for Lots Numbered One and Two (1&2) in Block Number One Hundred Seventy Two (172) of City of Port Arthur in Jefferson County, Texas

Namely the “property deeds” for dwelling and Property located at 448 DeQueen Blvd. in Port Arthur Texas

In order that the Co- Defendant “Joyce M. Guy and Edward McCray” collectively herein fully comply under all the terms and conditions of any contract in regards to the new home being said

Federal Government built home “free of charge” Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein must remain in home for at least 3 years.

Request Number 81.


herein “you” from the time frame of March 14th 2008 1:48 pm hour while your

acting attorney of record and continual making the same “representation and presentation”


U.S. Docket No. 1:10-CV-00055 against the Pro Se Plaintiff Louis Charles Hamilton II herein You fully legally continual in the usage of the “United States Postal System” in a “Mail and Wire Fraud” scheme of things defense against “The United States District Court For The Eastern Division of Texas Beaumont Division” in December 3rd 2014 and all defense derive thereafter December 3rd 2014 Before the


In that you Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”,

herein are continual fully legally intent to the usage of the “United States Postal System” in a “Mail and Wire Fraud” scheme of things to continual concealed, obstructed, kept secret, tuck away, hidden, scuttle for the legal behalf of the Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein copies of said required “property deeds” for Lots Numbered One and Two (1&2) in Block Number One Hundred Seventy Two (172) of City of Port Arthur in Jefferson County, Texas

Namely the property located at 448 DeQueen Blvd. in Port Arthur Texas 77640 as described in Pro Se Plaintiff attached document # 14 “General Warranty Deed” of the Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein to furtherance’s continual concealed, obstructed, kept secret, tuck away, hidden, scuttle for the legal behalf of the Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein said “property deeds” Namely “General Warranty Deed” for Lots Numbered One and Two (1&2) in Block Number One Hundred Seventy Two (172) of City of Port Arthur in Jefferson County, Texas

Namely the “property deeds” for dwelling and Property located at 448 DeQueen Blvd. in Port Arthur Texas in order that the Co- Defendant “Joyce M. Guy and Edward McCray” collectively herein fully comply under all the terms and conditions of any contract in regards to the new home being said

Federal Government built home “free of charge” Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein must remain in home for at least 3 years.

Request Number 82.


herein “you” from the time frame of March 14th 2008 1:48 pm hour while your acting attorney of record and continual making the same “representation and presentation”


U.S. Docket No. 1:10-CV-00055 against the Pro Se Plaintiff Louis Charles Hamilton II herein You fully legally intent continual in the usage of the “United States Postal System” in a “Mail and Wire Fraud” scheme of things defense against “The United States District Court For The Eastern Division of Texas Beaumont Division” in December 3rd 2014 and all defense derive thereafter December 3rd 2014 Before the

Honorable U.S. Magistrate Judge Zack Hawthorn U.S. Docket No. 1:14-CV-00592 against the Pro Se Plaintiff Louis Charles Hamilton II herein withholding “subject matter” the old home being “physical material evidence” in said suit in common law in the

58th Judicial District Court of Jefferson County Texas docket No. A-180805 since November 26th 2007 with Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein is said old home; dwelling is fully legally forever destroyed by

SWMJ Construction Inc., 525 N. Sam Houston Pkwy East, Suite 600, Houston, Texas 77060 in connection with a Housing Grant in excess of $72,500.00 U.S Dollars




Or (Sabine Pass Restoration Program “SPRP”) Awarding Federal Agency: United States Department of Housing and Urban Development TDHCA Federal Award Number: B-06-DG-48-0002 Federal Award Year (Year of Award from HUD to TDHCA): 2006 TDHCA Award Year: 2007 For the property located at 448Dequeen Blvd. in Port Arthur Texas 77640.


that you were fully aware on or after March 14th 2008, Pro Se Plaintiff herein request Pursuant to Texas rule of civil procedure 196 Pro Se Plaintiff Discovery request for Production of Documents, Namely “Property Deeds”

You Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein fully legally intent continual in the usage of the “United States Postal System” in a “Mail and Wire Fraud” scheme of things defense against “The United States District Court For The Eastern Division of Texas, Beaumont Division” in December 3rd 2014 and all defense derive thereafter December 3rd 2014 Before the

Honorable U.S. Magistrate Judge Zack Hawthorn U.S. Docket No. 1:14-CV-00592 against the Pro Se Plaintiff Louis Charles Hamilton II herein in withholding same “subject matter” of the production of said Co-Defendant(s) Joyce M. Guy and Edward McCray herein collective “Property Deeds” ” in a continual time frame dates of now year of 2015

“Mail and Wire Fraud” scheme of things to continual concealed, obstructed, kept secret, tuck away, hidden, scuttle for the legal behalf of the Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein produced copies of said required “property deeds” for Lots Numbered One and Two (1&2) in Block Number One Hundred Seventy Two (172) of City of Port Arthur in Jefferson County, Texas

Namely the property located at 448 DeQueen Blvd. in Port Arthur Texas 77640 as described in Pro Se Plaintiff attached document # 14 “General Warranty Deed” of the Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein well beyond things to continual concealed, obstructed, kept secret, tuck away, hidden, scuttle for the legal behalf of the Co-Defendant(s)

“Joyce M. Guy and Edward McCray” collectively herein into future dates of June 30th of 2015 in this U.S. Docket No. 1:14-CV-00592 ” in a “Mail and Wire Fraud” scheme of things to continual concealed, obstructed, kept secret, tuck away, hidden, scuttle for the legal behalf of the

Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein hidden copies of said required “property deeds” for Lots Numbered One and Two (1&2) in Block Number One Hundred Seventy Two (172) of City of Port Arthur in Jefferson County, Texas

Namely the property located at 448 DeQueen Blvd. in Port Arthur Texas 77640 as described in Pro Se Plaintiff attached document # 14 “General Warranty Deed” of the Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein this continual

“Mail and Wire Fraud” scheme of things defense against “The United States District Court For The Eastern Division of Texas, Beaumont Division” in December 3rd 2014 and all defense derive thereafter December 3rd 2014 Before the Honorable U.S. Magistrate Judge Zack Hawthorn.


fully legally intent continual in the usage of the “United States Postal System” in a “Mail and Wire Fraud” scheme of things defense against “The United States District Court For The Eastern Division of Texas, Beaumont Division” in December 3rd 2014 and all defense derive thereafter December 3rd 2014 Before the

Honorable U.S. Magistrate Judge Zack Hawthorn U.S. Docket No. 1:14-CV-00592 against the Pro Se Plaintiff Louis Charles Hamilton II herein in the continual usage of Co-Defendant(s) “Joyce M. Guy” “Subscribed and Sworn”, fraudulent, fictitious Affidavit in Support of Motion for Sanctions against “You” Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein as described in Pro Se Plaintiff attached Document # 15 “Affidavit of Joyce M. Guy” dated September 11th 2009

Namely Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”,

herein “Subscribed and Sworn” legal documented “Verification” dated the 11th day of September 2009 to be statements under oath to be true and correct




Hurricanes Rita, Umberto and Ike to the property located at 448 DeQueen Blvd. in Port Arthur, Texas to be that on or about April 2nd 2008 and April 11, 2008, your falsely claiming of such “firsthand knowledge” of any of the Pro Se Plaintiff herein required discovery request to be material factual, 100% the truth against Federal Penalty of perjury in comparison to Pro Se Plaintiff attached Document # 11


Texas Rules of Civil Procedures to Cause No. A-180805 in a civil suit in the 58th Judicial District Court of Jefferson County Texas was in your Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein legal possession Custody and Control since March 14th 2008 and not the dates of April 2nd 2008 and April 11, 2008 as you’re falsely claiming with fully legally intent continual in the usage of the

“United States Postal System” in a “Mail and Wire Fraud” scheme of things defense herein in the continual usage of Co-Defendant(s) “Joyce M. Guy” “Subscribed and Sworn”, fraudulent, fictitious Affidavit in Support of Motion for Sanctions against “You” Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein as described in Pro Se Plaintiff attached Document # 15 “Affidavit of Joyce M. Guy” dated September 11th 2009

Request Number 85.


fully legally intent continual in the usage of the “United States Postal System” in a “Mail and Wire Fraud” scheme of things defense against “The United States District Court For The Eastern Division of Texas, Beaumont Division”

Before the Honorable U.S. Judge Marcia A. Crone and Honorable U.S. Magistrate Keith F. Giblin, in 2010 (April) 30th to be exact said Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, acting attorney of record and all defense derive thereafter in 2010 (April) 30 th for the legal behalf of Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, and the Co-Defendant(s) Defendant “Joyce M. Guy and Edward McCray” collectively herein

U.S. Docket No. 1:10-CV-00055 against the Pro Se Plaintiff Louis Charles Hamilton II herein in the continual usage of Co-Defendant(s) “Joyce M. Guy” “Subscribed and Sworn”, fraudulent, fictitious Affidavit in Support of Motion for Sanctions against “You” Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein as described in Pro Se Plaintiff attached Document # 15 “Affidavit of Joyce M. Guy” dated September 11th 2009

Namely Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein “Subscribed and Sworn” legal documented “Verification” dated the 11th day of September 2009 to be statements under oath to be true and correct




Hurricanes Rita, Humberto and Ike to the property located at 448 DeQueen Blvd. in Port Arthur, Texas to be that on or about April 2nd 2008 and April 11, 2008, your falsely claiming of such “firsthand knowledge” of any of the

Pro Se Plaintiff herein required discovery request to be material factual, 100% the truth against Federal Penalty of perjury in comparison to Pro Se Plaintiff attached Document # 11



“United States Postal System” in a “Mail and Wire Fraud” scheme of things defense herein in the continual usage of Co-Defendant(s) “Joyce M. Guy” “Subscribed and Sworn”, fraudulent, fictitious Affidavit in Support of Motion for Sanctions against “You” Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein as described in Pro Se Plaintiff attached Document # 15 “Affidavit of Joyce M. Guy” dated September 11th 2009.


fully legally engage in the usage of the “United States Postal System” in a “Mail and Wire Fraud” scheme of things defense against “The 58th Judicial District Court of Jefferson County Texas Before the Honorable Bob Wortham” on September 11th 2009 to be exact said Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein as acting attorney of record and all defense derive thereafter from the exact dates of December 18th 2007 throughout September 11th 2009 for the legal behalf of Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, and the Co-Defendant(s) Defendant “Joyce M. Guy and Edward McCray” collectively herein in withholding same “subject matter” of the production of said Co-Defendant(s) Joyce M. Guy and Edward McCray herein collective “Property Deeds” ” in a continual time frame dates of now in the year of 2015 March 30th to be exact a continual

“Mail and Wire Fraud” scheme of things defense against “The 58th Judicial District Court of Jefferson County Texas Before now appearing before the

Honorable W. Kent Walston, Presiding in the year of 2015 to continual concealed, obstructed, kept secret, tuck away, hidden, scuttle for the legal behalf of the Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein produced copies of said required “property deeds” for Lots Numbered One and Two (1&2) in Block Number One Hundred Seventy Two (172) of City of Port Arthur in Jefferson County, Texas

Namely the property located at 448 DeQueen Blvd. in Port Arthur Texas 77640 as described in Pro Se Plaintiff attached document # 14 “General Warranty Deed” of the Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein

Well beyond things to continual concealed, obstructed, kept secret, tuck away, hidden, scuttle for the legal behalf of the Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein into future dates of June 30 th of 2015 in this U.S. Docket No. 1:14-CV-00592 ” in the continual usage of Co-Defendant(s) “Joyce M. Guy” “Subscribed and Sworn”, fraudulent, fictitious Affidavit in Support of Motion for Sanctions against “You” Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein as described in Pro Se Plaintiff attached Document # 15 “Affidavit of Joyce M. Guy” dated September 11 th 2009





Hurricanes Rita, Humberto and Ike to the property located at 448 DeQueen Blvd. in Port Arthur, Texas to be that on or about April 2nd 2008 and

April 11, 2008, your falsely claiming of such “firsthand knowledge” of any of the Pro Se Plaintiff herein required discovery request to be material factual, 100% the truth against Federal Penalty of perjury in comparison to Pro Se Plaintiff attached Document # 11


Texas Rules of Civil Procedures to Cause No. A-180805 in a civil suit in the 58th Judicial District Court of Jefferson County Texas was in your Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein legal possession Custody and Control since March 14th 2008 1:48 pm hour and not the dates of April 2nd 2008 and April 11, 2008 as you’re falsely claiming with fully legally intent continual in the usage of the

“United States Postal System” in a “Mail and Wire Fraud” scheme of things defense herein in the continual usage of Co-Defendant(s) “Joyce M. Guy” “Subscribed and Sworn”, fraudulent, fictitious Affidavit in Support of Motion for Sanctions against “You” Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein as described in Pro Se Plaintiff attached Document # 15 “Affidavit of Joyce M. Guy” dated September 11th 2009.


fully legally engage in the usage of the “United States Postal System” in a “Mail and Wire Fraud” scheme of things defense against “The 58th Judicial District Court of Jefferson County Texas Before the Honorable Bob Wortham” on September 11th 2009 to be exact said Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein as

Acting attorney of record and all defense derive thereafter from the exact dates of December 18th 2007 throughout September 11th 2009 for the legal behalf of Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, and the Co-Defendant(s) Defendant “Joyce M. Guy and Edward McCray” collectively herein in withholding same “subject matter” of the production of said Co-Defendant(s) Joyce M. Guy and Edward McCray herein collective “Property Deeds” ” in a continual time frame dates of now in the year of 2015 March 30 th to be exact a continual

“Mail and Wire Fraud” scheme of things defense against “The 58th Judicial District Court of Jefferson County Texas Before now appearing before the Honorable W. Kent Walston, Presiding in the year of 2015 in this continual (RICO) enterprise “Mail and Wire Fraud” scheme of things defense against the Pro Se Plaintiff personal property namely Construction Company Tools Listed as follows:

a. Brand New Hitachi Air Compressor #2700009 $680.00 b. Bosch Drill M# Brute S# NV $345.00 c. “Portacable Skill saw $137.00 d. Dewalt Sawall $97 e. “Hitachi Nail Gun (Framing) $327.00 f. “Hitachi Roofing Nailer $315.00 g. Gas Power Generator $300.00 h. Extension ladder $127.00 i. 100 ft. of air hose $95. j. 50ft. of air hose $42. k. 100ft. electric cord $70 l. 50ft. electric cord $38 m. (4) Framing hammers $37. (each) n. “Pro Se Plaintiff “Personal Hammer” $48. o. “Leather tool belt” $50. p. Kobalt Razor Knife $17. q. Swanson pencil set & refills $22. r. “Black tool box & Respiratory $138.00 s. “Extreme Safety Face Shield” $30 t. Ear plugs (2) pack $16. u. (4) Normal face respirators with strap $12. v. Small assortment pliers set $35. w. (2) Tuck pointers $24. x. (1) Square mouth shovels $18. y. (1) set of blueprints $1200.00 z. Gas container 15. aa. Masonry trowel $18. bb. “Fatmax 35ft. tape measure $30. cc. Catspaw nail puller $12. dd. Speed square $8.

ee. Contractor Calculator $34. ff. Crowbar $17. gg. Utility knife (3) $9. (Each) hh. Nail Punch $8. ii. Maxx Gloves $34. jj. Canvas Tarp 95ft. X 180ft. $100.00 kk. Roofing shovels (2) $48. (Each) ll. Saw blades with drill bits $24. mm. (2) Speed square (Plastic) $5. (Each) nn. 25ft. “Fatmaxx tape measure $19.00 oo. 3-way air hose fitting set $38. pp. Case of Gatorade $12. qq. Residential framing book $21. rr. (2) Paint brushes $14. (Each) ss. (1) Paint scraper $14. tt. (1) Paint scraper wire handle $10.



Before the Honorable U.S. Judge Marcia A. Crone and Honorable U.S. Magistrate Keith F. Giblin, in 2010 (April) 30th to be exact said Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, acting attorney of record and all defense derive thereafter in 2010 (April) 30th for the legal behalf of

Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, and the Co-

Defendant(s) Defendant “Joyce M. Guy and Edward McCray” collectively herein U.S. Docket No. 1:10-CV-00055 against the Pro Se Plaintiff Louis Charles

Hamilton II herein in the continual usage of Co-Defendant(s) “Joyce M. Guy” “Subscribed and Sworn”, fraudulent, fictitious Affidavit in Support of Motion for Sanctions against “You” Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein as described in Pro Se Plaintiff attached Document # 15 “Affidavit of Joyce M. Guy” dated September 11th 2009








“United States Postal System” in a “Mail and Wire Fraud” scheme of things defense herein in the continual usage of Co-Defendant(s) “Joyce M. Guy” “Subscribed and Sworn”, fraudulent, fictitious Affidavit in Support of Motion for Sanctions against “You” Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein as described in Pro Se Plaintiff attached Document # 15 “Affidavit

of Joyce M. Guy” dated September 11th 2009 in a continual time frame dates of now in the year of 2015 March 30th to be exact in a continual

“Mail and Wire Fraud” scheme of things defense against “The United States District Court for the Eastern Division of Texas, Beaumont Division”

Before the Honorable U.S. Judge Marcia A. Crone and Honorable U.S. Magistrate Keith F. Giblin, in 2010 (April) 30th in this continual (RICO) enterprise “Mail and Wire Fraud” scheme of things defense against the Pro Se Plaintiff personal property namely Construction Company Tools Listed as follows:

uu. Brand New Hitachi Air Compressor #2700009 $680.00 vv. Bosch Drill M# Brute S# NV $345.00 ww. “Portacable Skill saw $137.00 xx. Dewalt Sawall $97 yy. “Hitachi Nail Gun (Framing) $327.00 zz. “Hitachi Roofing Nailer $315.00 aaa. Gas Power Generator $300.00 bbb. Extension ladder $127.00 ccc. 100 ft. of air hose $95. ddd. 50ft. of air hose $42. eee. 100ft. electric cord $70 fff. 50ft. electric cord $38 ggg. (4) Framing hammers $37. (each) hhh. “Pro Se Plaintiff “Personal Hammer” $48. iii. “Leather tool belt” $50. jjj. Kobalt Razor Knife $17. kkk. Swanson pencil set & refills $22. lll. “Black tool box & Respiratory $138.00 mmm. “Extreme Safety Face Shield” $30 nnn. Ear plugs (2) pack $16. ooo. (4) Normal face respirators with strap $12. ppp. Small assortment pliers set $35. qqq. (2) Tuck pointers $24. rrr. (1) Square mouth shovels $18. sss. (1) set of blueprints $1200.00 ttt. Gas container 15. uuu. Masonry trowel $18. vvv. “Fatmax 35ft. tape measure $30.

www. Catspaw nail puller $12. xxx. Speed square $8. yyy. Contractor Calculator $34. zzz. Crowbar $17. aaaa. Utility knife (3) $9. (Each) bbbb. Nail Punch $8. cccc. Maxx Gloves $34. dddd. Canvas Tarp 95ft. X 180ft. $100.00 eeee. Roofing shovels (2) $48. (Each) ffff. Saw blades with drill bits $24. gggg. (2) Speed square (Plastic) $5. (Each) hhhh. 25ft. “Fatmaxx tape measure $19.00 iiii. 3-way air hose fitting set $38. jjjj. Case of Gatorade $12. kkkk. Residential framing book $21. llll. (2) Paint brushes $14. (Each) mmmm. (1) Paint scraper $14. nnnn. (1) Paint scraper wire handle $10. Request Number 89. Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein


Before the Honorable U.S. Magistrate Judge Zack Hawthorn U.S. Docket No. 1:14-CV-00592

Fully from the time frame dates of December 3rd 2014 to be exact said Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, acting attorney of record and all defense derive thereafter in the future year of 2015 for the legal behalf of Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, and the Co-Defendant(s) Defendant “Joyce M. Guy and Edward McCray” collectively herein against the Pro Se Plaintiff Louis Charles Hamilton II herein in the continual “Mail and Wire Fraud” scheme of things defense usage of Co-Defendant(s) “Joyce M. Guy” “Subscribed and Sworn”, fraudulent, fictitious Affidavit in Support of Motion for Sanctions against “You” Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein as described in Pro Se

Plaintiff attached Document # 15 “Affidavit of Joyce M. Guy” dated September 11th 2009



Namely the official date your falsely claiming of such “firsthand knowledge” of any of the Pro Se Plaintiff herein required discovery request for copies of deeds, property deeds or any other such physical document in Co-Defendants’ possession, custody or control that shows actual ownership of the property of the dwelling located at 448 DeQueen Blvd., Port Arthur, Texas

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

counsel of record namely Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein shall produce copies of any and all construction estimates for repairs in Defendants’ possession, custody or control in relationship to the damage caused by




“United States Postal System” in a “Mail and Wire Fraud” scheme of things defense herein in the continual usage of Co-Defendant(s) “Joyce M. Guy” “Subscribed and Sworn”, fraudulent, fictitious Affidavit in Support of Motion for Sanctions against “You” Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein as described in Pro Se Plaintiff attached Document # 15 “Affidavit of Joyce M. Guy” dated September 11th 2009 in a continual time frame dates of now in the year of 2015 March 30th to be exact in a continual



oooo. Brand New Hitachi Air Compressor #2700009 $680.00 pppp. Bosch Drill M# Brute S# NV $345.00 qqqq. “Portacable Skill saw $137.00 rrrr. Dewalt Sawall $97 ssss. “Hitachi Nail Gun (Framing) $327.00 tttt. “Hitachi Roofing Nailer $315.00 uuuu. Gas Power Generator $300.00 vvvv. Extension ladder $127.00 wwww. 100 ft. of air hose $95. xxxx. 50ft. of air hose $42. yyyy. 100ft. electric cord $70 zzzz. 50ft. electric cord $38 aaaaa. (4) Framing hammers $37. (each) bbbbb. “Pro Se Plaintiff “Personal Hammer” $48. ccccc. “Leather tool belt” $50. ddddd. Kobalt Razor Knife $17. eeeee. Swanson pencil set & refills $22. fffff. “Black tool box & Respiratory $138.00 ggggg. “Extreme Safety Face Shield” $30 hhhhh. Ear plugs (2) pack $16. iiiii. (4) Normal face respirators with strap $12. jjjjj. Small assortment pliers set $35. kkkkk. (2) Tuck pointers $24.

lllll. (1) Square mouth shovels $18. mmmmm. (1) set of blueprints $1200.00 nnnnn. Gas container 15. ooooo. Masonry trowel $18. ppppp. “Fatmax 35ft. tape measure $30. qqqqq. Catspaw nail puller $12. rrrrr. Speed square $8. sssss. Contractor Calculator $34. ttttt. Crowbar $17. uuuuu. Utility knife (3) $9. (Each) vvvvv. Nail Punch $8. wwwww. Maxx Gloves $34. xxxxx.Canvas Tarp 95ft. X 180ft. $100.00 yyyyy. Roofing shovels (2) $48. (Each) zzzzz. Saw blades with drill bits $24. aaaaaa. (2) Speed square (Plastic) $5. (Each) bbbbbb. 25ft. “Fatmaxx tape measure $19.00 cccccc. 3-way air hose fitting set $38. dddddd. Case of Gatorade $12. eeeeee. Residential framing book $21. ffffff. (2) Paint brushes $14. (Each) gggggg. (1) Paint scraper $14. hhhhhh. (1) Paint scraper wire handle $10. Request Number 90. Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein


Before the Honorable U.S. Magistrate Judge Zack Hawthorn U.S. Docket No. 1:14-CV-00592 fully from the time frame dates of December 3rd 2014 to be exact said Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, acting attorney of record

And all defense derive thereafter in the future year of 2015 for the legal behalf of Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein continual “Mail and Wire Fraud” scheme of things defense against Pro Se

Plaintiff to deprive “him” in Actual Damages in the conspire $10,800.00 U.S. Dollars Breach of Construction Contract and profits derive thereof, for Chief Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 (RICO) enterprise scheme of things continue causing such loss of wages and loss of profit earning well into 2015 with 6% interest incurred in connection, conspiracy, plotting, collaboration, scheming, conspire, collusion, with

Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein and the property located at Lots Numbered One and Two (1&2) in Block Number One Hundred Seventy Two (172) of City of Port Arthur in Jefferson County, Texas

Namely the property located at 448 DeQueen Blvd. in Port Arthur Texas 77640 as described in Pro Se Plaintiff attached document # 14 “General Warranty Deed” of the Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively to include but not limited to

Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein fully legally intent continual in the usage of the “United States Postal System” in a continual “Mail and Wire Fraud” scheme of things defense against “The United States District Court For The Eastern Division of Texas, Beaumont Division”

Before the Honorable U.S. Magistrate Judge Zack Hawthorn U.S. Docket No. 1:14-CV-00592 herein to continual deprive the Pro Se Plaintiff “Louis Charles Hamilton II” in Actual damages in the Conspire Construction 2007 Contract for the property located at 5050 east 7th street in Port Arthur Texas 77640 , for

Chief Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 (RICO) enterprise scheme of things continue causing such loss of wages and loss of profit earning well into 2015 with 6% interest incurred.

Chief Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No.

24058299 Directly provided (RICO) enterprise skilled attorney at law racket,

scheme, plot, conspire, concert, leadership and obstruction of Justice thereof

among other devise, instruments, trick,

Skilled shams to deprive the Pro Se Plaintiff herein thereof all “Actual

Damages” respectfully with 6% interest incurred since date of Pro Se Plaintiff

direct date of Injury November 17th 2007

To include Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”,

herein continual engaging in a “Mail and Wire Fraud” scheme of things defense

to deprive Pro Se Plaintiff in “Actual damages” of namely $336,000.00 U.S.

Dollars in “loss wages” and “Loss Earning capacity” from date of injury

December 17th 2007 – 2014 to include figure this computation well into 2015

this (RICO) enterprise scheme of things continue causing such loss of wages and

loss of earning capacity at a loss rate of $48,000.00 per year with 6% interest

incurred

And further deprive Pro Se Plaintiff herein in “actual damages” in excess

of $3800.00 U.S. dollars for Chief Defendant Antoine L. Freeman J. D. Attorney

at Law Texas Bar No. 24058299 herein conspire (RICO) enterprise in a continual

“Mail and Wire Fraud” scheme of things defense in full conspiracy, plotting,

collaboration, scheming, conspire, collusion, with Co-Defendant(s) “Joyce M.

Guy and Edward McCray” and the actual theft of Pro Se Plaintiff personal

property namely construction company tools, with 6% interest incurred.


fully legally intent continual in the usage of the “United States Postal System” in a “Mail and Wire Fraud” scheme of things defense against “The United States District Court For The Eastern Division of Texas, Beaumont Division” Before the Honorable U.S. Judge Marcia A. Crone and Honorable U.S. Magistrate Keith F. Giblin, in 2010 (April) 30th to be exact said Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, acting attorney of record

And all defense derive thereafter in the future year of 2015 for the legal behalf of Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein and Co-Defendant(s) “Joyce M. Guy” and Edward McCray” in a continual “Mail and Wire Fraud” scheme of things defense against Pro Se Plaintiff to deprive “him” in Actual Damages in the conspire $10,800.00 U.S. Dollars Breach of Construction Contract and profits derive thereof, for

Chief Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 (RICO) enterprise scheme of things continue causing such loss of wages and loss of profit earning well into 2015 with 6% interest incurred in connection, conspiracy, plotting, collaboration, scheming, conspire, collusion, with Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein and the property located at Lots Numbered One and Two (1&2) in Block Number One Hundred Seventy Two (172) of City of Port Arthur in Jefferson County, Texas

Namely the property located at 448 DeQueen Blvd. in Port Arthur Texas 77640 as described in Pro Se Plaintiff attached document # 14 “General

Warranty Deed” of the Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively to include but not limited to

Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein fully legally intent continual in the usage of the “United States Postal System” in a “Mail and Wire Fraud” scheme of things defense against “The United States District Court For The Eastern Division of Texas, Beaumont Division”

Before the Honorable U.S. Judge Marcia A. Crone and Honorable U.S. Magistrate Keith F. Giblin, in 2010 (April) 30th to be exact in U.S. Docket No. 1:10-CV-00055 herein to continual deprive the Pro Se Plaintiff “Louis Charles Hamilton II” in

Actual damages in the Conspire Construction 2007 Contract for the

property located at 5050 east 7th street in Port Arthur Texas 77640 , for Chief

Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299

(RICO) enterprise scheme of things continue causing such loss of wages and loss

of profit earning well into 2015 with 6% interest incurred.





Skilled shams to deprive the Pro Se Plaintiff herein thereof All “Actual





to deprive Pro Se Plaintiff in Actual damages of namely

$336,000.00 U.S. Dollars in “loss wages” and Loss Earning capacity from

date of injury December 17th 2007 – 2014 to include figure this computation

well into 2015 this (RICO) enterprise scheme of things continue causing such loss

of wages and loss of earning capacity at a loss rate of $48,000.00 per year with

6% interest incurred



at Law Texas Bar No. 24058299 herein conspire in a continual “Mail and Wire

Fraud” scheme of things defense (RICO) enterprise conspiracy, plotting,

collaboration, scheming, conspire, collusion, with Co-Defendant(s) “Joyce M.

Guy and Edward McCray” and the actual theft of Pro Se Plaintiff personal

property namely construction company tools, with 6% interest incurred.



Before the Honorable U.S. Magistrate Judge Zack Hawthorn U.S. Docket No. 1:14-CV-00592 fully from the time frame dates of December 3rd 2014 to be exact said Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, acting attorney of record for his own legal behalf

And all defense derive thereafter in the future year of 2015 for the legal behalf of Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein continual “Mail and Wire Fraud” scheme of things defense against Pro Se Plaintiff to deprive “him” in Actual Damages in the conspire $10,800.00 U.S. Dollars Breach of Construction Contract and profits derive thereof, for

Chief Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 (RICO) enterprise scheme of things continue causing such loss of wages and loss of profit earning well into 2015 with 6% interest incurred in connection, conspiracy, plotting, collaboration, scheming, conspire, collusion, with



Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein fully legally intent continual in the usage of the “United States Postal System” in a

“Mail and Wire Fraud” scheme of things defense against “The United States District Court For The Eastern Division of Texas, Beaumont Division”

Before the Honorable U.S. Magistrate Judge Zack Hawthorn U.S. Docket No. 1:14-CV-00592 herein to continual deprive the Pro Se Plaintiff “Louis Charles Hamilton II” in

Actual damages in the Conspire Construction 2007 Contract for the

property located at 5050 east 7th street in Port Arthur Texas 77640 , for Chief

Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299

(RICO) enterprise scheme of things continue causing such loss of wages and loss

of profit earning well into 2015 with 6% interest incurred.





Skilled shams to deprive the Pro Se Plaintiff herein thereof All “Actual





to continual deprive Pro Se Plaintiff in Actual damages of namely

$336,000.00 U.S. Dollars in “loss wages” and Loss Earning capacity from

date of injury December 17th 2007 – 2014 to include figure this computation

well into 2015 this (RICO) enterprise scheme of things continue causing such loss

of wages and loss of earning capacity at a loss rate of $48,000.00 per year with

6% interest incurred

And further continual deprive Pro Se Plaintiff herein in “actual damages”

in excess of $3800.00 U.S. dollars for Chief Defendant Antoine L. Freeman J. D.

Attorney at Law Texas Bar No. 24058299 herein conspire (RICO) enterprise

conspiracy, plotting, collaboration, scheming, conspire, collusion, with Co-

Defendant(s) “Joyce M. Guy and Edward McCray” and the “actual theft” of Pro

Se Plaintiff personal property namely construction company tools, with 6%

interest incurred.


fully legally engaged in the usage of the “United States Postal System” in a “Mail and Wire Fraud” scheme of things defense against

“The 58th Judicial District Court of Jefferson County Texas Before the Honorable Bob Wortham” on December 18th 2007 throughout the year 2015 to be exact said Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein as

Acting attorney of record and all defenses derive thereafter from the exact dates of December 18th 2007 throughout November 13th 2009 10:22 am hour for the legal behalf of the Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein in withholding same “subject matter” in a continual

“Mail and Wire Fraud” scheme of things defense against “The 58th Judicial District Court of Jefferson County Texas Before now appearing before the

Honorable W. Kent Walston, Presiding in the year of 2015 for “The 58th

Judicial District Court of Jefferson County Texas in this continual (RICO) enterprise “Mail and Wire Fraud” scheme of things defense fully ongoing from the time frame dates of December 18rd 2007 to be exact said Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, acting attorney of record

And all defense derive thereafter in the future year of 2015 for the legal behalf of Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein continual “Mail and Wire Fraud” scheme of things defense against Pro Se Plaintiff to deprive “him” in actual

Damages in the conspire $10,800.00 U.S. Dollars Breach of Construction Contract and profits derive thereof, for Chief Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 (RICO) enterprise scheme of things continue causing such loss of wages and loss of profit earning well into 2015 with 6% interest incurred in connection, conspiracy, plotting, collaboration, scheming, conspire, collusion, with



Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein fully legally engaged in the usage of the “United States Postal System” in a “Mail and Wire Fraud” scheme of things defense herein to continual deprive the Pro Se Plaintiff “Louis Charles Hamilton II” in Actual damages in the Conspire Construction 2007 Contract for the property located at 5050 east 7th street in Port Arthur Texas 77640, for

Chief Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 (RICO) enterprise scheme of things continue causing such loss of wages and loss of profit earning well into 2015 with 6% interest incurred.





Skilled shams to deprive the Pro Se Plaintiff herein thereof all “Actual





to deprive Pro Se Plaintiff in actual damages of namely $336,000.00 U.S. Dollars

in “loss wages” and “Loss Earning capacity” from date of injury December 17th

2007 – 2014 to include figure this computation well into 2015 this (RICO)

enterprise scheme of things continue causing such loss of wages and loss of

earning capacity at a loss rate of $48,000.00 per year with 6% interest incurred



at Law Texas Bar No. 24058299 herein conspire (RICO) enterprise conspiracy,

plotting, collaboration, scheming, conspire, collusion, with Co-Defendant(s)

“Joyce M. Guy and Edward McCray” and the actual theft of Pro Se Plaintiff

personal property namely construction company tools, with 6% interest

incurred.


Pro Se Plaintiff attached Document # 15 herein is that legally being “Affidavit” of Co-Defendant “Joyce M. Guy” herein this U.S. Docket No. 1:14-CV-00592


Pro Se Plaintiff attached Document # 15 herein is that legally being “Affidavit” of Co-Defendant “Joyce M. Guy” herein was “Subscribed and Sworn on the 11th Day of September 2009 before a Notary Public.


Pro Se Plaintiff attached Document # 15 herein is that legally being “Affidavit” of Co-Defendant “Joyce M. Guy” herein Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein fully legally engaged in the usage of the

“United States Postal System” a true and correct copy of Pro Se Plaintiff attached Document # 15 herein is that legally being “Affidavit” of Co-Defendant “Joyce M. Guy” was served by certified mail, return receipt requested on Louis Charles Hamilton II at P.O. Box 342, Port Arthur, Texas 77640 on the 11 th Day of September 2009.


Pro Se Plaintiff attached Document # 15 herein is that legally being “Affidavit” of Co-Defendant “Joyce M. Guy” herein states: Mr. Freeman informed me between April 2nd 2008 and April 11th 2008 about Mr. Hamilton discovery request.

It was my decision and not Mr. Freeman’s decision not to respond to the discovery request of Mr. Hamilton. “Further affiant sayeth not.”


Pro Se Plaintiff attached Document # 15 herein states between April 2nd 2008 and April 11th 2008 “you” Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein fully aware and in agreement with Co-Defendant “Joyce M. Guy” herein from the time frame of April 2nd 2008 and April 11th 2008 throughout October 13th 2009 not to respond to the discovery request of Pro Se Plaintiff “Louis Charles Hamilton II”, herein “you” Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein having such “firsthand “ knowledge, acceptances, possession, custody and control of said discovery request on

March 14th 2008 1:48 pm hour while your acting attorney of record in civil suit in common law Docket No. A-180805 58th Judicial District Court of Jefferson County Texas and Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein continual making the same “representation and presentation”

Before the Honorable U.S. Judge Marcia A. Crone and Honorable U.S. Magistrate Keith F. Giblin, in 2010 (April) 30th to be exact said acting “attorney of record” and all defense derive thereafter in 2010 (April) 30 th for the legal behalf of the Co-Defendant(s) Defendant “Joyce M. Guy and Edward McCray” collectively herein U.S. Docket No. 1:10-CV-00055.


Pro Se Plaintiff attached Document # 15 herein states between April 2nd 2008 and April 11th 2008 “you” Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein fully aware and in agreement with Co-Defendant “Joyce M. Guy” herein from the time frame of April 2nd 2008 and April 11th 2008 throughout October 13th 2009 not to respond to the discovery request of Pro Se Plaintiff “Louis Charles Hamilton II”, herein “you”

Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein refused to inform the Honorable Bob Wortham, of the 58th Judicial District Court of Jefferson County Texas in Civil Suit in Common Law Docket No. A-180805

“Further affiant” “Joyce M. Guy” your retain client at some point in time

and namely Co-Defendant “Joyce M. Guy” herein clearly will not be responding from the time frame of April 2nd 2008 and April 11th 2008 throughout October

13th 2009 to any and all of the required discovery request of Pro Se Plaintiff “Louis Charles Hamilton II”, herein.


Pro Se Plaintiff attached Document # 15 herein states between April 2nd 2008 and April 11th 2008 “you” Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein fully aware and in agreement with Co-Defendant “Joyce M. Guy” herein from the time frame of April 2nd 2008 and April 11th 2008 throughout October 13th 2009 not to respond to the discovery request of Pro Se Plaintiff “Louis Charles Hamilton II”, herein “you”

Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein refused to inform the Pro Se Plaintiff “Louis Charles Hamilton II herein in Civil Suit in Common Law Docket No. A-180805

“Further affiant” “Joyce M. Guy” your retain client at some point in time

and namely Co-Defendant “Joyce M. Guy” herein clearly will not be responding from the time frame of April 2nd 2008 and April 11th 2008 throughout October 13th 2009 to any and all of the required discovery request of Pro Se Plaintiff “Louis Charles Hamilton II”, herein.

And you Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein made such Knowledge being legally know in fully legally engaged in the usage of the “United States Postal System” on the 11 th day of September 2009 to the Pro Se Plaintiff, and the Honorable Bob Wortham, of the 58 th Judicial District Court of Jefferson County Texas in Civil Suit in Common Law Docket No. A-180805 “Further affiant” “Joyce M. Guy” your retain client at some point in time and namely Co-Defendant “Joyce M. Guy” herein clearly will not be responding from the time frame of April 2nd 2008 and April 11th 2008 throughout October 13th 2009.

Request Number 102.


after “Your” claim Knowledge “Further affiant” “Joyce M. Guy” your retain client at some point in time and namely Co-Defendant “Joyce M. Guy” herein clearly will not be responding from the time frame of April 2nd 2008 and April

11th 2008 throughout October 13th 2009 to Pro Se Plaintiff (Many) discovery requests to include the production of property deeds for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas before the 58 th Judicial District Court of Jefferson County Texas in Civil Suit in Common Law Docket No. A-180805 “You”

Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein did not between the exact time frame of April 2nd 2008 and April 11th 2008 throughout April 2nd 2009 and April 11th 2009 being one exact year file an immediate Motion for with Drawl as Acting attorney of record for the behalf of the Co-Defendant(s) “Joyce M. Guy and Edward McCray”

Request Number 102.


after “Your” claim Knowledge “Further affiant” “Joyce M. Guy” your retain client at some point in time and namely Co-Defendant “Joyce M. Guy” herein clearly will not be responding from the time frame of April 2nd 2008 and April 11th 2008 throughout October 13th 2009 to Pro Se Plaintiff (Many) discovery requests to include the production of property deeds for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas before the 58 th Judicial District Court of Jefferson County Texas in Civil Suit in Common Law Docket No. A-180805

“You” Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein did not between the exact time frame of April 2nd 2008 and April 11th 2008 throughout November 12th 2009 file an immediate Motion for with Drawl as Acting attorney of record for the behalf of the Co-Defendant(s) “Joyce M. Guy and Edward McCray” after “Further affiant” “Joyce M. Guy” your retain client at some point in time and namely Co-Defendant “Joyce M. Guy” herein clearly will not be responding from the time frame of April 2nd 2008 and April 11th 2008.

Request Number 103.


after “Your” claim Knowledge “Further affiant” “Joyce M. Guy” your retain client at some point in time and namely Co-Defendant “Joyce M. Guy” herein clearly will not be responding from the time frame of April 2nd 2008 and April 11th 2008 throughout October 13th 2009 to Pro Se Plaintiff (Many) discovery requests to include the “production of property deeds” herein while “you” Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein having such

“firsthand “ knowledge, acceptances, possession, custody and control of said discovery request on

March 14th 2008 1:48 pm hour while your acting attorney of record in civil suit in common law Docket No. A-180805 58th Judicial District Court of Jefferson County Texas for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas before the 58th Judicial District Court of Jefferson County Texas in Civil Suit in Common Law Docket No. A-180805 while “You” Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein did not between the exact time frame of April 2nd 2008 and April 11th 2008 throughout November 12th 2009 files an immediate Motion for with Drawl as acting attorney of record for the behalf of the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein

Said Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively on June 9th 2009 as showing document #1 attached herein having already engaged in the transfer of said Lots Numbered One and Two (1&2) in Block Number One Hundred Seventy Two (172) of City of Port Arthur in Jefferson County, Texas


58th Judicial District Court of Jefferson County Texas docket No. A-180805 since November 26th 2007 with Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein connection namely





For the property located at 448Dequeen Blvd. in Port Arthur Texas 77640 which you was acting counsel for Co-Defendant(s) Joyce M. Guy and Edward McCray in a civil suit in the 58th Judicial District Court of Jefferson

County Texas docket No. A-180805 involving a breach of a $10,800 U.S. Dollars construction contract with the described Pro Se Plaintiff herein and “You” Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein did not between the exact time frame of April 2nd 2008 and April 11th 2008 throughout November 12th 2009 file an immediate

Motion for with Drawl as Acting attorney of record in before the 58 th Judicial District Court of Jefferson County Texas in Civil Suit in Common Law Docket No. A-180805 for the behalf of the Co-Defendant(s) “Joyce M. Guy and Edward McCray” after “Further affiant” “Joyce M. Guy” your retain client at some point in time and namely Co-Defendant “Joyce M. Guy” herein clearly will not be ever responding in any “fashion or form” from the time frame of April 2nd 2008 and April 11th 2008 throughout November 12th 2009

Request Number 104.


“All Subcontractors and material suppliers must serve the “property owner and

the General Contractor with a Pre0Lien Notice by no later than the 15 th day of

the second month from each and every month that you namely

“Subcontractors” provide labor and /or materials to the property and have not

been paid.

Request Number 105.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein “All Subcontractors” must serve the notice contractual retainage, if your contract with the Contractor who hire you allows them to withhold a percentage of monthly progress payments as contractual retainage

(Typically 5% to 10 % of the overall Contract amount, then you “All Subcontractors” must serve the property owner and the General Contractor with the notice of contractual retainage by the earlier of: (1) 30 days from completion of your work; or (2) with 30 days from completion of the entire project, whichever comes first.

Request Number 106.


this is a Mandatory Pre Lien Notice which must be served before you “All Subcontractors” can file a Lien for withheld unpaid retainage.

Request Number 107.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein “Further affiant” “Joyce M. Guy” your retain client at some point in time and namely Co-Defendant “Joyce M. Guy” herein clearly enter into a contract with Pro Se “Louis Charles Hamilton II” herein for a amount of $10,800.00 collectively with Co-Defendant “Edward McCray” Lots Numbered One and Two (1&2) in Block Number One Hundred Seventy Two (172) of City of Port Arthur in Jefferson County, Texas

Namely the property located at 448 DeQueen Blvd. in Port Arthur Texas 77640 which said dwelling, property located at 448 DeQueen Blvd. in Port Arthur Texas 77640 and you having view said contract since December 18 th 2007 throughout March 30th 2015 as also being attached herein as Pro Se Plaintiff document # 16 “Construction Contract” dated November 5th 2007

Request Number 108.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein Pro Se Plaintiff “Louis Charles Hamilton II” herein was not a Subcontractors as described in paragraph 104, 105, and 106 above.

Request Number 109.


Pro Se “Louis Charles Hamilton II” herein was the “General Contractor” “Further affiant” “Joyce M. Guy” your retain client at some point in time and namely Co-Defendant “Joyce M. Guy” herein clearly enter into a contract with Pro Se for a amount of $10,800.00 collectively with Co-Defendant “Edward McCray” Lots

Numbered One and Two (1&2) in Block Number One Hundred Seventy Two (172) of City of Port Arthur in Jefferson County, Texas

Namely the property located at 448 DeQueen Blvd. in Port Arthur Texas 77640 which said dwelling, property located at 448 DeQueen Blvd. in Port Arthur Texas 77640 and you having view said contract since December 18 th 2007 throughout March 30th 2015 as also being attached herein as Pro Se Plaintiff document # 16 “Construction Contract” dated November 5th 2007 with “Further affiant” “Joyce M. Guy” your retain client at some point in time and namely Co-Defendant “Joyce M. Guy” herein signature on said contract.


Pro Se “Louis Charles Hamilton II” herein was the “General Contractor” and arrange building material from suppliers to namely Co-Defendant “Joyce M. Guy” and “Edward McCray” herein Lots Numbered One and Two (1&2) in Block Number One Hundred Seventy Two (172) of City of Port Arthur in Jefferson County, Texas

Namely the property located at 448 DeQueen Blvd. in Port Arthur Texas 77640 which said dwelling, property located at 448 DeQueen Blvd. in Port Arthur Texas 77640.

Request Number 111.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein Parker Lumber-Port Arthur Texas 2948 Gulfway Drive 77642 (409) 983-2745 was the “material suppliers” in connection with Pro Se “Louis Charles Hamilton II” herein the “General Contractor” whom arrange building material from said suppliers on the behalf of namely Co-Defendant “Joyce M. Guy” and “Edward McCray” herein for Lots Numbered One and Two (1&2) in Block Number One Hundred Seventy Two (172) of City of Port Arthur in Jefferson County, Texas

Namely the property located at 448 DeQueen Blvd. in Port Arthur Texas 77640 which said dwelling, property located at 448 DeQueen Blvd. in Port Arthur Texas 77640

After your expert legal Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein viewing of Pro Se Plaintiff attached Document # 17

“Namely” Parker Lumber “Estimates and Invoice for $2869.08 from said “material suppliers” dated on the 22nd day of October 2007

Request Number 112.


all monetary funding as being, depicted, described and set forth in paragraphs 104 throughout 111 herein for Lots Numbered One and Two (1&2) in Block Number One Hundred Seventy Two (172) of City of Port Arthur in Jefferson County, Texas

Namely the property located at 448 DeQueen Blvd. in Port Arthur Texas 77640 which said dwelling, property located at 448 DeQueen Blvd. in Port Arthur Texas 77640 was paid out from private homeowner insurance company in connection with “Hurricane Humberto” causing damages to the dwelling of Co-Defendant “Joyce M. Guy” and “Edward McCray” herein for Lots Numbered One and Two (1&2) in Block Number One Hundred Seventy Two (172) of City of Port Arthur in Jefferson County, Texas

Namely the property located at 448 DeQueen Blvd. in Port Arthur Texas 77640 which said dwelling, property located at 448 DeQueen Blvd. in Port Arthur Texas 77640

Request Number 113.


under the terms and condition of said construction contract of Co-Defendant “Joyce M. Guy” agreed to put an advance of $3616 down on all materials as Pro Se Plaintiff document # 16 “Construction Contract” dated November 5 th 2007 fully describing such.

Request Number 114.


Co-Defendant “Joyce M. Guy” only put down $2869.08 on all materials as Pro Se Plaintiff document # 17 “Namely” Parker Lumber “Estimates and Invoice for $2869.08 from said “material suppliers” dated on the 22nd day of October 2007.


“Further affiant” “Joyce M. Guy” became your retain client at some point in time and namely Co-Defendant “Joyce M. Guy” herein clearly enter into a contract with Pro Se “Louis Charles Hamilton II” herein for a amount of $10,800.00 collectively with Co-Defendant “Edward McCray” Lots Numbered One and Two (1&2) in Block Number One Hundred Seventy Two (172) of City of Port Arthur in Jefferson County, Texas

Namely the property located at 448 DeQueen Blvd. in Port Arthur Texas 77640 which said dwelling, property located at 448 DeQueen Blvd. in Port Arthur Texas 77640 and you having view said contract since December 18 th 2007 throughout March 30th 2015

As also being attached herein as Pro Se Plaintiff document # 16 “Construction Contract” dated November 5th 2007 and Pro Se Plaintiff alleges a Breach of said contract in the 58th Judicial District Court of Jefferson County Texas, you Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein became attorney of record from the time frame of December 18th 2007 when you file a

“General Denial” (only) as claimed by you, further you, conspire, hidden, scuttled, obstructed, conceal, keep secrete, tuck away, between the dates of March 14th 2008 1:48 pm hour throughout March 30th 2015 among other discovery document primary “hidden, scuttled, obstructed, conceal, keep secrete, tuck away” namely the “property deeds” ” Lots Numbered One and Two (1&2) in Block Number One Hundred Seventy Two (172) of City of Port Arthur in Jefferson County, Texas

Namely the property located at 448 DeQueen Blvd. in Port Arthur Texas 77640 which said dwelling, property located at 448 DeQueen Blvd. in Port Arthur Texas 77640 which is a party to this civil suit in common law in the 58 th Judicial District Court of Jefferson County Texas Docket No. A-180805 while from the time frame of March 14th 2008 1:48 pm hour throughout December 11th 2009 when finally the

58th Judicial District Court of Jefferson County Texas Judge Bob Wortham granted Your Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein “Motion for with Drawl of Counsel on December 11th 2009 as described in Pro Se Plaintiff attached document # 2 herein 58th Judicial District Court of Jefferson County Texas “Docket” A-180805 “You”

Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein admit “you”, used the “United States Postal System” “Mail and Wire Fraud” scheme of things to concealed, obstructed, kept secret, tuck away, hidden, scuttle for the legal behalf of the Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein all said “subject matter” contain in the described Discovery request for , Production of Documents, Interrogatories, Request of Admission, and Request for Disclosure in accordance with the Texas Rules of Civil Procedures 194.2, 196, 197, and 198,.

After “Your” claim Knowledge “Further affiant” “Joyce M. Guy” your retain client at some point in time and namely Co-Defendant “Joyce M. Guy” herein clearly will not be responding from the time frame of April 2nd 2008 and April 11th 2008 throughout October 13th 2009 to Pro Se Plaintiff (Many) discovery requests to include the production of property deeds for the dwelling located at

448 DeQueen Blvd. in Port Arthur Texas before the 58th Judicial District Court of Jefferson County Texas in Civil Suit in Common Law Docket No. A-180805 while during this “Further affiant” “Joyce M. Guy” your retain client at some point in time and namely Co-Defendant “Joyce M. Guy” herein clearly will not be responding from the time frame of April 2nd 2008 and April 11th 2008 throughout October 13th 2009 namely





For the property located at 448Dequeen Blvd. in Port Arthur Texas 77640 which you was acting counsel for Co-Defendant(s) Joyce M. Guy and Edward McCray in a civil suit in the 58th Judicial District Court of Jefferson

County Texas docket No. A-180805 involving a breach of a $10,800 U.S. Dollars construction contract with the described Pro Se Plaintiff herein and

“You” Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein did not between the exact time frame of April 2nd 2008 and April 11th 2008 throughout November 12th 2009 file an immediate

Motion for with Drawl as Acting attorney of record in before the 58th Judicial District Court of Jefferson County Texas in Civil Suit in Common Law Docket No. A-180805 for the behalf of the Co-Defendant(s) “Joyce M. Guy and Edward McCray” as you’re Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein falsely claiming with fully legally intent continual in the usage of the

“United States Postal System” in a “Mail and Wire Fraud” scheme of things defense herein in the continual usage of Co-Defendant(s) “Joyce M. Guy” “Subscribed and Sworn”, fraudulent, fictitious Affidavit in Support of Motion for Sanctions against “You” Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein as described in Pro Se Plaintiff attached Document # 15 “Affidavit of Joyce M. Guy” dated September 11th 2009 in a continual time frame dates of now in the year of 2015 March 30th to be exact in a continual



iiiiii. Brand New Hitachi Air Compressor #2700009 $680.00 jjjjjj. Bosch Drill M# Brute S# NV $345.00 kkkkkk. “Portacable Skill saw $137.00 llllll. Dewalt Sawall $97 mmmmmm. “Hitachi Nail Gun (Framing) $327.00 nnnnnn. “Hitachi Roofing Nailer $315.00 oooooo. Gas Power Generator $300.00 pppppp. Extension ladder $127.00 qqqqqq. 100 ft. of air hose $95. rrrrrr. 50ft. of air hose $42. ssssss. 100ft. electric cord $70 tttttt. 50ft. electric cord $38

uuuuuu. (4) Framing hammers $37. (each) vvvvvv. “Pro Se Plaintiff “Personal Hammer” $48. wwwwww. “Leather tool belt” $50. xxxxxx. Kobalt Razor Knife $17. yyyyyy. Swanson pencil set & refills $22. zzzzzz. “Black tool box & Respiratory $138.00 aaaaaaa. “Extreme Safety Face Shield” $30 bbbbbbb. Ear plugs (2) pack $16. ccccccc. (4) Normal face respirators with strap $12. ddddddd. Small assortment pliers set $35. eeeeeee. (2) Tuck pointers $24. fffffff. (1) Square mouth shovels $18. ggggggg. (1) set of blueprints $1200.00 hhhhhhh. Gas container 15. iiiiiii. Masonry trowel $18. jjjjjjj. “Fatmax 35ft. tape measure $30. kkkkkkk. Catspaw nail puller $12. lllllll. Speed square $8. mmmmmmm. Contractor Calculator $34. nnnnnnn. Crowbar $17. ooooooo. Utility knife (3) $9. (Each) ppppppp. Nail Punch $8. qqqqqqq. Maxx Gloves $34. rrrrrrr. Canvas Tarp 95ft. X 180ft. $100.00 sssssss. Roofing shovels (2) $48. (Each) ttttttt. Saw blades with drill bits $24. uuuuuuu. (2) Speed square (Plastic) $5. (Each) vvvvvvv. 25ft. “Fatmaxx tape measure $19.00 wwwwwww. 3-way air hose fitting set $38. xxxxxxx. Case of Gatorade $12. yyyyyyy. Residential framing book $21. zzzzzzz. (2) Paint brushes $14. (Each) aaaaaaaa. (1) Paint scraper $14. bbbbbbbb. (1) Paint scraper wire handle $10.

To include Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein continual engaging in a “Mail and Wire Fraud” scheme of things defense

to deprive Pro Se Plaintiff in “Actual damages” of namely $336,000.00 U.S. Dollars in “loss wages” and “Loss Earning capacity” from date of injury December 17th 2007 – 2014 to include figure this computation well into 2015 this (RICO) enterprise scheme of things continue causing such loss of wages and loss of earning capacity at a loss rate of $48,000.00 per year with 6% interest incurred

And further deprive Pro Se Plaintiff herein in “actual damages” in excess of $3800.00 U.S. dollars for Chief Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 herein conspire (RICO) enterprise in a continual “Mail and Wire Fraud” scheme of things defense in full conspiracy, plotting, collaboration, scheming, conspire, collusion, with Co-Defendant(s) “Joyce M. Guy and Edward McCray” and the actual theft of Pro Se Plaintiff personal property namely construction company tools, with 6% interest incurred

To include but not limited to Chief Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 herein 100% foolishly admitting furtherance’s (Ready) to continual making the same 3 strikes (RICO) “representation and presentation” in a continual 2015 “Mail and Wire Fraud” scheme of things defense in full conspiracy, plotting, collaboration, scheming, conspire, collusion, with Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein collectively all (3) Defendants standing proudly now Before the

United States Magistrate Honorable Judge Zack Hawthorn notwithstanding the outrageous fictitious, fraudulent response to Pro Se Plaintiff “Interrogatories” as described in document # 9 attached herein Chief Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 fully “admitting and saying” he namely Antoine L. Freeman J. D. Attorney at Law was never even acting “Attorney of record” from December 18 th 2007 throughout December 11th 2009 only filed a simple “General Denial” (Only) in Texas State Court Docket No A-180805 …?

Request Number 115.


and his counsel of record before responding to each and every request for

admission having fully examine the 58th Judicial District Court of Jefferson

County Texas Civil Action for Docket No. A-180805

Namely all records, court documents, and exhibit(s) in its entirety before

respond to Pro Se Plaintiff Louis Charles Hamilton II herein propounding party

2015 Request for Admission, Set (1)

Request Number 116.


and his counsel of record before responding to each and every “Request for

Admission” having fully examine the 58th Judicial District Court of Jefferson

County Texas Civil Action for Docket No. A-180805

Namely all records, court documents, and exhibit(s) in its entirety before

respond to Pro Se Plaintiff Louis Charles Hamilton II herein propounding party

2015 Request for Admission, Set (2)


and his counsel of record before responding to each and every “Request for Admission” having fully examine each and every attached records, court documents, and exhibit(s) filed by Pro Se Plaintiff Louis Charles Hamilton II herein propounding party 2015 Request for Admission, set (1) in its entirety.


and his counsel of record before responding to each and every “Request for Admission”

Having fully examine each and every attached records, court documents, and exhibit(s) filed by Pro Se Plaintiff Louis Charles Hamilton II herein propounding party 2015 Request for Admission, set (2) in its entirety.



Having fully examine Chapter 96 of Title 18, United State Code: (RICO)

Racketeering Influences Corruption Organization, Title 18 U.S.C. § 1341, 1343

And 1349 “Mail and Wire Fraud”, section 1028(relating to fraud and

related activity in connection with identification documents),

Section 1503(relating to obstruction of justice) as it relate in connection

with the Pro Se Plaintiff “Louis Charles Hamilton II, Chief Defendant Antoine L.

Freeman J. D. “Attorney at Law”, and Co-Defendant(s) Joyce M. Guy and Edward

McCray herein all Complaints, records, affidavits, court records, transcripts, files

and documents, described legally fully herein Request for Admission, set (1) and

Request for Admission set (2) in its entirety.

Request Number 120.


and his counsel of record before responding to each and every “Request for

Admission” Having fully examine Computer Fraud and Abuse Act (CFAA) 18

U.S.C. § 1030

As it relate in connection with the Pro Se Plaintiff “Louis Charles Hamilton

II, Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, and Co-

Defendant(s) Joyce M. Guy and Edward McCray herein all Complaints, records,

affidavits, court records, transcripts, files and documents, described legally fully

herein Request for Admission, set (1) and Request for Admission set (2) in its

entirety.



Having fully examine Amendment VII of the United States of America as it relate in connection with the Pro Se Plaintiff “Louis Charles Hamilton II, Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, and Co-Defendant(s) Joyce M. Guy and Edward McCray herein

All Complaints, records, affidavits, court records, transcripts, files and documents, described legally fully herein Request for Admission, set (1) and Request for Admission set (2) in its entirety.


and his counsel of record before responding to each and every “Request for Admission” Having fully examine The Constitution of the State of Texas,

Article 16: "General Provisions" Section 37 provides for the constitutional protection of the mechanic's lien.

Section 50 provides for protection of a homestead against forced sale to pay debts, except for foreclosure on debts related to the homestead (mortgage, taxes, mechanic's liens, and home equity loans).

As it relate in connection with the Pro Se Plaintiff “Louis Charles Hamilton II, Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, and Co-Defendant(s) Joyce M. Guy and Edward McCray herein


Request Number 123.

Admit Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein and his counsel of record before responding to each and every “Request for Admission” Having fully examine 18 U.S.C. § 1001 : US Code - Section 1001: Statements or entries generally

(a) Except as otherwise provided in this section, whoever, in any matter within the jurisdiction of the executive, legislative, or judicial branch of the Government of the United States,

Knowingly and willfully - (1) falsifies, conceals, or covers up by any trick, scheme, or device a material fact;






and his counsel of record before responding to each and every “Request for Admission” Having fully examine U.S. Code: Title 28:1343




and his counsel of record before responding to each and every “Request for Admission” Having fully examined Texas Rules of Civil Procedures 194.2, 196, 197, and 198,




and his counsel of record before responding to each and every “Request for Admission” Having fully examined Texas Rules of Civil Procedures “Subpoena”




and his counsel of record before responding to each and every “Request for Admission” Having fully examined Texas Rules of Civil Procedures 10 “Withdrawal of Attorney”




and his counsel of record before responding to each and every “Request for Admission” Having fully examined Texas Disciplinary Rules of Professional Conduct, Particularly 8.04




and his counsel of record that “Antoine L. Freeman J.D. is an active “Attorney” in and for the State of Texas and this is his correct “Attorney at Law” Bar No. 24058299 in that further admitting “Antoine L. Freeman J.D. is described as a Defendant in U.S. Cause No. 1:14-CV-592


and his counsel of record that said Request for Admission, set (1) and Request for Admission set (2) in its entirety fully free from, fraudulent, fictitious, false, misleading material facts, in all “Subject Matter” described legally therein which are materially pertinent to Pro Plaintiff “Louis Charles Hamilton II” herein claims hereto in accordance with Rule 36,

Under which rule of federal procedure this request for admissions is

made, thereby answering all of the described legally fully herein Request for Admission, set (1) and Request for Admission set (2) in its entirety 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 .


and his counsel of record that “Antoine L. Freeman J.D. is an active “Attorney” in and for the State of Texas and this is his correct “Attorney at Law” Bar No. 24058299 in that further admitting

“Antoine L. Freeman J.D. is described as a Defendant in U.S. Cause No. 1:14-CV-592 and pursuant to Request for Admission set (two) at Request Number (127)

Said Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein after having fully examined Texas Rules of Civil Procedures 10 “Withdrawal of Attorney”

Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein furtherance’s admitting he was in fact “attorney of record” for Co-Defendant(s) Joyce M. Guy and Edward McCray” collectively from the exact time frame of December 18th 2007 throughout December 11th 2009 when

“Honorable Judge Bob Wortham” of the 58th Judicial District Court of Jefferson County Texas fully granted said Chief Defendant Antoine L. Freeman J. D. “Attorney at Law”, herein “Motion for “Withdrawal of Attorney” in Docket No. A-180805 on December 11th 2009 Dated on this ______ Day of ________________ 2015

By, _______________________________

Louis Charles Hamilton II

Pro Se Plaintiff

P.O. Box 17524

Sugar Land Texas 77496