Harry c. arthur third party request for admision (america)
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Harry c. arthur third party request for admision (america)

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Scrooge Attorney Harry C. Arthur Esq. "Third Party" Request for Admission ...United States and State of Texas (Defendants)

Scrooge Attorney Harry C. Arthur Esq. "Third Party" Request for Admission ...United States and State of Texas (Defendants)

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Harry c. arthur third party request for admision (america) Harry c. arthur third party request for admision (america) Document Transcript

  • In The United States District Court<br /> For the Eastern District of Texas<br /> Beaumont Division<br />Louis Charles Hamilton II<br />(Negro African American)<br />Plaintiff<br />Vs.<br />United States of America<br />State of Texas<br />Harris County<br />PLAINTIFF'S (First Set) INTERROGATORIES<br />REQUESTS FOR ADMISSIONS AND <br />REQUESTS FOR PRODUCTION<br />TO: Third Parties: <br />Harry C. Arthur Esq. LAW OFFICE OF HARRY C. ARTHUR et al, and MARINE BUILDING, L.L.C., <br />LARRY G. JUSTIN, RALPH M. WEAR, HUMBERTO R. TREJO, SONIA BEHRANA, PAT VARGAS GRADY, AA QUICK BOND, MIKE COX'S BAIL SVC, LACEY'S DELI, JONATHAN A. GLUCKMAN, WAYNE HELLER, RING INVESTIGATIONS MARK THERING, RING INVESTIGATIONS KANDY VILLARREAL, DARRELL W. JORDAN, DANIEL PEREZ-GARCIA, MARQUERITE HUDIG, CARL D. HAGGARD, F. M. (POPPY) NORTHCUT, SANDRA MARTINEZ and ALLEN J. GUIDRY<br />Pro Se Plaintiffs, (Louis Charles Hamilton II) <br />In the above entitled matter pursuant to Rules 33, 34, 36, and 37 of the Federal Rules of Civil Procedure, hereby propound the following Interrogatories, Requests for Admissions and Request for Production to Defendant which are to be read and interpreted in accordance with the instructions and definitions set forth below. <br />The answers to these Interrogatories must be signed and verified by the Defendant and a copy of the answers to Interrogatories and Responses to Admissions and Production must be served on the undersigned within thirty-five days after service of these Interrogatories and Requests.<br />INSTRUCTIONS<br />1. If any information called for by these Interrogatories or Requests is withheld on the ground that the information is privileged, constitutes attorney work-product or trial preparation materials by or for any other reason is exempt from discover, set forth the grounds or grounds for withholding the information, explain what type of information is being withheld, and furnish such other information as may be required to enable the court to adjudicate the propriety of the refusal to furnish the information.<br />2. These Interrogatories, Requests for Admissions and Requests for Production are intended to be continuing and you are requested to supplement or amend your answers if you obtain additional information responsive to any of the requests.<br />3. The singular includes the plural number, and vice versa. The masculine includes the feminine and neuter genders. Past tense includes the present tense unless the clear meaning is distorted by change of tense.<br />DEFINITIONS<br />1. The term “document” shall mean all writings and means of communication of any kind, including the original and non-identical copies (whether different from the originals by reason of notations made on such copies or otherwise) of any written, recorded, or graphic matter of any nature whatsoever, regardless of how recorded, including but not limited to the following: Letters, correspondence, memoranda, notes, diaries, statistics, telegrams, payments, and certificates for payment, statements/invoices, medical records and police reports, notices, confirmations, telegrams, receipts, pamphlets, magazines, newspapers; notations of any sort of conversation, telephone call, meeting or other communication; bulletins, printed matter, computer printouts, teletypes, invoices, checks (front and back), check stubs, transcripts, diaries, summaries, financial statements, expert opinions, studies and investigations, questionnaires and surveys, and work sheets (and all drafts, preliminary versions, alterations, modifications, revisions, changes, and amendments of any of the foregoing as well as any attachments or appendices thereto); and graphic or oral records or representations of any kind (including, without limitation, photographs, charts, graphs, microfiche, microfilm, videotape, recordings, and motions pictures); and electronic, mechanical and electric records or representations of any kind (including without limitation tapes, cassettes, disks and recordings); and other written, printed, typed, or other graphic or recorded matter of any kind or nature, whoever produced or reproduced, and whether preserved in writing, phone or record, film, tape, disk, or videotape.<br />2. The term “document” includes all documents by whomever prepared within the care, custody, or control of the Plaintiff as well as documents that they have a legal right to obtain, documents that they have a right to copy or have access to, documents that they have placed in the temporary possession, custody, or control of any third party including any attorney.<br />3. The term “identify” when used with respect to documents means: (a) for those documents introduced as deposition exhibits, give the number of the exhibit; (b) for those documents produced by parties to this litigation, a stamp with a document identification number, give that number; (c) for other documents, give sufficient information including date, subject matter, author, addressee or in the alternative produce the document.<br />4. The term “identify” when used with respect to a person means to state his or her full name and present and last known business or residential address and phone number. When referring to a public or private corporation, partnership, association or other organization or to a governmental agency means to state its full name and present and last known pertinent business address and phone number.<br />5. The term “identify” when referring to a statement means to identify who made it, who took or recorded it, and all persons, if any, present during the making thereof; to state when, where and how it was taken or recorded, and identify who has present or last known possession, custody or control thereof.<br />6. The terms “and” and “or” shall be construed either conjunctively or disjunctively to bring within the scope of these interrogatories any information which might otherwise be construed to be outside their scope.<br />Admit (1). HARRY C ARTHUR, LAW OFFICE OF HARRY C. ARTHUR, MARINE BUILDING, L.L.C., LARRY G. JUSTIN, RALPH M. WEAR, HUMBERTO R. TREJO, SONIA BEHRANA, PAT VARGAS GRADY, CHRIST CHURCH CATHEDRAL, <br />AA QUICK BOND, MIKE COX'S BAIL SVC, LACEY'S DELI, JONATHAN A. GLUCKMAN, WAYNE HELLER, RING INVESTIGATIONS MARK THERING, RING INVESTIGATIONS KANDY VILLARREAL, DARRELL W. JORDAN, DANIEL PEREZ-GARCIA, MARQUERITE HUDIG, CARL D. HAGGARD, F. M. (POPPY) NORTHCUT, SANDRA MARTINEZ and ALLEN J. GUIDRY are all (Appellees) before the Fifth Circuit Court of Appeals, Circuit Court Docket No.:11-20216<br />Admit (2). A civil dispute arise in which (Harry C. Arthur Esq.) declare in a tort of monetary losses in rental revenue at Marine Building L.L.C. in Houston Texas against “Christ Church Cathedral” in Houston Texas being filed in Harris County Courthouse.<br />Admit (3). (Harry C. Arthur Esq.) declare in a tort of also property value losses and or depreciation at Marine Building L.L.C. in Houston Texas against Christ Church Cathedral in Houston Texas also being filed in Harris County Courthouse.<br />Admit (4). The above Plaintiff herein (Hamilton II) filed civil suit against all described (Third Parties) above in regards to the tort filed by (Harry C. Arthur Esq.) in Houston Texas being filed in Harris County Courthouse.<br />Admit (5) The above Plaintiff herein (Hamilton II) filed a motion for Production of Deposition conducted upon (Harry C. Arthur Esq.)<br />Admit (6). Harry C. Arthur Esq. claim “work product doctrine on said discovery deposition conducted by Andy Vickery Attorney at Law.<br />Admit (7). Harry C. Arthur Esq. was false and fraudulent in claiming Andy Vickery Attorney at Law personal conducted Deposition as Harry C. Arthur Esq. own “Work Product.<br />Admit (8). The Deposition conducted by Andy Vickery as described in request for admission question # (7) above on the behalf of “Christ Church Cathedral” contain under oath information supply by (Harry C. Arthur Esq.) in regarding and direct concern in the business operation, finances, and rental revenue of the Marine Building L.L.C. and listing detail facts whom actually own “Marine Building L.L.C.<br />Admit (9). PRESIDENT, TREASURER and Director are active roles held by Harry C Arthur Esq. in the Business described as D & G Storages Inc. in Houston Texas<br />If admitted state fully what those active roles and circumstances are:<br />
    • Identify the exact person or persons, employees, and officers name, address, and day time phone number whom is under the direction of President Harry C. Arthur Esq. actives roles in the D & G Storages Inc. described herein
    • List and describe all other person or persons, employees, officers, having active roles, their exact roles and the name, address, and day time phone numbers of the person or persons, employees, officers having such roles in the D & G Storages described herein
    • What monies if any does Harry C. Arthur Esq. receive annually from Marine Building L.L.C.
    • What monies if any do the other person, and or persons, officers having actives roles in the D & G Storages received annually from the direction of Harry C. Arthur Esq. actives roles as President in the D & G Storages Inc.
    Admit (10). The Deposition conducted by Andy Vickery as described in request for admission question # (7) also was ask in the Deposition that Harry C. Arthur is acting PRESIDENT, TREASURER and Director having active roles held by Harry C Arthur in the Business described as D & G Storages Inc. in Houston Texas<br />Admit (11) The Deposition conducted by Andy Vickery as described herein request for admission question # (7) above also was ask in the Deposition conducted that Harry C. Arthur explain the relationship and active roles held by Harry C. Arthur Esq. in the Marine Building L.L.C. in Houston Texas<br />If admitted state fully what those roles and circumstances are:<br />
    • Identify the exact person or person name, address, and day time phone number whom is under the direction of Harry C. Arthur Esq. actives roles in the Marine Building L.L.C. described herein
    • List all other person or persons , employees, and officers having active roles, and the name, address, and day time phone numbers of the person or persons, employees and officers having such roles in the Marine Building L.L.C. described herein
    • What monies if any does Harry C. Arthur Esq. receive annually from Marine Building L.L.C. and in what legal capacity is the monies derived from
    • What monies if any do the other actives roles, employees, officers, person, and persons in the Marine Building L.L.C. received annually from the Marine Building L.L.C. and in what legal capacity is the money derived from
    Admit (12) Fred B. Cull is a business partner of sort in the D & G Storages Inc. and or Marine Building L.L.C. and or both<br />If admitted described exactly each of the relationship in full detail Fred B. Cull has with <br />
    • Law Office of Harry C. Arthur
    • Marine Building L.L.C.
    • D & G Storages Inc.
    • Kathryn Arthur
    Admit (13) Fred B. Cull relationship with Harry C. Arthur Esq. and his described business partner of sort in the D & G Storages Inc. and or Marine Building L.L.C. and or both with relationship of business Kathryn Arthur was a topic in the deposition conducted upon Harry C. Arthur Esq. by Andy Vickery (Attorney at Law) on the behalf of “Christ Church Cathedral”<br />Described exactly in full detail Fred B. Cull active legal role he has with and provide his correct address and day time phone number<br />
    • Law Office of Harry C. Arthur et al
    • Marine Building L.L.C.
    • D & G Storages Inc.
    • Kathryn Arthur
    State exactly when was the deposition conducted and list all person in attendances.<br />Production of Document Plaintiff herein Request Harry C. Arthur Esq. to supply and forward to the Plaintiff Louis Charles Hamilton II a complete certified copy of the Deposition conducted upon Harry C. Arthur Esq. by Attorney at Law “Andy Vickery in the Matter of (Arthur et al vs. Christ Church Cathedral) filed in Harris County Texas<br />Admit (12). D & G Storages Inc. business address is suit 300 “Marine Building L.L.C.<br />Admit (13) Law Offices of Harry C. Arthur et al business address is suit 200 “Marine Building L.L.C.<br /> Described exactly in full detail Kathryn Arthur active legal role she has with: <br />
    • Marine Building L.L.C.
    • D & G Storages Inc.
    • Law offices of Harry C. Arthur et al
    And provide Kathryn Arthur correct address and day time phone number<br />Submitted by Louis Charles Hamilton II <br />Pro Se Plaintiff<br />Certificate of Mailing Services<br />Comes Now the Pro Se Plaintiff, Louis Charles Hamilton II, Appearing in this Cause No. hereby certify and state against penalty of perjury that the following documents:<br />Plaintiff “third party” request for admission, Interrogatories, and Production of Documents was mail to the Defendant <br />(The United States of America et al Attorney of Record Eric Holder Attorney General for the United States of America) as address is indicated on file with the U.S. Clerk of Court Office in Washington D.C.<br />Plaintiff further states regular first class mail having been received at the correct address <br />1305 Prairie St # 200Houston, TX 77002-2019<br />Indicated for the third party: Harry C. Arthur Esq. <br />LAW OFFICE OF HARRY C. ARTHUR et al, and MARINE BUILDING, L.L.C., <br />LARRY G. JUSTIN, RALPH M. WEAR, HUMBERTO R. TREJO, SONIA BEHRANA, PAT VARGAS GRADY, AA QUICK BOND, MIKE COX'S BAIL SVC, LACEY'S DELI, JONATHAN A. GLUCKMAN,<br /> WAYNE HELLER, RING INVESTIGATIONS MARK THERING, RING INVESTIGATIONS KANDY VILLARREAL, DARRELL W. JORDAN, DANIEL PEREZ-GARCIA, MARQUERITE HUDIG, CARL D. HAGGARD, F. M. (POPPY) NORTHCUT, SANDRA MARTINEZ and ALLEN J. GUIDRY<br /> Dated the _______ day of __________, 2011<br />__________________________<br />Louis Charles Hamilton II<br />Pro Se Plaintiff <br />P.O. Box 20126<br />Houston Texas 77225<br />