In The United States District Court
For The Southern District of Texas
Houston Division
Slave Negro Louis Charles Hamilton II USN
Vs. U.S.
Docket No 4:2016-CV-00964
United States of America et al
PLAINTIFF'S
(First Set) INTERROGATORIES
REQUESTS FOR ADMISSIONS AND
REQUESTS FOR
PRODUCTION of Documents
Respectfully Appearance Slave Negro (Pro
Se Plaintiff) Louis Charles Hamilton II herein (USN) before “Honorable Court
Justice” Kenneth M. Hoyt, presiding herein U.S. Docket No 4:2016-CV-00964
United States Southern District of Texas Federal Courthouse
To: United States Attorney Wells Fargo
Plaza, 1000 Louisiana St #2300, Houston, TX 77002
To: Natalee B. Marion (Assistant Attorney
General) Federal I.D. No. 2724917 State Bar No. 240753362 P.O. Box 12548,
Capitol Station Austin, Texas 78711-2548
To: Patrick Nagorski Assistant County
Attorney Federal I.D. No. 1902658, State Bar No. 244074787, 1019 Congress, 15th
Floor Houston, Texas 77002 Attorney for Defendant (Harris County)
To: Dwayne R. Day Federal I.D. No.
00795314, State Bar No. 007953413401 Allen Parkway, Suite 100 Houston Texas 77019
Attorney for Defendant “Jonathan A. Gluckman (Attorney at Law)
To: Deidra Norris Sullivan (Attorney in
Charge) Fed I.D. No. 1338580 State Bar I.D. No. 1338580 Sr. Assistant City
Attorney P.O. Box 368, Houston Texas 77001-0368 Attorney for Defendant “City of
Houston Texas and Chief of Houston Texas, Police Department
To: Susana G. Sosa Federal I.D. No.
2292237, State Bar No. 24083894, P.O. Box 368, Houston Texas 77001-0368
Attorney for Defendant “City of Houston Texas and Chief of Houston Texas, Police
Department 77001-0368
To: Dwayne R. Day Federal I.D. No.
19937 State Bar I.D. No. 007955314 3401 Allen Parkway, Suite 100, Houston Texas
77019 “Attorney for Jonathan A. Gluckman (Attorney at Law)
To: Mark Thering Federal I.D. No.
582980 State Bar I.D. No. 24010918 1305 Prairie St, Suite 300 Houston Texas
77002 (Attorney for Defendant) Mark Thering, Mark Thering D/B/A “The Ring
Investigations, and Kandy Villarreal D/B/A “The Ring Investigations
To: Harry C. Arthur Esq. “Infamous
Houston Texas Scrooge Attorney” Federal I.D. No. 2286 State Bar I.D. No.
01364000 2104 Chenevert Houston, Texas 77003
PLAINTIFF'S
(First Set) INTERROGATORIES
REQUESTS
FOR ADMISSIONS AND
REQUESTS FOR PRODUCTION
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.
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.
INSTRUCTIONS
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.
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.
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.
DEFINITIONS
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.
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.
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.
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.
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.
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.
Request for ADMISSION(S):
All Defendant(s) collectively herein required 1000% official Admit: August 20th 1619 imposed “Human Rights Violation” of forced “Slavery Servitude” having an official ending in the “Entire” United States of America et al on or about February 7th 2013th in direct violation of the required ending passage of Defendant (USA) herein the 13th Amendment of the Constitution Passed by Defendant Congress on or about January 31, 1865, and ratified on December 6, 1865, following (American) 1865 Civil War.
All Defendant(s) collectively herein required 1000% official Admit: August 20th 1619 imposed “Human Rights Violation” of forced “Slavery Servitude” having an official ending in the “Entire” United States of America et al on or about February 7th 2013th in direct violation of the required ending passage of Defendant (USA) herein the 13th Amendment of the Constitution Passed by Defendant Congress on or about January 31, 1865, and ratified on December 6, 1865, following (American) 1865 Civil War.
- All Defendant(s) collectively herein required 1000% official Admit: Defendant (USA) herein Passed by Congress on January 31, 1865, and ratified on December 6, 1865, the 13th amendment abolished slavery in the United States and provides that "Neither slavery nor involuntary servitude, except as a punishment for crime whereof the party shall have been duly convicted, shall exist within the United States, after the precise date in time of December 6th, 1865
- All Defendant(s) collectively herein required 1000% official Admit: Defendant (USA) herein Passed by Congress on January 31, 1865, and ratified on December 6, 1865, the 13th amendment abolished slavery in the United States and provides that "Neither slavery nor involuntary servitude, except as a punishment for crime whereof the party shall have been duly convicted, shall exist within the United States, after the precise date in time of “Pro Se Plaintiff Louis Charles Hamilton II official Birth date of November 8th 1961
- All Defendant(s) collectively herein required 1000% official Admit: Defendant (USA) herein Passed by Congress on January 31, 1865, and ratified on December 6, 1865, the 13th amendment abolished slavery in the United States and provides that "Neither slavery nor involuntary servitude, except as a punishment for crime whereof the party shall have been duly convicted, shall exist within the United States, after the precise date in time of Defendant “United States of America et al” 44th U.S. President (Negro) Barack Hussein Obama official Birth date of August 4th 1961
- All Defendant(s) collectively herein required 1000% official Admit: Defendant (USA) herein Passed by Congress on January 31, 1865, and ratified on December 6, 1865, the 13th amendment abolished slavery in the United States and provides that "Neither slavery nor involuntary servitude, except as a punishment for crime whereof the party shall have been duly convicted, shall exist within the United States, after the precise date in time of First African American First Lady of Defendant “United States of America et al” “Michelle LaVaughn Robinson Obama” official Birth date of January 17th 1964
- All Defendant(s) collectively herein required 1000% official Admit: Defendant (USA) herein Passed by Congress on January 31, 1865, and ratified on December 6, 1865, the 13th amendment abolished slavery in the United States and provides that "Neither slavery nor involuntary servitude, except as a punishment for crime whereof the party shall have been duly convicted, shall exist within the United States, after the precise date in time of First African American Family of Defendant “United States of America et al” “Malia Ann Obama” official Birth date of July 4th 1998 and “Natasha Obama” official Birth date of June 10th 2001
- All Defendant(s) collectively herein required 1000% official Admit: Defendant (USA) herein Passed by Congress on January 31, 1865, and ratified on December 6, 1865, the 13th amendment abolished slavery in the United States and provides that "Neither slavery nor involuntary servitude, except as a punishment for crime whereof the party shall have been duly convicted, shall exist within the United States, “But” officially “Slavery Servitude” of Defendant “United State of America et al” continual onward after the precise date in time of Defendant “United States of America et al” 44th U.S. President (Negro) Barack Hussein Obama official took place on Tuesday, January 20, 2009 official first inauguration of Barack Obama as the 44th President of the United States
- All Defendant(s) collectively herein required 1000% official Admit: Defendant (USA) herein Passed by Congress on January 31, 1865, and ratified on December 6, 1865, the 13th amendment abolished slavery in the United States and provides that "Neither slavery nor involuntary servitude, except as a punishment for crime whereof the party shall have been duly convicted, shall exist within the United States, “But” officially “Slavery Servitude” of Defendant “United State of America et al” continual onward after the precise date in time of Defendant “United States of America et al” 44th U.S. President (Negro) Barack Hussein Obama second inauguration of Barack Obama as the 44th President of the United States official took place on January 20th 2013
- All Defendant(s) collectively herein required 1000% official Admit: Defendant (USA) herein Passed by Congress on January 31, 1865, and ratified on December 6, 1865, the 13th amendment abolished slavery in the United States and provides that "Neither slavery nor involuntary servitude, except as a punishment for crime whereof the party shall have been duly convicted, shall exist within the United States, “But” officially “Slavery Servitude” of Defendant “United State of America et al” continual onward after the precise date in time of Feburary 7th 2013 in Defendant “United States of America et al” and 44th U.S. President (Negro) Barack Hussein Obama, First African American First Lady of Defendant “United States of America et al” “Michelle LaVaughn Robinson Obama” official Birth date of January 17th 1964, and First African American Family of Defendant “United States of America et al” “Malia Ann Obama” official Birth date of July 4th 1998 and “Natasha Obama” official Birth date of June 10th 2001 all “Legally” Born Under “Slavery Servitude” of Defendant United States of America et al after the passage of the Defendant (USA) herein Passed by Congress on January 31, 1865, and ratified on December 6, 1865, the 13th amendment abolished slavery in the United States
- All Defendant(s) collectively herein required 1000% official Admit: Defendant (USA) herein Passed by Congress on January 31, 1865, and ratified on December 6, 1865, the 13th amendment abolished slavery in the United States and provides that "Neither slavery nor involuntary servitude, except as a punishment for crime whereof the party shall have been duly convicted, shall exist within the United States, after the precise date in time of “Pro Se Plaintiff Louis Charles Hamilton II official Birth date of November 8th 1961 “But” Slave Negro Louis Charles Hamilton II USN # 2712 Born Under “Slavery Servitude” of Defendant United States of America et al after the passage of the Defendant (USA) herein Passed by Congress on January 31, 1865, and ratified on December 6, 1865, the 13th amendment abolished slavery in the United States
- All Defendant(s) collectively herein required 1000% official Admit: Defendant (USA) herein Passed by Congress on January 31, 1865, and ratified on December 6, 1865, the 13th amendment abolished slavery in the United States and provides that "Neither slavery nor involuntary servitude, except as a punishment for crime whereof the party shall have been duly convicted, shall exist within the United States, after the precise date in time of “Pro Se Plaintiff Louis Charles Hamilton II official Slave Negro Daughter “Chandra D. Hamilton”, herein Born December 28th 1990- February 7th 2013 being an official Slave of the Defendant “United States of America” herein for exactly (23) Years
- All Defendant(s) collectively herein required 1000% official Admit: Defendant (USA) herein Passed by Congress on January 31, 1865, and ratified on December 6, 1865, the 13th amendment abolished slavery in the United States and provides that "Neither slavery nor involuntary servitude, except as a punishment for crime whereof the party shall have been duly convicted, shall exist within the United States, after the precise date in time of “Pro Se Plaintiff Louis Charles Hamilton II official Slave Negro Daughter “Chandra D. Hamilton”, herein Born December 28th 1990- February 7th 2013 being an official Slave of the Defendant “United States of America” herein for exactly (23) Years
- All Defendant(s) collectively herein required 1000% official Admit: Defendant (USA) herein Passed by Congress on January 31, 1865, and ratified on December 6, 1865, the 13th amendment abolished slavery in the United States and provides that "Neither slavery nor involuntary servitude, except as a punishment for crime whereof the party shall have been duly convicted, shall exist within the United States, after the precise date in time of “Pro Se Plaintiff Louis Charles Hamilton II” official Slave Negro Daughter “Natasha C. Hamilton”, herein Born December 30th 1991- February 7th 2013 being an official Slave of the Defendant “United States of America” herein for exactly (22) Years
- All Defendant(s) collectively herein required 1000% official Admit: Defendant (USA) herein Passed by Congress on January 31, 1865, and ratified on December 6, 1865, the 13th amendment abolished slavery in the United States and provides that "Neither slavery nor involuntary servitude, except as a punishment for crime whereof the party shall have been duly convicted, shall exist within the United States, after the precise date in time of “Pro Se Plaintiff Louis Charles Hamilton II” official Slave Negro (Son) Slave Negro “Aaron Michael Halvorsen (Hamilton II), herein Born April 28th 1986- February 18th 2013 being a official Slave of the Defendant “United States of America” herein for exactly (28) Years
- All Defendant(s) collectively herein required 1000% official Admit: Defendant (USA) herein Passed by Congress on January 31, 1865, and ratified on December 6, 1865, the 13th amendment abolished slavery in the United States and any and all (Born) DNA Negro Race within Defendant (USA) from the exact date of august 20th 1619 - February 7th 2013 being an official “Negro American Slave Subject of the Defendant “United States of America” herein pursuant to Defendant “United States of America et al” State of “Mississippi” finally freed the “Negro DNA American Slaves” on February 7th 2013
- All Defendant(s) collectively herein required 1000% official Admit: Pursuant forever to “Dred Scott” vs. Sandford, 60 U.S. 393 (1857) pursuant to Defendant “United States of America et al” State of “Mississippi” finally freed the “Negro DNA American Slaves” on February 7th 2013 each and every DNA Negro (American) Race residing and official birth dates within Defendant “United States of America et al” from the exact date of August 20th 1619 - February 7th 2013, Said “Negro DNA American” status is official Born Under “Slavery Servitude” of Chief Defendant “United States of America et al”
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