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
To
the Honorable Court Justice Kenneth Michael Hoyt ,Comes Now Slave Negro Pro Se Plaintiff “Louis Charles Hamilton II” (USN # 2712) herein
Files this motion for Production of document from “United States of America et
al Chief Defendant as follows:
To: U.S. Attorney's Office, Southern
District of Texas, Houston, Texas, 1000 Louisiana, Ste. 2300. Houston, TX,
77002 (Attorney for United States of America et al)
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 (Attorney for the State of Texas)
To: Patrick Nagorski Assistant County Attorney Federal I.D.
No. 1902658, State Bar No. 244074787, 1019 Congress, 15th Floor Houston, Texas
77002 (Attorney for 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: 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
To: Harry C. Arthur Federal I.D. #2286, State Bar. No.
01364000 2104 Chenevert Houston, Texas 77003
“Motion
for Production of Document(s) as follows:
Rule 34.
Producing Documents, Electronically Stored Information, and Tangible Things, or
Entering onto Land, for Inspection and Other Purposes
(a) In
General. A party may serve on any other party a request within the scope of
Rule 26(b):
(1) to
produce and permit the requesting party or its representative to inspect, copy,
test, or sample the following items in the responding party's possession,
custody, or control:
(A) any
designated documents or electronically stored information—including writings,
drawings, graphs, charts, photographs, sound recordings, images, and other data
or data compilations—stored in any medium from which information can be
obtained either directly or, if necessary, after translation by the responding
party into a reasonably usable form; or
(B) Any
designated tangible things; or
(2) To
permit entry onto designated land or other property possessed or controlled by
the responding party, so that the requesting party may inspect, measure,
survey, photograph, test, or sample the property or any designated object or
operation on it.
(b)
Procedure.
(1) Contents
of the Request. The request:
(A) must
describe with reasonable particularity each item or category of items to be
inspected;
(B) must
specify a reasonable time, place, and manner for the inspection and for performing
the related acts; and
(C) may
specify the form or forms in which electronically stored information is to be
produced.
(2)
Responses and Objections.
(A) Time to
Respond. The party to whom the request is directed must respond in writing
within 30 days after being served or — if the request was delivered under Rule
26(d)(2) — within 30 days after the parties’ first Rule 26(f) conference. A
shorter or longer time may be stipulated to under Rule 29 or be ordered by the
court.
(B)
Responding to Each Item. For each item or category, the response must either state
that inspection and related activities will be permitted as requested or state
with specificity the grounds for objecting to the request, including the
reasons. The responding party may state that it will produce copies of
documents or of electronically stored information instead of permitting
inspection. The production must then be completed no later than the time for
inspection specified in the request or another reasonable time specified in the
response.
(C)
Objections. An objection must state whether any responsive materials are being
withheld on the basis of that objection. An objection to part of a request must
specify the part and permit inspection of the rest.
(D)
Responding to a Request for Production of Electronically Stored Information.
The response may state an objection to a requested form for producing
electronically stored information. If the responding party objects to a
requested form—or if no form was specified in the request—the party must state
the form or forms it intends to use.
(E) Producing
the Documents or Electronically Stored Information. Unless otherwise stipulated
or ordered by the court, these procedures apply to producing documents or electronically
stored information:
(i) A party
must produce documents as they are kept in the usual course of business or must
organize and label them to correspond to the categories in the request;
(ii) If a
request does not specify a form for producing electronically stored
information, a party must produce it in a form or forms in which it is
ordinarily maintained or in a reasonably usable form or forms; and
(iii) A
party need not produce the same electronically stored information in more than
one form.
(c)
Nonparties. As provided in Rule 45, a nonparty may be compelled to produce
documents and tangible things or to permit an inspection.
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