Friday, May 20, 2016

Motion for Production of Document(s) Cmdr. Bluefin Sherlock Holmes Case of Texas State Hospital of Crooked Doctor "Mind Bender" US Docket No. 4:2016-CV-00964.


                                                       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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