In The District Court
______ Judicial District
Harris County, Texas
Cause No._____________
Louis Charles Hamilton II
Plaintiff
Civil Complaint
Vs. Jury Trial Demand
Harry C. Arthur
The Marine Building, L.L.C. (et al)
Defendant(s)
Comes Now the Plaintiff, Louis Charles Hamilton II, hereby appearing Pro Se Plaintiff files this complaint against the above named Defendant(s)
And for cause Plaintiff will show the Honorable U. S. District Court as follows:
I.
Parties
Plaintiff, Louis Charles Hamilton II, is an African American Male, Homeless Permanent Disable Veteran, a recipient from the Humanitarian Church effort(s) of the Beacon in Houston, Texas
And its “Spiritual loving connection” to Bishop Charles Andrew Doyle,
With its “supporting loving congregation flock” with the Christ Church Cathedral in Houston Texas at 1225 Texas Avenue, Houston, Texas 77002
In providing the Plaintiff (among the multitude of many, many, other(s)) with needed Hot Precious Food, opportunity for baths, Clothes, and Clean Laundry at these facilities (among many other things) being provided;
To include but not limited to; if the need arise for the Plaintiff in the area of medical attention it to is also there at the onsite clinic, with occasional counsel for future apartment and housing needs mental health, and other Self Help Humanitarian Vendors doing unselfish the same effort(s) on behalf of the Plaintiff and many, many, others,
To include but not limited to The Compass being located at the same facilities and in providing the Plaintiff (among many, many, others similarly situated) with unselfish Humanitarian Needs to the General Public as described above,
Regardless of Gender, Creed, Color, Religious preference, Sexual Orientation, Age, and or Mental/Physical Ability in association with the Beacon,
And Christ Church Cathedral and the teaching of Jesus Christ.
Plaintiff hereafter name (Hamilton) is registered with the Beacon by his Last 4 Social Security # 2712 on file with the Beacon since Plaintiff move to Houston Texas area on August 18 2009 from Plaintiff Home county of Jefferson County, Texas
And Plaintiff is currently still living homeless in the Houston Texas downtown area, mailing address:
· Louis Charles Hamilton II.
· c/o U.S. Vet Center
· 1418 Preston Street
· Houston, Texas 77002
Defendant(s): Harry C. Arthur (Attorney at law) within the State of Texas, TBN: 01364000 mailing address 1305 Prairie, Suite 200 Houston Texas 77002
Co-Defendant(s): the Marine Building, L.L.C., owner Harry C. Arthur one in the addresses as described above:
Defendant(s) may be served with a citation herein by serving Harry C. Arthur Attorney at Law at the above stated address for the Defendant
II.
Case Level
Plaintiff, intends to conduct a complete discovery on a level 2 cause of action pursuant to Texas Rules of Civil Procedure 190.3
Plaintiff respectfully seeks damage for Defamation, Discrimination, Intentional Infliction of emotional distress, Mental Anguish, Punitive/exemplary monetary relief(s) before a Jury Trial in excess of 2’400’000.00 (Two Million Four Hundred Thousand Dollars)
To include but not limited to the Defendant: Harry C. Arthur finance and Print a Front page Public apology in the Houston News Paper,
In the Interest of the Plaintiff in this above cause stating to the effects of Attorney Harry C. Arthur apologize to Derelict a.k.a (Hamilton);
To include but not limited to a Declaratory Judgment being entry into the records against all defendant(s) named here within for all of the act(s) as described by the Pro Se Plaintiff Louis Charles Hamilton II in this Complaint with interest incurred,
To include all court cost and any other legal cost may arise during the course of this civil action.
Facts
Defendant(s) here within filed a civil action on the 23 day of November 2009 at 2:31 pm in the Harris County, Texas District Court, Cause No. 2009-75693
Which is attached as Plaintiff appendix exhibit (A) for full facts allege in the Defendant(s) here after named (Arthur et al) wrongful conduct against the rights and dignity of the Plaintiff as described therein.
Defendant(s) (Arthur et al) unflinchingly, courageously, with the audaciously bold potty mouth, and a appear lost aptitude on life,
Accused the Plaintiff of being and I (Hamilton) quote verbatim a Derelict of Houston Texas, among other things
And filed such a disgusting display of discriminatory practices and defamatory statement(s) before a Honorable Court of Law seeking to cause (among other things) the excitement frenzy in the News media directed at the Defendant(s) wrongful cause, among others media agencies for such an outlandish display of a wild and far out their brash discriminatory and defamatory conduct(s)
To include but not limited to the Defendant(s) (Arthur et al) seeks damages from the Holy Church namely Christ Church Cathedral at 1225 Texas Avenue, Houston, Texas 77002
In excess of ($50,000.00) Fifty Thousand Dollars and base this upon the described derelict conducts of the Plaintiff (Hamilton) and (many others) in which defendant(s) seeks to pilferage from the said church Christ Church Cathedral affiliation with the Beacon as stated in the complaint of the Defendant(s) (Arthur et al).
The Plaintiff assert strong condemnation for such a twisted heart full of unwashed socks,
With a soul full of gunk Grinch type act(s) the Defendant(s) (Arthur et al) attempt to disgracefully attempt to achieve at the expensive of the Holy Church, The Honorable Court, and The Plaintiff.
Plaintiff will show this Honorable Court that the Defendant(s) (Arthur et al) having full knowledge that his actions would certainly cause a excitement and defendant was deliberate in doing so;
To include but not limited to causing the Plaintiff unwanted additional mental anguish and unwanted additional emotional distress for said conduct(s) of the Defendant(s) (Arthur et al)
In which Plaintiff now having constant entertaining thoughts of wanting to bash in said defendant(s) grill” and peel his wig completely of his hide until HPD “Swat” arrival for said defendant(s) (Arthur et al) needed relief.
Which the Plaintiff “wisely” instead sought the needed expedited medical attention at the VACM on the 16th day of December 2009 to obtain explain the defendant(s) actions before the Plaintiff Mental doctor
and obtain additional medications for such mental needs in hopefully refraining the Plaintiff from entertaining such mental thoughts of going to the Defendant(s) place of business and beating him within an inch of his life with a black’s Law Dictionary, thus their after dragging him about the neck to the nearest toilet and give him a swirly potty mouth attitude adjustment treatment with further mental thoughts being entertained their after the Plaintiff taking a Permanent Black marker and write on the naked back of the Defendant Harry C. Arthur, “Derelict lives here” with a long thick black arrow pointing down to the Defendant (Arthur)→ “bum hole”.
The Plaintiff will show this Honorable Court that the Plaintiff is not a derelict as described by the Defendant (Arthur et al) and in fact Plaintiff currently engaging in (3) civil actions before a U.S. District Court of Law and (1) civil action in Texas State District Court to achieve (among other things) breach of contract dispute for
Plaintiff lost revenue from being a construction contract being cheated after hurricane Katrina, Rita, and Umberto by crooked home owners. Among other positive things the Plaintiff having currently pursues.
The Plaintiff will show this Honorable Court that the Defendant (Arthur et al) knew that the Plaintiff economic condition was that of a state of being poor, and chose to defame and discriminate against the Plaintiff for such an indigent status.
The Plaintiff will show this Honorable Court that defendant(s) conduct was discriminatory towards Plaintiffs Status of also being a Disable American or alternatively a Disable American Veteran.
The Plaintiff will show this Court that the term Derelict is use under the (UCMJ) Uniform Code of Military Justice, which is a Charge that no Man or Services women would ever wanting attached to their indivual service jackets, and is to this date punishable under said (UCMJ) for “Derelict of Duty”.
The Plaintiff himself is a Navy Veteran, and if (Arthur et al) made such a statement during the course of the Plaintiff military services without a very good cause for such a charge
And had not very good evidence to produce such facts before a Captain Mast against the Plaintiff, (Arthur et al) would certainly & unexplainably be physically “lost at sea”.
The Plaintiff will show this Honorable Court that the Defendant(s) (Arthur et al) having full knowledge that the demographic Census in Houston Texas make up of the population of Beacon clients is a majority within the African Americans community, which the Plaintiff is a race of African American decent, and this comment was directed at the Plaintiff race status of African American being in a state of Derelicts
The Plaintiff will show this Honorable Court that at no time did the Plaintiff take a part in pissing, crapping and or vomiting or any other bodily fluid discharge being wrongfully place at the property of the Defendant(s) (Arthur et al).
The Plaintiff will show this Honorable Court that the Defendant(s) (Arthur et al) has lied in his complaint to obtain monetary reliefs in regards to his property being in a state of lost revenue when facts dictate the following:
a. The Marine Building is being under constant video tape with police patrol through the back area and all facts that said defendant stated in regards to sleeping on his property and rest room usage among other things is documented.
b. At no time dose the Marine building post sentry and or security to deter such behavior.
c. The Marine Building has over (12) separate tenets providing income/revenue into said build owner accounts and the majority of said income derives from said tenets being Attorney at Law residing in office space
Of the Defendant(s) (Arthur et al) to include but not limited to the parking income the Build has generated
d. at no time did the Defendant(s) (Arthur et al) implement a low cost sprinkler system around the outside of the build on a timer to deter unwanted usage of his property for sleeping purpose and a low cost deterrent.
e. Officer Cuffy and his fellow officers having been providing such extra police care to the Beacon and its clients and the general public in this area to include but not limited to the Defendant(s) interest as well
That Police reports will prove such professional police response having taken place in this area of the city long before (Arthur et al) file his civil action and is contradicting the Defendant(s) claims before the Honorable Court.
f. That Defendant(s) (Arthur et al) having no proof to provide before the Honorable Court that the Homeless Derelicts of Houston is the responsible party instead to the pissing, crapping and or vomiting on the said property instead of the General Public after leaving the local baseball arena, and or local clubs, their after using the parking facilities located around the Marine Building and having the need for emergency pissing, crapping, and or vomiting on the property of the Defendant(s).
g. the Marine Build is no “Trump Plaza”.
Wherefore Plaintiff Louis Charles Hamilton II, request that Defendant (Trail) responds to the above Requests for Admissions propounded by the Plaintiff pursuant to Federal Rule of Civil Procedure 26 (b) (1),
In accordance with the Civil Laws of the above entitled United States District Honorable Court.
On the _______ day of __________, 2009
By, ____________________________
Louis Charles Hamilton II
Pro Se Plaintiff
P.O. Box, 342
Port Arthur, Texas 77640
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