United States District Court
Southern District of Texas
Houston Division
Louis Charles Hamilton II
Plaintiff Motion for Temporary Injunction Freezing all
Business Records, Documents, and Assets
Vs. Civil action No.H-10-2709
Harry C. Arthur (Esq.)
Defendant
Law office of Harry C. Arthur et al
Co- Defendant(s)
Marine Building, L.L.C. et al
Co-Defendant(s)
Comes now the Pro Se Plaintiff Louis Charles Hamilton II; files the above entitled motion, with attached brief and exhibit(s) in support of Plaintiff Order to show cause, Temporary Restraining Order, Order Freezing all Records, Documents, and to secure all of the Defendant(s) herein, Collective assets.
And for cause the Pro Se Plaintiff Louis Charles Hamilton II will show as follows:
1. On the Emergency application of Plaintiff
2. (Louis Charles Hamilton II) (the “Application”) for an Order upon:
“Harry C. Arthur Esq.” and all defendant(s) listed as:
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, Kandy Villarreal, Mark Thering, Darrel Jordon, Daniel Perez-Garcia, Marquerite Hudig, Carl D. Haggard, F.M. (Poppy) Northcut, Sandra Martinez and Allen J. Guidry “collectively Defendant(s) to an Order”
1. Directing (Harry C. Arthur et al) to show why an order should not be entered, pending a final disposition of this action civil action:
Preliminarily enjoining Defendants (Harry C. Arthur et al) from Further Violating the United States Chapter 96 of Title 18, United State Code: (RICO) Racketeering Influences Corruption Organization, 1341 (relating to mail fraud), section 1343 (relating to wire fraud), section 1503 (relating to obstruction of justice), with other State Charges being levy in connection their of;
2. With further Honorable Court requirement(s) directing Defendant (Harry C. Arthur et al) to provide a verified accounting immediately, including, but not limited to, a verified written accounting of (Harry C. Arthur et al) interests in all entities owned, in whole or in part, or controlled by, related to, or associated or affiliated with (Harry C. Arthur et al) in the United States;
3. Freezing all of the Defendant(s) Business records, banking records, personal banking records, Documents Commercial property records and all assets for all of the above listed Defendant(s) collectively in The United States
4. Which is necessary to protect this Honorable Court ability to decide from the preponderances in deciding the weight of factual evidence,
5. With furtherance allowances in the Honorable Court ability in fully applying just awards of all equitable relief within all assets, moneys and property held directly or indirectly by the Defendant being held in lieu of,
6. For all of the Plaintiff direct damages with emotional pains and suffering, total national disgrace and for a conducted inconclusive conduct of Attorneys of Law in and for the State of Texas
7. To having among other things committing a criminal (RICO) “Mail and Wire” Fraud scheme of things against the Plaintiff rights, will, and dignity to which said Plaintiff Louis Charles Hamilton II seeks as a final full complete fair render judgments for all of the said extreme and outrageous conducts, vulgar hostile degrading acts and actions as complain of here in with all of the records store in the file of this numbered cause of action.
Wherefore the Plaintiff respectfully seeks and Order directing collectively Arthur Esq. from destruction of book keeping records, documents, banking records and all Assets
a. Or by others for Defendants (Arthur et al) direct and indirect beneficial interest which is necessary to effectuate and ensure compliance with the freeze imposed on the Defendants (Arthur et al) assets, preserve the books, banking records and all business documents and records of Defendants (Arthur et al), until the court having the ability to determine the extent to which the freeze should be lifted as to certain records, documents, records and assets in the custody of Defendants (Lawson M.D.)
b. Forfeiture of the Defendants (Arthur et al)) Deposition conducted by Andy Vickery;
c. Prohibiting the destruction, concealment, or alteration of documents by defendants; and
d. Preliminarily enjoying Defendants (Arthur et al) and their partners, owners, agents, employees, attorneys, or other Professional, anyone acting in concert with them, and any third party from filing a bankruptcy proceeding the Defendants (Arthur et al) without filing a motion on at least three (3) day’s notice to the Plaintiff and approval of this Honorable Court after hearing; and
Pending final adjudication, arbitration, negotiation, mediation, settlement of the Civil Cause of Action:
Louis Charles Hamilton II
Plaintiff
Vs.
Harry C. Arthur (Esq.)
Defendant
Law office of Harry C. Arthur et al
Co- Defendant(s)
Marine Building, L.L.C. et al
Co-Defendant(s)
Collectively Defendant(s)
Plaintiff enjoyment of An Order “Temporary Restraining” Defendant (Arthur et al) from violating the statutes and rules of the United States Namely Chapter 96 of Title 18, United State Code: (RICO) Racketeering Influences Corruption Organization, 1341 (relating to mail fraud), section 1343 (relating to wire fraud), section 1503 (relating to obstruction of justice), with other State Charges being levy in connection their of;
With further orders of this Honorable Court requirement(s) directing Defendants (Arthur et al) to provide a verified accounting immediately, including, but not limited to, a verified written accounting of (Arthur et al) interests in all entities owned, in whole or in part, or controlled by, related to, or associated or affiliated with (Arthur et al) in the United States of America.
Freezing all of the commercial property records, banking records, personal banking records, and all “assets” collectively of the Defendants (Arthur et al) in The United States.
Brief
1.
Good and sufficient cause and reasons exist why procedure other then notice of motion is necessary, for a Order to show cause, Temporary Restraining Order, and Order Freezing Assets; And Order to Secure All Defendants Business and personal banking records, Commercial Property records and immediate forfeiture of the Deposition conducted upon the Defendant Commander in Chief Defendant “Harry C. Arthur Esq.” upon a time unknown to the Plaintiff”
With Plaintiff attached support motion in opposition to dismiss filed herein before the Honorable Court with exhibits in support.
2.
This Honorable Court having jurisdiction over all of the subject matter of this action and over all of the Defendants collectively action in (Arthur et al) acts, and action in regards for needed “Temporary restraining Relief” as described herein” on behalf of the Plaintiff Louis Charles Hamilton II as described in the Complaint of the original complaint
And reinforced in the Amend complaint of the Plaintiff with detail factual facts for a cause of actions for the rightful full reliefs sought.
3.
In a civil-related court proceeding In the District Court of Harris County, Texas in the matter of Arthur et al vs. (Christ et el)
Which is a direct cause of Plaintiff cause of actions against each said described Defendants collectively herein for such extreme acts acting as “Acting Attorneys of law among other things in Defendants criminal structure of a “legal (RICO) “Mail and Wire” Corrupt Type Criminal Shenanigans” among other things in violation under Texas State Laws.
4.
Defendant (Arthur Esq.) admitting to actual ownership of the rightful rights to a Deposition dated
Plaintiff belief being conducted on or about the date of February 9th, 2007 with Defendant (Arthur Esq.) further pattern and practice of illegal bogus claims that said deposition being conducted is his own “personal work product and this also is protected and or simply falls under Defendants et al Attorney/Client Privileges.
*See Plaintiff attached exhibit (A) and (B)
Plaintiff request for production of documents and Defendants Arthur et al replies thereon.
Plaintiff moves the Honorable Court to take notice that the Defendant(s) completely conspire in committing to further perjury mistake in these false facts alone in the actual knowledge that (Arthur Esq.) deposition was conducted upon (Arthur Esq.)
Which is making this simply stupid and impossible to be direct examination work on (Arthur Esq.) himself with all work products involved therein for perpetration thereof being premeditated against (Arthur Esq.)…?
5.
Plaintiff respectfully assert before the Honorable Court Defendants (Arthur et al) collectively having already Manufacturing, invented, conjured, developed, built up, mechanized fictitious court proceedings accounts, then supply this criminal RICO Mail & Wire Fraud scheme of things
Within reports, and commercial property records, receipts and banking accounts involvement of all of “Co-Defendants (Marine Building et al) business records, tenant records and personal accounting all to be true before the Harris County Court records as apply for and as described in Plaintiff Amend Complaint against all collectively Defendants herein.
7.
All Defendants in (Arthur et al) most seriously acting with a pattern and practices of conformity, loyalty, and fidelity to the Defendant (Arthur Esq.) himself’
Who being “Commander in Chief” in all interest in the Commercial property complain of namely “Marine Building L.L.C. et al.
With “Law office of Harry C. Arthur Esq. et al” being the full direct instruments” to all executions of all legal documents, and records for the illegal usages in a criminal RICO “Mail and Wire” scheme things
With Harry C. Arthur personal private life reaping major rewards by wrongfully acting out a criminal RICO mail and wire fraud scam at the expense of the Plaintiff will, right, and dignity; Among others.
9.
Defendants (Harry C. Arthur et al) having now provided clear and convicting, condemn and villain evidence of a extremes and outrageous, conduct with
Actions, of a total harmful nature of being a suppose group of Professional Attorneys of laws…. no less with conflicting, contradictory, incompatible, inconsistent, differing, disagreeing statements in regards to among other thing
The Deposition of Attorney Andy Vickery and Kinney IV being conducted upon Arthur Esq. whom (Arthur et al) is now fraudulent with bogus intent by wrongfully claiming said deposition as his personal property under work product doctrine and Attorney Client privileges as described in Plaintiff attached exhibits herein.
Furtherance attempt to the apply hinder of Plaintiff full rights to direct evidences in this matter as described in the Plaintiff original complaint and Plaintiff attached exhibit (C) * Plaintiff motion to compel said deposition filed in Harris County Court Records. With Plaintiff exhibit (D) Defendant(s) reply to request file in Harris County records.
10.
Not with standing all facts against Defendants (Arthur et al) as described in the original complaint, and Amend Complaint with the exhibit(s) herein in support appears to support that a temporary injunction Order Freezing all Assets, all Commercial Business records of Marine Building L.L.C. et al, its documents, both Business and Personal Banking records of all described defendant(s) collectively above
And Order to Secure the Deposition of Andy Vickery and Kinney IV, conducted on (Arthur Esq.) is immediately proper, just, suitable, appropriate, accurate and polite for the Honorable Court to issue such an order
“With such “suspicious behavior” and fraudulent “Business dealings” of said Defendants (Harry C. Arthur et al) to include but not limited to all allegations of Violations under
Chapter 96 of Title 18, United State Code: (RICO) Racketeering Influences Corruption Organization,
Section 1341 (relating to mail fraud), section 1343 (relating to wire fraud), section 1503 (relating to obstruction of justice), with other State Charges being levy in connection their of;
All of which is of a civil/criminal shameful notoriety type in an inexplicable nature being committed
To include but not limited to all Defendants in (Harry C. Arthur et al) ability to provide multi-bogus fraudulent information, records, and documents under such corrupt RICO “Mail and Wire Fraud scheme business practices in that most Defendant(s) herein are in fact in an Attorney Profession of Law with the expert ability to further hinder the legal matter now appearing before the Honorable Court
If a restraining order is not enjoyed at this time on behalf of the Pro Plaintiff Louis Charles Hamilton II for an enforcement of all rightful freezes of all commercial property business records, documents, banking records and assets for proper inspection, studies and examination for evidences for all monetary Judgments in this action Plaintiff seeks; with out the Honorable Court enforcement;
Plaintiff Louis Charles Hamilton II is at further “great risk”, in large part of Defendant (Arthur) multi-ability to provide destruction, alter, hiding, deposal, transferring all of the described records, documents, commercial property records, defendants collective banking records
With two defendant(s) collectively already “fleeing” from “Marine Building L.L.C. et al” as described in Plaintiff attached exhibit (E) Photographs of “tenant exodus”
“A for rent signed” posted August 8th 2010 and exhibit (F) letter stamp return to sender Co-Defendant moved from all “pending civil actions” before the Honorable Court their after services of process having already been executed for Trial.
With other Defendant (Arthur et al) possible already secrete further fleeing from any “Civil collateral damages” as a result of civil prosecution for Defendant(s) collective conducts, acts and actions as described in the records, evidence, and files here within.
Defendants (Arthur et al) having the ability to further complicate the legal issue if a further court order is not enforce to Freezing all of the records documents and assets of the Defendant in The United States
And immediate forfeiture of the Defendants (Arthur et al) Deposition discovery evidence as stated;
Which Plaintiff Respectfully asserts this is now the case at this time frame to necessary fully protect this Honorable Court ability to award all rightful equitable relief of all assets, moneys and property held directly or indirectly by the Defendant (Arthur et al) And;
Or by others for Defendant (Arthur et al) direct and indirect beneficial interest is necessary to effectuate and ensure compliance with the freeze imposed on the Defendant (Arthur et al) assets, preserve the books, records and documents of Defendant (Arthur et al),
This Honorable Court having the ability to determine during any further hearing if required to the extent to which the freeze should be lifted as to certain assets in the custody of Defendant (Arthur et al) and
Immediate forfeiture from the Defendants (Arthur et al) Deposition conducted by Andy Vickery and Kinney; is necessary, just and proper in light of the exhibit(s) filed herein and the Plaintiff positions and the described fraudulent conducts of Defendant (Arthur Esq.) in regards to said discovery evidence (Deposition).
Plaintiff Respectfully requirements of an additional order Prohibiting the Defendant (Arthur et al) from destruction, concealment, or alteration of documents by defendant in relationship to this civil action; and a
Preliminarily enjoying of Defendant (Arthur et al) and their partners, owners, agents, employees, attorneys, or other Professional, anyone acting in concert with them, and any third party from filing a bankruptcy proceeding in regards to the assets of the Defendant (Arthur et al) without filing a motion on at least three (3) day’s notice to the Plaintiff and approval of this Honorable Court after hearing;
Conclusion
The Plaintiff Respectfully strongly, declare, state, emphasize, affirm, contend, defend, maintain, uphold, assert of having no legal ability at this current time frame to correctly obtain all documents base upon the evidence filed herein and the Defendants collective continue desire in the destruction, false allegations in connection to depositions, with the exodus of Defendant(s) with the records their after civil action having been instituted.
Plus the Pro Se Plaintiff respectful strong assortments of illegal exodus of several Defendants fleeing with documents, records, files, and exhibits wrongfully from cause of action warrant enforcement of the Honorable Court intervention on behalf of the Plaintiff during the course of this Civil Numbered cause before the Honorable Court.
Wherefore the Pro Se Plaintiff Louis Charles Hamilton II at this time frame respectfully moves the Honorable U.S. District Court after consider, deliberate, take into account, ponder, mull over, contemplate, bear in mind and respectfully confer with “Lady Justice” expedite for an Order on the Plaintiff behalf to:
Asking Defendant (Arthur et al) to appear through counsel of record “Law office of Harry C. Arthur et al” whom appearing Pro Se before the Honorable Court
At a hearing date preset to show cause why a Temporary order freezes all commercial and personal banking records, all asset(s) of Defendant (Harry C. Arthur et al) through both pre-post proceedings
And further asking Defendants (Arthur et al) to show cause why an Order to Secure All Defendants records, documents and assets of (Arthur et al), not being granted in Plaintiff favor and enforced on the Plaintiff behalf throughout both pre-post proceedings by the Honorable Court
With Plaintiff further enjoying the Honorable Court further protected Orders: Prohibiting Defendants (Arthur et al) engaging in the destruction, concealment, or alteration of all documents, papers, records, credentials, assets, books, and property(s) owned by defendants (Arthur et al);
And With further orders of this Honorable Court: requirement(s) directing Defendant (Arthur et al) to provide a verified accounting immediately, including, but not limited to, a verified written accounting of (Arthur et al) interests in all entities owned,
In whole or in part, or controlled by, related to, or associated or affiliated with (Arthur et al) in the United States of America.
With a Preliminarily enjoying all of the Defendants herein described above in (Arthur et al) and their partners, owners, agents, employees, attorneys, or other Professional, anyone acting in concert with them, and any third party from filing a bankruptcy proceeding in regards to the assets of the Defendants in (Arthur et al) without filing a motion on at least three (3) day’s notice to the Plaintiff and approval of this Honorable Court after hearing;
Definition: “Assets” In financial accounting, assets are economic resources. Anything tangible or intangible that is capable of being owned or controlled to produce value and that is held to have positive economic value is considered an asset. Simply stated, assets represent ownership of value that can be converted into cash (although cash itself is also considered an asset).
The balance sheet of a firm records the monetary value of the assets owned by the firm. It is money and other valuables belonging to an individual or business.Two major asset classes are tangible assets and intangible assets. Tangible assets contain various subclasses, including current assets and fixed assets.
Current assets include inventory, while fixed assets include such items as buildings and equipment.
Intangible assets are nonphysical resources and rights that have a value to the firm because they give the firm some kind of advantage in the market place. Examples of intangible assets are goodwill, copyrights, trademarks, patents and computer programs,
And financial assets, including such items as accounts receivable, bonds and stocks.
Current assets are cash and other assets expected to be converted to cash, sold, or consumed either in a year or in the operating cycle (whichever is longer), without disturbing the normal operations of a business. These assets are continually turned over in the course of a business during normal business activity. There are 5 major items included into current assets:
1. Cash and cash equivalents — it is the most liquid asset, which includes currency, deposit accounts, and negotiable instruments (e.g., money orders, cheque, bank drafts).
2. Short-term investments — include securities bought and held for sale in the near future to generate income on short-term price differences (trading securities).
4. Inventory — trading these assets is a normal business of a company. The inventory value reported on the balance sheet is usually the historical cost or fair market value, whichever is lower. This is known as the "lower of cost or market" rule.
5. Prepaid expenses — these are expenses paid in cash and recorded as assets before they are used or consumed (a common example is insurance). See also adjusting entries.
Long-term investmentsOften referred to simply as "investments". Long-term investments are to be held for many years and are not intended to be disposed of in the near future. This group usually consists of four types of investments:
1. Investments in securities such as bonds, common stock, or long-term notes.
2. Investments in fixed assets not used in operations (e.g., land held for sale).
3. Investments in special funds (e.g. sinking funds or pension funds).
Different forms of insurance may also be treated as long term investments.Fixed assets
Also referred to as PPE (property, plant, and equipment), these are purchased for continued and long-term use in earning profit in a business. This group includes as an asset land, buildings, machinery, furniture, tools, and certain wasting resources e.g., timberland and minerals. They are written off against profits over their anticipated life by charging depreciation expenses (with exception of land assets). Accumulated depreciation is shown in the face of the balance sheet or in the notes.These are also called capital assets in management accounting.
Intangible assets
They include patents, copyrights, franchises, goodwill, trademarks, trade names, etc. These assets are (according to US GAAP) amortized to expense over 5 to 40 years with the exception of goodwill.Tangible assets
Tangible assets are those that have a physical substance and can be touched, such as currencies, buildings, real estate, vehicles, inventories, equipment, and precious metals.With all commercial records, banking records both personal & business, all documents, rent receipts and all other documents relating to the Business records of this action and all defendant herein collective personal records.
4. And for any other reasoning this Honorable U.S. District Court in and For the Southern District of Texas, Houston Division,
5. Deems Just Honorable and proper on the behalf of the Pro Se Plaintiff Louis Charles Hamilton II.
Respectfully submitted and
Dated On the _______ Day of __________, 2010
By, ____________________________
Louis Charles Hamilton II
Pro Se Plaintiff
P.O. Box 20126
Houston, Texas 77225
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