United States District Court
Eastern District of Texas
Beaumont Division
Louis Charles Hamilton II Complaint
Pro Se Plaintiff Jury Demand
Vs.
Willie M. Zanders
Attorney at Law
Defendant
Walter A. Dennis and
Rosemary Dennis
Co-Defendant(s)
Comes Now the Pro Se Plaintiff, Louis Charles Hamilton II, hereby files a Complaint with the above Honorable Court and for Just Cause”
The Pro Se (Louis Charles Hamilton II) Plaintiff will show the Honorable Court all facts, circumstances and details as being entertain in Justice as follows:
1.
Parties
Pro Se Plaintiff , Louis Charles Hamilton II, African American Male, Currently Homeless U.S. Navy Veteran, Permanently Disable Veteran protected under: (ADA) American with Disability Act; And also minorities persons cover under Title VII of the Civil Rights Act of 1964; Domiciliary State of Texas, P.O. Box 20126 Houston, Texas 77225
2.
Defendant
Willie M. Zanders Esq.
A New Orleans L.A. Attorney at Law: Business Address is at 1100 Poydras Street, Suite 1455, New Orleans, Louisiana 70163
Co-Defendant(s)
Walter A. Dennis and
Rosemary Dennis (Home owners)
3826 General Taylor Street
New Orleans, LA 70125
3.
Venue
Venue is proper before the above Honorable Eastern District of Texas U.S. District Court in that:
Plaintiff parties: Pro Se Plaintiff Louis Charles Hamilton II current in reside within Jefferson County, Texas (Area) when all incident(s) as described herein occurred;
“Plaintiff receiving current mail only in Harris County Texas for Plaintiff safety reasoning.
Defendant parties:
Willie M. Zanders Esq.
1. A New Orleans L.A. Attorney at Law: Business Address is at 1100 Poydras Street, Suite 1455, New Orleans, Louisiana 70163
2. Co-Defendant(s) parties: Walter A. Dennis and Rosemary Dennis New Orleans residents 3826 General Taylor Street New Orleans, LA 70125
4.
Jurisdiction
The Plaintiff Louis Charles Hamilton II Respectfully moves and asserts that the above Honorable U.S. District Court has proper Jurisdiction venue over all subject matters involving herein under Federal Question(s); in which the (Government) is a party.
The amount of monetary fund’s in controversy exceed the Jurisdictional limits of $75,000.00,
Plaintiff “Louis Charles Hamilton II”, a citizen of Texas, proceeds Pro Se and in forma pauperis.
Defendant herein “Willie M. Zanders” is a Professional Attorney at Law, also licenses on the “Federal Venue” within the State of Louisiana.
Defendant Hereafter (Zanders) who is a Citizens of Louisiana, with his “Law Office” located at 1100 Poydras Street, Suite 1455 in New Orleans, Louisiana zip code 70163.
Co-Defendant(s) Walter A. Dennis and Rosemary Dennis New Orleans who also are residents at 3826 General Taylor Street in New Orleans, LA 70125
Co-Defendant(s) Hereafter (Dennis et al)
5.
Plaintiff hereby respectfully assert before the Honorable Court that a “true diversity in citizenship” exist between the all of the Parties as described above,
6.
Plaintiff Louis Charles Hamilton II herein seeks compensatory awards, intentional infliction of emotional distress and anguish,
Additionally exemplary awards” under Federal (RICO) Statues against Defendant (Zanders) and Co-Defendant (Dennis et al) individually as described herein for combine committed “acts and actions” in Violations under Chapter 96 of Title 18,
7.
United State Code: (RICO) Racketeering Influences Corruption Organization practices of Section 1341 (relating to mail fraud)
And Defendant (Zanders) and Co-Defendant (Dennis et al) in violation of section 1343 (relating to wire fraud),
Against the civil legal rights of the Plaintiff in connection with (Zanders) attempts in an illegal criminal covering shenanigans up type acts and actions of a construction contractual agreement
While Defendant (Zanders) acting in a Attorney of law “professional manner” of expertise
To aid (Dennis et al) in an furtherance scheme of things for consequential conspiracy in providing false materials facts in all court documentations contaminated with all defendants collusion of “Actual Mail and Wire Fraud” of the Honorable United States of America Judicial District Court “Mail and Wire System”.
all of which having in the past already been committed to the Plaintiff by Co-Defendant(s) described herein as one “Walter A. Dennis and Rosemary Dennis” here after identified as (Dennis et al)
8.
Throughout a well devise scheme criminal (RICO) “Mail and “Wire Fraudulent work product doctrine design, of the main Defendant (Zanders) to fraud and attempt to defeat the Plaintiff during several legal Federal civil proceedings before a Honorable Court of law.
To include but not limited Defendant herein (Zanders) herein collectively in gig, alliances, concert, and commitment(s) to all illegal criminal acts and actions of aiding and abetting,
Assisting and participating with Co-Defendant(s) (Dennis et al) in Fraud related activities related to damages dated back to 08/29/05 as a result “Hurricane Katrina “making land fall in the New Orleans L.A. Area
9.
With Defendant (Zanders) and Co-Defendant(s) (Dennis et al) committed “Mail and Wire” fraud type scheme of things involving Insurance check issued on or about:
10.
November 14, 2005 in the Amount of $46,185.50 from Fidelity National Insurance Company P.O. Box 330005 “Food loss Account” St. Petersburg’s Fl. 33733-8005, policy number 17251020862900, claim number 105-0066431 CK# 2020319 in collusion with Insured name “Walter Dennis” (Co-Defendant) with the same scheme of things on or about:
11.
December 29th, 2005 in the Amount of $17,200.00 from Fidelity National Insurance Company P.O. Box 330005 “Food loss Account” St. Petersburg’s Fl. 33733-8005, policy number 17251020862900, claim number 105-0066431 CK# 2043957 in collusion with Insured name “Walter Dennis” (Co-Defendant) with the same scheme of things on or about:
12.
December 28th, 2005 in the Amount of $10,500.00 from “United States Treasury” 2221 75628522 70070002 M1 FEMA WASH 00NC003867 Disaster Assistance in collusion with Rosemary Dennis (Co-Defendant) with the same scheme of things on or about:
13.
June 8th 2006 in the Amount of $8543.00 from “United States Treasury” 2221 76990791 70070002 M1 FEMA WASH 00NC004194 Disaster Assistance in collusion with Rosemary Dennis (Co-Defendant) with the same scheme of things involving
14.
“Whitney National Banking” account of “Walter A. Dennis and Rosemary T. Dennis 735 Dulles Ave Apt. 1207 Stafford, TX 77477 involving Defendant herein (Zanders) fraud in collusion of “Disaster Assistances” and recover relief repairs for the Home of Co-Defendant (Dennis et al),
15.
To include but not limited to Defendant (Zanders) conspiracy scheme of things with Co-Defendants (Dennis et al) in providing numerous false manufactured computation(s) in several court documents regarding“fake financially fraudulent building materials figures,
Double up building material figures to conspire in acts of direct fraud for providing false material facts of services of payments been already received, all being done with involvement in;
16.
“Construction Contracts, Service Order Invoices, Sub-Contractor proposals, Building Material Receipts and other material records involving fraud in excess of $49,500 Dollars for monies being provided by two third parties as described above.
17.
Defendant herein “Willie M. Zanders” Attorney at Law having done all destructive “Mail and Wire Fraud scheme of things with a total hostile, willful, wanton, illegal desire in collusion with (Dennis et al) under a “viscous corrupt criminal rouge type professional conduct of an Attorney of Law and doings so against the peace, civil rights, dignity and monetary earnings of the Plaintiff;
18.
While Defendant herein (Zanders) herein expressing a total disregard for all conscious in the legal assigned professional capacity of an “Attorney of Law” in and for the State of Louisiana to be actually involved and “fully committed” to acts & Actions of “Direct Mail and Wire” fraud” Obstruction of Justice among other fully committed activities
Against the Plaintiff rights under a “contractual breach of contract”
19.
To include but not limited to Defendant (Zanders) extreme acts of (RICO) criminal “Mail and Wire” Fraud scheme of thing being committed not only against the Plaintiff for this fraud scam
But also being committed against (two third parties) as described above whom all acted for the “humane well interest” of the Co-Defendants (Dennis et al) well being their after “Hurricane Katrina” destroyed their home located at 3826 General Taylor Street in New Orleans LA.
20.
Plaintiff assert Respectfully before the Honorable Court that the Co-Defendants (Dennis et al) provided all of the “material facts” needed In the creation and introduction of (Zanders) Attorney at law “fabricated computations figures of evidence and defamation campaign against the Plaintiff (Hamilton) on or about a date unknown and said “all bogus material facts and evidences being made under Defendant herein (Zander) exact “Work Product Doctrine” design on the behalf of (Dennis et al) to wit:
22.
Defendant (Zanders) in his professional capacity of an Attorney of Law supply (Dennis et al) numerous fabricated Fraudulent computations figures; In numerous legal court documents related to construction restoration works of the home in New Orleans L.A. After damages of Hurricane Katrina.
23.
Defendant (Zanders) conspire in hiding factual evideances of a squander scam in Insufficient funds of (Dennis et al) by providing the fictitious legal court documentations contaminated with fraudulent computations figures in regards to connection thereof a contractual construction agreement in (Dennis et al) needed “Hurricane Katrina” repairs.
24.
Defendant (Zanders) doing so against the Plaintiff legal rights in an “Mail and Wire fraud conspiracy scheme to fraudulent pursuit and hide squandered income, while defaming the Plaintiff in the process, while (Hamilton) other contractual agreement also being a direct cause of losses Plaintiff having to suffer additional from (Dennis et al) illegal actions
25.
Plaintiff (Hamilton) Respectfully assert before the Honorable Court
Co-Defendants (Dennis et al) did in fact make several filing of Defendant (Zanders) numerous fabricated Fraudulent computations work products, and claims against the Plaintiff construction reputation in this United States Eastern District of Texas Court “Mail and Wire” system.
26.
Plaintiff (Hamilton) Respectfully assert before the Honorable Court Co-Defendant (Dennis et al) doing all of this criminal act in collusion with Defendant (Zanders) as appearing “Pro Se before The United States District Court for The Eastern District of Texas Beaumont Division
27.
Plaintiff further respectfully assert such (RICO) Criminal and “Mail and Wire” fraud scheme of things was controversial in all direct material facts as aid in Co-Defendant(s) (Dennis et al) filing of Defendant (Zanders) “Mail and Wire” fraudulent rogue work product with bogus computations of monetary figures and defamatory statement of the Plaintiff construction reputation in all said legal court documents.
28.
Plaintiff (Hamilton) assert before the Honorable Court Defendant (Zanders) conspiracy Being done illegally in aiding at attempts of defeating Plaintiff in the civil matter still pending over a contractual disputed between Plaintiff and Co-Defendant (Dennis et al).
29.
Plaintiff will show the Honorable Court that Co-Defendant(s) (Dennis et al) thus using all said rouge factious fabricated computations of monetary figures, defamation statements, double up building material documentations filed among all other proper court appearance documentations with “direct defamatory statements of the Plaintiff construction reputation
Supply by Defendant herein (Zanders) to Co-Defendants (Dennis et al) to attempt to wrongfully appear being legal, just, and proper before said several Honorable United States Eastern District Court of Law That Co-Defendant(s) (Dennis et al ) did not squander relief funds in excess of $35,000.00 dollars between the time period of August 29th 2005 throughout the 31st of December 2007
30.
To furtherance a apperance before the Honorable United States Eastern District Court that Co-Defendant(s) (Dennis et al) were not on a spending spree of said disaster relief funds in Sugar Land Texas Area from the dates of Hurricane Katrina throughout February 2007 , and (Dennis et al) did not purchase a “New Vehicle” with said fundamental funds
To included but not limited to Co-Defendants (Dennis et al) doing the same squander spree of fundamental reconstruction funds throughout the end of December 31 of 2009.
31.
To include but not limited to this (RICO) “Mail and Wire” criminal ploy scheme of things by (Zanders) and (Dennis et al) being committed also against said ( two third Parties) in connection with the Plaintiff (Hamilton) performance of restoration of all works as agreed under said contract with all “third parties” fundamental monetary provisions being said source of revenue for the restoration of (Dennis et al).
32.
Plaintiff assert Defendant herein (Zanders) Attorney at Law then further “posted, promoted and publish a huge bogus (RICO) criminal scheme of things throughout the United States “mail system and wire system via said wire transmission first through out the Texas Eastern District Federal Court Wire system
In the caption under Plaintiff (Hamilton) vs. Mr. And Mrs. Dennis et al Civil Action No. 1:09-CV-289 via from the United States Mail service across state line of Texas from Co- Defendant(s) (Dennis et al) 3826 General Taylor Street, New Orleans, LA 70125 address,
33.
Then Defendant herein (Zanders) secondly continue his same criminal collectively in concert with the Co-Defendant(s) (Dennis et al) “Mail and Wire” fraud scheme of things in the past filed of already numerous bogus document and records filed on or about May 29th 2007 in the United States Louisiana Federal Court Wire system via from the United States Mail in a motion to dismiss Plaintiff Complaint Civil No. 07-1510
32.
Being all done illegally by (Zanders) in aiding at furtherance of attempts of defeating Plaintiff (Hamilton) in the civil matter still pending over a contractual disputed between Plaintiff and Co-Defendant(s) (Dennis et al).
Which this criminal (RICO) “Mail and Wire Fraud scheme of things was not only to cheat against the Plaintiff earn revenue in regards construction restoration of Co-Defendant(s) (Dennis et al) home.
33.
This collusion fraud scam of Defendant (Zanders) involving also criminal (RICO) “Mail and “Wire Fraud scheme of things against (two third parties) as described above whom acted for the humane interest of Co- Defendant(s)(Dennis et al) well being their after “Hurricane Katrina” destroyed their home located at 3826 General Taylor Street in New Orleans
Which the Plaintiff will show the Honorable Court the monetary funds was designated for the Plaintiff economic interest as described under the contractual agreement between the Plaintiff and Co-Defendant(s)(Dennis et al).
34.
Plaintiff Respectfully Assert the above Honorable United States District Court has subject matter Federal Jurisdiction over all Matters involving:
Violations under Chapter 96 of Title 18, United State Code: (RICO) Racketeering Influences Corruption Organization
Section 1341 (relating to mail fraud) and section 1343 (relating to wire fraud),
35.
Additionally the above Honorable U.S. District Court having subject jurisdiction over matters involving “Obstruction of Justice” and Fraud upon a United States District Honorable Court committed by Defendant (Zanders) on the Behalf and bequest of the Co-Defendant(s) (Dennis et al) to preserve any criminal proceeding as a result of (Dennis et al) crooked underhanded activities as designated herein
With The Honorable United States District Court entertainment holding “Special Jurisdiction” for all criminal (RICO) offense involving a “Mail and Wire” Fraud Scheme of things having been already committed by Defendant herein “Willie M. Zanders” (Attorney at Law) against the Plaintiff rights, will, and dignity as
36.
Described herein being done singularly and collectively against the Plaintiff Louis Charles Hamilton II, while involving both the State of Texas United States District Federal Court Judicial system..!
And in the past the State of Louisiana United States District Federal Court Judicial system..!
With defendant herein “Willie M. Zanders Esq.” furtherance of said (RICO) “Mail and Wire” fraud scheme in violation of both said mentioned states laws being “Texas and Louisiana” to include but not limited to all local laws governing thereof’ in connection to all facts complain of herein and provided
37.
By the Pro Se Plaintiff Louis Charles Hamilton II in connection to among other things a “Mail and Wire Fraud scheme of thing of Defendant (Zanders) Attorney of Law in conspiracy in connection with Co-Defendant “Mr. Walter A. Dennis” and Co-Defendant “Mrs. Rosemary Dennis” of 3826 General Taylor Street New Orleans, L.A. 70125 to Fraud the Plaintiff, FEMA and Private Insurance Companies.
38.
To include but not limited to the Honorable U.S. District Court having the exercise fundamental Jurisdiction over all State(s) Subject matters involving Defendant (Zanders) “Fraud scheme activities upon the United States District Court(s) for the Eastern District of Texas involvement of the Plaintiff (Hamilton) construction reputation
Which this additionally was wrongfully done in Defendant (Zanders) capacity of an Attorney of law(s) and a officer of the Honorable Federal Courts system in and for the State of Louisiana
39.
To include but not limited defendant herein (Zanders) carry out a (RICO) Criminal Organization of a well premeditated plans in connection and concert with (Dennis et al) to Fraud the Plaintiff during several Federal Judicial proceeding while systematically involving the usage of among other things such acts as actual criminal scheme of things involving fraud of the Honorable Court System for illegal profit being committed during a legal federal civil court proceeding
40.
With the Honorable United States District of America Eastern District Court exercise its fundamental Jurisdiction of proper venue to Honorably file a “Declaratory Judgment” in that all material facts herein are Deem absolute True as described by the Plaintiff
Warranting Declaratory Judgment in favor of the Plaintiff with compensatory, and exemplary awarding being in favor of the Plaintiff Louis Charles Hamilton II just relief sought herein.
41.
Fact(s)
To Wit: The Pro Se Plaintiff Louis Charles Hamilton II, Respectfully assert all truthful material facts herein before the above entitled-Honorable U.S. District Court and making Declaration under Penalty before Law in that on or about:
42.
The Plaintiff will Respectfully show the Honorable Court the above-captioned matter was first commenced in the U. S. District Court for the Eastern District of Louisiana on April 2, 2007 with a complaint against the Co-Defendants (Dennis et al ) filed by contractor Louis Charles Hamilton II
for “Breech of Contract,” and “Defamation and Intentional Infliction of Emotional Distress.”
43.
Furthermore, the Plaintiff will Respectfully show the Honorable Court the Plaintiff's application to proceed in forma pauperis was granted on June 5, 2009.
44.
The Plaintiff will Respectfully show the Honorable Court that the Plaintiff seeks the following specific sums:
(1) $21,000 for Breach of contract;
(2) $49,500 and $8,500 in Damages for two contracts allegedly lost as a result of Defendant's defamation of plaintiff;
(3) $2,400 in uncompensated extra work performed by Plaintiff;
(4) $49,500 in damages for intentional infliction of emotional distress; and
(5) an unspecified amount for fraud in a on going Civil Action in New Orleans LA United States District Court.
(6). Exemplary Damages Under (RICO) Statues.
45.
The Plaintiff Respectfully will show the Honorable Court that:
(1) Co-Defendant's moved to Texas prior to Hurricane Katrina making landfall.
(2) Co-Defendants continue to live in Texas after Plaintiff filed a building permit on their behalf for work at the General Taylor address in New Orleans;
(3) Co-Defendants had been living in Texas for over a year and eight months before they decided to restore the New Orleans home;
(4) Co-Defendants currently used a cell phone that has a Texas area code
(5) Co-Defendants' purchase a (SUV)/car which displays a Texas license plate.
(6) Co-Defendants' obtain services of Church Volunteers to finish 30% finial Construction phase of the Home in Contractual agreement with the Plaintiff.
46.
The Plaintiff will Respectfully show the Honorable Court that the Co-Defendant's (Dennis et al) Main Building located at 3826 General Taylor in New Orleans LA. Had water filled through out the lower level of the home,
to include all main upper floor Levels, primary cause by rising flood waters and high sustaining winds from “Hurricane Katrina”.
47.
The Plaintiff Respectfully show the Honorable Court that the lower Rom and Main floor, sheet rock had loosening, rotten and mold completely through out the flood phase and has been removed.
48.
The Plaintiff will Respectfully show the Honorable Court that the Foundation of this home located in the lower level is made of concrete with a bath room concrete pad poured over the lower pad and plumbing running underneath this area, this are has to be reform/frame for a New Bath Room, with framing for a utility room.
49.
The Plaintiff will Respectfully show the Honorable Court that the Living Room's hard wood floors had been exposed to sitting under flood waters until completely fallen apart with mildew infestation growing.
Furthermore, the mildew infestation accrued to the tile floors in the lower level of this home.
50.
The Plaintiff will Respectfully show the Honorable Court that the upstairs Bathroom flooring, sub-flooring, and floor joists are completely rotten from termite damaged and had caved, causing extensive needs of structure re-framing in that area, to include changing out of the sewer line.
51.
The Plaintiff will Respectfully show the Honorable Court that the Co-Defendants (Dennis et al) agreed to restore the sheet rock though out @ 8” o. c. with a texture finish, prime, and painted to the customer color scheme. Insulation in the ceiling and walls as required.
Furthermore the Defendants agreed that the first Multi construction to install New Water Line, Complete Demo of the Entire Home, Demo out the Upstairs bath room, treat all studs for mold, remove all debris from underneath the home.
52.
The Plaintiff will Respectfully show the Honorable Court that the Defendants agreed to replace trim board throughout the home.
53.
The Plaintiff will Respectfully show the Honorable Court that the Co-Defendants (Dennis et al) agreed to completely restore Hardwood to the Living Room floor, refinish the bed room hardwood floor, tile the lower level concrete floor, including tiling the Kitchen and Bathroom floor, replace rotten sub-flooring as needed.
54.
The Plaintiff will Respectfully show the Honorable Court that the Co-Defendants (Dennis et al) agreed to a new 19 x 13 Framing designing to the lower level bathroom, to include 3/8-inch custom clear glass with shower enclosure,
With marble enclosed sitting shelf, new tile through out upstairs Bathroom with New custom designed vanity glass shelving system, and utility room in the basement, including new framing of the master bedroom closet.
55.
The Plaintiff will Respectfully show the Honorable Court that the Co-Defendants (Dennis et al) agreed to Re-Frame the entry garage door with first a foundation, framed up to a rough opening for a New French Window Scheme.
56.
The Plaintiff Respectfully will show the Honorable Court that the Co-Defendants (Dennis et al) agreed to the installation of all Cabinet, Bathroom fixtures, lighting and necessary plumbing for New Water Line throughout as required.
57.
The Plaintiff Respectfully will show the Honorable Court that the Co-Defendants Dennis et al) agreed to New Up Grade Electrical Wiring through out and panel box, to be performed by a Licensed Electrical Vendor.
58.
The Plaintiff will show the Honorable Court Respectfully that the Co-Defendants (Dennis et al) agreed to have the exterior of the home Stripped/Scraped, Primed and Painted to the customers color scheme.
Including a new facial replacement view of the front of the home of windows and front entry door to a French window scheme,
Furthermore, The Co-Defendants (Dennis et al) agreed to have weather boards replaced which were damaged by termites mainly in the front of the home to include replacement of weather boards for construction of New French window replacements as required.
59.
The Plaintiff will Respectfully show the Honorable Court that the Defendants (Dennis et al)agreed to have the Spiral Stair case restored and replaced on second level, New Stair case @ Main level and # Lower Level,
Including construction of a Cinder block/concrete base for New AC Central Heating Unit.
60.
The Plaintiff will Respectfully show the Honorable Court that the Co-Defendants (Dennis et al) agreed to the installation of Burglar Bar's custom designed for the windows on the left and right side of the home (Included in bid).
61.
The Plaintiff will show Respectfully to the Honorable Court that the Co-Defendants Dennis et al) agreed to a New Water Line change throughout the Home (and new sewer line) as required
62.
The Plaintiff will show the Honorable Court that the Defendants agreed to new concrete flooring poured, in basement for New Ceramic Tile throughout.
63.
The Plaintiff will show the Honorable Court that the Co-Defendants (Dennis) wrote a letter after several dispute arise between “Main Defendant (Zanders Esq.) and Co-Defendant(s) (Dennis et al);
Which was in fact received by the U.S. District Court, Eastern Louisiana filed and date stamped received April 12, 2010 which states as follows according to “Federal Court Records”:
The Co-Defendants herein (Dennis et al) “have no knowledge of the law” and furtherances hired Attorney Willie Zanders for representation in this matter.
The Co-Defendants (Dennis et al) were under the impression that (Defendant) Mr. Zanders Esq. would enroll and respond to this matter.
A copy of the contract and receipt of payment for his attorney fee attached.
64.
The Plaintiff will show the Honorable Court that at a later date copy of the Receipt For Payment of Legal Fees attach to the above mentioned letter which reads:
RECEIPT FOR PAYMENT OF LEGAL FEES
I, Willie M. Zanders, hereby acknowledge receipt of a check in the amount of Twenty-Five Hundred Dollars ($2,500) in connection with a Contract for Legal Services to represent WALTER A. DENNIS, SR and his wife (ROSEMARY DENNIS) in a lawsuit filed against them by LOUIS CHARLES HAMILTON who claims to be a contractor.
Signed by William M. Zanders Dated 5/12/07
65.
The Plaintiff will show the Honorable Court that after the Co-Defendants (WALTER A DENNIS and ROSEMARY DENNIS) reconciled differences with their Attorney Defendant (WILLIE M ZANDERS, SR – LSBA No 13778)
filed a “Pro Se” Motion to allow the Defendant Attorney (Willie M. Zanders, Sr.) to be enrolled as their attorney of record.
Furthermore, the Co-Defendants (Dennis et al) requested 14 days after the enrollment as attorney of record to file pleadings to the Plaintiff's ( Louis Charles Hamilton II) Motions to Seal Contact Information, Motion for Sanctions, Motion to Freeze Assets, and Motion for Contempt.
66.
The Plaintiff (HAMILTON) will show the Honorable Court that the above named Motions (Ref No 65) was approved by the Defendant (Zanders Esq.) on or about the 7 Day of June 2010.
Furthermore, the Co-Defendants (Dennis et al) signed a Certificate of Service on or about 7 Day of June 2010.
67.
The Plaintiff (Hamilton) will show the Honorable Court that a visual inspection was performed on the pier foundation of the Co-Defendants (Dennis et al) located at 3826 General Taylor St, New Orleans, Louisiana to assess its structural condition after Hurricane Katrina and the flooding aftermath by S.Z.S. Consultants, Inc and their report and recommendations was signed by Sam Z. Scandaliato, PE (Professional Engineer in Civil Engineering).
68.
The Plaintiff (Hamilton) will show the Honorable Court that the above (Ref No. 67) Report determined that the Co-Defendant's (Dennis et al) house at 3826 General Taylor St, New Orleans, Louisiana was structurally safe for repairs, requiring some structural repairs.
Furthermore, The pier, foundation, walls, exterior siding, and roofing system all appeared to be intact and reported as relatively in fair condition.
69.
The Plaintiff (Hamilton) will show the Honorable Court that the itemized recommended structural repairs are as follows:
1. Termite damage and decay damage in the middle of the Home near the second level and three areas of the front in the lower ground level. All of these locations plus any other damaged areas, will require replacement of the framing components. It is also recommended that the house be inspected and treated by a qualified and licensed pest control contractor during the restoration.
2. There is some minor cracking in the chain wall of the front porch. This does not appear to be a major structural concern, but it would be a good time to re-point the mortar joints.
3. The bottom 3' 4' of wooden siding is soft and has deteriorated and therefore should be replaced. The siding provide some structural stability to houses built with this typical construction and needs to be replaced in kind.
4. Although there is no evidence of deterioration of the nailing in the structural framing, it is recommended that one extra galvanized nail be added as extra protection at the base of each studs.
5. All mechanical, electrical, and HVAC equipment that was affected by floodwaters will have to be replaced/repaired per code by a licensed and certified contractor.
6. Once all pours materials, such as sheetrock have been removed, it is recommended that all structural elements that were submerged in floodwaters and exposed to mold growth be sanitized and treated. Chlorine based cleaning followed with a copper sulfate treatment should prevent and provide a longer term resistance to mold growth.
70.
The Plaintiff (Hamilton) will show the Honorable Court that S.Z.S Consultants, Inc billed the Co-Defendants (Dennis et al) $275 for 5 hours @ $55.00).
71.
The Plaintiff (Hamilton) will show the Honorable Court that Permit #07BLD-01889 was issued on 02/26/07 for the project address of the Co-Defendants (DENNIS et al) for hurricane damaged dwelling.
72.
The Plaintiff (Hamilton) will show the Honorable Court that the above (Ref No. 71) was paid by money order no 08686616865 on 2/26/07 to the City of New Orleans City Hall Located at 1300 Perdido Street, New Orleans, Louisiana 70112.
73.
The Plaintiff (Hamilton) will show the Honorable Court that the Co-Defendant (Dennis et al ) was Invoiced for Work Performed which included
1. Demo & Gut out the entire home except closet walls and ceiling – remove all nails.
2. Remove all debris underneath the home.
3. Treat all studs and all framing underneath the home for mold with 1/3 bleach and 1/3 water solution. Including the Hardwood floor in the front Bed Room, and make ready for New Construction of the Home.
Furthermore, the Plaintiff (HAMILTON) will show the Honorable Court that the Invoice was for Labor and Materials totaling $3,500 with a draw of $2,500. signed on by the Plaintiff (Hamilton) and the Co-Defendants (Dennis).
74.
The Plaintiff (Hamilton) will show the Honorable Court that B.B.F. General Repairs submitted to the Plaintiff (Hamilton) DBA Multi Construction on 3/2/07 for the Plumbing Proposal for the Co-Defendant's home located on General Taylor St in New Orleans, Louisiana for $3,675.00.
75.
The Plaintiff (Hamilton) that on 2/28/07 a Proposal was submitted to the Plaintiff (HAMILTON)- for the Co-Defendant's (Dennis et al) home on General Taylor, New Orleans, LA 70125 by Flooring by Design LLC, Robert Theard, owner (504)232-2806 and Corey Mitchell (504)621-8870 for flooring and installation according to specification of the customer for $7,350 (20% down and 80% Upon Completion.
76.
The Plaintiff (Hamilton) will show a receipt for custom Bamboo flooring trim for $2725.00 per customer request.
77.
The Plaintiff (Hamilton) will show that a Permit for Electrical Work was issued by the City of New Orleans, LA to Robinson Electrical Contractors on 3/9/07 for 12 New Circuits.
Furthermore, The Plaintiff (Hamilton) will show the Honorable Court was invoiced by Robinson's Electrical Contractors for work completed which included complete Electrical Rewire including Panel Box, Breakers, Standard Switches, Outlets and filing fees, Installation of Light Fixtures and Ceiling Fans. Total Cost of the electrical work was $8,350 with $7,000 paid and a balance of $1,350.
78.
The Plaintiff (Hamilton) will show the Honorable Court that a proposal was lost due to the Co-Defendants (Dennis et AL) defamation of character with Defendant (Zanders Esq.) conspiracy involved also their-in to wit:
The Plaintiff (Hamilton) Submitted the following to Angela Dennis of 2045 Beck St. in New Orleans, LA 70131.
1. The Home located at 2045 Beck St in New Orleans LA 70131 had shingles removed by the high sustaining winds, from Hurricane Katrina.
2. Their after causing the Roof to leak into the Family Room, and the Master Bath Room causing damage to the ceiling in the Family Room (Mainly the Carpet & Ceiling) & (Insulation in that ceiling area).
Note: continue leaking exposure will further cause mold growth and need of entire ceiling she rock replacement and Home treatment for Mold Infestations
3. The Bath Room has suffered severe damage to the sheet rock, ceiling & wall's.
4. The Family Room Ceiling need painting at this stage.
5. The Bath room Wall's & Ceiling Sheet Rock Needs Replacement, Prime & Painted.
6. The Home roof shingles Chiefly Needs replacement (ASAP) to further save any future Damages.
All Material guaranteed to be as specified, and the above work was performed in accordance with the drawings and specifications provided for the above, and was completed in a substantial workmanlike manner.
All agreements contingent upon strikes, accidents, or delays beyond our control.
Multi-Construction hereby proposes simultaneously performing the repairs/restoring as listed as follows:
A. Restore the sheet rock in the Master Bathroom throughout with ½ inch green board @ 8” o.c. With a texture finish, prime & painted to the customer color scheme. Restore all fixtures, Insulation in the ceiling and wall as required.
B. Replace carpet in the family room.
C. Paint the ceiling in the family room.
D. Remove and replace (1) Layer of (32) squares of shingles & underlayment and replace with a 30 year type shingles replacement to include installment of all vent jacks, lead covers and turbine whirly birds.
Reseal all pipes & ease tin, with a 30 lbs felt Underlayment & Valley Tin, cut and installment of shingles under Dane County FL, installment application, protect yard and shrubs and (2) year workmanship warranty.
E. Touch and clean all work area's as needed.
Cost & Material Outline:
Materials meaning as specified to performed said work:
Labor and Materials Roofing: ($9400.00)
Note: This roofing cost do not cover container cost for removal of Debris if the city do not cover this removal under FEMA or any other means.
Labor and Materials Bathroom: ($3400.00)
Labor and Materials Family Room: ($3800.00)
For the agreed sum of ($16,600.00) in accordance with our agreement: 1/3 down, 1/3 thereafter half complete, Half complete meaning, New Roof Installment, & Sheet Rock Installment in the Bathroom (Hung, Taped, & Texture, Ready for Painting.
79.
The Plaintiff (Hamilton) will show the Honorable Court that a Complaint was filed in the United States District Court, Eastern District of Louisiana and was date stamped as received on 2007 Apr 2 PM 1:07 by Loretta G Whyte, Clerk. Complaint No 07-1510 SECT.B MAG1. The complaint is as follows:
1. The Co-Defendants (Dennis Et Al) hired the Plaintiff to rebuild their Home after Hurricane Katrina Destroyed if from rising food waters.
2. The Co-Defendants (Dennis Et Al) entered into a contract on or about 2/24/07 with the Plaintiff to fix their home back to normal,
among other things to provided custom design to the front facial appearance of the Main windows located at both downstairs garage level
And upper Master bedroom to a Custom French Window setting inside the rough opening information provided by the Co-Defendant(s).
To include among other things a 3/8- inch custom clear glass shower enclosure with a marble sitting stool and octagon window for said shower.
3. The Co-Defendant(s) (Dennis Et Al.) failed in full as described in Paragraph (E) and (H) of the contract to provide said window insulation after meeting with custom window company there by refusing to purchase said custom design as described in the contract Including Window to match pre-existing windows rough opening after demo was completed.
The Co-Defendant(s) (Dennis Et Al) further ordered to now change framing design to normal windows and purchase normal windows and install said normal windows and close in the shower custom window design.
4. The Co-Defendant(s)(Dennis Et Al) had the Plaintiff refund from Vendors of home merchandise for flooring @ (2) times, and at some point the Co-Defendant(s) became vulgar with “racial slurs” toward Fai K. Yee of New Orleans Cabinet Counter-tops,
In that the Co-Defendant(s) stated: “form him to go back to his country” and “leave the United States.”
5. The Co-Defendants (Dennis Et Al) harassed the Plaintiff (Hamilton) to perform extra work & provide the Material for free on two columns in the Dinning Room area that never existed.
6. The Co-Defendant(s) further had the Plaintiff provide framing for heater unit in Master Bed Room and refused to compensate claiming the Plaintiff was at fault.
7. The Co-Defendant(s) (Dennis Et Al) caused delay in the electrical work of their home by waiting to have the installation of the central air/heating unit.
8. The Co-Defendant(s) (Dennis Et Al) wanted the Plaintiff (Hamilton) to have the Plumber to re-install galvanized plumbing waterlines underneath the home against city code
And was vulgar to the “Plaintiff” in this regard via a second opinion by “Pipes Are Us” Plumbing, stating he wanted “to save his fucking money”.
9. The Co-Defendant(s) there after receiving insurance claim fund(s) to fix their entire Home,
filed a second claim to fix/patch small roof leak, (the Plaintiff met with the adjuster and shown him the small roof leak
And the repairs that the Plaintiff had further made to said roof which was not covered under the original contract the Plaintiff and the Co-Defendant(s) entered into.
10. The Co-Defendant(s) (Dennis) thereafter filing claim with their insurance company for small roof leak,
put the Plaintiff on notice to no longer perform any further work, until they give the Plaintiff further notice and receive monies to fix the small roof Leak from their insurance company.
11. The Co-Defendant(s) (Dennis Et Al) thereafter windows had been complete but not as agreed upon in the contract became hostile
And went to a State Inspector for the State of Louisiana making claims against the Plaintiff among other things, in regards to, Windows & Non Electrical Inspection being completed and permits filing of their home.
12. The Co-Defendant(s) (Dennis Et Al) further implicated the Plaintiff (Hamilton) and the Customer of the Plaintiff @ 3816 General Tay
Mr. and Mrs. Singleton with said inspector in violation of work on that home without proper city permits and illegal/underhanded practices in regards to that home rebuild process
And to further show that the Home owner themselves of said property @ 3816 General Taylor was also illegal/underhanded as described above against city ordnances.
13. The Co-Defendant(s) (Dennis Et Al) caused the Plaintiff (Hamilton) great delays and undue stress in their re-building process by all of the actions described above.
Cause of Action
I. Breech of Contract
1. The Co-Defendant(s) (Dennis Et Al) violated the terms and conditions of the contract by refusing carry out as described in paragraph (E) and (H) of said Contract.
2. The Co-Defendant(s) caused undue delays in carrying out their own duties as described in regards to electrical and installment of Central AC/Heating unit.
3. The Co-Defendant(s) had non sufficient funds to carry out all of their terms and conditions of the contract in its entirety,
In regards to monies to secure all building materials as required for a full, final and complete Home packages as described in said contract,
To include for the Plaintiff (Hamilton) to receive this final payment for services rendered.
II. Fraud
1. The Co-Defendant(s) (Dennis Et Al) thereafter receiving monies from their insurance company to fix their entire flood damaged home enter into a contract with the Plaintiff (Hamilton) with full knowledge that the monies had been used/squandered.
And the remaining funds was not sufficient to cover the Plaintiff's labor costs as well as all of the material cost to completely restore their home as described in the the contract.
2. The Co-Defendant(s) (Dennis Et Al) with the full knowledge entered into a contract for Custom Shower Work & Custom French Windows and New Front Facial Appearance
And that they had Non-Sufficient funding to cover such custom work, and labor cost as described in the contract.
III. Defamation and Intentional
Infliction of Emotional Distress
1. The Co-Defendant(s) (Dennis Et. Al.) had been stating to the Plaintiff's customer @ 3816 General Taylor in New Orleans LA and City/State inspectors among others,
That the Plaintiff(Hamilton) is the cause for their Windows that finally had been installed in violation of the contract and their current conditions in delays among other things in their home repairs,
And that the Plaintiff (Hamilton) had been providing sub-standard carpentry work through out their rebuilding phase on the Home @3826 General Taylor.
2. The Co-Defendant(s) (Dennis) had a State Inspector accuse the Plaintiff in this regard as stated above on the Plaintiff's cell phone
And further requested a High Noon meeting with all the Plaintiff(s) contracts that the Plaintiff had been working on and why the Plaintiff had not pulled required permits on the 3816 General Taylor Project.
Demand
1. Declaratory Judgment Declaring that the Co-Defendants violated the terms and conditions of the contract.
2. Declaratory Judgment Declaring that the Co-Defendants have committed the act as described in the cause of actions for Fraud.
3. Declaratory Judgment Declaring that the Co-Defendant(s) committed the acts as Described against Mr. Fai K. Yee owner of New Orleans Cabinet Countertop, Molding and Construction Co. Inc.
4. Order the Co-Defendant(s) to Issue a Public Printed Apology to Mr. Fai K. Yee
5. Award the Plaintiff (Hamilton) Actual Damages in the amount of $2,400.00 for the changes in framing design aqs well as compensation for the framing of the upstairs Heater Unit stand.
6. Award the Plaintiff (Hamilton) Declaratory Judgment for Breech of Contract,
With an Award in the Amount of $21,000.00 for said Breech of Contract, which is the total remaining in the contract with the Co-Defendant(s) of $49,500.00.
7. Award the Plaintiff Damages in excess of $49,500.00 for Fraud.
8. Award Plaintiff Damages in excess of $49,500.00 for Defamation and Intention Infliction of Emotional Distress.
9. Award the Plaintiff Punitive Damages for the Reprehensibility of the Co-Defendant(s) conduct in the excess of $49,500.00.
10. Order the Co-Defendant(s) to pay all Court Costs, The Plaintiff's (Hamilton) Legal costs, and any Attorney Cost the Plaintiff may occurred.
11. Any other Award the Court Deems Just and Proper in favor of the Plaintiff and the General Public.
80.
The Plaintiff (Hamilton) will Respectfully show the Honorable Court that the Plaintiff filed another complaint on April 3, 2009 with the U.S. District Court Eastern District of Texas and it was stamped received by David J. Maland, Clerk and numbered 1:09CV0289. Judge Heartfield presiding Judge and Judge Hines Magistrate.
81.
The Complaint is as follows:
1. The Co-Defendant(s) (Dennis Et. Al) hired the Plaintiff (Hamilton) to rebuild their home after Hurricane Katrina destroyed it from rising flood waters.
2. The Co-Defendant(s) (Dennis Et. Al) entered into a contract with the Defendant (Hamilton) to fix their home back to normal, among other things to include, custom design the Front facial appearance of all windows and doors to a “custom French” window setting inside the rough opening, information provided by the Co-Defendant(s).
3. To include a 3/8 inch custom clear glass shower enclosure with a marble sitting stool and octagon window for said shower, (photo on file).
4. The Co-Defendant(s) (Dennis Et. Al.) failed in full as described paragraph (E) and (H) of the contact and refusing to purchase said windows and doors thereafter Plaintiff provided the framing for such a custom design.
5. The Co-Defendant(s) in addition to this became vulgar with race slur toward Fai K. Yee, Owner of New Orleans Cabinet Counter Top, in that “Rose Mary”, stated for him to go back to his country and leave the United States.
6. The Co-Defendant(s) harassed the Plaintiff to perform extra work and provide the material for the placement of the AC/Heater Unit.
7. The Plaintiff (Hamilton) purchased Blocks (Concrete) and Mortar Mix and built a outside stand for said unit, which now the Co-Defendant(s) charge that this additional work was not under contract, to build a stand in the up stair Bed Room Closet.
8. The Co-Defendants (Dennis Et. Al.) harassed the Plaintiff (Hamilton) to provide materials for two columns in the Dining Room area that never existed.
9. The Co-Defendant(s) caused delay in the Electrical Work of their home by useless waiting to have the insulation of the Central Air / Heating unit.
10. The Co-Defendant(s) (Dennis Et. Al. ) wanted the Plaintiff (Hamilton) to have the Plumber to re-install galvanized plumbing waterlines underneath the home against current city code.
11. The Co-Defendant (Dennis Et. Al.) were making a major fuss, to attempt to force the Plaintiff to give up and not finish their repairs because the Co-Defendant(s) had been living in Texas for over a year and eight months with the full knowledge that the home owner monies had been squandered off on a new (SUV) Truck, among other things,
12. And the Co-Defendant(s) (Dennis et al) had non-sufficient funds to carry out all of their terms and conditions of the contract in its entirety from the very start.
13. The Co-Defendant(s) then acted out with Defamation against the Plaintiff (Hamilton) throughout the “Broadmoor District” stating that the Plaintiff had been providing sub-standard carpentry work throughout the Co-Defendant(s) rebuilding phase, and at one point made it clear that the Plaintiff will lose the Customer due in large part to their scheme to cost the plaintiff another contract for $49,500.00 “Labor Only” with the home across the street from the Co-Defendant(s) and close friends of the Co-Defendant(s).
14. The Co-Defendant(s) acted out this same Defamation Scheme against the Plaintiff at City Hall, State Inspectors, and the Broadmoor Community Hall Meeting.
15. The Co-Defendant(s) (Dennis Et. Al.) even stated that Mr. James Singleton (former City Councilman at 3816 General Taylor had committed fraud through the Plaintiff by not pulling required permits for the work the Plaintiff did in his home repair work.
16. The Co-Defendant(s) even Defamed the Plaintiff out of another contract in the excess of $8,500 with their own Daughter's Home Repairs.
17. The Co-Defendant(s) has caused the Plaintiff great and undue stress to the point the Plaintiff used a (8) man crew to work extra hours which the Plaintiff Paid for with fund(s) from another Home Repair Job In order to expedite the Plaintiff Obligations under the contract entered into withs the Co-Defendants (Dennis Et. Al.)
Cause of Action
1. The Plaintiff seeks compensation for Breech of Contract in excess of $21,000.
2. Damages for Fraud.
3. Loss of Earning by Defamation in excess of $58,000.00 actual contract(s), to include damages for future Defamation to the Plaintiff Work Reputation within the “Broadmoore district” with a longevity of work in this area.
4. Compensation for extra work in the excess of $2,400.00.
5. Order the Co-Defendant's to issue a public printed apology to Mr. Fai K. Yee.
6. Declaratory Judgment Declaring the Co-Defendant(s) committed fraud and breech off contract against the Plaintiff (Hamilton).
7. Award the Plaintiff damages for mental anguish, intention infliction of emotional distress in the excess of $49,500.
8. Award the Plaintiff for Damages for the extreme and Reprehensibility of the Co-Defendant's conduct in excess of the minimum Jurisdictional limits of this above entitle Honorable Court.
9. Order the Co-Defendants to Pay all Court Cost, Prejudgment and Post-Judgment Interest at the legal rate and for any and all further relief, both general and special, exemplary, legal, and equitable to which the Plaintiff May Be Justly Entitled.
82.
The Plaintiff will show the Honorable Court that the Defendant (Zanders) in the “Rogue” capacity of a Professional Attorney at Law”,
Furtherances wrongfully supply Co-Defendants (Dennis et al) with a total disregards for his proceeding in danger as a office of the Courts or proceeding with the same total disregards, disability of consequentiality of (Zanders) illegal activities in supplying
To the Co-Defendants (Dennis et al) all legal Court Documentations for filing before a Honorable Court” to be pronounce as pro se in defense of all stated facts as outline in paragraph (80) and (81) levy against (Dennis et al) by the Plaintiff herein (Hamilton)
To Include but not limited to Defendant (Zanders) supply his personal conspiracy appearances in providing all bogus legal court documentations for filing with contaminated false banking computations,
A host of professional cover up accountability & Activities scheme of things since past date “Hurricane Katrina” made land fall and caused Co-Defendants herein (Dennis et al) all current legal predicaments now pending before this “Honorable Court”.
83.
Defendant (Zanders) furtherances supply all bogus “material facts” of financially business sound monetary figures in actual cost repairs transactions;
84.
Defendant (Zanders) furtherances supply conspiracy in conditions of fault in construction repair phases to aid in defamation of the Plaintiff construction reputation in defense of the Co-Defendants (Dennis et al);
85.
Defendant (Zanders) Furtherance supply bogus alibi for Co-Defendant (Dennis et al) under the circumstances surrounding missing banking fundamental contractual funds;
86.
Defendant (Zanders) Furtherance supply and alternatively destroying evidences of construction pictures, past banking records since 2007, missing building materials receipts since 2007, volunteers accordance recommendations for free replacement in construction repairs and volunteers accountabilities since 2007.
87.
As a direct result of all of the extreme and outrageous described activities herein committed against the Plaintiff, will, peace, dignity the Plaintiff (Hamilton) suffer and continue to suffer the following:
1. Damage to Construction Reputation
2. Extensive “unwanted and undue” legal litigation for “loss revenue” since February 2007
3. Extreme intentional infliction of emotional distress and Mental Anguish since February 2007 .
4. Loss of past earing with interest incurred since 2007
5. Loss of all past contractual agreements as described fully herein since 2007
88.
Wherefore Pro Se Plaintiff Louis Charles Hamilton II, Prays; and moves the Honorable Court for the following
Cause of action(s):
The Plaintiff reincorporates and states fully all of the above set forth fully herein in paragraph (1) through (88) for cause of actions against the peace, rights and dignity of the (Plaintiff) Louis Charles Hamilton II:
1.
Plaintiff seeks Declaratory Judgment being made entered into the records of this action against the Defendants, (Zanders) and (Dennis et al)
Individually and collectively as described herein said complaint being committed all acts and actions described fully herein in Violations under Chapter 96 of Title 18, United State Code: (RICO) Racketeering Influences Corruption Organization in connection with Section 1341 (relating to mail fraud)
And Defendant (Zanders) and Co-Defendant (Dennis et al) in furtherances violation of (RICO) section 1343 (relating to wire fraud), (RICO) “Money laundry of Financial transactions to conceal the “Identity, source, and legitimate origin”,
Obstruction of Justice, Civil Conspiracy, Destruction, alter and or direct destruction of “material Civil Evideances”, Fraud upon the Honorable Court and Defamation of the Plaintiff Construction reputation in this (RICO) Criminal activities ag.
2.
Plaintiff seeks Actual, accumulative, compensatory, consequential, continuing, expectation damages, foreseeable,
future, incidental, indeterminate, reparable, lawful, proximate, prospective, special, speculative, substantial,
punitive, defamation and permanent damages;
Intentional Infliction of Emotional Distress and Mental Anguish being entry into the records against Defendant (Willie M. Zanders) in the Amount of $90,000. (Ninety Thousand US Dollars)
To include but not limited to: Exemplary treble damages under (RICO) statue being awarded to the Plaintiff (Hamilton)
And entry into the records against Defendant (Willie M. Zanders) in the Amount of $180,000. (One Hundred and Eighty Thousand Dollars).
With full interest incurred since date of injury February of 2007.
For a total Award being levy against Defendant (Willie M. Zanders) $270,000.00 (Two Hundred and Seventy Thousand Dollars) in favor of the Plaintiff (Hamilton)
3.
Award to the Plaintiff (Hamilton) Damages from the Co-Defendants (Dennis et al) in the form of exemplary damages (Only) in the Amount of $180,000.
(One Hundred and Eighty Thousand Dollars) from the original amount already being complain of and current in entertainment before a Honorable Court of Law.
Interest incurred since date of injury February of 2007.
Defendant's pay all court cost, Attorneys Cost.
4.
Plaintiff (Hamilton) seek the Honorable United States District Court Courtesies in disciplinary referral of Attorney at Law (Willie M. Zanders) to the Louisianan Lawyer Bar Associated governing Attorney Disciplinary activities
For full legal “Disbarment proceeding commence against” (Zanders Attorney at Law) for all of his “hostile, extreme, outrageous illegal criminal (RICO) conducts, and Fraudulent actions as described herein through out the complaint of the Plaintiff Louis Charles Hamilton II
5.
And for all “Deem Just and being Honorable before this United States Eastern District of Texas Judicial Court on the behalf of the Pro Se Plaintiff.
Dated this _____ Day of ______________, 2011
By: Pro Se Plaintiff
__________________________
Louis Charles Hamilton II
P.O. Box 20126
Houston Texas 77225
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