In The United States District Court
For the District of Texas
Beaumont Division
Louis Charles Hamilton II
Plaintiff COMPLAINT
Vs.
Antoine L. Freeman, J.D. Attorney at Law
Texas Bar # 24058229
Defendant
And
Edward McCray
Joyce M. Guy
Co-Defendant(s)
Comes Now the Plaintiff, Louis Charles Hamilton II,
The Pro Se Plaintiff in this Cause complains of the Defendant(s) Antoine L. Freeman, J.D. (Attorney at Law) hereafter name (Freeman),
Co-Defendant(s) Edward McCray hereafter name (McCray)
Co-Defendant(s) Joyce M. Guy hereafter name (Guy) and for cause the Plaintiff will show as follows: I.
Jurisdiction
The Plaintiff Louis Charles Hamilton II, Respectfully Asserts the above Honorable District Court has proper Venue over all subject matters involving Federal Question(s); in which the (Government) is not a party.
The amount of monetary fund’s in controversy exceed the Jurisdictional limits of $75,000.00,
The Treacherous atrocity committed to the Plaintiff to include but not limited to taking advantage of “Mental Disadvantage Adults, retired Handicap Senior Citizens with such a non-conformity Behavior for local laws of State and Federal Civil/Criminal/Judicial/ divisions thereof;
In Racketeering, Fraudulent in multiple Business operations of a shameful notoriety type in an inexplicable nature committed against the Plaintiff (among others) is within the proper venue of the above Entitled Honorable Court.
Parties
II.
The Plaintiff (Hamilton) now a resident within Harris County, Texas,
Navy Veteran, Former Construction Contractor.
The Defendant(s) (Freeman) an (Attorney at Law) Bar # 24058299 within the State of Texas, office located in Jefferson County, Texas
The Co-Defendant (McCray) resident of Jefferson County, Texas
The Co-Defendant (Guy) resident of Jefferson County, Texas, her’ mother Mrs. Norma Guy whom also raised the Plaintiff (Hamilton) as one of her own’ with her other son (Allen T. Guy) Plaintiff best (Child hood friend) son of Mr. Ulyess Guy Sr.
Whom (Guy Sr.) also raised the Plaintiff as one his own sons’ up to the point the Plaintiff left his home town of Port Arthur, Texas in February 12, 1980 for the (U.S. Navy)
Return to the Jefferson County, Texas area right after Hurricane “Rita” made landfall in November of 2005 to began helping in any rebuilding needs within Jefferson County, Texas as a direct result of said Hurricane, “Rita”.
III.
Venue
Venue is proper before this Honorable United States District Court entertainment in that all incidents, actions, and extreme/outrageous behavior of a relentless cruel style type nature by each and every Defendant(s) herein as described by the Plaintiff occurred within Jefferson County, Texas;
All Financial Institutions, Person/Persons Government/Private agencies being wrongfully and fraudulently victimized by said Co-Defendant(s) (Guy and McCray) fraudulent acts and actions,
Moreover, all subject matter herein is within the Jurisdiction view of this above entitled Honorable Court to further entertain fully throughout;
To include but not limited to the United States Federal Government (among others) being Victimized by a Fraudulent Long-Term Racketeering Business Enterprises Scheme of things by the Co-Defendants (McCray and Guy) so deplorable
With such a heinous design “in itself” to include Fraudulent Misappropriation of Federal Programs namely (FEMA) involved in disaster recover reliefs being siphoned off in more than a rate at (3) counts
To include the Inexplicable Misappropriation of additional Federal Programs in excess of $76,000.00 for a New Home in connection to FEMA Fraud
While Co-Defendant(s) (Guy and McCray) having additionally acted against the Estate of Mrs. Norma Guy each Co-Defendant(s) own natural “Mother/Mother in law”
Being that all said fraudulent scheme of things occurred against each party; namely the Plaintiff (Hamilton) among and or other namely Government/Private Institutions, Person/persons was design and scheme in large parts by Co-Defendant(s) (McCray and Guy) within the Jurisdiction of Jefferson County, Texas
Defendant (Freeman) while acting in the Position of an Attorney at Law on record no less in Caption:
Louis Charles Hamilton II vs. Edward McCray and Joyce M. Guy,
Cause No. A-180805 before the Honorable 58th District Court, within Jefferson County, Texas,
Defendant (Freeman) Committed to an underhanded, unscrupulous atrocity of a Legal Attorney at Law during “all facets” of a “court proceeding” with conspirer in the same wrongful extreme and outrageous (scheme of things) with the Co-Defendant(s) (McCray and Guy) for purpose of covering up the underhanded, unscrupulous, atrocious acts of the Co-Defendant;
To include but not limited to involving his (Freeman) “Attorney malpractice” in connection to the Defendant(s) (McCray and Guy) conduct within a “legal court proceeding” also occurred within Jefferson County, Texas
IV.
Introduction
The Pro Se Plaintiff Louis Charles Hamilton II seeks cause of action(s) and monetary compensatory relief(s) for the following:
A Murder for Hire Scheme of the (Plaintiff) being plotted by the Defendant(s) (McCray and Guy), with Conspiracy in a scheme to aid in a Murder for Hire Scheme by a (Attorney of Law) to harm/maim and or cause possible death of the (Plaintiff)
From being any further as a witness in connection to a “civil action” involving the treacherous extreme and outrageous conduct of the Co-Defendant(s) (Guy and McCray)
Racketeering and fraudulent Business activities (among other Illegal operations) that did in fact occurred within Jefferson County, Texas,
To include but not limited to all Defendants “Collectively conspired” in a scheme to maim and or cause permanent physical injury being committed to the physical well being of the Plaintiff for being a witnesses as described herein and eliminate for any future witness thereof;
And or cause to put to permanent Death in connection to all facts herein,
With other “confederates involvement” in concert to commit to the same;
To Further conspire with Co-Defendant(s) (Guy and McCray) and Defendant (Freeman) by way of further intimidate/placement of Plaintiff in fear of loss of life by use of stalking/terrorizing/ and possible future death if Plaintiff continue to reside within his Home County of Jefferson; within the State of Texas;
To the point Plaintiff “common sense of things dictates”, that if extreme distance from all Defendant(s) described herein do not take place with light speed
Any further delays would be very detrimental to the Plaintiff well being in a Non-Healthy fashion;
If this did not occur as the Plaintiff working Independent proactively on the behalf of all State and Federal governmental law enforcement entities to probe with relentless engagement into a “treasure trove” of Illegal Activates being committed against the United State of America, (among others) to include the Plaintiff (Hamilton II) himself;
Notwithstanding all Facts and circumstances surrounding of the setting/planting/placement of large amounts of drugs on the Plaintiff property Namely “Cocaine” to attempt to discredit the Plaintiff with (PAPD) Port Arthur Police Department (among others) State and Federal agencies to cover up the Co-Defendant(s) (Guy and McCray) tracks
Not withstand the same kind of scheme of things to discredit the Plaintiff further before the Honorable 58th District Court during ongoing “Court proceeding”
In lieu of all fraudulent facts to further provide the Plaintiff from being an effective creditable witness against said Co-Defendant(s) (Guy and McCray) misappropriation of Federal Program funds and Grants (among other false pretense) by said Co-Defendant(s)
In that the Plaintiff “accidental discovery” of one “Hell of a long lists” of treacherous corruption and Racketeering in Illegal business activities by the Defendant(s) herein; (Guy and McCray)
Involving (among other things) Corruption, Racketeering and Fraud involved against Many, Many, Handicap Elderly Senior Citizens and other mentally Disadvantage Adult(s)
Which Co-Defendant(s) (Guy and McCray) claiming (G &G Services) as a “legit business of operation” dealing in “Adult Health Care” with further extreme and outrageous acts of;
Conspirer in Obstruction of Justice and false representation in a Court of Law by an (Attorney of Law) with the intent to deceive the Honorable Court in having already providing, producing
And refusal in committing to all said production thereof already Ordered by a Court of Law;
Said Discovery Materials in Connection to further commit to Obstruction of Justice of evidence, concealment and or destroying evidences which exculpatory said documents should lend to clearing or tending to clear Co-Defendant(s) (McCray) and (Guy) from alleged faults or guilt’s levy by the Plaintiff as described in the proceeding before the Honorable 58th District Court in Jefferson County, Texas
In which Defendant (Freeman) further engage against his “ethical and fiduciary duties” of standard of care as an (License Attorney of Law) within the State of Texas with a “willing and wanton” disregard for any type of consequences of his (Freeman) actions there after committing to the extreme treacherous and outrageous conduct with hostile acts and actions directed at the Plaintiff
For the sole purpose of conspirers to further deceive, destroyed, and place a concealment in all document(s) and all “Material Facts” that tends to prove guilt of Defendant(s) (Guy) and (McCray) as described by the Plaintiff in all of the Racketeering and Fraudulent Business Illegal activities among other Illegal corrupt activities
As described herein of the Co-Defendant(s) (Guy) and (McCray)
There after a Court Order was commenced and filed within the records of cause no. A-180805 for Defendant (Freeman) to produce said discovery evidence on the Behalf of Co-Defendant(s) (McCray) and (Guy) collectively on the 9/11/2009,
With said production to be enforced and completed by the 11/6/2009 as order per by the Honorable Court;
Defendant (Freeman) total willing and wanton conduct to further Conspire in a scheme of things to commit to Obstruction of Justice by a (Attorney of Law) for purpose of total delay of all discovery in a Civil Court action with a list of Illegal activities of the Co-Defendant(s) being Know by said Attorney in connection with (Guy and McCray) Racketeering business scheme to eliminate the Plaintiff as a witness thereof;
Notwithstanding Said scheme of things involved in numerous Civil Court delay(s) committed by a (Attorney of law) for purpose and design in concert of the execution of a “Murder for Hire scheme/plan” in connection, collusion, with Co-Defendant(s) (Guy and McCray) wrongful acts for the Plaintiff from being a witnesses of any further said corrupt business Racketeering and other Illegal activities,
Obstruction of Justice by (Attorney of Law) in connection to the concealment of all potential witnesses and providing fictitious witnesses thereof some 2 years and 4 months later;
In connection with the same scheme of things in concert, collusion, with the Co-Defendant(s) (Guy and McCray) against the Plaintiff rights of a Legal Court Proceeding to an Initial discovery device of a Request for Initial disclosure Motion pursuant to Rule 194 of the Texas Rules of Civil Procedure and Rule 194.2.
Which the Defendant (Freeman) clearly violated this by (10) fold as the Court records surely indicate this to be a fact;
With Defendant (Freeman) in Conspiracy in full concert with Co-Defendant(s) (Guy and McCray) in all facets of a State Court District Court proceeding within the State of Texas to concealment, hide, destroyed, all evidences and witnesses;
Including but not limited to the elimination of the Plaintiff (Hamilton II) himself,
With numerous Perjury and subordination of perjury in document and affidavits filed by (Freeman)
With other Illegal civil/criminal activities committed by Defendant(s) (Freeman) in all facets of a State Court District Court proceeding,
Namely Affidavits on file in court records to avoid sanction levy against Defendant (Freeman) by the Plaintiff with further acts and actions involving
Subornation of Perjury thereof by a (Attorney of Law) in connection to the Illegal activities of Co-Defendant(s) (Guy and McCray) in Request for Admission, and Interrogatories,
Corrupt Business Fraud and Racketeering activity in monetary transactions in two Business and Banking Institutions in connection thereof,
With racketeering and fraud in the Business operation once located at the property(s) located at 1807 east 7th street in Port Arthur, Texas under the Company (J Can Company) and stolen goods namely (“Scrape Metal”) derived thereof from unlawful activities by Co-Defendant(s) (Guy and McCray) and all confederates conspiring therein,
And the wrongful placement of all monetary ill gotten gain in a Financial Banking/Credit Institution, with no Federal and State taxes ever, ever, being even ever, consider in the process of being made payable to the Federal Government and the State of Texas for such taxes purpose as the Business operations dictate
With Conspirer activities by a (Attorney at Law) in connection to conceal thereof;
Business Fraud and Racketeering by corrupt Illegal Business enterprise company namely (G & G Services) for a long-term fraudulent racketeering activity(s) scheme of things
Against more than in excessive of (30) - (60) helpless elderly handicap citizens and disadvantaged citizens in a corrupt business enterprise scheme occurred within Jefferson County, Texas, from the dates of 05/02/1997 throughout the Month of December of 2009 for over a (12) year period of time in this scheme involving the Elderly Senior handicap Citizen(s) and Mentally disadvantaged adults.
Corrupt Business Fraud and Racketeering by a Scheme and design of another (Second) business enterprise (J Can Company) with the “full intent” to promote the carrying on of “specified unlawful activity” for “long-term Illegal pilferage” in namely “scrap metal” against the “City of Port Arthur” ordinances and local laws in connection to (J Can Company) every days Business operations activities;
And further racketeering scheme of things involving business enterprise with intent to further Fraud elderly Senior Handicap Citizens and other Disable and total helpless disadvantaged and mental challenged Citizens in (among other things) providing actual “Professional Physical Health Care” for elderly senior citizens and other disable and total helpless disadvantage Citizens,
While Co-Defendant(s) (Guy) and (McCray) said scheme of things to include further committed to fraud activities with other none professional employed personal by (G & G Services)
And or actual semi-qualified employees of the Defendant(s) (Guy and McCray) company (G&G Services) involved in this bogus fraudulent Health care business enterprise scheme in Port Arthur, Texas and surrounding community;
Retaliation against witness namely the Plaintiff Louis Charles Hamilton II, by the Co-Defendant(s) (McCray and Guy), their confederates with Defendant (Freeman) conspiracy involve thereof;
Embezzlement & Fraud design by Co-Defendant(s) (Guy and McCray) against the elderly and disadvantage namely Mrs. Norma Guy and her Estate at 5050 east 7th street in Port Arthur, Texas and Lillian Marsh,
To include other similarly situated being victimized by a part of this same scheme of things by (Guy and McCray) with Defendant (Freeman) conspirer involvement thereof to full commitment in concealment & destroying evidence tend to showing Co-Defendant(s) (Guy and McCray) Guilt in all described treacherous activities thereof;
Co-Defendant(s) (Guy and McCray) Theft and Fraud of Programs concerning programs receiving Federal Funds, FEMA Disaster Damages Hurricane relief Funds for Hurricane “Rita”, “Umberto”, and “Ike” at two different location during the same time period for each Disaster allotment;
Theft of Federal Grants in excess of $76,000.00 for a New Home;
Theft and Fraud of Insurances Companies in connection to Disaster Damages Hurricane relief Funds for Hurricanes “Rita”, Umberto, and Ike”.
Financial Institution Fraud in concealment of all illegal gotten gains in a concealment scheme of assets within several Banking institutions,
To include but not limited to knowingly and willfully make a materially false, fictitious, and fraudulent representation to avoid transaction reporting requirement under State and Federal Laws within a banking institution
Knowingly and willfully provide materially false, fictitious and fraudulent representation and information in connection thereof before a Court of Law in connection to the Business activities of the Company (G & G Services) and its Federal and State Taxes requirements.
Racketeering and Fraudulent Business activities derive in non-payment of Federal and State Taxes in a scheme in connection with all of the Illegally racketeering activities through Fictitious several Business fraudulent fronts acting as legitimate Public Business know as (G & G services) and (J Can Company);
With the full intent to further, continue to resume conduct in “possible dangerous drug trade activities from the past under the (J Can Company) Business front;
With acts of “Felonies in possession” of a “Hand Gun” while hosting racketeering activates,
Sales, possession of stolen goods namely “Scrap Metal” under (J Can Company);
To include but not limited to facts and circumstances surrounding Co-Defendant (McCray) previous arrest(s) for Drug Trafficking Namely (“Manufactory Crack Cokecaine)
Legal Malpractices and breach of Ethical and Fiduciary duty being committed by an (Attorney of Law) in connection to all of the mention schemes of things as described in this complaint
And all evidences, records, exhibit(s), files, Motions, Transcripts, Investigation(s) documents having already being place in the Clerk of Court office in the Jefferson County, Texas of the 58th District Court in support of the Plaintiff full Facts as described herein
With further conspirer and cover up all Illegal activities, Defamation, Intentional Infliction of Emotional Distress and Mental Anguish, Exemplary/Punitive Awards, Actual, Special, Proximate, General, Equitable, Compensatory, Consequential, Excessive, Necessary, Pecuniary, Declaratory Judgment and Substantial Damages
Having been committed by all of the above named Defendant(s) (Freeman), (McCray) and (Guy)
To include but not limited to Defendant(s) (Freeman), (McCray), and (Guy) confederate agents acting in concert with the Defendant to commit the same of all the above as Identified by the Plaintiff against the Peace, Rights and dignity of the said Plaintiff and those being person/persons and agencies victimized .
V.
Facts.
This particular style civil action complaint arise first within the Jurisdiction of the 58th District Honorable Court before the Honorable Bob Wortham in Jefferson County, Texas, City of Beaumont
Before a Live Civil Court proceeding for the Plaintiff to achieved (among other things) Monetary awards for breach of a constructional contract agreement to fix a home located at 448 Dequeen blvd in Port Arthur, Texas their after storm related damages from namely several Hurricanes causing damages to stated residences
Further construction work being possibly provided at the resident of 5050 east 7th street in Port Arthur, Texas to include damages being awarded to the Plaintiff for in addition (among other things)
Assault and Battery of the Plaintiff physical person in connection with the Co-Defendant(s) (Guy and McCray) fraudulent acts and theft of Plaintiff construction tools which complaint was filed on the 26th day of November 2007 by the Plaintiff in a Pro Se style setting before the above mention Honorable 58th District Court;
Defendant (Freeman) acting in the capacity of an Attorney of Law License No. 24058299 within the State of Texas for the behalf of the Co-Defendant(s) (Guy and McCray) already wrongful actions as described in the State Court filings; enter into the Clerk of court records said Attorney appearances on the 18 day of December 2007
Plaintiff will show this Honorable Court that on or about November 16th, 2007 that the Co-Defendant(s) (McCray and Guy) entered into, and Breached, a Construction Contract for work to be performed at 448 DeQueen Blvd in Port Arthur, Texas.
Plaintiff will show this Court, additionally, Plaintiff alleges Fraud, Assault and Battery at two counts by Edward McCray on the 16th of November, 2007 which the Plaintiff was further, on 11/17/07 assaulted again (by Edward McCray and injury occurred) to Plaintiff (left) shoulder which Plaintiff sought emergency Medical Assistant at Christus St. Mary’s Hospital.
Plaintiff will further show this Court that both Co-Defendants (Guy and McCray) refuse thereafter Port Arthur Police Officer pleaded with both Co-Defendants for the return of the Plaintiff’s tools that the Co-Defendants (Guy and McCray) accepted full knowledge that they were both keeping the Plaintiff from performing any other Construction/Carpentry work and earning capacity.
To include but not limited to stealing from the Plaintiff the following construction tools
(A) A brand new Hitachi air compressor S# 2700009 $980.00
(B) Bosch Drill M# Brute S# NV $345.00
(C) 100’ air hose (aprox) $95.00
(D) 50’ (aprox) $42.00
(E) 100’ electrical cord (aprox) $70.00
(F) 50’ electrical cord (aprox) $38.00
(G) 4 framing hammers (aprox) $37.00 each
(H) Plaintiff’s personal framing hammer $48.00
(I) ‘’ tool belt (leather) $50.00
(J) ‘’ Kobalt razor knife $17.00
(K) ‘’ Swanson pencil set & refills $22.00
(L) ‘’ Black tool box & respirator $138.00
(M) ‘’ Extreme safety face shield (aprox) $30.00
(N) Ear plugs (2) packs (aprox) $16.00
(O) (4) normal face respirators with strap $12.00
(P) Small assortment pliers set (aprox) $35.00
(Q) (2) tuck pointer(s) masonry (aprox) $24.00
(R) (1) square mouth shovel (aprox) $18.00
(S) Shoe box of construction photos “priceless”
(T) (1) set of blueprints $1200.00
(U) (1) gas container (aprox) $15.00
(V) (1) masonry trowel (aprox) $18.00
(W) (1) Fatmax 35’ tape measure $30.00
(X) (1) Catspaw nail puller (aprox) $12.00
(Y) (1) speed square $8.00
(Z) 1 Contractor Calculator (aprox) $34.00
(AA) (1) crowbar (aprox) $17.00
(BB) (3) utility knives (aprox) $9.00 each
(CC) (1) nail punch (aprox) $8.00
(DD) Maxx gloves (aprox) $34.00
(EE) Portable saw $137.00
(FF) DeWalt Saws-All $97.00
(GG) Hitachi nail gun (framing) $327.00
(HH) Hitachi roofing nailer $315.00
(II) Sledge hammer $28.00
(JJ) Gas powered generator $300.00
(KK) (1) ladder $127.00
(LL) Canvas tarps, 95’x180’ $100.00
(MM) (2) roofing shovels (aprox) $48.00 each
(NN) (1) package saw blades & drill bits $24.00
(OO) (2) speed squares $5.00 each
(PP) (2) paint brushes (aprox) $14.00
(QQ) (1) paint brush pan set (aprox) $12.00
(RR) (1) paint scraper wire handle (aprox) $10.00
(SS) (1) paint scraper set $14.00
(TT) (1) air hose fitting set $38.00
(UU) (1) residential framing book $21.95
Plaintiff will show this Honorable Court the Defendant (Freeman) with or while having the full knowledge described from the Co-Defendant(s) themselves (McCray) and (Guy) previous experiences of the Plaintiff sending (PAPD) Port Arthur Police Department in the involvement of the corruption and fraudulent business affairs of (J Can Company) racketeering and scheme of things in the pilferage of stolen scrap metals,
Shortly after the main incident broke out between the Plaintiff and Co-Defendants, (McCray and Guy) in regards to the contract in excess of ($10,800) occurred and being complained of currently in the 58th District Court;
Plaintiff will further show this Honorable Court Defendant (Freeman) having Knowledge through Defendant(s) client (McCray and Guy) in all facts surrounding the Plaintiff further sending State of Texas Services (2) times to the aid and provide protection of Mrs. Norma Guy a elderly handicap Senior Citizen and her Estate
While Plaintiff asking The State of Texas to further, provide over the Affairs of Ms. Lillian Marsh (living in the same residence with Mrs. Norma Guy)
A mentally Challenged Adult female need protection and her’ well-being and physical Interest (among other things) being protected from the wrongful actions of the Co-Defendant(s) (McCray and Guy)
In which Defendant (Freeman) complained vigorously of “in open court records”;
Plaintiff will further be able to effectively show the Honorable Court that the Plaintiff filed Court Document(s) and having providing the same to the Co-Defendants (McCray and Guy) Attorney of record (Freeman) stating to the effects of placement of the Co-Defendant(s) (Guy and McCray) into “legal custody” for all of their Crooked Corrupt and wrongful activities in resolution of their Fraudulent activities directed at the Plaintiff and Mrs. Norm Guy and her’ Estate;
With the entire arsenal of the United States Criminal division(s) already being order forthwith ready and place on standby notice:
United State Inspector Attorney General, IRS, DEA, ATF, Texas Attorney General Office, Texas Department of DADS, Texas Department Protective Services for the Elderly, (among others)
In standby mode for being used in “full force” with the Plaintiff blessing and “personally writing” supplying and turning over all civil evidence achieved,
To include digging up all other “temporarily hidden” documents, evidences, files, records, and under covering up each and every dollar/nickel/penny of all Ill gotten gains monetary fund’s under a Civil style Federal Racketeering Corrupt Pro Se Style Civil action”
*Special Note*
To: (United State of America et al)
And (The State of Texas et al)
Plaintiff will be surely cussing, screaming, and standing looking over the shoulder of each and every Criminal Department and Civil Department under the entire U.S. Governmental agencies as described herein
Plaintiff Further Gives Notice herein to:
United States et al; and The State of Texas et al
The Next Civil action Plaintiff shall be endorse and be having the need of filing will be against the U.S. Government et al, and The State of Texas et al
To assure the “Safety of the Nation” as well as the Community of Jefferson County, Texas,
and the Plaintiff among others that these (“Two Mad Dogs Ruffians”) Co-Defendant(s) (McCray) and (Guy) are “so deep and so far” within a “Federal Prison system” each time the Co-Defendant(s) (Guy) and (McCray) “eye lashes” “blink” it will sound like “massive storming thunder burst” into their collective ear holes”, with ever other just following for the Defendant(s) (Freeman) for the conspiracy involvement as described herein:
*See : Louis Charles Hamilton, II, and all other citizens in and for the State of North Dakota, Vs. State of North Dakota; North Dakota Department of Labor; Disciplinary Board of the Supreme Court of the State of North Dakota; Governor John Hoeven cause No.:3:01-CV-00095,
*See: Louis Charles Hamilton, II, and all other citizens in and for the State of North Dakota, Vs. NAACP cause No. 3:01-CV-00069
*See: Louis Charles Hamilton II, Vs. Cass County Courthouse 3:98-CV-00110 with “full media exposure” for any future incompetency being needed of exposure involved in the aforementioned as previously done to the above stated “Governmental and Judicial” Defendants.
(Among others) for their wrongs of the past “If there is any further need for any fore mention potential parties consideration of entertaining this to be a “weak and don’t take the Plaintiff serious enough” type of Civil Harmless Threat”
Plaintiff will further be able to effectively show the Honorable Court that the Plaintiff having sent State of Texas Investigators with the Texas Department of Aging and Disability Services (Complaint Identification Number 21883)
To investigate into the corruption of Business activities of (G & G Services) and involving numerous senior handicap Elderly and mental disadvantage Adults in Jefferson County, Texas with Defendant (Freeman) having full Knowledge of this also;
Notwithstanding facts of Defendant (Freeman) knowledge of statements made “under oath” of Physical harm being plotted against the Plaintiff well being;
Plaintiff will State with Respectful strong assert(s) of Defendant (Freeman) Conspiracy to cause the Plaintiff among other things
Additional lost in time in Defense of a Professional Legal assault by an “Attorney of law” no less to circumvent, concealment and conspiracy in destroying of evidence and hiding of potential witnesses and or providing fictitious witness in a obstruction of Justice scheme of things,
With (Freeman) aid in subordination of perjury testimony in court records and files, in connection with attempt to conceal, destroy, and or aid by way of scheme and conspire with Co-Defendant(s) (Guy and McCray) multiple Racketeering Business enterprises, and other fraudulent scheme of things to hide massive years of ill gotten gains and a long list of other corrupt activities
Moreover, Defendant (Freeman) and Co-Defendant(s) (McCray) and (Guy) plot to cause no less the maim and or caused to be put to Death said Plaintiff by confederates involvement;
To include but not limited to Co-Defendant(s) (Guy and (McCray) enticement and excitement of said confederates to being in fear of loss of their collective “Drug Crack trafficking trade” Companies;
Which Co-Defendant(s) (McCray) and (Guy) also use this same scheme of things to also aid in having the Plaintiff “maimed” and or placing Plaintiff at a state of “loss of Life” in connection to the enticement and excitement of said confederates of being in fear of the Plaintiff and their possible “Drug dealing activities” being interrupted at the hands of the Plaintiff.
To which said confederates aid Co-Defendant(s) (McCray) and (Guy) in a cover up
Notwithstanding numerous attempts already made to act against the Plaintiff physical & mental well being to “cover up” the hoist of racketeering business enterprises and other fraudulent activities involving (among other things) massive FEMA Frauds, Federal Grant Frauds, Insurances Company Fraud, Embezzlement against the elderly in a Business, Federal and State Tax evasion(s) embezzlement of the Estate of Mrs. Norma Guy
Thus causing the Plaintiff to be in fear because of the same wrongful extreme and outrageous conduct as described throughout of the Co-Defendant(s) (Guy and McCray) and Defendant (Freeman) collectively behavior;
With Plaintiff suffering in addition collateral lost enjoyment of the Plaintiff hometown within the State of Texas,
The Loss of Peaceful enjoyment involvement and companionship with the Plaintiff both set of Parents, other family members, relatives, and Friends.
With Defendant (Freeman) in full compliance, concert, and conspiracy thereof throughout all acts and action(s) as described herein and before the Honorable 58th District Court, and the court records, files documents, exhibits, and transcripts’ in connection thereof.
Plaintiff will show the Honorable Court that Defendant (Freeman) refuse to act fair at any time throughout all the court proceeding in Cause No. A-180805 by way of total refusal to comply even after the Honorable Court order said Defendant (Freeman) in compliance with doing so;
By way of providing said damaging material, evidence against Co-Defendant(s) (McCray and Guy)
Plaintiff will show the Honorable Court some 2 years and 4 months and counting in which Defendant (Freeman) continue to conspiracy of said production of lawful evidences already Order being produce by a District State Court Judge.
At, which for said outrageous refusal to turn over document that tend to show guilt of the Co-Defendants (Guy and McCray) as described by the Plaintiff in Court records among other investigation agency
At which Defendant (Freeman) breach his own contractual agreement with the State of Texas for a practicing Attorney to be committing these kind of Illegal criminal and civil activities against his own legal interest in lieu of Co-Defendant(s) (McCray and Guy) clients personal Interest to cover up the Racketeering and Fraudulent business Scheme among many other same type scheme of things being committed by Co-Defendant(s) (McCray and Guy).
Plaintiff will show the Court the legal malpractices directed at the Plaintiff legal cause
Which Defendant (Freeman) fully willing, wanton, worked in this direction and fully conscious in doing so;
Against a precious “Law degree” of a (Attorney in law) said conduct activities other Attorney(s) of Law Nationwide would “never dream” of placing themselves in such jeopardy, predicament against the application of normal rules of standard care of a client Interest,
Against the rules of ethics of a Attorney at Law and the governing rules against such civil/criminal conduct,
With all other rules governing and levy over Attorney of Laws practicing within the State of Texas, against said activities as described in this complaint.
Plaintiff will show the Honorable Court Co-Defendants (Guy and McCray) committed to Defamation of the Plaintiff’s Construction Reputation (among other defamatory statements) to claim:
a. The previous home located at 448 DeQueen was fixed up under sub-standard construction application and care at the hands of the Plaintiff.
b. The Previous home located at 448 Dequeen blvd in Port Arthur, Texas is was at that time made inhabitable because of the sub-standard construction application and care at the hands of the Plaintiff, to which Co-Defendant(s) (Guy and McCray) obtain additional Federal Program Grant in excess of $76,000.00.
To wit: The Co-Defendant(s) (Guy and McCray) further fraudulent scheme of things include achieving (among other things) additional monetary funds from federal Grants programs in excess of $76,000.00
For a “New Home” at the location of 448 DeQueen blvd in Port Arthur Texas in connection to Further Fraud activities already, issue by Federal FEMA Disaster Hurricane relief funds
In which said previous “FEMA FUNDS” and Insurances Companies disaster relief funds already being fraudulently obtained and wrongfully personally squandered in the past,
Before said Co-Defendant(s) (Guy and McCray) obtained the additional $76,000.00 Federal Program Grant for a New Home located at the location of 448Dequeen blvd in Port Arthur, Texas;
With Defendant (Freeman) in concert and conspiracy in the concealment of all of these material facts from a court of law
By way of all of “Bad Faith corrupt legal tactic in a legal court proceeding directed at the Plaintiff discovery devices for a judgment against other illegal activities of Co-Defendant(s) (McCray and Guy);
To include but not limited to the future maiming and or causing of death of the Plaintiff as described here within.
Plaintiff will further show this Honorable court Co- Defendant(s) (McCray) and (Guy) destroyed and concealed all documents to lend to Defendant(s) guilt; documents showing the following records:
a. (G and G Services) business records
b. (J Can Company) business records
c. Patient/victims records of (G and G Services)
d. All bookkeeping records, and Tax records involved in paragraph (a) and (b) above
e. Employee records
Plaintiff will further show this Honorable Court that the company listed in paragraph (A) above (G & G Services) above was designed for the following;
A. To deceive Seniors Handicap Citizens and mentally challenged Adults in a business that’s providing proper professional “Health Care”.
B. To obtain possession of further funds through embezzlement and or other fraudulent devices, Illegal activities by any means necessary from Seniors, Handicap Citizens and mentally challenged Adults life savings.
C. To appear as a Partnership when one partner namely (Ulyess Guy Sr.) having been dead since 20th day of November 2003 and (G & G Services) still operating well into December of 2009 when Texas State investigators finally became involved. Some six years and counting after (Guy Sr.) death (Guy Sr.) is involved in a Racketeering and Fraudulent Business Scheme..?
D. To appear (Ulyess Guy Sr.) having also been paying some sort of Federal and State taxes under the structure of a partnership some (six years) after (Guy Sr.) death.
E. To appear as a Partnership when one of the other partners having mental illness in the past and continue to suffer with Dementia among other mental illness Namely (Mrs. Norma Guy) and is involved in a Racketeering and Fraudulent Business Scheme..?
To include but not limited to (Mrs. Norma Guy) being a part of a further scheme to cheat Federal Government and The State of Texas out of Taxes..? With the Mental Illness (Mrs. Norma Guy) currently suffers for approximately some (6) – (10) years in the past.
F. To appear as a legal legitimately operating Business company within a Banking and Credit financial Institution.
G. To appear as a Legal legitimately operating Business company operating within Jefferson County, Texas County Clerk’s Office when the Company (G & G services) has not been registered legal in Jefferson county clerk office records since 05/02/2007
H. To appear as a legal legitimately operating Business company with qualified employed personal providing legit Professional “Health Care Services for the Senior Handicap Elderly Citizens and the Mental Disadvantage Adults.
Which Co-Defendant (Joyce M. Guy) stated under “Oath” under direct examination of the Plaintiff on August 11th of 2009 that (G & G Services) was operating during that date in open court;
Plaintiff will show the Honorable Court that the Company list in paragraph (B) above (J Can Company) was design for the following:
(A). To obtain and operate in stolen goods namely “Scrap Metals”.
(B). To be a new start up front company that operate in concealment in “Drug Trafficking” below (PAPD) Port Arthur Police Department radar and DEA investigation services.
(C). With the further representation made by Co-Defendants (Guy) and (McCray) of (J Can company) being legal and legitimately operating Business within a Banking Institution and a Credit financial Institution.
(D). To give the Fictitious Representation that (J Can Company) is a legal and legitimately operating Business Company within the County Clerk’s office in Jefferson County, Texas.
(E). To appear as a legal and legitimately company that’s paying State and Federals taxes on all business income derive in the transactions of (J Can Company) by Co-Defendant(s) (Guy and McCray).
Plaintiff will show the Honorable Court that the Co-Defendant(s) (Guy and McCray) Embezzlement activities include the Estate of Mrs. Norma Guy
To wit: in that the Income derived from the Late Mr. Ulyess Guy Sr. pension fund from said retirement from the City of Port Arthur
Combine with Mrs. Norma Guy from said retirement funds from Park Place Hospital,
With combine Income of Lillian Marsh living at the same residence of Mrs. Norma Guy
And the fraudulent income derived from (G & G Services), is in fact partial income derived on Mrs. Norma Guy’s interest to include but not limited to
Monetary fund’s being payee to the Estate of Mrs. Norma Guy as a result of Hurricane Damages twice “Rita & Ike” causing damages for Insurances companies and Federal FEMA Disaster relief funds
In which Co-Defendant (Joyce M. Guy) did in fact apply for and received to fix the Estate” However the Estate of Mrs. Norma Guy is in a state of total mismanagement and fallen apart in structure repairs, with need roofing repairs (among other things) as described during Sworn testimony during court hearing held on the 11th day of august 2009 by Allen T. Guy under direct examination of the Plaintiff.
To include but not limited to facts that the Estate should and could have been up kept even without the aid of any Federal grants and or any Insurances companies payments base upon Mrs. Norma Guy Net Income received during her retirement golden years after the Death of her Husband (Guy Sr.) with Lillian Marsh Income also in support.
Plaintiff will show the Honorable Court that the Plaintiff went to the (PAPD) Port Arthur Police Department and reported all Illegal activities of the Co-Defendant(s) to include the bounty of $10,000.00 being made against the Plaintiff life.
Plaintiff will show the Honorable Court the Defendant (Freeman) attempted to obtain many times the actual physical where about of the Plaintiff in a scheme before the court in open court records,
To the point the Plaintiff warn (Freeman) of his security violation against the Plaintiff rights from further physical harm at the hands of the Co-Defendant (McCray) himself
And or any confederates acting in concert to aid the Defendant (Freeman) and Co-Defendants (Guy and McCray) cause in silencing of the Plaintiff from being a witness in the Criminal Racketeering Business enterprise and other Fraudulent activities of Co-Defendant(s) (McCray and (Guy) which this scheme went on more than twice by Defendant (Freeman);
To include but not limited to the false representation made in the Honorable 58th District Court by Defendant (Freeman) on the 11th day of December 2009 in regards to turning over all discovery request per Court Orders
To include but not limited to Defendant (Freeman) refusal to investigate all of Plaintiff witnesses before hand by a “third party private Investigator” or “get involved Himself” before providing perjury information in Plaintiff request for Admission Request in regards to the witness (Lewis Garza).
Notwithstanding Defendant(s) (Freeman) conspirer in the concealment of the Co-Defendant(s) (Guy and McCray) witnesses and or fictitious witnesses for over a period of 2 years and 3 months in concealment
Notwithstanding Defendant(s) (Freeman) engagement in the conspirer of inflating the Plaintiff monetary loss in connection with the Co-Defendant(s) (Guy and McCray) scheme of things to cover up all Federal and State criminal activities.
The Plaintiff will show the Honorable Court that nothing he (Hamilton) did was the direct and proximate cause for the damages the Plaintiff sustained as a result of the Co-Defendants (McCray), (Guy), and (Freeman) Treacherous atrocity of a shameful notoriety type in an inexplicable nature committed against the Plaintiff, among Financial Institutions, Person/Persons, and Government/Private agencies.
Conclusion.
“Litigation is the pursuit of Practical ends, not a game of chess.”
Felix Frankfurther,
Indianapolis vs. Chase Nat’l Bank, 314 U.S. 63, 69 (1941)
Wherefore Plaintiff Louis Charles Hamilton II, Prays; and moves the Honorable Court for the following:
Damages.
1.The Plaintiff reincorporates and states fully all of the above set forth fully herein for all Awards for Compensatory Damages on the behalf of the (Plaintiff) Louis Charles Hamilton II:
2. Plaintiff seeks Declaratory Judgment being entered into the records of this action against the Defendant, (Freeman) Co-Defendant(s) (McCray) and (Guy) individually as described herein.
3. Plaintiff Seeks Awards Damages for Legal Malpractices and Breach of Ethical and Fiduciary duty directed wrongfully by Defendant (Freeman) against the Plaintiff rights involved in a Civil Proceeding in excess of (12) X the Jurisdictional Amount of $75,000.00 and or in excess of $900,000.00 (by a Jury) in this Trial;
4.Plaintiff seeks Awards for Defamation by Co-Defendant(s) (McCray) and (Guy) in an amount 3 X the Jurisdictional amount of $75,000.00 and or in excess of $225,000.00 (by a Jury) in this Trial;
To include but not limited to the same awards of Defamation awards for Defendant (Freeman) conspiracy in connection thereof the as stated previously herein in amount excessive of $225,000.00 (by a jury) in this trial;
5. Plaintiff seeks Awards for Intentional Infliction of Emotional Distress and Mental Anguish in an amount 10 X the Jurisdictional amount of $75,000.00 and or in excess of $750,000.00; from each Defendant(s) (Freeman), (McCray) and (Guy) (by a Jury) in this trial;
6.Plaintiff seeks “Actual Damages” in a amount to be determined during the Trial of this matter in connection to the Defendant (Freeman) inflation of the Plaintiff loss of daily wages at the pay rate of $58.00 per hour X (2) years (3) months and counting as of this undersign date the Plaintiff continue to suffer from the Defendant(s) Freeman Legal Malpractice conspiracy in connection with the Co-Defendant(s) (McCray) and (Guy),
7. Plaintiff seeks Special, Proximate, General, Equitable, Compensatory, Consequential, Excessive, Necessary, Pecuniary, and Substantial Damages in an amount awarded proper and just by the Jury of this Trial
8. Plaintiff Respectfully Request a Judicially expedited Order on the Behalf of the Estate of Mrs. Norma Guy, to include but not limited to Mrs. Norma Guy Best interest in health and finances thereof;
To include but not limited to Ms. Lillian Marsh a Mentally disadvantage Adult that reside within the same residence of 5050 east 7th street in Port Arthur Texas with Mrs. Norma Guy for the “State of Texas” hereby forthwith to execute a Guardianship and protection over all Interest therein both legal and Equitable from the Hands of the fraudulent dishonest Illegal practicing hands of the Co-Defendant(s) (Guy) and (McCray) as described herein
There if the Honorable 58th District Honorable Court in Jefferson County, Texas having not done so already by the time the Plaintiff having advance the subject matter of all facts stated herein for a Trial in this matter,
Plaintiff shall seek an order to show cause hearing in this regards alone for said Protective Order of the Court;
9.The Plaintiff seeks’ special Awards for the Loss of Peaceful enjoyment and involvement in the companionship with the Plaintiff both set of Parents, other family members, relatives,
And Friends in Jefferson County Texas, in an amount in excess of (12) X the Jurisdictional amount of $75,000. Or in excess of $900,000.00 From Defendant(s) (Freeman), (McCray) and (Guy) (by a Jury) in this Trial
10. Plaintiff seeks damages for punitive/exemplary awards in an amount in excess of (12) X the jurisdictional amount of $75,000.00
Or In excess of $900,000.00 from each Defendant(s) (Freeman), (McCray), and (Guy) (by a Jury) in this Trial;
11. Plaintiff seeks all court costs, pre/post Judgment cost; and any other legal costs that may arise during the course of these proceedings, and or any needed other consultant Attorney expense.
12. Plaintiff seeks any and all other awards that this Honorable United States District Court deems just and proper on the behalf of the Pro-Se Plaintiff, Louis Charles Hamilton II,
In accordance with the Civil laws of the United State of America,
to include but not limited to The Honorable Court invoke on behalf of the Plaintiff All just finder fee’s and Criminal Awards, (IRS Awards) and or any other governmental awards both State and Federal that the Plaintiff may be entitled to for bring the two “Mad Dogs Ruffians” arrest and conviction.
On the _______ Day of __________, 2010
By, ____________________________
Louis Charles Hamilton II
Pro Se Plaintiff
P.O. Box, 20126
Houston, Texas 77225
No comments:
Post a Comment