In The United States District Court
For the District of Texas
Beaumont Division
Louis Charles Hamilton II
Plaintiff
Vs.
Antoine L. Freeman, J.D. Civil No. 1:2010-CV-00055
Defendant
And
Edward McCray
Joyce M. Guy
Co-Defendant(s)
Plaintiff first set of Production of Document(s)
Comes Now the Pro Se Plaintiff, Louis Charles Hamilton II, in this Cause Civil No. 1:2010-CV-00055
Hereby moves Defendant(s) (Guy and McCray) collectively for inspection and copies of the following documents:
1. Complete and full copies and accountability of all “present” Tangible assets those that have a physical substance and can be touched, such as currencies, buildings, real estate, vehicles, inventories, equipment, and precious metals the Defendants (Guy and McCray) having possession of during this present time frame in their collectively marriage.
2. To include a listing and description of all tools and equipment(s);
3. To include all live stock, farm animals, domestic animals, cattle, sheep, pigs, horses, birds, and stock within the United States;
Defendant (Guy and McCray) provides a complete listing of all Current assets as of this undersign date
Asset are cash and other assets expected to be converted to cash, sold, or consumed either in a year or in the operating cycle (whichever is longer), without disturbing the normal operations of a business. These assets are continually turned over in the course of a business during normal business activity. There are 5 major items included into current assets:
4. Cash and cash equivalents — it is the most liquid asset, which includes currency, deposit accounts, and negotiable instruments (e.g., money orders, cheque, bank drafts).
5. Short-term investments — include securities bought and held for sale in the near future to generate income on short-term price differences (trading securities).
7. Inventory — trading these assets is a normal business of a company. The inventory value reported on the balance sheet is usually the historical cost or fair market value, whichever is lower. This is known as the "lower of cost or market" rule.
8. Prepaid expenses — these are expenses paid in cash and recorded as assets before they are used or consumed (a common example is insurance). See also adjusting entries.
9. Defendant (Guy and McCray) provides complete copies and accountabilities of all Long-term investments;
Often referred to simply as "investments". Long-term investments are to be held for many years and are not intended to be disposed of in the near future. This group usually consists of four types of investments: Investments in securities such as bonds, common stock, or long-term notes; Investments in fixed assets not used in operations (e.g., land held for sale); Investments in special funds (e.g., sinking funds or pension funds).
10. Defendant (Guy and McCray) provided complete copies and accountabilities of all Defendant (Guy and McCray) Fixed asset in the United States
11. Also referred to as PPE (property, plant, and equipment), these are purchased for continued and long-term use in earning profit in a business. This group includes as an asset land, buildings, machinery, furniture, tools, and certain wasting resources e.g., timberland and minerals. They are written off against profits over their anticipated life by charging depreciation expenses (with exception of land assets). Accumulated depreciation is shown in the face of the balance sheet or in the notes.
13. (Guy and McCray) provides a complete copies of all civil suit case number(s) being filed in a civil court of law within the United States against Defendant (Guy and McCray) with a brief description of all cause of action(s) filed in said suit; the correct name of each of the Plaintiffs’ and a brief description of the disposition of each civil action and amount(s) of any settlement(s) agreement(s);
14. (Guy and McCray) provides a complete copies of all criminal case number(s) being filed in a criminal proceeding before a court of law within the United States against each and all of Defendant described as (Guy and McCray)
15. And Defendant (Guy and McCray) provided state the full type of each criminal charges filed and or arrested;
16. provide a brief statement of what the charges was for ,
17. if any drugs was involved state the exact kind of illegal drugs involved
18. and the exact amount taking into police custody and which arresting agencies conducted said Arrest;
19. And provided The Attorney acting on said child behalf (Guy and McCray)at the time of arrest for criminal charges (Attorney) name, address, and day time telephone number
20. And brief description of the disposition of each of the criminal arrest/conviction against said (Guy and McCray) if prison time state exact how long and if it was state of Federal prison or both
21. To include providing the same for all county/city jail arrest within Jefferson County, Texas.
22. Defendant (s) (Guy & McCray) produce a copies of Mortgage documents, deeds, property deeds or any other such physical document that shows actual ownership of the property of the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas 77640 and the Name, address and day time telephone Number of the person involved in such described documentations on the behalf of the Defendants.
23. Copies of all insurances claims documents/ Mortgage documents that is related to damages Defendant apply for and claim for property damages as a result of Hurricanes Rita, Umberto, and Ike, with copies of all Insurances check and FEMA checks paid to Defendants for said disaster relief to include FEMA applications and insurances documentations as it relates to defendant(s) apply for assistances in the Past for Hurricane related damages to the property located at 448 Dequeen in Port Arthur, Texas 77640
24. And providing the same as described in paragraph (23) above for the property located 5050 east 7th street in Port Arthur, Texas 77640 (Defendant (Guy) having power of Attorney over on the behalf of Mrs. Norma Guy estate.
25. Defendant(s) (Guy and McCray) Collectively provide Complete banking records showing saving and checking and depositing and credit cards and all debit cards transactions … with a monthly itemized financial history for each period starting throughout October 18th 2007 throughout the end of the banking cycle for December 31st 2007
From both accounts at Banks one in Port Arthur Texas and Port Neches Federal Credit union in Nederland Texas to include both individual and joint banking accounts Defendants may own during this time frame.
26. Complete Cell phone records for defendant Joyce M. Guy @ (409) 718-1897 from October 18th, 2007 to November 18, 2007.
27. A Complete Copies of all Construction estimates made by contractors for repairs and repairs that was preformed in relationship to damages Defendant apply for Insurance funds; provide the insurance company name and address and day time telephone number;
28. And Complete copies of all FEMA funds checks and all other claims for property damages as a result of Hurricanes Rita, Umberto, and Ike, in the Past for Hurricane related damages to the property located at 448 Dequeen in Port Arthur, Texas 77640
29. And providing the same for the property located 5050 east 7th street Port Arthur, Texas 77640 on the behalf of Mrs. Norma Guy estate; Complete copies of all FEMA funds checks and all other claims for property damages as a result of Hurricanes Rita, Umberto, and Ike, in the Past for Hurricane related damages to the property located at 5050 east 7th street in Port Arthur Texas, 77640
30. To include provide the name, address, and day time business telephone Number of each said contractor, insurances adjuster and the name of each said insurance company with their individual telephone number physical address and agents names for both properties as described in paragraph (29 and 30) above.
31. Defendant(s) provided complete copies of All business records for the J Can Business Company; records that provide proof of ownership,
32. And records for Federal and State taxes records for (J Can Business Company,
33. All accounts received records copies of scrape metals received and weights records and deposit and expensive records,
34. All banking records credit cards/debit records derive in the J can company,
35. Records for all redemptions in Beaumont Texas
36. And all payments of scrape metals revenue gain in Beaumont Texas Scrap metal recycle companies from the dates of October 18th 2007 throughout the end of December 2009.
37. A Complete Copies of all Construction receipts for all building material purchase from all estimates made by contractors for repairs that is related to damages Defendant apply for and claim for property damages as a result of Hurricanes Rita, Umberto, and Ike, in the Past for Hurricane related damages to the property located at 448 Dequeen in Port Arthur, Texas 77640 and the property located 5050 east 7th street Port Arthur, Texas 77640 on the behalf of Mrs. Norma Guy estate; to include the name, address, and day time business telephone Number of each said contractor providing such repairs check that been paid out to Lowell’s showing matching receipts for said materials.
38. Copy of Power of Attorney over Mrs. Norma Guy and Her estate and or documentation to the Author providing such a decree.
39. Complete copies of all photos, notes, letters, and application, diagrams that the Defendant made representations to any private insurance company
40. And Complete copies of all photos, notes, letters, and application, diagrams that the Defendant made representations to Federal government agency dealing with Federal FEMA Funds and Federal Grants funds for a New $76,000.00 home in connections with the damages to the property located at 448 Dequeen in Port Arthur, Texas 77640
41. And provide the same for the property located 5050 east 7th street Port Arthur, Texas 77640 on the behalf of Mrs. Norma Guy estate claims for damages; to include the name, address, and day time business telephone Number of each said agent and or adjuster involved as described above.
42. Complete copies of all patient, medical records, health records, and medical charts for all patients involved in G & G Services
43. To include all payment records that’s involved with each said patient, medical records, health records, and medical charts for all patients involved in G & G Services from the date said G & G Services filed this startup company of sorts with the county clerk office in Beaumont Texas throughout the date it was shut down by the Texas Department Disability Services in 2010.
44. To include all 1. Vital Signs: Body Temperature, Pulse Rate (Heart Rate), Blood Pressure and Respiratory Rate.
2. Intake: Medication, Fluid, Nutrition, Water and Blood, etc.
3. Output: Blood, Urine, Excrement, Vomitus and Sweat, etc.
4. Observation on Pupil size.
5. Capability of four limbs of body
2. Intake: Medication, Fluid, Nutrition, Water and Blood, etc.
3. Output: Blood, Urine, Excrement, Vomitus and Sweat, etc.
4. Observation on Pupil size.
5. Capability of four limbs of body
45. Progress notes
46. Assessment and plan
To included all Basic contents as listed below
The information recorded with a personal health record could start with * Name, birth date, residence and emergency contact * Sex, Blood type * Date of last physical examination * Dates and results of tests and screenings * Major illnesses and surgeries, with dates * List of medication, dosages and duration of prescription * Any allergies * Any chronic diseases * Any history of illnesses in the family[1]Although the specific content of the medical record may vary depending upon specialty and location, it usually contains the patient's identification information, the patient's health history (what the patient tells the health-care providers about his or her past and present health status), and the patient's medical examination findings (what the health-care providers observe when the patient is examined). Other information may include lab test results; medications prescribed; referrals ordered to health-care providers; educational materials provided; and what plans there are for further care, including patient instruction for self-care and return visits.[3] In some places, billing information is considered to be part of the medical record.[4]
[edit] Format
Traditionally, medical records have been written on paper and kept in folders. These folders are typically divided into useful sections, with new information added to each section chronologically as the patient experiences new medical issues. Active records are usually housed at the clinical site, but older records (e.g., those of the deceased) are often kept in separate facilities.The advent of electronic medical records has not only changed the format of medical records but has increased accessibility of files. The use of an individual dossier style medical record, where records are kept on each patient by name and illness type originated at the Mayo Clinic out of a desire to simplify patient tracking and to allow for medical research.
[edit] Medical history
The medical history is a longitudinal record of what has happened to the patient since birth. It chronicles diseases, major and minor illnesses, as well as growth landmarks. It gives the clinician a feel for what has happened before to the patient. As a result, it may often give clues to current disease states. It includes several subsets detailed below.Surgical history
The surgical history is a chronicle of surgery performed for the patient. It may have dates of operations, operative reports, and/or the detailed narrative of what the surgeon did.
Obstetric history
The obstetric history lists prior pregnancies and their outcomes. It also includes any complications of these pregnancies.
Medications and medical allergies
The medical record may contain a summary of the patient's current and previous medications as well as any medical allergies.
Family history
The family history lists the health status of immediate family members as well as their causes of death (if known). It may also list diseases common in the family or found only in one sex or the other. It may also include a pedigree chart. It is a valuable asset in predicting some outcomes for the patient.
Social history
The social history is a chronicle of human interactions. It tells of the relationships of the patient, his/her careers and trainings, schooling and religious training. It is helpful for the physician to know what sorts of community support the patient might expect during a major illness. It may explain the behavior of the patient in relation to illness or loss. It may also give clues as to the cause of an illness (e.g. occupational exposure to asbestos).
Habits
Various habits which impact health, such as tobacco use, alcohol intake, exercise, and diet are chronicled, often as part of the social history. This section may also include more intimate details such as sexual habits and sexual orientation.
Immunization history
The history of vaccination is included. Any blood tests proving immunity will also be included in this section.
Growth chart and developmental history
Capacity
When a patient does not have capacity (is not legally able) to make decisions regarding his or her own care, a legal guardian is designated (either through next of kin or by action of a court of law if no kin exists). Legal guardians have the ability to access the medical record in order to make medical decisions on the patient’s behalf. Those without capacity include the comatose, minors (unless emancipated), and patients with incapacitating psychiatric illness or intoxication.
Medical emergency
In the event of a medical emergency involving a non-communicative patient, consent to access medical records is assumed unless written documentation has been previously drafted (such as an advance directive)
Respectfully submitted and
Dated on the _______ day of __________, 2010
By, ____________________________
Louis Charles Hamilton II
Pro Se Plaintiff
No comments:
Post a Comment