United States District Court
Southern District of Texas
Houston Division
Cause No. 4:10-cv-02220
Louis Charles Hamilton II Plaintiff Motion in
Plaintiff Opposition of Defendant
(Lawson M.D.) And collectively
(St. Joseph Medical Center et al)
Vs. And Defendant(s) (D Bret Edwards)
Motion to Dismiss Civil Action
Samuel Benjamin Magnus-Lawson, M.D., a/k/a Rex Okusaga a/k/a Prince Benjamin Magnus-Lawson of Lagos Nigeria, Africa
St. Joseph Medical Center, et al
D. Bret Edwards
Johanna Ann Magnus-Lawson
Jane and John Doe
Collectively Defendant(s)
Come Now Pro Se Plaintiff Louis Charles Hamilton II files His, Motion in Opposition of Defendant(s) (St. Joseph Medical Center et al) And Defendant(s), (D Bret Edwards) and Defendant(s); (Lawson M.D.) Motion to Dismiss this Civil Action
And for cause the Plaintiff show as follows:
I.
The Plaintiff action has been referred to the Honorable Bob Casey U.S. District Court for Harris County, Texas for all management of pre trial matters and pending motions filed now before the Honorable Court;
II.
The Plaintiff a Texas resident and domiciliary, proceeds pro se. Defendant(s) (Lawson M.D.) and (St. Joseph Medical Center et al) appearing with counsel, Defendant(s) (D Bret Edwards (Esq.) appearing pro se also jointly files motion to dismiss this action sighting failure to state a cause of action and various other reasoning namely “wishing they each could collectively seriously now flee” the Honorable U.S. District Court command, authority, control and Jurisdiction.
III.
The Plaintiff moves before the Honorable U.S. District Court that pursuant to Fed. R. Civil Procedure 12 (B) (1) (2) and (7)
The above entitled Honorable U.S. District Court is entitled to exercise, entertain and amuse its Honorable self’
Upon all set of circumstances, situations, conditions, status, state of affairs and positions of each and every name defendant(s) herein combine, intermix part(s) as stated and involved herein until the Honorable Court has
Honorably reflect on, take into account, mull over, care about, ponder, and be concern about each,
And every particulars, facts, information, niceties and fine points of detail(s) as described in the Original Complaint, Amend Complaint, Supplemental facts, all present Motions filed with the court and supporting exhibit(s), records, documents, Deposition(s), and evidence contain herein and filed by the Pr Se Plaintiff Louis Charles Hamilton II,
For the Honorable Court to come to the sound, logical, understandable and most likely deduction, inference and conclusion that a dismissal of this civil action in favor of each and every Defendant as described herein the records would be
A big boo-boo, slip up, miscalculation of the Honorable Court to take such an error in light of each set of details, particulars, facts, information, reality, specifics and essentials the Plaintiff has presented at this time frame
With each supporting factual exhibit(s) filed herein in support thus far long before Plaintiff having already obtain present Discovery devices from each said Defendant(s) and their prospective counsel of record;
Namely Plaintiff being successfully obtaining all discovery devices of “Request for production of document(s), Interrogatories, request for admissions, and Depositions”, from each said described defendant(s) above to further secure Plaintiff truth to oppose any further summary judgment dismissal requests made by each defendant(s) and their prospective counsel of record.
Each of the name defendant(s) above seeking removal from this U.S. District Court action and base their hopes in large parts Plaintiff’s failure to state a claim upon which relief can be granted
Plaintiff respectfully assert/submits Plaintiff complaint, and Amend Complaint, supplemental facts with all facts presented has been profess, maintain, allege, contention, accusation enough for a declaration that each of the Defendant(s) herein as described above
Be brought before the Honorable U.S. Court jurisdiction to further foster a true understanding of all of the particulars as laid out by the Pro Se Plaintiff,
And be further Honorably promoted by the stated U.S. District Honorable Court and advance before a Jury Trial for each of the disgraceful, extreme and outrageous offensive acts and actions so despicable of a shameful and shocking notoriety nature warranting each name defendant(s) Motion to dismiss Plaintiff’s Complaint be denied with prejudice”.
The Plaintiff seeks a very long list of “civil cause” of action(s) against each name defendant(s) under among other things civil relief notwithstanding that;
The Defendant, Herein (Lawson M.D.) Violation(s) of and Non-conformity Behavior for the United States Immigration and Naturalization Service (INS) regulation and rules thereof;
Namely the United States Oath of Allegiance (officially referred to as the "Oath of Allegiance," 8 C.F.R. Part 337 (2008).
With Defendant (Lawson M.D.) and confederates-Co-Defendant(s) listed above commit civil cause of action under (RICO) Racketeer Influenced and Corrupt, Title 18, United States Code,
To include but not limited many other stated cause of action(s), against each name defendant(s) herein as described in the Original Complaint,
And amend described cause of action listed in the Amend Complaint for among others cause of actions totally like’
“Medical malpractices, breach of fiduciary duties, legal malpractice, medical fraud, actual fraud, breach of contract, defamation; Intentional Infliction of emotional distress and mental anguish”
Among other stated cause of actions as out line for the Honorable Court in the records not to allow an honorable defendant(s) dismissal as they each request at this time.
Plaintiff original complaint, amend complaint, and all supplemental facts may not be and should not be dismissed on the combine defendants’ motion
Because Plaintiff did in fact states some sort of several claim(s), baseless though it may eventually prove to be; in the eyes of the Defendant(s) “only”, and inartistically as the complaint may be drawn by said defendant(s) combine logic,
And their prospective counsel of records ineffective, pathetic, rubbish, worthless and useless defense; in light of all truthful facts being brought to light
Plus the Plaintiff never “knew nor met” a defendant thus far whom he filed civil action against who went kicking & singing along happy before an Honorable U.S. District Court Inspection” with out filing for a dismissal,
Especially with such extreme, hostile, nasty, spiteful, malicious, ghastly and grave acts and actions as detailed, described and levy against each said named defendant(s) herein the records being present before the Honorable Court;
IV.
Conclusion
“No man has the rights to commit aggression on the equal rights of another; and this all from which the laws ought to restrain him;
Every man is under the natural duty of contributing to the necessities of the society;
And this is all the law should enforce on him: and no man having a natural right to be the judge between himself and another,
It is his natural duty to submit to the umpirage of an impartial third. When the laws have declared and enforced all of this, they have fulfilled their function”
“Thomas Jefferson”
Wherefore the Pro Se Plaintiff Louis Charles Hamilton II,
At this time respectfully moves the above-Honorable U.S. District Court
To denied dismiss of each name Defendant(s) herein from this civil cause of action
And their respective counsel to include denial of counsel joint motion(s) to dismiss this civil action for reasoning institute described and stated above with prejudice.
Respectfully submitted and dated on the ________
Day of _______________, 2010
By, ________________________________
Louis Charles Hamilton II
Pro Se Plaintiff
P.O. Box 20126
Houston, Texas 77225
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