United States District Court
Southern District of Texas
Houston Division
Louis Charles Hamilton II Amend Complaint
Pro Se Plaintiff Jury Demand
Vs. Civil action No.H-10-2709
Harry C. Arthur (Esq.)
Defendant
Law office of Harry C. Arthur et al
Co- Defendant(s)
Marine Building, L.L.C. et al
Co-Defendant(s)
1.
Comes Now the Pro Se Plaintiff, Louis Charles Hamilton II, hereby files a Amend Complaint with the above Honorable Court and for Cause”
The Plaintiff will show the Honorable Court all facts as follows:
2.
Parties
Pro Se Plaintiff
Louis Charles Hamilton II, African American Male, Currently Homeless U.S. Navy Veteran, Permanently Disable Citizen 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
3.
Defendant
Harry C. Arthur Esq.
A Houston Personal Injury Attorney
1305 Prairie Street Suite 200
Houston, Texas 77002
Advertisement states:
CALL THE FIRM THAT CARES!
CALL THE FIRM THAT CARES!
4.
Co- Defendant(s)
Law offices of Harry C. Arthur
1305 Prairie Street Suite 200 Houston, Texas 77002
Harry C. Arthur (Owner) (Personal Injury Attorney) suite 200
Larry G. Justin (Case Manger) suite 200
Ralph M. Wear (Case Manger) suite 200
Humberto R. Trejo (Criminal Attorney) suite 200
Sonia Behrana (Attorney) suite 200
Pat Vargas Grady (Attorney) suite 200
5.
Co- Defendant(s)
Marine Building, L.L.C. et al
1305 Prairie Street Houston, Texas 77002
Harry C. Arthur (Owner) suite 200
(Tenants)
1. AA Quick Bond suite 100
2. Mike Cox’s Bail SVC suite 101
3. Lacey’s Deli
4. Jonathan A. Gluckman (Attorney) suite 102
5. Wayne Heller (Criminal Attorney) suite 103
6. Law offices of Harry C. Arthur suit 200
7. The Ring Investigations Mark Thering suite 300
8. The Ring Investigations Kandy Villarreal suite 300
9. Mark Thering (Attorney) suite 300
10. Darrel Jordon ( Criminal Attorney)
11. Daniel Perez-Garcia (Criminal/Immigration Attorney) suite 300
12. Marquerite Hudig (Criminal Attorney) suite 300
13. Carl D. Haggard (Attorney Mediator) suite 300
14. F.M. (Poppy) Northcut (Criminal Attorney) suite 300
15. Sandra Martinez (Criminal Attorney) suite 300
16. Allen J. Guidry (Criminal Attorney) suit 300
6.
Venue
Venue is proper before the Honorable Southern District of Texas U.S. District Court in that all parties reside within Harris County, Houston Texas when all incident(s) as described herein occurred;
All defendant(s) herein were at the time frame being Complain of; were within their individual persons and their places of Professional business are located within Harris County, Houston Texas;
7.
Jurisdiction
The Plaintiff Louis Charles Hamilton II, Respectfully Asserts the above Honorable U.S. District Court has proper Jurisdiction 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,
8.
Plaintiff Respectfully Assert the above Honorable U.S. 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),
Additionally the above Honorable U.S. District Court having subject jurisdiction over matters involving “Defamatory Libel” and “Obstruction of Justice” with The Honorable Court Entertainment of “Special Jurisdiction” for offense of among other things having been committed by defendant(s) singularly or collectively in Conspiracy to Fraud against the United States Federal Government assistant Programs for profit;
To include but not limited to the Court having the exercise fundamental Jurisdiction over State of Texas Subject matters involving “Malicious Civil Tort”, “Intrinsic Fraud”, “Breach of Fiduciary duty”, “Fraud upon the Court in the capacity of a Attorney of law(s) and officer of the Courts State of Texas
To include but not limited to all defendants herein collectively in concert, conspire, and commitment(s) to acts and actions of aiding and abetting, Assisting and participating,
To comment of (RICO) violations against the Plaintiff rights and dignity
While systematically involving the usage of among other things such as invidious discrimination & defamatory practices, to include defendant(s) collectively committed to;
Actual Fraud being committed during a civil court proceeding,
While further actual Fraud upon the State of Texas Civil Court system in the introduction of fabricated evidence and material facts with fabricated evidence and material facts being posted and promoted and publish in a scheme through mail fraud and wire transmission for the purpose of furthering a scheme to defraud if the transmission of media coverage
In an additional incident to the accomplishment of an essential part of a scheme for profit.
Fraud upon the Public through Court records and Media transmissions for all of which was in a fraudulent scheme for profit at the expense of the Plaintiff legal rights & dignity.
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 of Law in that on or about (Nov. 23, 2009 -- three days before Thanksgiving Day)- To Wit:
The Defendant (Arthur) and Co-Defendant(s) hereafter named (Law office of Harry C. Arthur)
And Co-Defendant(s) (Marine Building L.L.C.) instituted a malicious civil action tort against Christ Church Cathedral Naming the (Beacon) within the suit seeking several cause of actions namely aim to shut down (Christ);
Which capture “News Head lines” as breaking news story local and nation wide through transmitting via device such as newspapers, radio, T.V. and Internet” labeling Houston Texas as “Derelict town” “USA” and the Defendant “Harry C. Arthur Esq. a/k/a “Scrooge” going to put a handle on things and toss out the “Nasty” Plaintiff and all homeless people at the homeless center base upon them being a nuisances among other charges made by (Arthur).
To include but not limited to defendant(s) collectively sought to among other things impose a permanent injunction against (Christ) to shut down The Beacon, the homeless center, on the ground it's a "private nuisance”;
Claiming among other things in a “Hostile Tort containing defamatory, discriminatory and Invidious Discrimination fashion that the Plaintiff and other(s) similar situated just simply mill about, panhandle, bum cigarettes, urinate, defecate, sleep and make a general nuisance of themselves;
See: Harry C. Arthur et al and the Marine Building L.L.C. et al vs. (Christ) Filed in Harris County Texas District Court in Houston Texas.
In said suit against Christ Church Cathedral, filed on Nov. 23, 2009 -- three days before Thanksgiving – The Defendant herein Arthur and The Co-Defendant Marine Building et al seek a minimum of $250,000 in damages from Christ Church Cathedral and The Beacon to compensate them for the loss of rentals in the three-story building and its market value.
Defendant Arthur's trial firm is in the building, which is located diagonally across an intersection from The Beacon.
The Beacon is operated by Cathedral Health & Outreach Ministries, a nonprofit established by the cathedral.
The Plaintiff asserts that (Arthur) in Christ church cathedral alleges that the "derelicts" (Christ church cathedral) assists has become a public nuisance, destroying the value of his business and property in the process.
To include but not limited to Defendant (Arthur) further defaming and applying invidious discrimination tact’s against the Plaintiff reputation by accusing the Plaintiff to be a danger to the health and safety of others in the adjacent areas,”
The defendant (Arthur) suit further states. “The (Plaintiff) and other individuals sing play music, dance, and fight and (do) other “undesirable activities”
The Defendant (Arthur) says. Further that "If all you do is feed them, you encourage them to stay on the street. And I'm afraid that may be kind of a little bit what's happening. They don't have any incentive to do anything."
The Plaintiff will show the Honorable Court that each and every defendant listed and described above conspire in concert with their individual legal profession as (Attorney of Law) to organize fraudulent representation of Finances in “material facts” in civil tort filing as described above in that the defendants collectively willfully wanton and aggressively committed the following:
1. Made a fraudulent bogus submission of material facts in Judicial Court records in Harris County Texas that each defendant separately business operation structure in connection with The Marine Building L.L.C. financial income was effected and in great, risk, loss and jeopardy as described in the complaint of (Arthur);
a. Made a further fraudulent bogus submission of material facts of insinuation, suggestion, implication, allusion and innuendos in Judicial Court records that each defendant as described herein personal financial income and all assets derive their of from said business structure as being describe as: Tangible assets those that have a physical substance and can be touched, such as currencies, buildings, real estate, vehicles, inventories, equipment, and precious metals
b. To include all live stock, farm animals, domestic animals, cattle, sheep, pigs, horses, birds, and stock within the United States;
c. To include all live stock, farm animals, foreign animals, cattle, sheep, pigs, horses, birds, and stock;
d. To include all 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). in the United States
e. To include all Short-term investments — include securities bought and held for sale in the near future to generate income on short-term price differences (trading securities).
g. To include all 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.
h. To include all 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.
j. 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.
l. To include all "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).
2. Was effected and in great risk, loss, and jeopardy as described in the complaint of (Arthur) because of the action of the Plaintiff and other similarly situated ;
3. Defendant (Arthur) then further in judicial court document filing in said malicious civil tort made the further fraudulent bogus submission of material facts of insinuation, suggestion, implication, allusion and innuendos in Judicial Court records that each defendant as described herein combine business financial income and (assets) & their personal income and (assets) after deductions of, housing or rent, phone bills, electricity, gas, water and sewer, cable, waste removal, maintenance or repairs, transportation, insurance, food, dining out, pets, personal care, medical, entertainment, taxes (Federal and State), saving or investments
As described above was not even enough for (Arthur) future financial business survival and security thereof in the Marine Building L.L.C. and base this all on the actions of the Plaintiff being a “Derelict” among other defamatory statements publish in a “Civil Tort”
Plaintiff will show the Honorable Court each defendant singularly and collectively was fully aware of his actions (most defendants being Attorneys of law no less) in holding together and collectively in such omission of actual material facts and allowing (Arthur) in the presentation of all combine fraudulent financial statement(s) being filed before a Texas Court of law by defendant (Arthur) in a hostile tort fashion of each defendant(s) independent business dealing collectively together.
Plaintiff Respectfully state before the Honorable Court that The Marine Building at the time frame (Arthur) made bogus, fraudulent, false wording before a Harris County Court of Law within the State of Texas in regards to “Lost Revenue and its association with extra rentals”, defendant(s) collectively “new at the very moment they were all combine in providing false material facts when no such possible “Rental space revenue loss exist
Nor were their any extra spacing for rental at the time frame (Arthur) made complaint against (Christ) nor were their any losses at all in combine said rental property revenue within the “Marine Building L.L.C. et al
To include but not limited to such other factors that the plaintiff “investigation computation” render true facts that all Co-Defendant(s) Listed above under the “Marine Building L.L.C. et al do in fact having total possession, total custody and total control of all “possible rental spacing” as stated on the building directory
Plaintiff will show the Honorable Court that the Defendant (Arthur) and Co-Defendant (Law office of Harry C. Arthur) and the (Marine Building L.L.C. et al) were very delusional, hallucinating, figment of the imagination, and under miss guided myth in the impression and mirage that the Co-Defendants (Marine Building L.L.C.) were with extra spacing for rentals
To include the Plaintiff will show the Honorable Court defendant (Arthur) providing in official court document dated (-----) with (Arthur) signature to the effect of statement in regards to the Defendant (Arthur) financial dire state was above average for his business, and his personal interest and to include for his entire family are all among doing quite financially well off;
To the point (Arthur) stated in court records that the past devastating economic down fall effects having no effect upon the defendant (Arthur) and his et al.
The Plaintiff will show the Honorable Court all defendant(s) singulary and or collectively were committed to making extreme calculations and execution(s) of false prejudice or stereotyping statements of the reputation of the Plaintiff as described in the “Tort” filed against (Christ) of being substandard which defendant carry out this scheme for profit through the Wide spread media News agencies both local and National ” at the expense of Plaintiff to be of a“
Nasty horrid revolting reputation” in connection with defendant(s) collective “Financial scheme/crime of things for profit”
And conspiracy in connection thereof, for unauthorized access of a protected media computer, public records and court records & court: txed
And all protected records thereof, in which all defendant(s) herein collectively did access said mail and wire computer device(s) to provide and promote tremendous amounts of “Negative” fraudulent personal and business information which were “indeed” attempt to be used in a fraudulent advantage way to fraud for wrongful future gains of monies and to scam in the devalue of real estate property of the Co-Defendant(s) (Marine Building L.L.C.) and surrounding area’s
To include but not limited to all defendants commitment to a further conjure to work collective for defendant (Arthur) scheme of things in among other things in obstruction of justice in connection to collection(s) thereof of all ill-gotten gains
And placing a long “term of loss value on (Christ) property in the Houston Down town area
Misrepresentation of all material facts in regards to all defendants financial business survival, endurance, continued existence, dilemma, predicament, and possible financial business death during a Legal Judicial proceeding, and in public records
Fraudulent omission in the presentation of all material facts in official court records in regards to the Defendants business financial dire situation to fraud the “Interest of (“Christ”) against the rights of the Plaintiff.
The Plaintiff will show the “Honorable Court Defendant(s) collective scheme of things could not for any reasoning exclude the Plaintiff from this group (Beacon Clients) because it would be counter productive to the “Master Plan” if casting the Plaintiff as the only decent, clean, dirt free, cleanse, spotless, sophisticated, skilled, learn, knowledgeable, educated, and privileged person among the group and opposite from the group and the defendant(s) collective scheme has no chance ever of survival.
The Plaintiff will show the Honorable Court the Defendant(s) collective scheme of things in the usage of “Invidious Discrimination tactic & Defamatory tactic” against dignity because the Plaintiff is a part of group associated with (Beacon Clients) also was express by the sarcasm, mockery, cynicism, travesty of exaggeration(s) of the Plaintiff to be with out cause to exist and Plaintiff only existence on earth in the Houston Texas area is for free food @ the (Beacon) only”
To include but not limited to facts surrounding the defendant(s) collectively wrongful use of liable/slander against (HPD) Houston Police Department to their advantage by ways of making false claims of no security being properly provided in the area of the (Beacon) or lack there of as stated in the complaint of the defendant(s) which is so untrue and supported by Police reports in the city of Houston Texas during the time frame (Arthur) made complaints against (Christ).
In which the Defendant(s) collectively further sought safely to carry out their Organization well premeditated plans to degrade the downtown area “Property Value” around (“Christ”) with its claims of the Plaintiff being “Total Human Trash “
While defendant(s) herein collectively plan a systematic using/planning hostile by further future means to obtain the Property of (Christ) with the unwitting “Media” usage for wide spread media coverage in connection with a financial scheme & fraudulent crime of things
With the “Media” also as the main driving device to carry out for the defendant(s) devily clever collective “sham and scheme” of things to create a property lost for the benefit of the Marine building L.L.C. with the Plaintiff being unwittingly at the “Hands of all defendant(s) herein being the source of all “depreciation and degrading factors” against (Christ) property and the local area property for a profit scam
The defendants collective scheme of things to devalue the property of (“Christ”) and the real estate for the benefit of Co-Defendant in this action Marine Building L.L.C in the downtown Houston, Texas area To include but not limited to the Free promotional Advertisement for Co-Defendant (Law office of Harry C. Arthur) being the Reputed Ruthless Law Firm
And all of the ill-gotten revenue derive their of from the “New Reputed Ruthless Law Firm Reputation” with Defendant (Arthur) and Co-Defendant (Law Office of Harry C. Arthur et al) further scheme and sham of things being wrongfully promotion with the free planned usage of the unsuspecting, unwitting, unconscious, efforts of all media agencies both “local and national” with the “Internet” included at the expensive of the Plaintiff and other instantaneously similar the same.
All was indeed done unjust, and most certainly unwanted against the Plaintiff “rights and dignity”, to include this scheme of things was further to fraudulent cheat (Christ) out of monetary federal/private/donation funds in excess of ($250,000) base all wrongfully upon the Plaintiff being “Street Nasty Trash” in the area around The Marine Building L.L.C. for a future profit scheme of the Defendant(s) collective shame to include alternatively Plaintiff is able to show the defendant(s) having further premeditated plans after the impose permanent injunction against the (Beacon) defendant(s) sought to further obtain (Christ) property for them self or some other real estate conglomerate for further scam for profit(s).
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 (66) for cause of actions against the rights and dignity of the (Plaintiff) Louis Charles Hamilton II:
Which all was indeed directed wrongfully at the Pro Se Plaintiff(s) Louis Charles Hamilton II;
Plaintiff seeks Declaratory Judgment being entered into the records of this action against the Defendant, (Arthur) Co-Defendant(s) (Law office of Harry C. Arthur et al) and Co-Defendant (Marine Building L.L.C. et al) individually and collectively as described herein committed all acts and actions as described fully herein in Violations committed under Chapter 96 of Title 18, United State Code: (RICO) Racketeering Influences Corruption Organization practices against the legal rights of the Plaintiff in connection with Fraud as described in paragraph
No comments:
Post a Comment