Plaintiff Amend “Actual Damages” To “Motion for Summary Judgment” No. A-180805

No. A-180805

IN THE DISTRICT COURT 58TH JUDICIAL DISTRICT Court of JEFFERSON COUNTY, TEXAS

Louis Charles Hamilton II
Plaintiff

V.

Joyce Guy & Edward McCray ET AL
Defendant

Plaintiff Amend

“Actual Damages” To “Motion for Summary Judgment”

Comes Now the Pro Se Plaintiff Herein Respectfully Amend “Actual Damages” to Plaintiff motion to “Summary Judgment” as follows:

1. Defendant(s) “Joyce M. Guy” and “Edward McCray” collectively in addition to The Theft of all of the Plaintiff Construction Company “tools” as being described in the complaint before the “Honorable Court”.

2. Defendant(s) collectively cost the Pro Se Plaintiff $48,000.00 minimal “lost wages” and “lost earning capacity” per year since November 17th 2007 date of injury

3. throughout November 17th 2014 for a period of (7) years at a total “lost wages” and “lost earning capacity” in excess of $336,000.00 U.S. Dollars

4. Defendant(s) Joyce Guy & Edward McCray Refuse to even acknowledge in discovery request “Request for Admission Questions”

being in said possession, custody and control of Pro Se Plaintiff “Personal Property” namely “Construction Tools in excess of $3093.00 U.S. Dollars as this being Pro Plaintiff Special Independent Contractor “Trade and Profession”.

Pro Se Plaintiff files in Support of Plaintiff Motion for “Summary Judgment” affiant “Subscribed and Sworn” Affidavit of “Lewis Garza”

in Support of Summary Judgment in favor of the Pro Se Plaintiff “Louis Charles Hamilton II

Stating: On November 17th, 2007 I took my stepson to 448 DeQueen Blvd. in Port Arthur Texas. To do work on a house. He had a few thousand dollars in tools.

The Owner of the home kept all of the tools and refused to return them.

Ladders, generator, Nail guns, & numerous hand tools.

Lewis Garza

Subscribed and Sworn on the 14th day of November 2014

“Kendra Monk” Notary Public, State of Texas

1.

Wherefore Pro Se Plaintiff “Louis Charles Hamilton II herein shall request, state, and argue before the “Honorable Court” on the 17th day of December 2014 at 8:30 am hearing before the “Honorable Court” to “Amend” to the Complaint, Summary Judgment

“Actual Damages” to Include “Lost wages” and “lost earning capacity” as of November 17th 2007 being wrongfully enforced upon the Pro Se Plaintiff in the “Theft” of all of the “Construction tools” described in the Original Complaint

2.

Wherefore Pro Se Plaintiff “Louis Charles Hamilton II herein respectfully state before the “Honorable Court” to Amend “Actual Damages” to this civil action to include and represent “lost wages” and “lost earning capacity” as already stated in Pro Se Plaintiff Motion for “Summary Judgment” being wrongful civilly caused to the Pro Se Plaintiff, in the

“Theft” of “Personal Property” which Defendant causing Pro Se Plaintiff to continue suffrage such “lost wage” and “Lost earning capacity” in excess of $48,000.00 per year since 2007 (November) for a total of 7 years as of November 17th 2014.

3.

Wherefore Pro Se Plaintiff “Louis Charles Hamilton II herein Respectfully state further before the “Honorable Court” to Amend “Actual Damages” to include 6% interest incurred since date of injury November 17th 2007 to the “lost wages” and “lost earning capacity” in excess of $48,000.00 U.S. Dollars

Being “actual damages” Pro Se Plaintiff “lost wages” and “lost earning capacity” at a rate of (7) years = $336,000.00 U.S. Dollars as of November 17th 2014 and this is ongoing until the final resolution of this “Civil Suit” in “Common Law”.



By, _______________________________
Louis Charles Hamilton II
Pro Se Plaintiff
P.O. Box 17524
Sugar Land Texas 77496

“Lewis Garza” Sworn Affidavit in Support of Pro Se Plaintiff motion for Summary Judgment No. A-180805

No. A-180805

IN THE DISTRICT COURT 58TH JUDICIAL DISTRICT OF JEFFERSON COUNTY, TEXAS

Louis Charles Hamilton II
Plaintiff

V.

Joyce Guy & Edward McCray ET AL
Defendants.


Pro Se Plaintiff herein files “Subscribed and Sworn” Affidavit of “Lewis Garza” in Support of Summary Judgment in favor of the Pro Se Plaintiff

Stating: On November 17th, 2007 I took my stepson to 448 DeQueen Blvd. in Port Arthur Texas. To do work on a house. He had a few thousand dollars in tools.

The Owner of the home kept all of the tools and refused to return them.

Ladders, generator, Nail guns, & numerous hand tools.

Lewis Garza

Subscribed and Sworn on the 14th day of November 2014

“Kendra Monk” Notary Public, State of Texas

Pro Se Plaintiff state, declares, and affirms before the Honorable 58th Judicial District court of Jefferson County Texas,

Defendant(s) Joyce M. Guy and Edward McCray supplied false, misleading, fraudulent information in their reply through Attorney of Record Antoine L. Freeman, J. D.

In response to Pro Se Plaintiff Set of Request for Admission pursuant to Rule 198 of the Texas Rules of Civil Procedure said (Request for Admission) filed as exhibit attached herein to Plaintiff Motion for Summary Judgment” in regards to Construction tools at

Question 11. Admit that the Co-Defendant introduce himself to the Plaintiff step father when Plaintiff was delivering tools to the home located at 448 DeQueen Blvd. in Port Arthur Texas. (Response) DENIED

Question 14. Admit that the Defendants collectively have in their custody, possession and control Plaintiff construction tools. (Response) DENIED

The Pro Se Plaintiff State before the “Honorable Court” the Defendant(s) “Joyce M. Guy” and Edward McCray” having possession, custody, and ongoing (7) years continual control collectively over

the Pro Se Plaintiff “Personal Property” Namely All of His Company Construction Tools” in excess of $3093.00 U.S. Dollars.

Pro Se Plaintiff files Affiant “Lewis Garza” Sworn Affidavit in Support of Pro Se Plaintiff motion for Summary Judgment, as Affiant is in fact Pro Se Plaintiff “Step-Father” for over a period of 25 years married to Plaintiff Natural “Mom”, Retired from Gulf Oil Corporation,

And a “Vietnam Veteran” ready to Stand before a Jury Trial in this civil matter in a suit in common law and state them same factual circumstances, wrongful acts and actions into the “Hostile Theft” of The Pro Se Plaintiff “Construction tools”.

Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves the Honorable Court to view Affiant “Lewis Garza” Sworn Affidavit in Support of Pro Se Plaintiff motion for “Summary Judgment”

and reach a Full, Final and Complete Judgment of This Honorable 58th District Court of Jefferson County Texas

in Favor of the Pro Se Plaintiff motion for “Summary Judgment”.



By, _______________________________
Louis Charles Hamilton II
Pro Se Plaintiff
P.O. Box 17524
Sugar Land Texas 77496

"U.S. District Court" Louis Charles Hamilton II vs. Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 et al

66.

                                    Cause of Actions

Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” a Cause of Actions exist against Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 And Co-Defendant(s) “Joyce M. Guy and Edward McCray”

Collectively for “Actual Fraud” and the performance thereof in the capacity of a “Attorney of Law” to include constructive fraud, fraudulent intent, fraudulent pretense, fraudulent concealment, fraudulent misrepresentation, fraudulent conveyance, Extrinsic Fraud, Fraud in fact and Fraud in law, fraud in the execution of Plaintiff construction contract by Co-Defendant(s) “Joyce M. Guy and Edward McCray” for purpose to fraud “Insurance Company”

To include collectively Fraud on the Court involving fraudulent activities upon the 58^th Judicial District Court of Jefferson County Texas, and all court records, court documents, electronic transmission, court transcripts, and document thereof

Fraud against Insurances Companies, State of Texas, and the United States of America FEMA and Federal Housing Grant agencies involving Past Hurricane storm related damages all of which being described in paragraph (66) herein involving the Pro Se Plaintiff herein being past, present, and future thereof to commit monetary Fraud gain in among other things Fraud of Insurances Companies, State of Texas, and the United States of America FEMA and Federal Housing Grant agencies involving the dwelling located at 448 DeQueen Blvd. In Port Arthur Texas

Committed against the civil rights, peace, and dignity of the Pro Se Plaintiff Louis Charles Hamilton II herein before a civil suit in common law within the State of Texas. 

                                                67.

                                    Cause of Actions

Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” a Cause of Actions exist against Co-Defendant(s) “Joyce M. Guy and Edward McCray” for Defamation of The Pro Se Plaintiff reputation and his Profession in construction in connection with Co-Defendant(s) collectively fraudulently activities to obtain a New Home

And Co-Defendant(s) collectively maintain such defamation acts to secure a 76,000.00 U.S. Dollars Federal Housing grant in that the Pro Se Plaintiff “Louis Charles Hamilton II” herein is the “direct cause” of the dwelling located at 448 in DeQueen Blvd. in Port Arthur Texas being un-inhabitable for human living conditions due primary for substandard faulty structural construction repairs of said dwelling being committed by Pro Se Plaintiff herein

 Whom never even made any such repairs on said home just (Pro Se Plaintiff) construction contract being executed and  used to continue fraud the Insurance company for more monetary wrongful gain of “insurance Company repair funds

other than Co-Defendant(s) actually fixing Hurricane Humberto storm dames to dwelling located at 448 DeQueen Blvd. in Port Arthur Texas as described in this complaint  Co-Defendant(s) ) “Joyce M. Guy and Edward McCray” Committed against the civil rights, peace, and dignity of the Pro Se Plaintiff Louis Charles Hamilton II, herein.

                                                68.

                                    Cause of Actions

Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” a Cause of Actions exist against Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 for “Actual Damages”

 In this (RICO) and Fraudulent numerous conspiracy corrupted scheme of things and corrupted activities in concert, and full collusion being also brought and paid for to “expert cooking the “legal court books” of a Honorable 58^th Judicial Court of Jefferson County Texas in Favor of the corrupted (RICO) described Co-Defendant(s) herein

To further along promote and fully cover up all (RICO) activities, Fraud of Insurances companies, FEMA and Federal Housing Grants both being “past and present” mutable fraudulent activities of the Co- Defendant(s) “Joyce M. Guy and Edward McCray” herein involving the Pro Se Plaintiff Louis Charles Hamilton II “Among others” being fully described herein to include but not limited to

                                                69.

Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 (RICO) and Fraudulent numerous conspiracy corrupted scheme of things activities in concert, and full collusion in the capacity of a “Attorney of Law” against the Pro Se Plaintiff personal property namely “Construction tools” in excess of #3000.00 U.S. Dollars and lost wages at a minimums of $48,000.00 U.S. dollars per year “lost wages” since date of injury of November 2007

And Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 to “continue depriving” the Pro Plaintiff of his entire “Construction Trade” and “Profession” in such a complex illegal rooted (RICO) conspirer and fraud of the court system “scheme of things” being attached to the “Actual theft” of all of the Pro Plaintiff Construction tools and profession trade thereof for a period now exceed (7) years and counting well into 2015

As “Defendant and Co-Defendant” collectively enjoys and having monetary gain collectively thereof from such wrongful ongoing (7) years “civil victory” and corrupted (RICO) Fraudulent advantages, corrupted acts, and actions over the Pro Se Plaintiff civil rights, peace and dignity, and fairness to the Texas Civil Rules of Civil Procedures in a “civil suit” in “common law” as being described herein this complaint

                                                70.

Further being described once before the same U.S. District Court of Eastern District of Texas when (Pro Se Plaintiff) filed his first original (RICO) complaint being legally made thereof and now no question beyond any doubt ever being so “crystal clear” in 2014 (November) the Pro Se Plaintiff confident in being precise, and having a “well understanding” into this well twisted, calculated, future plotted, manipulated, (RICO) mutable Fraudulent count enterprising “scheming activities” derive thereof and its involvement with Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 herein for

 “Actual Damages” exceeding (7) years conspire collectively with Co-Defendant(s) herein to depriving the Pro Se Plaintiff of his “personal property” namely “Construction tools” in excess of $3000.00 U.S. Dollars and “lost wages” at a minimums of $48,000.00 U.S. Dollars

Pro Se Plaintiff being an “Independent Construction Contractor” suffrage “lost wages” per (7) year since date of injury of November 2007 in the “Actual Theft” of Said Construction tools. With 6% interest incurred since date of injury being November 2007 into the future of 2015 as this Complaint being “examine and entertain” before the “Honorable Justice” of such “Actual Damages”

                                                71.

Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 herein so did in all facts, court records, and real life circumstances commit to, designed further to caused the Pro Se Plaintiff herein to suffer extreme “monetary hardship” in such lost of “Actual Damage” in excess of $336,000.00 U.S. Dollars in (7) years of “Lost wages” and counting into 2015

 This (RICO) scheme of things in still enforced, ongoing and very live against the Pro Se Plaintiff Louis Charles Hamilton II

As Defendant (Attorney at Law) herein (RICO) activities with the Co-Defendant(s) same (RICO) activities commit his (Attorney at Law) profession to commit to fraud of the Court “while” being in possession, custody, and control as a “Officer of said 58^th Judicial District Court of Jefferson County Texas

Further Defendant (Attorney at Law) herein (RICO) activities acts and actions fully continue to depriving both past and present causing the Pro Plaintiff to continue suffrage “Actual Damages” in excess of $3000.00 U.S. Dollars in Lost of said “Construction tools” and the “Profession Trade” thereof since November 2007 well into the future of 2015.

                                                72.

Pro Se Plaintiff seeks same such “Actual Damages” exceeding (7) years Co-Defendant(s) “Edward McCray and Joyce M. Guy” herein depriving the Pro Se Plaintiff of his “personal property” namely “Construction tools” in excess of $3000.00 U.S. Dollars and “lost wages” at a minimums of $48,000.00 U.S. Dollars being a Independent Construction Contractor “lost wages” per (7) year ongoing lost since date of injury of November 2007 in the “Actual Theft” of Said Construction tools.

With 6% interest incurred since date of injury being November 2007 being lost as being described in paragraph (68) herein Defendant (Attorney at Law) conspire (RICO) with the  Co-Defendant(s) “Edward McCray and Joyce M. Guy” In the ongoing Civil Action suit in Texas State Court Docket No. A-180805 before the 58^th Judicial District Court of Jefferson County Texas

Pro Se Plaintiff seeks such actual damages in a “Summary Judgment motion” just filed in November of 2014 and being heard “oral and argue” before the “Honorable 58^th Judicial District Court of Jefferson County Texas on December 17^th 2014 at 8:30 am as this “Honorable 58^th Judicial Court

Having full ongoing expert “subject matter jurisdiction” over the Co-Defendant(s) “Joyce M. Guy” and “Edward McCray” and all “actual damages” Pro Se Plaintiff seeks therein “State Court”

73.

Other than Co-Defendant(s) “Joyce M. Guy” and “Edward McCray” Collectively ongoing (RICO) Fraudulent activities among other “Federal Subject matter jurisdiction” wrongful “acts and actions” being committed in concert, collusion, and enjoyed manipulation and monetary gain derived thereof with Defendant as the Pro Se Plaintiff herein “Federal Questions” being raised before the “Honorable Justice” as to the Defendant and Co-Defendant(s) collective criminal/civil corrupted scheming uncivil behavior being committed

Against the Pro Se Plaintiff civil rights, peace, will, and dignity in a Civil Suit in common Law in connection with the Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 defense thereof.

which this “United States Eastern District Court of Texas having full expert “Honorable Justice” Subject Matter” over such among other things (RICO) activities described herein full

And the further full knowledge Defendant (Attorney at Law) executed in full wrongful conspire involvement being of a “Legal expert” to commit to among other things “obstruction of justice”, corrupted, misleading, manipulation” and fraud commitment upon the 58^th Judicial District Court of Jefferson County Texas in the public professional trade “among all things”

The “fiduciary capacity” of a legal “Attorney at Law” and “Officer of the Court” in and For the State of Texas.

                                                74.

Cause of Actions

Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” a Cause of Actions exist for “Intentional Infliction of Emotional Distress” against Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 and Co-Defendant(s) “Joyce M. Guy and Edward McCray”.

Pro Se Plaintiff herein Incorporated and state all Defendant (Attorney at Law) and Co-Defendant(s) herein enjoyed collectively their “Intent” scheming fraudulent manufactory purpose in wanting the Pro Se Plaintiff herein to suffer, extreme agony, heartache, distraint,  Accompany substantially massive monetary loss of “tools and services” in the Construction profession,

                                                75.

Humiliation, Defamation, and crushing legal defeat to inflict “excessive mental anguish” as a result of their combine craft complex ongoing conspire (RICO) elements, and fraud on the court to execute the same (RICO) objective

All of which being past, present, and further derive thereof Pro Se Plaintiff suffrage such future (7) years of ongoing “mental intent contempt” of the Defendant and Co-Defendant(s) enforced legal corrupted strong hold over the “common law” rights of the Pro Se Plaintiff

Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 and Co-Defendant(s) “Joyce M. Guy and Edward McCray”.

Civilly  accomplish with strong corrupted concealment motive not to be “confused or construed” with a simple attorney mistake by Defendant (Attorney at Law) a combine collective “cause of action” before the “Honorable Justice” for continual past, present, and future “Intentional Infliction of Emotional Distress”.

                                                76.

Cause of Actions

Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” a Cause of Actions exist for “Declaratory Judgment” of the Honorable Court against Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 and against Co-Defendant(s) “Joyce M. Guy and Edward McCray” as to all of the “material subject matter” fully declared past, present and future Before the Honorable Justice herein

Of the Defendant and Co-Defendant(s) Collective conclusive, conspire, concert, agreements, engagement, and execution, pilot, maneuver, manipulated, scheme upon  (RICO) actions and dealing,

Among other extreme behavior in fraudulent Corruption of The 58^th Judicial District Court System to induce, and perpetrate such Fraud upon the Court for a period in excess of (19) Months as each so stated, affirm, and declared statement of “material facts”, “events” and “circumstances” described fully herein this Complaint

                                                77.

Put an end to a doubt as to the “gross civil intention” of “Antoine L. Freeman J. D.  An “Attorney”, direct at the Pro Se Plaintiff “Civil Liberties” for a cause of action for “Declaratory Judgment” is made enter into the “Honorable Justice” decision, and final announcement of the Court Records against said Defendant.     

                                                78.

 Put an end to a doubt as to the “gross civil intention” of “Joyce M. Guy” and “Edward McCray” and their extreme scheming corrupted fraudulent behavior in “patter and practices” of Mutable (RICO) Fraudulent Scheming Enterprising Endeavors

Co-Defendant(s) Collective conclusive conspire agreements, engagement, and execution, pilot, maneuver, manipulated, scheme upon (RICO) actions and mutable fraudulent underhanded dealing(s),

Among other extreme outrageous behavior in fraudulent Corruption of “among others” The 58^th Judicial District Court System to induce, and perpetrate such Fraud upon the Court for a period in excess of (19) Months

As each so stated, affirm, and declared statement of “material facts”, “events” and “circumstances” described fully herein this Complaint direct at the Pro Se Plaintiff  “Civil Liberties” a cause of action for “Declaratory Judgment” is made enter into the “Honorable Justice” decision, and final announcement of the Court Records against said Co-Defendant(s) Collectively.

                                                79.

Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” a Cause of Actions exist for ‘Treble Damages” made enter into the “Honorable Justice” decision, and final announcement of the Court Records against said Defendant

Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 and Co-Defendant(s) “Joyce M. Guy” and Edward McCray” Collectively for their combine “wicked”, monstrous, appalling, atrocious, disgraceful, corrupted behavior direct at the Pro Se Plaintiff  “Civil Liberties” .

                                                80.

Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves the Honorable Court Justice, to Award to the Pro Se Plaintiff “Declaratory Judgment” against Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 and Co-Defendant(s) “Joyce M. Guy” and Edward McCray” Collectively in favor of the Pro Se Plaintiff.

                                                81.

Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves the Honorable Court Justice, to Award to the Pro Se Plaintiff “Actual Damages” against Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 for fraudulent conspire against Pro Se Plaintiff “personal property” namely “Construction Tools” Pro Se Plaintiff Personal property Lost in tool(s) is in excess of $3093.00 dollars

Award further with full 6% interest rate incurred since date of injury from November 16^th 2007 continual on into 2015 in excess of at a rate of (7) years and continual counting in favor of the Pro Se Plaintiff 6% interest incurring.

                                                82.

Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves the “Honorable Court Justice”, to Award to the Pro Se Plaintiff “Actual Damages” against Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 for fraudulently conspire against Pro Se Plaintiff as described herein this complaint for “Actual Damages” of “Lost wages” and “Loss of earning capacity” incurred in the “Continual Actual Theft” and “further executed fraudulent conspirers activities 

 Derive thereof” and fully committed, manipulated, scheme against by Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 herein in the “expert legal professional capacity” as a “Attorney of Law”

 Civilly in a Suit in “common Law” against the Pro Se Plaintiff “personal property” namely “Construction tools”, involving Pro Se Plaintiff Special Trade, Skill and Profession thereof, in excess of $48,000.00 U.S. Dollars per year in lost wages Being a accumulated rate now in excess of $336,000.00 U.S. Dollars for the past (7) years “Lost wages” and “Lost earning capacity” Pro Se Plaintiff endure suffrage thereof.

“Award” further with full 6% interest rate incurred since date of injury from November 16^th 2007 continual on into 2015 in excess of at a rate of (7) years past and continual counting in favor of the Pro Se Plaintiff 6% interest incurring.

                                                83.

Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves the “Honorable Court Justice” for damages in the amount of the Honorable Court Justice for the Plaintiff suffrage of “Intentional Infliction of Emotional Distress” and “Mental Anguish” in Excess of the Jurisdictional amount of $75,000.00 U.S. Dollars against Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 in Favor of the Pro Se Plaintiff.

                                                84.

Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves the “Honorable Court Justice” for damages in the amount of the Honorable Court Justice for the Plaintiff suffrage of “Intentional Infliction of Emotional Distress” and “Mental Anguish” in Excess of the Jurisdictional amount of $75,000.00 U.S. Dollars against  Co-Defendant(s) “Joyce M. Guy” and Edward McCray” in favor of the Pro Se Plaintiff.

                                                85.

Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves the “Honorable Court Justice” for Award of “Treble Exemplary Damages” Statue of the “Honorable Court Justice” against Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 in favor of the Pro Se Plaintiff.

                                                86.

Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves the “Honorable Court Justice” for Award of “Treble Exemplary Damages” Statue of the “Honorable Court Justice” against Co-Defendant “Joyce M. Guy” and Edward McCray” Collectively in favor of the Pro Se Plaintiff.

                                                87.

Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves the “Honorable Court Justice” for damages in the amount of the Honorable Court Justice for the Plaintiff suffrage of Defamation of the Pro Se Plaintiff Construction Reputation in Excess of the Jurisdictional amount of $75,000.00 U.S. Dollars against Co-Defendant(s) “Joyce M. Guy” and “Edward McCray” collectively in favor of the Pro Se Plaintiff.

                                                88.

Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves the “Honorable Court Justice” for accumulative, compensatory, consequential, continuing, expectation damages, foreseeable, Future, incidental, indeterminate, reparable, lawful, proximate, prospective, special, speculative, substantial, Awards in Excess of the Jurisdictional amount of $75,000.00 U.S. Dollars against Co-Defendant(s) “Joyce M. Guy” and “Edward McCray” collectively in favor of the Pro Se Plaintiff for (RICO).

                                                89.

Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves the “Honorable Court Justice” for accumulative, compensatory, consequential, continuing, expectation damages, foreseeable, Future, incidental, indeterminate, reparable, lawful, proximate, prospective, special, speculative, substantial,

 Awards in Excess of the Jurisdictional amount of $75,000.00 U.S. Dollars against Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 in favor of the Pro Se Plaintiff for (RICO).

                                                90.

Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves the “Honorable Court Justice” for a Order the Defendant and Co-Defendant(s) collectively pay all court cost of this U.S. Civil Court Action.

                                                91

Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves and Request  the “Honorable Court Justice” for any further, Just, proper, Damages, Orders, and Awards The “Honorable Court Justice” Deems favorable for the behalf of Pro Se Plaintiff “Louis Charles Hamilton II” herein.

 

By, _______________________________

     Louis Charles Hamilton II

     Pro Se Plaintiff

      P.O. Box 17524

     Sugar Land Texas 77496

"U.S. District Court" Louis Charles Hamilton II vs. Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 et al

54.

            Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 herein used his skills as a “Attorney of Law” to commit fully to “Obstruction of Justice” for (16) months in refusal to reply to Pro Se Plaintiff Discovery Request to “facilitate”, and “conceal” Co-Defendant(s) “Joyce M. Guy and Edward McCray” by provide (Attorney in Law) Professional Legal efforts to evade the 58^th Judicial District Court of Jefferson County Texas proper administration of Justice in the complaint A-180805 against all of the Fraud activities already being described in said complaint against said Co-Defendant(s) herein.

            Furthermore Defendant (Attorney at Law) keeping the “Honorable Court” and The Pro Se Plaintiff isolated in 2008 while the ongoing (RICO) racket scheme of things currently ongoing fraudulent activities involving the secrete destruction of the old home located at 448 DeQueen Blvd. in Port Arthur Texas in exchange for a new one at the same location all of which being secretly done while the “older home” still being a civil issue of Fraud as described by the Pro Se Plaintiff before the “Honorable Court”.

                                                            55.

Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 herein “facilitate” all of his own “Fraudulent Activities” upon the Pro Se Plaintiff and fraud of the 58^th Judicial District Court of Jefferson County Texas for the full benefit of hiding the Co-Defendant(s) “Joyce M. Guy” and “Edward McCray” numerous corruption activities with the usage of the “United States Mailing System” to further long this fraudulent “scheme of things” before a “Honorable Court of Law” within the State of Texas and further long this “civil scheme” against the Pro Se Plaintiff as being described herein this complaint.

                                                56.

Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 herein “facilitate” all of the Co-Defendant(s) “Joyce M. Guy” and “Edward McCray” described corruption(s) and fraudulent activities with the usage of the “United States Mailing System” to further long this fraudulent “scheme of things” before a “Honorable Court of Law” within the State of Texas and further long this “civil scheme” against the Pro Se Plaintiff as being described herein this complaint.

                                                57.

Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 herein “facilitate” all of his own “Fraudulent Activities” and that he further conspire to and did in all facts and circumstances “facilitate” provide concealment, evade Justice for all of the Co-Defendant(s) “Joyce M. Guy” and “Edward McCray” described corruption(s) and “fraudulent activities” with the usage of the Jefferson County “Clerk of Court” Office Computer System, electronic records, and filing system thereof to further long this fraudulent “scheme of things”

 Before an “Honorable Court of Law” within the State of Texas and further long this “civil scheme” against the Pro Se Plaintiff as being described herein this complaint.

                                                58.

Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 herein “facilitate” and engage further in the usage of Extrinsic Fraud and tactics in the position as opposition counsel for the legal interest of Co-Defendant(s) “Edward McCray and Joyce M. Guy” to stop, conceal and hinder  Pro Se Plaintiff from rightfully being involved in said discovery request, so Pro Se Plaintiff not being able to obtaining favorable evidence to use as a advantage to prosecute civilly against the Co-Defendant(s) “Joyce M. Guy” and “Edward McCray” in the civil suit in State Court.

                                                59.

Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” Co –Defendant(s) “Joyce M. Guy and Edward McCray” committed to defamation of the Pro Se Plaintiff as being a dishonest, unskilled, substandard Construction Contractor and Pro Se Plaintiff is the reasoning for the older home located at 448 DeQueen Blvd. in Port Arthur Texas being demolished for providing faulty contractor structural work and repairs being unskillfully provided by Pro Se Plaintiff herein.

                                                60.

Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” Co –Defendant(s) “Joyce M. Guy and Edward McCray” used the defamation of the Pro Se Plaintiff substandard construction performance tactics with their previously Home Owner Insurance Company to satisfied any suspicion concerning the $10,800.00 dollars already wrongfully squander by said Co-Defendant(s) herein.

To include Co –Defendant(s) “Joyce M. Guy and Edward McCray” herein used the same defamation of the Pro Se Plaintiff character against the “Texas Department of Housing & Community Affairs” claiming further Pro Se Plaintiff being a substandard contractor in construction performance by providing faulty contractor structural work and repairs skills to the dwelling of 448 DeQueen and Pro se Plaintiff being directly responsible for the need of destruction of the old dwelling thereof in Port Arthur Texas

 in order through this same wrongful scheme of defamation of the Pro Se Plaintiff contractor skills to obtain further a New Home with this scheme of things through the “Texas Department of Housing & Community Affairs” other than the Co-Defendant(s) own numerous actual fraudulent activities in engaging in squandering all of the funds paid out for actual repairs as a result of Hurricane “Rita”, “Ike” and “Humberto” being done to said home.

                                                61.

Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 herein “facilitate” the same defamation of the Pro Se Plaintiff as being a dishonest, unskilled, substandard Construction Contractor and Pro Se Plaintiff is the reasoning for the older home located at 448 DeQueen Blvd. in Port Arthur Texas being torn down and a new one being built.  As described in paragraph (59 and 60) above.

                                                62.

Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” Co –Defendant(s) “Joyce M. Guy and Edward McCray” on or about the dates of April 2^nd 2008 and or April 11^th 2008 Co-Defendant(s) admitted collectively of the involvement to “Entice”, “Induce”, “Allure”, and “Ensnare” Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 herein in his “Legal Capacities” as a “Attorney at Law”

 To commit to “Actual Fraud” of the 58^th Judicial Court” of Jefferson County Texas  For the (RICO) purpose of “delays”, “concealment”, “omitting” and “hindering” all material facts, accounts, material circumstances both being past and present of the Co-Defendant(s) “corrupted enterprise activates”

 The Pro Se Plaintiff herein made numerous complaints thereof in Court filing records “Docket No. A-180805 and Before the State of Texas Investigation Services into the elderly

As well as all “discovery investigations” Pro Se Plaintiff was pursuing presently during said State Court Civil Complaint involving Co –Defendant(s) “Joyce M. Guy and Edward McCray” herein

In which further on or about April 2^nd 2008 and or April 11^th 2008 Co –Defendant(s) “Joyce M. Guy and Edward McCray” herein

Fully Conspire, maneuver, pilot, manipulated, scheme and monetary paid and financially secure Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 herein in his “Legal Capacities” as a “Attorney at Law” throughout the dates of November 13^th 2009 of his “paid in full legal services” for a total of (19) months to absolutely Violate Rule 193.1 Texas Civil Procedure in replying to the Pro Se Plaintiff Discovery request

 In order to fully engage in the covering up (RICO) collective scheme of things of Co-Defendant(s) “Joyce M. Guy and Edward McCray” having committed against The Pro Se Plaintiff,

58^th Judicial District Court, Insurances Companies, State of Texas, and The United States of America’, in a long criminal corrupted enterprise of “Fraud for Monetary Gain” of said Co-Defendant(s) collectively “rip off” activities being described herein now Before The above entitled “Honorable” United State Federal Court having subject jurisdiction matter over the” Defendant and Co-Defendant(s)”.

                                                63.

Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” Co –Defendant(s) “Joyce M. Guy and Edward McCray” on or about the dates of April 2^nd 2008 and or April 11^th 2008 throughout the present date of this U.S. Civil Complaint being made in the year of 2014 (November)

Said Co-Defendant(s) Collectively Promoted, Pilot, Scheme, Induce, Engaged, and fully Conspire with Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 herein to obtain in his “Legal Capacities” as a “Attorney at Law” in concert

 Violations of Chapter 96 of Title 18, United State Code: (RICO) Racketeering Influences Corruption Organization, Section 1341 (relating to mail fraud), section 1343 (relating to wire fraud), section 1028(relating to fraud and related activity in connection with identification documents), Section 1503(relating to obstruction of justice), Falsification of “Material facts”,

Fraud upon the 58^th Judicial District Jefferson County Court, Fraud on The State of Texas, and The United States of America in such “Monetary Conspiracies involving the Pro Se Plaintiff herein, and Hurricane “Rita”, Humberto” and “Ike” related storm damages with the usage of such numerous corrupted Fraudulent tooling maneuvers, and manipulated complex activities involving among other things

All Jefferson County Clerk of Office records, 58^th Judicial Court documents, electronic court filing transmission, court transcripts, and The United States Mailing System to promote, secure, and continue maintaining such (RICO) activities against the Pro Se Plaintiff Louis Charles Hamilton II herein

With Co-Defendant(s)  collectively Racketeering Influences Corruption Organization activities being described both past and present now in a further racketeering scheme of things involving a “Rouge Attorney” activities through Co-Defendant(s) “Joyce M. Guy and Edward McCray”  paid for hire “legal expert services” of Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 herein.

                                                64.

Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” Co –Defendant(s) “Joyce M. Guy and Edward McCray” promoted, conspire and secure (RICO) “Obstruction of Justice” activities of Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 herein against 58^th Judicial District Court complaint made thereof

For a Period of (19) months between on or about April 2^nd 2008 and or April 11^th 2008 throughout November 13^th 2009 to continue well into 2015 such (RICO) activities having continual legal affects as being described herein this U.S. Civil Complaint against the Pro Se Plaintiff civil rights, peace, and dignity.

                                                65.

                                    Cause of Actions

Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” a Cause of Actions exist against Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 And Co-Defendant(s) “Joyce M. Guy and Edward McCray”  

Collectively for each Violations of Chapter 96 of Title 18, United State Code: (RICO) Racketeering Influences Corruption Organization, Section 1341 (relating to mail fraud), section 1343 (relating to wire fraud), section 1028(relating to fraud and related activity in connection with identification documents), Section 1503(relating to obstruction of justice),

(RICO) activities upon the 58^th Judicial District Court of Jefferson County Texas, and all court records, court documents electronic transmission, court transcripts, to include but not limited to “(RICO)” activities committed against “The Honorable Bob Wortham” himself being presiding Judge of Docket No. A-180805 filed in Jefferson County Texas,

(RICO) against Insurances Companies, State of Texas, and the United States of America FEMA and Federal Housing Grant agencies

To include but not limited to (RICO) activities disguised in a Attorney/Client Privileges, work doctrine, and all communications derived thereof

All (RICO) involvements being wrongfully committed against the civil rights, peace, and dignity of the Pro Se Plaintiff Louis Charles Hamilton II herein before a civil suit in common law within the State of Texas.  

 

 

"U.S. District Court" Louis Charles Hamilton II vs. Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 et al

38.

Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” Defendants Antoine L. Freeman, J.D. “Attorney at Law” at the very start clearly in December of 2007  was engaging in Professional Skills of a Attorney at Law” in a “Legal” ongoing court room obligations to defend this civil case A-180805 against Pro Se Plaintiff

Defendant made Fraud upon the 58^th Judicial Court claiming in a document filed by defendant his only legal job was to draft a (Simple) General denial on behalf of the Defendants filed on December 18^th 2007, as such to avoid a default on behalf of Co-Defendant(s) by filing his original Answer and at that point his “Fiduciary Duty” to his clients and before the Court ended on that date December 18^th 2007 and was legally completely over,

Which this is not the case as Defendant (Attorney at Law) Fully scuttles all discovery materials received from Plaintiff in this civil matter from December 18^th 2007- November 13^th 2009 being the official day while in possession of Plaintiff request to disclose Pursuant to Rule 194 during the entire year of 2008-2009 Defendant Antoine L. Freeman, J.D. “Attorney at Law fail well within (30) days of this request, for the information or material described in Rule 194.2: by a period of over (2) years past the (30) days requirement to answer not only Pro Se Plaintiff “Request to Disclose” Pursuant to Rule 194,

Defendant (Attorney at Law) was also served Pursuant to Rule 198 of the Texas Rules of Civil Procedure Plaintiff Request for Admission(s) and Pursuant to Rule 197 of the Texas Rules of Civil Procedure Pro Se Plaintiff Set of Interrogatories all of which required a reply within (30) days of these request as Defendant a skilled (Attorney at Law) having full knowledge that a discovery phase process had commence in this civil legal matter refuse to submit any “response or reply” to all being described in paragraph (38) herein for a period of (1) year and (11) Months and Pro Se Plaintiff Filed “Motion for sanctions” against said Defendant (Attorney at Law) in violation of Rule 193.1 of the Texas Rules of Civil Procedure.

                                                39.

Defendant (Attorney at Law) in his defense of Plaintiff motion for Sanctions committed to the Following Fraudulent activities upon the 58^th Judicial District Court of Jefferson County Texas and all court records derive thereof.

a.     Engage in having Co-Defendant “Joyce M. Guy” Subscribed and Sworn a Affidavit in Support of Defendant (Attorney at Law) dated September 11, 2009

b.     File a Response to Plaintiff’s Motion For Sanctions also committed to the same act of having this document “Subscribed and Sworn on the 11^th day of September 2009

c.      Submitted all fact therein as being true before a Court of Law.

40.

Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” Affidavit of Co-Defendant “Joyce M. Guy” admit Defendant (Attorney at Law) informed Co-Defendant between April 2^nd, 2008 and April 11^th, 2008 about Pro Se Plaintiff “Discovery Request” providing proof that Defendant (Attorney at Law) was in fact in possession, custody, and control of said discovery request while representing to the “Honorable Court” this was not the case.

                                                41.

Defendant (Attorney at Law) herein did not file any notice with the Pro Se Plaintiff or the District Court of Jefferson County Texas that he was not representing the legal interest of the Co-Defendant(s) “Joyce Guy and Edward McCray”, there after filing “the original answer” with the District Court back in December 18^th of 2007 when Defendant (Attorney at Law) herein in fact stating having Pro Se Plaintiff Discovery in Defendant own Affidavit being in his possession as of April 2^nd, 2008.

                                                42.

 Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” Defendant (Attorney at Law) herein stated to the Honorable 58^th Judicial District Court also, that his only duty was to file a original general denial (only) and this was what his “Legal” services as a Attorney in this matter was only retain for in his defense for Sanctions against him as described herein this complaint.,”

“However” Pro Se Plaintiff States”, “Affirm” and “Declare” and further maintain that Defendant Antoine L. Freeman J. D. “Attorney at Law” Texas Bar No. 24058299 did in fact make a court appearance in a hearing the Pro Se “set” before the Honorable 58^th District Court

Pro Se Plaintiff also filed a (TRO) “Temporary Restraining Order” in this same civil matter A-180805 against Co-Defendant “Joyce M. Guy” to protect her own “Mother” Norma Guy, and the resident living in that dwelling whom Co-Defendant (Guy) having “Power of Attorney” Over her Mother Legal Affairs, filed in Jefferson County #2010042042 at which during this same time frame Co-Defendant having process the same scheme and scam of things regarding Insurance and FEMA fraud of the property of 5050 East 7^th street in Port Arthur Texas being Norma Guy Home Mother of the Co-Defendant (Guy).

                                                43.

Defendant (Attorney at Law) made another court appearance and argued this issue of a (TRO) alone before the Honorable Judge Bob Wortham, and at no time was Defendant not acting in the capacity as “Attorney of Record” from the time of filing his notice of counsel until Defendant (Attorney at Law) filed Motion to withdraw as Attorney of Record. 

Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” Defendant (Attorney at Law) herein sat on Pro Se Plaintiff entire Discovery Request in excess of 16 Months and refuse to file a reply, file any type notice with the court during this 16 Months time period while Texas Rules of Civil Procedure require

Defendant a professional Attorney at Law Adhere to local rules of the Court System and reply within (30) days not on a time table of (16) later after service of Said Discovery request by Pro Se Plaintiff Louis Charles Hamilton II.

                                                44.

Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” Defendant (Attorney at Law) herein, further state Defendant then took a even bolder set in “Obstruction of Justice” in that after (16) of scuttling Pro Se Plaintiff Discovery request to further Hide all of the corruption going on at present time in the destruction of the old home and the new one being built, during this ongoing Civil Suit and all of the inquiries being made by the Pro Se Plaintiff regarding Fraud relating to Insurance Companies Former Contractors, and Hurricane “Rita”, “Ike” and “Humberto”.

Defendant (Attorney at Law) herein provided further Fraud upon the Court in Fraudulent Information in the Interrogatories, and Never Investigated the circumstances of the questions being raised surrounding the “Theft” of The Pro Se Plaintiff Construction Tools by the Co-Defendant(s) “Joyce M. Guy” and “Edward McCray”,

 Defendant (Attorney at Law) completely cover up the Co-Defendant(s) collective wrong doings from the Honorable Court per Pro Se Plaintiff Discovery Request being scuttled for (16) months time frame as being described in paragraph (43) above.

                                                45.

 Defendant (Attorney at Law) made as if no Construction tools where ever on the property of the Pro Se Plaintiff being complain of

 To include Defendant (Attorney at Law) supply false answer(s) in the same Interrogatories that the Co-Defendant “Edward McCray” never even meeting the Pro Se Plaintiff Step Father (Lewis Garza) whom actually help delivery all of Pro Se Plaintiff said in excess of $3000.00 U.S. Dollars in construction tools to the dwelling in his Truck to the Home of The Co-Defendant(s) “Joyce M. Guy” and “Edward McCray” on November 16^th 2007. Defendant (Attorney at Law) did not Investigate any of these facts nor was he ever even concern to attempt to investigate into the issues of the were about of Pro Se Plaintiff Construction tools.

                                                45.

Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” after Defendant (Attorney at Law) was officially no longer “Attorney of record” of the Civil action in Texas State Court from the time frame of December 18^th 2007 – filing General Denial to November 13^th 2009 when Defendant (Attorney at Law) filed with the Clerk of Court of Jefferson County Texas a Motion for Withdrawal of Counsel

The Co-Defendant “Joyce M. Guy and Edward McCray” continue to refuse to turn over said “Discovery Request” of the Pro Se Plaintiff

 To the point a Court Order of the 58^th Judicial District Court was obtain and enforced as Follows:

                                                46.

Ordered that Co-Defendants “Joyce Guy and Edward McCray” shall produce copies of deeds, property deeds or any other such physical document in Defendants possession, custody or control that shows actual ownership of the property of the dwelling located at 448 DeQueen Blvd., Port Arthur, Texas

                                                47.

Ordered that Co-Defendants “Joyce Guy and Edward McCray” shall produce copies of any and all construction estimates for repairs in Defendants’ possession, custody or control in relationship to the damages caused by Hurricanes Rita, Humberto and Ike to the Property located at 448 DeQueen Blvd. in Port Arthur, Texas.

As so Ordered on the 10^th day of May 2010 by the 58^th Judicial District Court of Jefferson County Texas filed at 11:46 am.

                                                48.

Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” that Co-Defendants “Joyce Guy and Edward McCray” remain in Hostile abscond scuttle refusal of the Honorable Court Order as of the undersigned date in the Month of November 2014 of this Complaint being refilled in U.S. District Court.

                                                49.

Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” because of Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 acting in his skilled profession to fraud the court and belittle the Pro Se Plaintiff and his discovery request for a period in excess of 16 months in possession thereof

To include Defendant (Attorney at Law) herein unethical commitment to conspire further under the disguise of “Attorney/Client” privileges. Work Product doctrine, and all Communications thereof being secrete between the Defendant (Attorney at Law) and the Co-Defendant(s) “Joyce Guy and Edward McCray”

To the point such Fraud commits by the Defendant (Attorney at Law) on the Jefferson County 58^th Judicial District Court completely forced the Pro Se Plaintiff to be at an extreme “civil disadvantage” in the ongoing court proceeding in the time frame of 2007-2009 and present in 2014 throughout 2015

Based solely upon Defendant (Attorney at Law) Rouge (RICO) “obstruction of Justice” among other things being fully professional hire “Legal Gun” knowledge thereof to scuttle, omit, delay and fraudulently mishandling required duties to supply a honest, required respond to all of Pro Se Plaintiff discovery request in a timely fashion, within the (16) months being in possession, custody and control of said Pro Se Plaintiff Discovery request.

                                                 50.

 Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299  retainer fees was solely paid to keep the Co-Defendant(s) numerous discover fraud by the Pro Se Plaintiff absolutely 100% top secret from the 58^th Judicial Court”

while the other newer $76,000.00 U.S. Dollars “scheme of things” being in current play and  process to now a ongoing (RICO) fraud the Co-Defendant(s) concocted involving Fraud (Now) The “Texas Department of Housing & Community Affairs” issuance of a “Housing Grant” in favor for the Co- Defendant(s) “Joyce Guy and Edward McCray”

All of which in fact being fraudulently obtain from “Federal Housing Grant” on the behalf of “Texas Department of Housing & Community Affairs” while the civil suit is “Live” and pending” which Co-Defendant(s) conspire to keep this under wraps from any financial setback glitches being fully caused by The Pro Se Plaintiff bring this additional Fraudulent activities before The Honorable Court well deserved attention.

                                                51.

Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 in his History of being a Skilled “Attorney at Law” in and for the State of Texas

“Never” once scuttle, hide and thereof flat out being in refusal in the filing of a timely Discovery request for a period exceeding over (30) days against any Attorney, Law Firm or other Pro Se (Litigant)

In comparison to the double dealing, 100% skilled rouge super late filing reply to Pro Se Plaintiff numerous Discovery request being late in excess of (16) months and absolutely 100% in full violation of Texas Rules of Civil Procedures 193.1 All of which Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” solely done by Defendant (Attorney at Law) (Only) to conspire in the illegal (RICO) aid to hide all of the Co-Defendant(s) “Joy M. Guy” and “Edward McCray”  many corrupted Business Enterprises endeavors,

Mutable Counts of Fraudulent activities involving Hurricane “Rita”, “Ike” and Humberto” Monetary rip off scams against FEMA, Building Contractors estimate and invoices and Home Owner Insurances Companies repair funds

Couple with the (Now) live ongoing new 2009 fraud activities of the Co-Defendant(s) “Joy M. Guy” and “Edward McCray” involving “Federal Housing Grant” on the behalf of “Texas Department of Housing & Community Affairs” in excess of $76,000.00 U.S. Dollars

                                                52.

 Defendant (Attorney at Law) herein known lying with a consciousness mind and disregard for the consequences for his actions in the “capacity as an Attorney of Law”, Antoine L. Freeman J. D.  conspire to continue to use his legal lawyer skills” in the full “aid and abetting”, and commitment to “Obstruction of Justice” in the capacity of a Attorney at Law forthwith in providing his own numerous Attorney fraud legal commitment upon the 58^th Judicial District of Court of Jefferson County Texas, the Court records thereof as being fully described in this U.S. District Court Complaint.

 And being in full criminal (RICO) concert, collusion, corruption and conspiracies thereof for all monetary fraudulent assets gains of the Co-Defendant(s) “Joy M. Guy” and “Edward McCray”

 Both being “ill-gotten pirate loot” from the “past” Hurricanes Seasons “Rita”, Ike” and “Humberto” and “present” pirate loot” “Federal Housing Grant” on the behalf of “Texas Department of Housing & Community Affairs” in excess of $76,000.00 U.S. Dollars of the Co-Defendant(s) “Joy M. Guy” and “Edward McCray”

                                                53.

Fully affecting the Pro Se Plaintiff (Life) with “among other things” cause of action for “actual damages” being in excess of $336,000.00 U.S. Dollars in “lost wages” from 2007 – 2014 and “actual damages” in excess of “3093.00 U.S. Dollars in all of the Pro Se Plaintiff Construction tools causing the Plaintiff undue unwanted extreme hardship, infliction of emotional distress and anguish  in the  “Theft of Pro Se  Construction Profession” for a ongoing time frame over (7) years and still counting well into 2015 The Texas State Civil Suit is “Live” and ongoing due in large part to Defendant (Attorney at Law) herein

Numerous (RICO) “acts and activities” to commit “among other things” a ,complete assault of “Obstruction of Justice” and “Fraud upon a Court” in the 58^th Judicial District Court of Jefferson County Texas

In a Suit in “Common Law” for the rouge disgrace benefit of his skilled profession as a “Attorney of Law” to skillfully cover up a Co-Defendant(s) “Joy M. Guy” and “Edward McCray” clients “Long Bogus Quite Profitable Crooked Road of “Fraudulent History” being described fully herein and direct against The civil rights, peace and dignity of the Pro Se Plaintiff herein.