“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