The Plaintiff Further State before “The Honorable Court”,
The Defendant was served a First Set of “Interrogatories” in this action, Pursuant to Rule 197 of the Texas Rules of Civil Procedure. By and through their Attorney of Record and filing such now
As Plaintiff Exhibit (I), Herein as The Plaintiff state Brief material facts that the Defendant(s) collectively answer to question 24 and 25 as follows:
(24) What was all of the terms and conditions of said contract in regards to repairs to the home located 448 Dequeen blvd. in Port Arthur, Texas
Answer
Plaintiff would repair damages done by Hurricane for a total price of $10,800 and Defendant would put $3,616 down towards the total price.
(25) Was the Contract forward to any insurance companies for payment to cover said construction cost?
Answer
Yes
The Plaintiff fully direct the Honorable Court attention to these facts
1. Defendant (Already) in facts received from said “Unknown Insurance” company in excess of approximately $6,500 dollars to fix said home and this money was squander and spent up from their Banking saving/checking account quite very long before The Defendants even enter into said Construction Contract with Plaintiff on 11/05/2007
Defendants were served Pursuant to Rule 194 Texas Rules of Civil Procedure. By and through their Attorney of Record Plaintiff request for Disclosure which Defendants at that time refused through their Attorney of record
To simply Identify Said “Unknown Insurance Company” which is very Material to this Action and was pursued long before “Plaintiff Interrogatories” was even served upon the Defendant(s) and Filed
Now as Plaintiff Exhibit (J) herein Plaintiff request for Disclosure Pursuant to rule 194
Defendant(s) did in fact received from this “Unknown Insurance Company” a balance of Monetary Funds in addition from what already was forwards to said Defendant(s) based upon the Plaintiff “Construction Contract” of $10,800.00,
Which the Defendants further supply and combine their “twisted scheme of things” was to physically use the Plaintiff Construction Contract of $10.800.00 to achieve such a “Cruel Criminal Scheme of things” against not only the Plaintiff
But also to include The “Unknown Insurance Company” for More Monies in addition to the amount already received from said “Unknown Insurance Company” for repairs as being described now
before the Honorable Court in PLAINTIFF MOTION FOR FINAL SUMMARY JUDGMENT,
Notwithstanding “Facts” to the “Honorable Court”
“Yours Honor”
Never Ever, Ever, Was Any Actual Monies ever being spent on any Actual Physical Construction Repairs from any described storm damages in the past by any
Construction Contractors and or Sub-Contractors ever being performed at any time at the home located at 448 Dequeen Blvd. in Port Arthur Texas,
From any Hurricane damages by (Rita & Humberto) as such repair funds was indeed paid out to cover all extreme needed structural repairs in the Past for these “Trifling Defendant(s)”, making such claims against their “Insurance Companies, Construction Contractors in the Past, and to include now FEMA
As this same “Crooked Scheme of Things” was in fact executed more than once by the Defendants collectively in the past from another Hurricane (Rita) Damage of said 448 Dequeen Home,
long before the Plaintiff Construction Contract filed herein was even drafted for Repairs for Damages of “Hurricane Humberto” against another such Building Construction Contractor for (Rita) storm damages…
And as this same “Crooked Scheme of Things” was in fact executed in the past by the Defendants collectively on The Home Located at 5050 East 7th Street in Port Arthur Texas
Namely Defendant (Joyce Guy) owns Mother Home (Norma J. Guy) whom Defendant (Joyce Guy) had power of Attorney over her mother legal affairs at this time frame and used this to “Her” continued wrongful crooked advantages
To include such a “bogus rip off scheme of things” by the Defendant(s) collectively against all Hurricane damages of both said homes and “Unknown Insurance Companies” which moneys was in fact paid out for all needed repairs in full in the past storm history,
And defendants completely civil/criminally squander every nickel in a “Long History “ of “thievery” Scheme of things against “FEMA and Insurances Companies” following such “Natural Hurricane Damages” and Now the same Scheme of things involved against the Plaintiff herein and his personal property
(Construction tools),
And The Insurance Company, and FEMA, in which the Defendant “Home” At 448 Dequeen Blvd. in Port Arthur Texas was in facts completely demolished for Defendants crooked combine failures to supply any needed repairs (Ever) when all such funds being legally designed for such said Hurricane Repairs to said property located at 448 Dequeen Blvd. in Port Arthur Texas
As The Plaintiff States now Before “The Honorable Court” facts that a New Home being built at the cost of $76,000.00 on a Federal Grant.
As described in Plaintiff exhibit (I) First Set of “Interrogatories” in this action, question(s) 7-12
On Defendants collectively long continue corrupted history road of scams, rip off’s, thievery acts, as described herein fully being executed by Both Defendant Collectively.
All building materials as being described herein Plaintiff Exhibit (E) *Parker Lumber In Port Arthur Texas 2948 GulfWay Drive for the delivery of $2869.08 dollars in building materials for repairs to said 448 Dequeen home that was in fact delivery was refunded and or sold,
And not for any benefit of the said home storm damages but pure wrongful monetary Defendant(s) collectively financial gains.
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