Wherefore Pro Se Plaintiff Louis Charles Hamilton II herein Docket No. A-180805, filed and Respectfully Moves before the Honorable 58th District Court of Jefferson County Texas His “Honorable Court” except, Plaintiff motion for Traditional Summary with all exhibit(s) A-1, and A-L,
being filed with the Clerk of Court Records of Jefferson County Texas, and The Honorable Court further being most favorable to the Pr Se Plaintiff claims as presented and supported, and the Honorable Court Being of the opinion Plaintiff Motion is with “merit” and should be granted into the Court Records.
2.
Wherefore Pro Se Plaintiff Louis Charles Hamilton II herein Docket No. A-180805, Further Respectfully Moves the Honorable 58th District Court of Jefferson County Texas His “Honorable Court” Plaintiff recovery damages for wrongful lost of tools in excess of $3093.00 dollars with full 6% interest rate incurred since date of injury from November 16th 2007
3.
Wherefore Pro Se Plaintiff Louis Charles Hamilton II herein Docket No. A-180805, Further Respectfully Moves the Honorable 58th District Court of Jefferson County Texas His “Honorable Court” Plaintiff recovery damages for “Breach of Contract” at the rate of Profit Plaintiff would have incurred,
Said being “Breach of Contract” incurred before any construction was started “However” Plaintiff purchased $2869.08 dollars in building materials as described in Plaintiff exhibit (E) to repair said home at 448 Dequeen Blvd. in Port Arthur Texas which the Plaintiff is entitled to $7931.00 dollars subtracted from the $10,800.00 dollars Contract being Profit.
4.
Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves The Honorable Court for said damages and Profit of $7931.00 dollars with full 6% interest rate incurred since date of injury November 16th 2007
5.
Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves The Honorable Court for damages in the amount of the Honorable Court Justice for the Plaintiff suffrage of “Intentional Infliction of Emotional distress,
“Loss of earning capacity and Hardship” incurred in the “Theft” of the Plaintiff Construction tools”, and extreme Judicial Awards further being granted to the Plaintiff “Louis Charles Hamilton II for “Exemplary Damages” being well enforced by this “Honorable Court”
against said Defendant(s) “Joyce Guy” and Edward McCray” for their combine extreme, dishonest, hostile, corrupted, actions, directed at the Plaintiff herein’,
and his personal property and assault upon the Plaintiff.
To include but not limited” to Defendant “Joyce Guy and Edward McCray”
Fraud of the Insurance Company scheme of things involving Pro Se Plaintiff $10,800.00 dollars construction contract in a
“Exemplary Damages” respectfully set by this Honorable Court with full 6% interest rate incurred since date of injury November 16th 2007
6.
Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves The Honorable Court that Defendant(s) “Joyce Guy and Edward McCray” pay the amount of “Actual Damages” to the Plaintiff in the Amount of $11,024.00 with full 6% interest rate incurred since date of injury November 16th 2007
To include Defendant(s) paying all filing fees and all “Court Cost” incurred in this Civil Matter.
7.
Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves The Honorable Court to grant the Plaintiff attached joining motion filed herein with good “Merit” to have the “Long Arm of The Law” Namely
8.
“The Jefferson County Sherriff’s Office” to fully enforce and place a “Property Lien” on the described Property of 448 DeQueen Blvd. in Port Arthur Texas, in favor of the Pro Se Plaintiff herein Louis Charles Hamilton II which Defendant(s) “Joyce Guy and Edward McCray”
Was so Order By This Honorable 58th District Court of Jefferson County Texas to 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., and fully failing to adhere to an Honorable Court Order.
As described in Plaintiff Exhibit (L) attached herein.
Further providing The “Honorable 58th Judicial Court” a secured Judicial Honest biting well deserved Judgment being rendered in this quite seriously civil matter of the collectively Defendant(s) namely “Joyce Guy and Edward McCray” ill manner back woods buck wild country state of extreme,
“Hostile and Fraudulent” actions being most favorable to the “Laws of the State of Texas”,
Most favorable to the Pro Se Plaintiff Civil Rights, Damages and Compensation as described fully in the records herein this Civil Action.
9.
Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves The Honorable Court
for any further, Just, proper, Damages and Awards The Honorable Court Deems Judicial in and For 58th District Court of Jefferson County Texas in Favor of The Pro Se Plaintiff herein.
By,_______________________________
Louis Charles Hamilton II
Pro Se Plaintiff
P.O. Box 17524
Sugar Land Texas 77496
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