Louis Charles Hamilton II IN THE DISTRICT COURT
Plaintiff 58TH JUDICIAL DISTRICT
V.
Joyce Guy & Edward McCray ET AL OF JEFFERSON COUNTY, TEXAS
Defendants.
PLAINTIFF MOTION FOR PROPERTY LIEN
Comes Now Before The Honorable 58th District Court the Pro Se Plaintiff, Louis Charles Hamilton II,
Motion before the Honorable Court, For a Property Lien, being enforced on the Property located at 448 DeQueen Blvd. in Port Arthur Texas and for just cause the Pro Se Plaintiff state as Follows:
Defendant(s) “Joyce Guy and Edward McCray” Was so Order By This Honorable 58th District Court of Jefferson County Texas on the 10th day of May 2010 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., in Port Arthur Texas and fully failing to adhere to an Honorable Court Order.
As described in Plaintiff Exhibit (L) attached herein to Plaintiff Motion for Final Summary Judgment. Defendant(s) “Joyce Guy and Edward McCray” quite secure in their combine all out refusal to except the Honorable Court Authority, in Producing such said documents by this “Honorable Court” being as physical document in Defendants’ possession, custody or control that shows actual ownership of the property of the dwelling located at 448 DeQueen Blvd., in Port Arthur Texas
And actual real ownership of said Property is in fact being in a state of unknown ownership while a civil dispute is ongoing over said dwelling located at 448 DeQueen Blvd., in Port Arthur Texas and stands as a question of disputed Law now concern before this Honorable 58th District Court
Said described dwelling above herein is in a ongoing “Live” Civil Construction “Breach of Contract” dispute, among other cause of actions before this Honorable 58th District Court of Jefferson County Texas in docket No. A-180805 And as of this undersigned day in the month of November in the year of 2014 said Defendant “Joyce Guy and Edward McCray”
Remain faithful in their combine refusal to identify the actual ownership of the said dwelling located at 448 DeQueen Blvd., in Port Arthur Texas as was required by this Honorable Court to do so, Defendant(s) already shown the Plaintiff he having no civil rights in this action in Jefferson County Texas and continue showing said Honorable 58th District Court of Jefferson County Texas having no real “Authority” at all Over said described Defendant(s) listed above namely “Joyce Guy and Edward McCray”
Further Defendant(s) collectively showing said Honorable 58th District Court of Jefferson County Texas having no real “Authority” over the Property located at 448 DeQueen Blvd. in Port Arthur Texas being well within Jefferson County Jurisdiction, Authority Namely this Honorable 58th District Court of Jefferson County Texas.
Defendant(s) “Joyce Guy and Edward McCray” having a Civil dispute in regards to among other things:
“Actual Damages” being owed to the Plaintiff in the Amount of $11,024.00 with full 6% interest rate incurred since date of injury November 16th 2007
As described in Plaintiff “Motion for Summary Judgment” with all of the exhibit(s), documents, and records herein. This Property is in fact under the Control of said Defendant(s) at the time this dispute derived thereof and said dwelling located at 448 DeQueen Blvd., in Port Arthur Texas
Defendant(s) “Joyce Guy and Edward McCray” Continue to be in the physical custody, control, and possession of the Property located at 448 DeQueen Blvd. in Port Arthur Texas being well within Jefferson County Jurisdiction, Authority Namely this Honorable 58th District Court of Jefferson County Texas.
As of this undersigned date in 2014 while Defendant(s) collectively refusal before this Honorable 58th District Court Orders to provide actual ownership of said disputed property in this Civil Matter
Docket No. A-180805 as of this undersigned date in the Month of November 2014.
Plaintiff Respectfully Moves before the Court that a Court Order being justly enforce against said dwelling located at 448 DeQueen Blvd., in Port Arthur Texas is justified in light of The Defendant(s) “Wicked” “Hostile” unwanted actions Directed at the Plaintiff with actual damages being in excess of the Amount of $11,024.00 with full 6% interest rate incurred since date of injury November 16th 2007
Further Plaintiff Respectfully Moves before the Court that a Court Order being justly enforce against said dwelling located at 448 DeQueen Blvd., in Port Arthur Texas in light of The Defendant(s) Bold Refusal of this 58th District Court of Jefferson County Texas “Honorable Court Orders” dated the 10th day of May 2010 For Defendant(s) “Joyce Guy and Edward McCray” herein
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., in Port Arthur Texas as described in said Court Orders attached to the records of this Civil action and being filed as Plaintiff exhibit (L) in support of a issuance of a Final Summary Judgment in Favor of The Pro Se Plaintiff Louis Charles Hamilton II herein.
Plaintiff state Respectfully before The Honorable Court such an order is required to secure a proper judgment in this matter before this Honorable Court in favor of the Plaintiff, to include the Defendant(s) combine Numerous Crafty Fraudulent behavior as described by the Pro Se Plaintiff
And Investigated by the State of Texas in Exhibit(s) also files herein the records of this civil action, showing Plaintiff Judgment, damages, and compensation derived from the Defendant(s) actions is at risk if such a Court Order is not enforce further by the “Honorable 58th District Court” herein Jefferson County Texas against Defendant(s) “Joyce Guy and Edward McCray”.
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 Jefferson County Texas State Law”
Namely “The Jefferson County Sherriff’s Office” on behalf of the “Honorable 58th District Court to fully enforce and place a “Property Lien” on the described unknown ownership Property located at 448 DeQueen Blvd. in Port Arthur Texas, in favor of the Pro Se Plaintiff herein Louis Charles Hamilton II in light of this ongoing civil litigation pending against said dwelling at the Hands of the described Defendant(s) herein.
Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves The Honorable Court that Defendant(s) “Joyce Guy and Edward McCray” pay the full amount incurred by the “Honorable Court” and The Jefferson County Sheriff’s Office to execute PLAINTIFF MOTION FOR PROPERTY LIEN against said Defendant(s) herein and the enforcement of said Property Lien.
Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves The Honorable Court for any further, Just, proper devise to secure said dwelling until this Civil Dispute has reach a Full, Final and Complete Judgment of This Honorable 58th District Court of Jefferson County Texas
By,_______________________________
Louis Charles Hamilton II
Pro Se Plaintiff
P.O. Box 17524
Sugar Land Texas 77496
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