The Plaintiff Further State before “The Honorable Court”,
A hearing was held before The 58th District Court on Plaintiff Motion to Compel Production of Documents and the Court “Ordered that 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
To include the Court “Ordered further that the 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 damages caused by Hurricanes Rita, Humberto, and Ike to the property located at 448 Dequeen Blvd. in Port Arthur, Texas
This Order of the 58th District Court was executed on May 10, 2010 and from that time frame to this very undersigned date the Defendant(s) refuse to comply with said “Court Orders” and produce said discovery Production of document request while Defendant(s) having the authority to comply with said Court Orders,
Defendant(s) Joyce Guy and Edward McCray will never ever comply with any Judicial District Court Orders within the State of Texas, and this 58th District Court of Jefferson County Texas has been proven to be quite beneath the Defendants Authority, Reach, and quite simply powerless thus far against said Defendants Joyce Guy and Edward McCray, and their Attorney of the Past Antoine L. Freeman, J. D. Texas Bar No. 24058299. And made to look quite foolish in being an “Honorable Court”
Even while Defendant(s) were with a Attorney of record it was His paid duties to mislead the 58th District Court and provide nothing being real Judicial Evidence in Favor of the Plaintiff that is actual in rendering a real physical documented response from “Joyce Guy and Edward McCray” and showing their numerous Fraud activities as described by the Pro Se Plaintiff in the Records herein of this civil complaint
Plaintiff files 58th Judicial Court Orders as Plaintiff exhibit (L) herein and state respectfully before the Honorable 58th District Court”.
That all required Court orders of this Honorable 58th District Court is very material in this particular case, and well within the means of the Defendants abilities to Honor such a Judicial Court Order as they flat out refusing to do so
Defendant(s) collectively in the past did submit Hurricane damages construction contractor’s estimates to their Insurance Companies for Hurricanes Rita, Humberto, and Ike for the property located at 448 DeQueen blvd. in Port Arthur, Texas. Just as they did Plaintiff Construction Contract and as admitted in Plaintiff “Request for Admission” exhibit (K)
As this being a standard practice for any home owner to submit to their home owner insurance companies construction contractors estimates for Hurricanes related damages to receive funding based upon contractors estimates and the Defendants refuse to retrieve any Public Records in this regards, especially with their “Insurance Companies” Banking records “notwithstanding giving up
the actual Identity of said “Insurance Companies”
Defendant(s) Joyce Guy and Edward McCray collectively are even definite in not providing any proof of actual ownership of the property in question at 448 DeQueen Blvd. in Port Arthur Texas as the Honorable 58th District Court so Order said Defendant(s) in doing so in this simple regards.
Contempt of court generally refers to conduct that defies disrespects or insults the authority or dignity of a court. Often, contempt takes the form of actions that are seen as detrimental to the court's ability to administer justice.
In this case the Defendant(s) Joyce Guy and Edward McCray rely on their defines of the Honorable Court Orders to reply on the 58th District Court of Jefferson County Texas assumed inability to administer justice in favor of the Plaintiff,
Notwithstanding Defendants Joyce Guy and Edward McCray do not even began to adhere to this Honorable Court authority/actions, even while being with their Attorney of Record of the past Antoine L. Freeman, J. D. Texas Bar No. 24058299 now creating one big messy miscarriage of Justice as of this undersigned date.
Civil contempt sanctions typically end when the party in contempt complies with the Court order, or when the underlying case is resolved. And this case has not been resolved, the actions of the Defendant(s) to defend their acts provides that a summary judgment is in favor of the Plaintiff and is warrant with all of the Plaintiff exhibit(s) in support thereof,
Defendant(s) took the extra civil/criminal steps in hiring a Attorney of Law to disguise their civil case, mislead the Honorable Court and at all cost bury the physical evidence, while misused the Rules of Texas Civil procedure to aid in the inability of this 58th District Court to administer justice in favor of the Plaintiff.
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