Friday, November 7, 2014

Louis Charles Hamilton II PLAINTIFF MOTION FOR FINAL SUMMARY JUDGMENT No. A-180805

Plaintiff Personal Lost in tool(s) $3093.00 dollars, to include Plaintiff brand New “Hitachi Air Compressor” $680.00 #2700009 purchased @ Lowell’s in “New Orleans, L.A.”

Plaintiff was working during the aftermath of Hurricane (Katrina) and can prove such a massive collection of tools

The Defendants (Told) the Port Arthur Texas (Police) Dept. that the Plaintiff has no receipts for his tools and all of his tools are staying on their property of the Defendant(s), “Joyce Guy and Edward McCray”

“However” the Plaintiff was only allowed to have back his own “Construction Lab top Computer” that was on the Property of the Defendant(s).

Plaintiff Further state before the Honorable Court the Affidavit of the Defendant (Joyce Guy) dated September 11, 2009 support a entry of Summary Judgment in Favor of the Plaintiff (Alone) by the

Defendant (Joyce Guy) very own Sworn statement being Plaintiff exhibit (A)

As Follows: The Defendant (Joyce Guy) Fully aware of a civil action pending against (Her) and from the date of December 18, 2007 throughout the undersigned date of said exhibit (A) Affidavit of

Defendant (Joyce Guy) September 11, 2009 being approximately “One Year and Nine Months” Defendant having full knowledge of Civil suit is in progress as she quite refusal to comply with discovery” regardless of her hired Gun “Attorney”

Defendant work to not comply with any discovery at this time frame as well as a all out refusal of a “Honorable Court order” being Plaintiff exhibit (L) dated 10th of May 2010.

Thus bring the Defendant(s) well document actions in refusal to comply with the local rules of This Honorable District Court to a total time of Defendant refusal from the issuance of said Court Order to now a new time frame of “Two Years and Eight Months” Defendant(s) total disregards for this “Live” Civil action,

and their combine conduct fully dictates and logical, legal, Conclusion that a

Summary Judgment is warrant, Just and Proper”.

Any further litigation of this civil action is a pure disgrace of the Honorable 58th District Court times in dealing with such “Hostile” described Defendant(s) collectively as their combine continue disregard actions for “Court Authority before the “Honorable Court”

also support the Plaintiff Claims made against the Doggeries Acts of Defendant(s) “Joyce Guy and Edward McCray”

Notwithstanding the only way any discover will be obtain from these Defendant(s) is through a Strong Arm
“Court Order”

That the Defendant(s) collectively being placed in Jefferson County Jail until all such required discover is fully provided to the Plaintiff and the Honorable Court Records

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