Thursday, November 6, 2014

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

The Plaintiff Further State before “The Honorable Court”,

The defendant(s) as described in Plaintiff exhibit (K) Request for Admission dated October 14, 2009 supply their collective response in regards to “Request for Admission question No. 5 and question

No. 6 as follows:

Admit the Defendants herein received $7000 from their home owner insurance company.

RESPONSE: ADMITTED

Admit the Defendant herein forward construction Contract of 10,800 to their home owner insurance company/mortgages company to receive an additional amount to cover construction difference amount.

RESPONSE: ADMITTED

The Defendants admitted this was the case involving the Plaintiff and his construction contract for $10,800, while at the same time during discovery hiding this unknown Insurance Company Identity completely from being brought into question in this civil matter,

As a precise witness in favor of all of The Plaintiff claims that the defendant squanders $7000.00 from the Hurricane claim of (Rita) long before the $10,800 Contract of Plaintiff was even introduced to said insurance company

While the Defendant(s) making the actual presentation to said Insurance Company that more repairs funds was needed, to include that physical construction repairs had did in fact commence on the home at 448 DeQueen blvd. in Port Arthur Texas after $7000.00 of repair funds being already forward to said Defendant(s) for such storm related repairs

Plaintiff states before the Honorable 58th District Court of Jefferson County Texas Defendants continue to hide all Insurance and banking records in regards to exact amount the Defendants received in repairs funds, exact dates, and what was spent with the $7000.00 first installment of said Insurance Companies repair funds for very need construction repairs in the year of 2007.

Plaintiff Exhibit (K) is material proof before the “Honorable Court” of the Plaintiff involvement in this civil matter by the defendants own admission to exhibit (K), request for Admission question 5 and 6

Providing additional fact before “The Honorable Court examination” of said Request for Admission that the Defendant(s) collectively knowingly executed and hatched a plan to conspire, scheme, and deliberation of a intent to commit fraud Against The Unknown Insurance Company”

While making the Plaintiff the primary tool /mark to achieved additional monetary fund’s there after defendants already having their squandering ways with the first $7000.00 funds of Construction Repair funds.

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