Plaintiff Amend “Actual Damages” To “Motion for Summary Judgment” No. A-180805

No. A-180805

IN THE DISTRICT COURT 58TH JUDICIAL DISTRICT Court of JEFFERSON COUNTY, TEXAS

Louis Charles Hamilton II
Plaintiff

V.

Joyce Guy & Edward McCray ET AL
Defendant

Plaintiff Amend

“Actual Damages” To “Motion for Summary Judgment”

Comes Now the Pro Se Plaintiff Herein Respectfully Amend “Actual Damages” to Plaintiff motion to “Summary Judgment” as follows:

1. Defendant(s) “Joyce M. Guy” and “Edward McCray” collectively in addition to The Theft of all of the Plaintiff Construction Company “tools” as being described in the complaint before the “Honorable Court”.

2. Defendant(s) collectively cost the Pro Se Plaintiff $48,000.00 minimal “lost wages” and “lost earning capacity” per year since November 17th 2007 date of injury

3. throughout November 17th 2014 for a period of (7) years at a total “lost wages” and “lost earning capacity” in excess of $336,000.00 U.S. Dollars

4. Defendant(s) Joyce Guy & Edward McCray Refuse to even acknowledge in discovery request “Request for Admission Questions”

being in said possession, custody and control of Pro Se Plaintiff “Personal Property” namely “Construction Tools in excess of $3093.00 U.S. Dollars as this being Pro Plaintiff Special Independent Contractor “Trade and Profession”.

Pro Se Plaintiff files in Support of Plaintiff Motion for “Summary Judgment” affiant “Subscribed and Sworn” Affidavit of “Lewis Garza”

in Support of Summary Judgment in favor of the Pro Se Plaintiff “Louis Charles Hamilton II

Stating: On November 17th, 2007 I took my stepson to 448 DeQueen Blvd. in Port Arthur Texas. To do work on a house. He had a few thousand dollars in tools.

The Owner of the home kept all of the tools and refused to return them.

Ladders, generator, Nail guns, & numerous hand tools.

Lewis Garza

Subscribed and Sworn on the 14th day of November 2014

“Kendra Monk” Notary Public, State of Texas

1.

Wherefore Pro Se Plaintiff “Louis Charles Hamilton II herein shall request, state, and argue before the “Honorable Court” on the 17th day of December 2014 at 8:30 am hearing before the “Honorable Court” to “Amend” to the Complaint, Summary Judgment

“Actual Damages” to Include “Lost wages” and “lost earning capacity” as of November 17th 2007 being wrongfully enforced upon the Pro Se Plaintiff in the “Theft” of all of the “Construction tools” described in the Original Complaint

2.

Wherefore Pro Se Plaintiff “Louis Charles Hamilton II herein respectfully state before the “Honorable Court” to Amend “Actual Damages” to this civil action to include and represent “lost wages” and “lost earning capacity” as already stated in Pro Se Plaintiff Motion for “Summary Judgment” being wrongful civilly caused to the Pro Se Plaintiff, in the

“Theft” of “Personal Property” which Defendant causing Pro Se Plaintiff to continue suffrage such “lost wage” and “Lost earning capacity” in excess of $48,000.00 per year since 2007 (November) for a total of 7 years as of November 17th 2014.

3.

Wherefore Pro Se Plaintiff “Louis Charles Hamilton II herein Respectfully state further before the “Honorable Court” to Amend “Actual Damages” to include 6% interest incurred since date of injury November 17th 2007 to the “lost wages” and “lost earning capacity” in excess of $48,000.00 U.S. Dollars

Being “actual damages” Pro Se Plaintiff “lost wages” and “lost earning capacity” at a rate of (7) years = $336,000.00 U.S. Dollars as of November 17th 2014 and this is ongoing until the final resolution of this “Civil Suit” in “Common Law”.



By, _______________________________
Louis Charles Hamilton II
Pro Se Plaintiff
P.O. Box 17524
Sugar Land Texas 77496