No. A-180805
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 “Writ of Garnishment”
Comes Now Before The Honorable 58th
District Court the Pro Se Plaintiff, Louis Charles Hamilton II, herein
Motion
before the Honorable Court, For “Writ of Garnishment” against the Defendant(s) Business
listed as Follows:
(1).
E and J Collectibles
(409) 330-048 448 DeQueen Blvd. in Port Arthur Texas
Information
about E & J Collectibles
E & J
Collectibles is in the Used Merchandise Stores business and this category has 2
companies in Port Arthur and a total number of businesses in Texas.
(2).
R J Can
Company 1807 East 7th Street Port Arthur Texas (Office) located at 448 DeQueen
Blvd. in Port Arthur Texas 77640
(3).
G and G
Service Company P.O. Box 515, 416 DeQueen Blvd. in Port Arthur Texas (Office)
located at 448 DeQueen Blvd. in Port Arthur Texas 77640
(4).
“Cars and
Pieces” Located in Beaumont Texas (Office) also located at 448 DeQueen Blvd. in
Port Arthur Texas 77640
And for just
cause Before the Honorable 58th District Court of Jefferson County Texas the
Pro Se Plaintiff herein declares, affirm and state as Follows:
I.
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.
II.
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.
III.
Defendant(s) “Joyce Guy and Edward McCray” mutable business E
and J Collectibles (409) 330-048 448 DeQueen Blvd. in Port Arthur Texas, J Can
Company 1807 East 7th Street Port Arthur Texas,
G and G
Service Company P.O. Box 515, 416 DeQueen Blvd. in Port Arthur Texas and, “Cars
and Pieces” Located in Beaumont Texas (Office) also located at 448 DeQueen Blvd.
in Port Arthur Texas 77640
Are all in fact legally owned by the Defendant(s)
collectively herein as records do in fact “indicate” and on file with the “Jefferson
County clerk”
At this time
the Pro Se Plaintiff Louis Charles Hamilton II Respectfully caution the
“Honorable Judicial 58th District Court” to
take Calm raised eye brow calculations of "Judicial Notice" to the
Following Plaintiff Brief in Support of a “Writ of Garnishment” against the
Defendant(s) “Joyce Guy and Edward
McCray”
Plaintiff
Attached Brief in Support
1.
Defendant(s) “Joyce
Guy and Edward McCray” refused to file proof of the required discovery as
required in a “direct court order” which the Defendant(s) both were in fact in “full
attendance” before The Honorable Court when such an Order was so enforced by
the Court and stated on Court Records.
“Elementary
Simply” Defendant(s) “Joyce Guy and Edward McCray” collectively
thinking not only The Pro Se Plaintiff “Louis Charles Hamilton II herein but to
include but not limited to
The “Honorable 58th District Court” of
Jefferson County Texas to be at a sad state of being absolutely extra green-n- slow,
lacking “intelligence or common sense” and very dull to understand the cold,
scheming, cunning, calculating, dishonest, corrupted, double-dealing,
fraudulent “Grand Theft” history of the Defendant(s) involving among other
things,
Committed to many counts of “Insurance and FEMA” $$$ Heisting
which said discovery of the Pro Se Plaintiff Defendant(s) “Joyce Guy and Edward McCray” refusing the said court order would
in fact produce quite a “Outstanding” scary “Criminal and Civil extremely high
profile embarrassing situation and predicament of “prison penalties” both being
100% against the Peace and Dignity against The “State of Texas” and The “U.S.
Federal Government Justice Dept.” criminal codes.
To the Point this “civil action” herein is also known
to be Pro Se Plaintiff Louis Charles Hamilton II a/k/a Cmdr. Bluefin (USN)
“Sherlock
Holmes” Case of “The Dead Man Who Paid Taxes”
2.
Plaintiff further
state that on or about June/18/2009 a “Mechanics Lien” was filed in Jefferson
County Texas by: SWMJ Construction against Blk. 172 Lt. 1-2 own by Defendant(s)
“Joyce
Guy and Edward McCray” for primary “Hurricane “Rita”, “Ike” and “Humberto ” related
Construction storm damages,
“First American Title Insurance Co. 510 Bienville
Street, Floor 2r “Johanna” New Orleans LA 70130 being the Returnee
Which the Defendant(s) “Joyce Guy and Edward McCray”
Collectively refusal of said Court Order in this said
discovery documents ,involving full details, of the Construction Company and
the terms and condition of the contract for repairs, Funds paid out for
repairs, by all parties involved namely “First American Title Insurance Co.
3.
Plaintiff further
state that on or about November/16/2010 a “Mechanics Lien” was filed in
Jefferson County Texas by: DSW Homes on Property own by Defendant(s) “Joyce Guy and Edward McCray” BlK.4 Lt. 10 For primary
“Hurricane “Rita”, “Ike” and “Humberto ”
related Construction storm damages,
“First American Title Insurance Co. 510 Bienville
Street, Floor 2r “Johanna” New Orleans LA 70130 being the Returnee
4.
Plaintiff further
state before the “Honorable Court” that Defendant(s) “Joyce Guy
and Edward McCray” having “Deed” to the Property located in Port Arthur
Texas Lt. 1-2 Blk. 172 filed in Jefferson County Texas #2014012455 filed
04/22/2014
5.
Plaintiff further
state before the “Honorable Court” that Defendant(s) “Joyce Guy
and Edward McCray” having “Deed” to the Property located in Port Arthur
Texas Lt. 8 Blk. 210 filed in Jefferson County Texas #2007032430 filed
08/17/2007
6.
Plaintiff further
state before the “Honorable Court” that Defendant(s) “Joyce Guy
and Edward McCray” having “Deed” to the Property located in Port Arthur
Texas Lt. 11 Blk. 94 filed in Jefferson County Texas #2008022271 filed
06/20/2008
7.
Plaintiff further state before the
Honorable Court that Defendant(s) “Joyce Guy” having “Power of Attorney” over Norma Guy
Her dead mother and Now “Deed” to the Property located in Lakeview Texas Lt. 10
Blk. 4 filed in Jefferson County Texas #2010042042
8.
Plaintiff further
state before the Honorable Court that Defendant(s) “Joyce Guy” having “Deed” to the Property
located in Port Arthur Texas Lt. 8 Blk. 210 filed in Jefferson County Texas
#2007032430 filed 08/17/2007 real estate 1807 Rev. Ransom Howard Street Port
Texas Geographic ID 053400-000-237400-00000-5 “Commercial Vacant Lot”.
9.
Plaintiff further state
before the Honorable Court that Defendant(s) “Joyce Guy” having “Power of
Attorney” over “Norma Guy” Her dead mother “legal affairs” and Now upon
information and belief “Deed” to the Property located 5050 east 7th
street in Port Arthur Texas
Notwithstanding
Defendant(s) “Joyce Guy” having “Power of Attorney” over “Norma Guy”
Her dead mother legal affairs primary for
“Hurricane “Rita”, “Ike” and “Humberto ”
related Construction storm damages, to the Property located 5050 east 7th
street in Port Arthur Texas.
10.
Plaintiff further state
before the “Honorable Court” quite Judicially seriously that Defendant(s) “Joyce Guy
and Edward McCray” secretly conspire in full conclusion to keep hidden through their retained “Attorney of Record”
Antoine L. Freeman J. D. Texas Bar No.
24058299 that actually being filed in Jefferson County Clerk office on the June/18/2009
While This “Live”
Civil Action is ongoing since November 17th 2007 and a legal
discovery request already being made by The Pro Se Plaintiff “Louis Charles
Hamilton II” herein into the Records of Hurricane “Hurricane “Rita”, “Ike” and “Humberto ” related Construction storm
damages, and its involvement with
“First American Title Insurance Co.” 510 Bienville
Street, Floor 2r “Johanna” New Orleans LA 70130 being the Returnee and the
property located at 448 Dequeen Blvd. in Port Arthur Texas
Defendant(s) 100% Bold in being a flat out refused of
the Honorable 58th District Court “Court Order” to produce said Records
relating to “Hurricane “Rita”, “Ike” and
“Humberto ” related Construction storm damages, and its involvement with
the Defendant(s) “Joyce Guy and Edward
McCray”
Shockingly a legal transfer of the Defendant(s) “Joyce Guy and Edward McCray” collectively
property of 448 DeQueen blvd. Said
property Namely 448 DeQueen Blvd. in Port Arthur Texas 77640
Namely being Lot 1-2 Block 172 Jefferson County Texas
records #2009022762 filed on June/18/2009 was in fact transfer to the “Texas Department of Housing &
Community Affairs” and Attorney of Record Antoine L. Freeman J. D. Texas Bar
No. 24058299
Now boldly as
a Attorney of Law” lying to The “Honorable 58th District Court”
about his position as Attorney of
record for the Defendant(s) “Joyce Guy and Edward McCray” Docket No. A-180805
Antoine L.
Freeman J. D. Texas Bar No. 24058299 fully hidden the Pro Se Plaintiff herein Louis
Charles Hamilton II “Request for Admission”, Disclosure Documents and
“Interrogatories” request and legally refused to file a timely reply to them
for over 3 + years
11.
Plaintiff further
state before the “Honorable Court” Defendant(s) “Joyce Guy and Edward McCray” while this
civil action ongoing since November 17th 2007 and with their retained “Attorney of Record” Antoine L. Freeman J. D. Texas Bar No.
24058299 filed Financing statement on June /18/2009 with “Texas Department
of Housing & Community Affairs” Jefferson County Texas records #2009022763
12.
Plaintiff further
state before the “Honorable Court” Defendant(s) “Joyce Guy and Edward McCray” while this
civil action ongoing since November 17th 2007 Defendant(s) received a release of “Deed” dated on
July/22/2013 from the “Texas Department of Housing & Community Affairs”
Jefferson County Texas records #2013023794
13.
Plaintiff further
state before the “Honorable Court” Defendant(s) “Joyce Guy and Edward McCray” while this
civil action ongoing since November 17th 2007 Defendant(s) received a Termination from the “Texas
Department of Housing & Community Affairs” Jefferson County Texas records
#2013023794
448 DeQueen Blvd. “Property Deed” being in the
possession of the Defendant(s) “Joyce
Guy and Edward McCray”
As of
April/22/2014 which the “Texas Department
of Housing & Community Affairs”
housing Grant the Defendant(s) fraudulently obtain was in fact a “Federal Housing Grant” for “Texas
Department of Housing & Community Affairs”
As admitted by
the Defendant(s) through their “Attorney of Record” Antoine L. Freeman J. D. Texas Bar No. 24058299 in his reply to
Plaintiff First Set of Interrogatories” dated October 14th 2009
Exactly 4
months and 5 days from June/18/2009 to October 14th 2009 a knowing legal transfer of the Defendant(s) “Joyce Guy and Edward McCray”
collectively property of 448 DeQueen blvd. was in fact transfer to the “Texas Department of Housing &
Community Affairs” during this ongoing civil action
Meanwhile “Attorney of Record” making numerous false claiming
before the “Honorable Court” he was never was acting or having any involvement on
the behalf of the Defendant(s) “legal interest”
However Antoine
L. Freeman J. D. Texas Bar No. 24058299 being in the possession, custody and
control of the Pro Se Plaintiff “Request for Admission”, “Disclosure Documents”
And
“Interrogatories” now filed as Exhibit(s) attached to Pro Se Plaintiff Motion
for Final Summary Judgment filed by “Attorney
of Record” on signature Antoine L.
Freeman J. D. Texas Bar No. 24058299 proves in addition;
14.
Pro Se Plaintiff seeking Federal Action in The Eastern
District Court of Texas of “Racketeer
Influenced and Corrupt Organizations Act” (RICO) Hamilton v. Freeman et al Filed: February 2, 2010
as 1:2010cv00055 Plaintiff:
Louis Charles Hamilton, II Defendant: Antoine L Freeman, Edward McCray, Joyce
M Guy
Against the Defendant(s) “Joyce Guy and Edward McCray” and their Attorney of Record Antoine L.
Freeman J. D. Texas Bar No. 24058299
When said
Attorney of Record did in fact filed Court Document(s) herein the files of this
“civil action”
Claiming “among
other things” that Attorney of record did not violated Rule 193.1 as was only
retain to file a “General Denial” to this action (ONLY) “However Plaintiff
exhibit(s) “Request for Admission”, “Disclosure Documents” And
“Interrogatories” dictate before the “Honorable Court”
Attorney of Record conspire with Defendant(s) “Joyce
Guy and Edward McCray” to fully Withholding all discovery information from
2007-2010 when Attorney was release from Defendant(s) defense
To include Attorney
of Record Antoine L. Freeman J. D. Texas Bar No. 24058299 conspire with
Defendant(s) “Joyce Guy and Edward McCray”
Collective
outlandish criminal failure to supply any “materials facts” of the physical
property transfer of 448 DeQueen
Blvd. in Port Arthur Texas 77640
Namely being Lot 1-2 Block 172 Jefferson County Texas to the ownership of “Texas Department of Housing & Community
Affairs” during this ongoing civil action before the 58th District
Court of Jefferson County Texas Before the “Honorable Bob Wortham” Judicial
Watch.
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