Thursday, November 13, 2014

Plaintiff Louis Charles Hamilton II Motion For “Writ of Garnishment” and Brief in Support No. A-180805


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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