IN THE DISTRICT COURT 58TH JUDICIAL DISTRICT OF JEFFERSON COUNTY, TEXAS
Louis Charles Hamilton II
Plaintiff
V.
Joyce Guy & Edward McCray ET AL
Defendants.
PLAINTIFF MOTION FOR SANCTIONS
Motion before the Honorable Court, For a Sanctions, being enforced against the Defendant(s) and for just cause the Pro Se Plaintiff state as Follows:
Defendant(s) “Joyce Guy and Edward McCray” Was so Order By This Honorable 58th District Court of Jefferson County Texas on the 10th day of May 2010 to produce copies of deeds, property deeds or any other such physical document in Defendants’
Possession, custody or control that shows actual ownership of the property of the dwelling located at 448 DeQueen Blvd., in Port Arthur Texas and fully failing to adhere to an Honorable Court Order.
Defendant(s) already refused completely discovery devises being numerous requests of the Plaintiff threw the Crafty shady slights of hand acts and actions Attorney of Record “Antoine L. Freeman, J.D. Texas Bar No. 24058299
Fully Committing to the same fraud in conspiring with the Defendant(s) to with hold all records of to this civil action at any cost, considering the enforced criminal penalties in light of the many frauds being committed against Insurance companies, and FEMA claims for damages, as a result of this History of Hurricane Damages of related God Act’s as described by the Plaintiff his “Investigation Concluded”
That Elementary Indeed, the Defendant(s) are quite crafty in hustling numerous fake business, to include but not limited to Defendant(s) engaging illegal sales of a “Crack Industry” for which Defendant (Edward McCray) convicted twice of Federal Traffic of Crack Cokecaine, serving two separate prison terms,
Which Plaintiff also described before the Honorable Court Defendant(s) business of recycle of Cans, as resulting also raid by PAPD Dept. for the City of Port Arthur Texas engaging in “illegal scrap metal Industry”
While Defendant(s) “Joyce Guy” already committed for way to many uncountless years of a undocumented “gruesome medical business” taking care of the Poor elderly Senior Citizens not even having documented health Lic# or any kind with the State of Texas or any kind of Insurance on this medical business, or proper personal dealing with Poor elderly Senior Citizens.
Pro Se Plaintiff moves respectfully before the Honorable Court that these Crude Defendant(s) be dealt there on devise
To include having a total disregard for the Honorable Court, Plaintiff, Civil Rights, Peace and Dignity
And an Ordered into these records for sanctions being fully merit against the Defendant(s) “Joyce Guy” and “Edward McCray” for their collective refusal of the 58th District Court Orders attached herein with this Motion for sanctions against the Defendant(s).
Defendant(s) having stolen the Plaintiff lively hood of Construction tools’ in excess of $3093..00 dollars in their possession, custody and control over now a period of 7 years and counting.
Defendant and Defendant’s Attorney did in fact violated rule 193.1 by failing to respond to Plaintiff’s discovery request AS Plaintiff files all Proof attached to Plaintiff Motion for Final Summary Judgment
Defendant(s) continue to commit to the same, and refusal of a Court Order to submit to Plaintiff Discovery Request
Court Order was enforced on the 10th day of May 2010
Defendant(s) continual to commit to refusal of The Jefferson County 58th District Judicial “Court Order” being now 4 years and 6 Months and counting
The Defendant(s) Extreme “Wicked” and “Hostile” unwanted actions Directed at the Plaintiff “Civil Rights”, “Peace” and “Dignity” within Jefferson County Texas with actual damages being in excess of the Amount of $11,024.00 combine for Defendant(s) “Breach of Contract” with full 6% interest rate incurred since date of injury November 16th 2007
1.
Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves the Honorable Court to grant the Plaintiff attached joining motion for sanctions filed herein with good “Merit” for the Discovery which was Order to be produced by The Court
Defendant(s) “Joyce Guy and Edward McCray” Was so Order By This Honorable 58th District Court of Jefferson County Texas on the 10th day of May 2010 to produce copies of deeds, property deeds or any other such physical document in Defendants’ possession, custody or control that shows actual ownership of the property of the dwelling located at 448 DeQueen Blvd., in Port Arthur Texas
Defendant(s) Further Order to be produced by The Court Defendant(s) “Joyce Guy and Edward McCray” Was so Order By This Honorable 58th District Court of Jefferson County Texas on the 10th day of May 2010 to produce
Copies of any and all construction estimates for repairs in Defendants’ possession, custody or control in relationship to damage caused by Hurricanes Rita, Humberto and Ike to the property located at 448 DeQueen Blvd. in Port Arthur, Texas.
And apply civil sanctions against the Defendant(s) in excess of $1000.00 U.S. dollars per every year between the dates of 2010-2014 the Defendant(s) collectively being quite bold hostile disrespectful fleeing absconded completely from the civil actions as they were so required to produce such discovery via the Honorable Court Order of the 58th District Court of Jefferson County Texas.
2.
Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves the Honorable Court sanctions amount being granted in favor of the Plaintiff in the amount of $4500.00 U.S. Dollars from dates of 10th day of May 2010 throughout December 17th 2014
As undersigned date being before “Oral Arguments/Hearing” on the 17th day of December 2014 at 8:30 before the Court.
3.
Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves The Honorable Court for any further, Just, proper until this Civil Dispute has reach a Full, Final and Complete Judgment of This Honorable 58th District Court of Jefferson County Texas in Favor of the Pro Se Plaintiff.
By, _______________________________
Louis Charles Hamilton II
Pro Se Plaintiff
P.O. Box 17524
Sugar Land Texas 77496
No comments:
Post a Comment