38.
Pro Se Plaintiff herein
“States”, “Affirm” and “Declare” further before the “Honorable Justice” Defendants Antoine L. Freeman, J.D. “Attorney
at Law” at the very start clearly in December of 2007 was engaging in Professional Skills of a
Attorney at Law” in a “Legal” ongoing court room obligations to defend this
civil case A-180805 against Pro Se Plaintiff
Defendant made Fraud upon the 58th Judicial Court
claiming in a document filed by defendant his only legal job was to draft a (Simple)
General denial on behalf of the Defendants filed on December 18th
2007, as such to avoid a default on behalf of Co-Defendant(s) by filing his
original Answer and at that point his “Fiduciary Duty” to his clients and
before the Court ended on that date December 18th 2007 and was
legally completely over,
Which this is not the case as Defendant (Attorney at Law)
Fully scuttles all discovery materials received from Plaintiff in this civil
matter from December 18th 2007- November 13th 2009 being
the official day while in possession of Plaintiff request to disclose Pursuant
to Rule 194 during the entire year of 2008-2009 Defendant Antoine L. Freeman,
J.D. “Attorney at Law fail well within (30) days of this request, for the
information or material described in Rule 194.2: by a period of over (2) years
past the (30) days requirement to answer not only Pro Se Plaintiff “Request to
Disclose” Pursuant to Rule 194,
Defendant (Attorney at Law) was also served Pursuant to Rule
198 of the Texas Rules of Civil Procedure Plaintiff Request for Admission(s)
and Pursuant to Rule 197 of the Texas Rules of Civil Procedure Pro Se Plaintiff
Set of Interrogatories all of which required a reply within (30) days of these
request as Defendant a skilled (Attorney at Law) having full knowledge that a
discovery phase process had commence in this civil legal matter refuse to
submit any “response or reply” to all being described in paragraph (38) herein
for a period of (1) year and (11) Months and Pro Se Plaintiff Filed “Motion for
sanctions” against said Defendant (Attorney at Law) in violation of Rule 193.1
of the Texas Rules of Civil Procedure.
39.
Defendant (Attorney at Law) in his defense of Plaintiff
motion for Sanctions committed to the Following Fraudulent activities upon the
58th Judicial District Court of Jefferson County Texas and all court
records derive thereof.
a. Engage in having Co-Defendant “Joyce
M. Guy” Subscribed and Sworn a Affidavit in Support of Defendant (Attorney at
Law) dated September 11, 2009
b. File a Response to Plaintiff’s Motion
For Sanctions also committed to the same act of having this document
“Subscribed and Sworn on the 11th day of September 2009
c. Submitted all fact therein as being true
before a Court of Law.
40.
Pro Se Plaintiff herein
“States”, “Affirm” and “Declare” further before the “Honorable Justice”
Affidavit of Co-Defendant “Joyce M. Guy” admit Defendant (Attorney at Law)
informed Co-Defendant between April 2nd, 2008 and April 11th,
2008 about Pro Se Plaintiff “Discovery Request” providing proof that Defendant (Attorney
at Law) was in fact in possession, custody, and control of said discovery
request while representing to the “Honorable Court” this was not the case.
41.
Defendant (Attorney at
Law) herein did not file any notice with the Pro Se Plaintiff or the District Court
of Jefferson County Texas that he was not representing the legal interest of
the Co-Defendant(s) “Joyce Guy and Edward McCray”, there after
filing “the original answer” with the District Court back in December 18th
of 2007 when Defendant (Attorney at Law) herein in fact stating having Pro Se
Plaintiff Discovery in Defendant own Affidavit being in his possession as of
April 2nd, 2008.
42.
Pro Se Plaintiff herein “States”, “Affirm” and
“Declare” further before the “Honorable Justice” Defendant (Attorney at Law)
herein stated to the Honorable 58th Judicial District Court also,
that his only duty was to file a original general denial (only) and this was
what his “Legal” services as a Attorney in this matter was only retain for in
his defense for Sanctions against him as described herein this complaint.,”
“However” Pro Se
Plaintiff States”, “Affirm” and “Declare” and further maintain that Defendant Antoine
L. Freeman J. D. “Attorney at Law” Texas Bar No. 24058299 did in fact make a
court appearance in a hearing the Pro Se “set” before the Honorable 58th
District Court
Pro Se Plaintiff also
filed a (TRO) “Temporary Restraining Order” in this same civil matter A-180805 against
Co-Defendant “Joyce M. Guy” to protect her own “Mother” Norma Guy, and the
resident living in that dwelling whom Co-Defendant (Guy) having “Power of
Attorney” Over her Mother Legal Affairs, filed in Jefferson County #2010042042
at which during this same time frame Co-Defendant having process the same
scheme and scam of things regarding Insurance and FEMA fraud of the property of
5050 East 7th street in Port Arthur Texas being Norma Guy Home
Mother of the Co-Defendant (Guy).
43.
Defendant (Attorney at
Law) made another court appearance and argued this issue of a (TRO) alone
before the Honorable Judge Bob Wortham, and at no time was Defendant not acting
in the capacity as “Attorney of Record” from the time of filing his notice of
counsel until Defendant (Attorney at Law) filed Motion to withdraw as Attorney of
Record.
Pro Se Plaintiff herein
“States”, “Affirm” and “Declare” further before the “Honorable Justice”
Defendant (Attorney at Law) herein sat on Pro Se Plaintiff entire Discovery
Request in excess of 16 Months and refuse to file a reply, file any type notice
with the court during this 16 Months time period while Texas Rules of Civil
Procedure require
Defendant a
professional Attorney at Law Adhere to local rules of the Court System and
reply within (30) days not on a time table of (16) later after service of Said
Discovery request by Pro Se Plaintiff Louis Charles Hamilton II.
44.
Pro Se Plaintiff herein
“States”, “Affirm” and “Declare” further before the “Honorable Justice”
Defendant (Attorney at Law) herein, further state Defendant then took a even
bolder set in “Obstruction of Justice” in that after (16) of scuttling Pro Se
Plaintiff Discovery request to further Hide all of the corruption going on at
present time in the destruction of the old home and the new one being built,
during this ongoing Civil Suit and all of the inquiries being made by the Pro
Se Plaintiff regarding Fraud relating to Insurance Companies Former
Contractors, and Hurricane “Rita”, “Ike” and “Humberto”.
Defendant (Attorney at
Law) herein provided further Fraud upon the Court in Fraudulent Information in
the Interrogatories, and Never Investigated the circumstances of the questions
being raised surrounding the “Theft” of The Pro Se Plaintiff Construction Tools
by the Co-Defendant(s) “Joyce M. Guy” and “Edward McCray”,
Defendant (Attorney at Law) completely cover
up the Co-Defendant(s) collective wrong doings from the Honorable Court per Pro
Se Plaintiff Discovery Request being scuttled for (16) months time frame as
being described in paragraph (43) above.
45.
Defendant (Attorney at Law) made as if no
Construction tools where ever on the property of the Pro Se Plaintiff being
complain of
To include Defendant (Attorney at Law) supply false
answer(s) in the same Interrogatories that the Co-Defendant “Edward McCray” never
even meeting the Pro Se Plaintiff Step Father (Lewis Garza) whom actually help
delivery all of Pro Se Plaintiff said in excess of $3000.00 U.S. Dollars in construction
tools to the dwelling in his Truck to the Home of The Co-Defendant(s) “Joyce M.
Guy” and “Edward McCray” on November 16th 2007. Defendant (Attorney
at Law) did not Investigate any of these facts nor was he ever even concern to
attempt to investigate into the issues of the were about of Pro Se Plaintiff
Construction tools.
45.
Pro Se Plaintiff herein
“States”, “Affirm” and “Declare” further before the “Honorable Justice” after
Defendant (Attorney at Law) was officially no longer “Attorney of record” of
the Civil action in Texas State Court from the time frame of December 18th
2007 – filing General Denial to November 13th 2009 when Defendant
(Attorney at Law) filed with the Clerk of Court of Jefferson County Texas a
Motion for Withdrawal of Counsel
The Co-Defendant “Joyce
M. Guy and Edward McCray” continue to refuse to turn over said “Discovery Request”
of the Pro Se Plaintiff
To the point a Court Order of the 58th
Judicial District Court was obtain and enforced as Follows:
46.
Ordered that Co-Defendants
“Joyce Guy and Edward McCray” shall 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., Port Arthur, Texas
47.
Ordered that Co-Defendants
“Joyce Guy and Edward McCray” shall produce copies of any and all construction
estimates for repairs in Defendants’ possession, custody or control in
relationship to the damages caused by Hurricanes Rita, Humberto and Ike to the
Property located at 448 DeQueen Blvd. in Port Arthur, Texas.
As so Ordered on the 10th
day of May 2010 by the 58th Judicial District Court of Jefferson
County Texas filed at 11:46 am.
48.
Pro Se Plaintiff herein
“States”, “Affirm” and “Declare” further before the “Honorable Justice” that
Co-Defendants “Joyce Guy and Edward McCray” remain in Hostile abscond scuttle
refusal of the Honorable Court Order as of the undersigned date in the Month of
November 2014 of this Complaint being refilled in U.S. District Court.
49.
Pro Se Plaintiff herein
“States”, “Affirm” and “Declare” further before the “Honorable Justice” because
of Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 acting
in his skilled profession to fraud the court and belittle the Pro Se Plaintiff
and his discovery request for a period in excess of 16 months in possession
thereof
To include Defendant
(Attorney at Law) herein unethical commitment to conspire further under the
disguise of “Attorney/Client” privileges. Work Product doctrine, and all
Communications thereof being secrete between the Defendant (Attorney at Law) and
the Co-Defendant(s) “Joyce Guy and Edward McCray”
To the point such Fraud
commits by the Defendant (Attorney at Law) on the Jefferson County 58th
Judicial District Court completely forced the Pro Se Plaintiff to be at an extreme
“civil disadvantage” in the ongoing court proceeding in the time frame of 2007-2009
and present in 2014 throughout 2015
Based solely upon
Defendant (Attorney at Law) Rouge (RICO) “obstruction of Justice” among other
things being fully professional hire “Legal Gun” knowledge thereof to scuttle,
omit, delay and fraudulently mishandling required duties to supply a honest,
required respond to all of Pro Se Plaintiff discovery request in a timely
fashion, within the (16) months being in possession, custody and control of
said Pro Se Plaintiff Discovery request.
50.
Pro Se Plaintiff herein “States”, “Affirm” and
“Declare” further before the “Honorable Justice” Defendant Antoine L. Freeman
J. D. Attorney at Law Texas Bar No. 24058299 retainer fees was solely paid to keep the
Co-Defendant(s) numerous discover fraud by the Pro Se Plaintiff absolutely 100%
top secret from the 58th Judicial Court”
while the other newer
$76,000.00 U.S. Dollars “scheme of things” being in current play and process to now a ongoing (RICO) fraud the
Co-Defendant(s) concocted involving Fraud (Now) The “Texas Department of
Housing & Community Affairs” issuance of a “Housing Grant” in favor for the
Co- Defendant(s) “Joyce Guy and Edward McCray”
All of which in fact being
fraudulently obtain from “Federal Housing Grant” on the behalf of “Texas
Department of Housing & Community Affairs” while the civil suit is “Live”
and pending” which Co-Defendant(s) conspire to keep this under wraps from any
financial setback glitches being fully caused by The Pro Se Plaintiff bring
this additional Fraudulent activities before The Honorable Court well deserved
attention.
51.
Pro Se Plaintiff herein
“States”, “Affirm” and “Declare” further before the “Honorable Justice”
Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 in
his History of being a Skilled “Attorney at Law” in and for the State of Texas
“Never” once scuttle,
hide and thereof flat out being in refusal in the filing of a timely Discovery
request for a period exceeding over (30) days against any Attorney, Law Firm or
other Pro Se (Litigant)
In comparison to the
double dealing, 100% skilled rouge super late filing reply to Pro Se Plaintiff numerous
Discovery request being late in excess of (16) months and absolutely 100% in full
violation of Texas Rules of Civil Procedures 193.1 All of which Pro Se
Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable
Justice” solely done by Defendant (Attorney at Law) (Only) to conspire in the illegal
(RICO) aid to hide all of the Co-Defendant(s) “Joy M. Guy” and “Edward McCray” many corrupted Business Enterprises endeavors,
Mutable Counts of
Fraudulent activities involving Hurricane “Rita”, “Ike” and Humberto” Monetary
rip off scams against FEMA, Building Contractors estimate and invoices and Home
Owner Insurances Companies repair funds
Couple with the (Now)
live ongoing new 2009 fraud activities of the Co-Defendant(s) “Joy M. Guy” and
“Edward McCray” involving “Federal Housing Grant” on the behalf of “Texas
Department of Housing & Community Affairs” in excess of $76,000.00 U.S.
Dollars
52.
Defendant (Attorney at Law) herein known lying
with a consciousness mind and disregard for the consequences for his actions in
the “capacity as an Attorney of Law”, Antoine L. Freeman J. D. conspire to continue to use his legal lawyer
skills” in the full “aid and abetting”, and commitment to “Obstruction of
Justice” in the capacity of a Attorney at Law forthwith in providing his own
numerous Attorney fraud legal commitment upon the 58th Judicial
District of Court of Jefferson County Texas, the Court records thereof as being
fully described in this U.S. District Court Complaint.
And being in full criminal (RICO) concert,
collusion, corruption and conspiracies thereof for all monetary fraudulent
assets gains of the Co-Defendant(s) “Joy M. Guy” and “Edward McCray”
Both being “ill-gotten pirate loot” from the “past”
Hurricanes Seasons “Rita”, Ike” and “Humberto” and “present” pirate loot” “Federal
Housing Grant” on the behalf of “Texas Department of Housing & Community
Affairs” in excess of $76,000.00 U.S. Dollars of the Co-Defendant(s) “Joy M.
Guy” and “Edward McCray”
53.
Fully affecting the Pro
Se Plaintiff (Life) with “among other things” cause of action for “actual
damages” being in excess of $336,000.00 U.S. Dollars in “lost wages” from 2007 –
2014 and “actual damages” in excess of “3093.00 U.S. Dollars in all of the Pro Se
Plaintiff Construction tools causing the Plaintiff undue unwanted extreme hardship,
infliction of emotional distress and anguish in the “Theft of Pro Se Construction Profession” for a ongoing time
frame over (7) years and still counting well into 2015 The Texas State Civil
Suit is “Live” and ongoing due in large part to Defendant (Attorney at Law) herein
Numerous (RICO) “acts
and activities” to commit “among other things” a ,complete assault of “Obstruction
of Justice” and “Fraud upon a Court” in the 58th Judicial District
Court of Jefferson County Texas
In a Suit in “Common
Law” for the rouge disgrace benefit of his skilled profession as a “Attorney of
Law” to skillfully cover up a Co-Defendant(s) “Joy M. Guy” and “Edward McCray” clients
“Long Bogus Quite Profitable Crooked Road of “Fraudulent History” being described
fully herein and direct against The civil rights, peace and dignity of the Pro
Se Plaintiff herein.
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