66.
Cause of Actions
Pro Se Plaintiff herein
“States”, “Affirm” and “Declare” further before the “Honorable Justice” a Cause
of Actions exist against Defendant Antoine L. Freeman J. D. Attorney at Law
Texas Bar No. 24058299 And Co-Defendant(s) “Joyce M. Guy and Edward McCray”
Collectively for
“Actual Fraud” and the performance thereof in the capacity of a “Attorney of
Law” to include constructive fraud, fraudulent intent, fraudulent pretense,
fraudulent concealment, fraudulent misrepresentation, fraudulent conveyance, Extrinsic
Fraud, Fraud in fact and Fraud in law, fraud in the execution of Plaintiff
construction contract by Co-Defendant(s) “Joyce M. Guy and Edward McCray” for
purpose to fraud “Insurance Company”
To include collectively
Fraud on the Court involving fraudulent activities upon the 58th
Judicial District Court of Jefferson County Texas, and all court records, court
documents, electronic transmission, court transcripts, and document thereof
Fraud against
Insurances Companies, State of Texas, and the United States of America FEMA and
Federal Housing Grant agencies involving Past Hurricane storm related damages all
of which being described in paragraph (66) herein involving the Pro Se
Plaintiff herein being past, present, and future thereof to commit monetary
Fraud gain in among other things Fraud of Insurances Companies, State of Texas,
and the United States of America FEMA and Federal Housing Grant agencies
involving the dwelling located at 448 DeQueen Blvd. In Port Arthur Texas
Committed against the
civil rights, peace, and dignity of the Pro Se Plaintiff Louis Charles Hamilton
II herein before a civil suit in common law within the State of Texas.
67.
Cause of Actions
Pro Se Plaintiff herein
“States”, “Affirm” and “Declare” further before the “Honorable Justice” a Cause
of Actions exist against Co-Defendant(s) “Joyce M. Guy and Edward McCray” for
Defamation of The Pro Se Plaintiff reputation and his Profession in
construction in connection with Co-Defendant(s) collectively fraudulently activities
to obtain a New Home
And Co-Defendant(s)
collectively maintain such defamation acts to secure a 76,000.00 U.S. Dollars
Federal Housing grant in that the Pro Se Plaintiff “Louis Charles Hamilton II” herein
is the “direct cause” of the dwelling located at 448 in DeQueen Blvd. in Port
Arthur Texas being un-inhabitable for human living conditions due primary for
substandard faulty structural construction repairs of said dwelling being
committed by Pro Se Plaintiff herein
Whom never even made any such repairs on said
home just (Pro Se Plaintiff) construction contract being executed and used to continue fraud the Insurance company
for more monetary wrongful gain of “insurance Company repair funds
other than Co-Defendant(s)
actually fixing Hurricane Humberto storm dames to dwelling located at 448
DeQueen Blvd. in Port Arthur Texas as described in this complaint Co-Defendant(s) ) “Joyce M. Guy and Edward
McCray” Committed against the civil rights, peace, and dignity of the Pro Se
Plaintiff Louis Charles Hamilton II, herein.
68.
Cause of Actions
Pro Se Plaintiff herein
“States”, “Affirm” and “Declare” further before the “Honorable Justice” a Cause
of Actions exist against Defendant Antoine L. Freeman J. D. Attorney at Law
Texas Bar No. 24058299 for “Actual Damages”
In this (RICO) and Fraudulent numerous
conspiracy corrupted scheme of things and corrupted activities in concert, and
full collusion being also brought and paid for to “expert cooking the “legal court
books” of a Honorable 58th Judicial Court of Jefferson County Texas in
Favor of the corrupted (RICO) described Co-Defendant(s) herein
To further along promote
and fully cover up all (RICO) activities, Fraud of Insurances companies, FEMA
and Federal Housing Grants both being “past and present” mutable fraudulent
activities of the Co- Defendant(s) “Joyce M. Guy and Edward McCray” herein involving
the Pro Se Plaintiff Louis Charles Hamilton II “Among others” being fully
described herein to include but not limited to
69.
Defendant Antoine L.
Freeman J. D. Attorney at Law Texas Bar No. 24058299 (RICO) and Fraudulent
numerous conspiracy corrupted scheme of things activities in concert, and full
collusion in the capacity of a “Attorney of Law” against the Pro Se Plaintiff
personal property namely “Construction tools” in excess of #3000.00 U.S.
Dollars and lost wages at a minimums of $48,000.00 U.S. dollars per year “lost wages”
since date of injury of November 2007
And Defendant Antoine
L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 to “continue depriving”
the Pro Plaintiff of his entire “Construction Trade” and “Profession” in such a
complex illegal rooted (RICO) conspirer and fraud of the court system “scheme
of things” being attached to the “Actual theft” of all of the Pro Plaintiff
Construction tools and profession trade thereof for a period now exceed (7)
years and counting well into 2015
As “Defendant and
Co-Defendant” collectively enjoys and having monetary gain collectively thereof
from such wrongful ongoing (7) years “civil victory” and corrupted (RICO)
Fraudulent advantages, corrupted acts, and actions over the Pro Se Plaintiff civil
rights, peace and dignity, and fairness to the Texas Civil Rules of Civil
Procedures in a “civil suit” in “common law” as being described herein this
complaint
70.
Further being described
once before the same U.S. District Court of Eastern District of Texas when (Pro
Se Plaintiff) filed his first original (RICO) complaint being legally made thereof
and now no question beyond any doubt ever being so “crystal clear” in 2014
(November) the Pro Se Plaintiff confident in being precise, and having a “well
understanding” into this well twisted, calculated, future plotted, manipulated,
(RICO) mutable Fraudulent count enterprising “scheming activities” derive
thereof and its involvement with Defendant Antoine L. Freeman J. D. Attorney at
Law Texas Bar No. 24058299 herein for
“Actual Damages” exceeding (7) years conspire
collectively with Co-Defendant(s) herein to depriving the Pro Se Plaintiff of
his “personal property” namely “Construction tools” in excess of $3000.00 U.S.
Dollars and “lost wages” at a minimums of $48,000.00 U.S. Dollars
Pro Se Plaintiff being an
“Independent Construction Contractor” suffrage “lost wages” per (7) year since
date of injury of November 2007 in the “Actual Theft” of Said Construction
tools. With 6% interest incurred since date of injury being November 2007 into the
future of 2015 as this Complaint being “examine and entertain” before the “Honorable
Justice” of such “Actual Damages”
71.
Defendant Antoine L.
Freeman J. D. Attorney at Law Texas Bar No. 24058299 herein so did in all
facts, court records, and real life circumstances commit to, designed further
to caused the Pro Se Plaintiff herein to suffer extreme “monetary hardship” in
such lost of “Actual Damage” in excess of $336,000.00 U.S. Dollars in (7) years
of “Lost wages” and counting into 2015
This (RICO) scheme of things in still enforced,
ongoing and very live against the Pro Se Plaintiff Louis Charles Hamilton II
As Defendant (Attorney
at Law) herein (RICO) activities with the Co-Defendant(s) same (RICO)
activities commit his (Attorney at Law) profession to commit to fraud of the
Court “while” being in possession, custody, and control as a “Officer of said
58th Judicial District Court of Jefferson County Texas
Further Defendant
(Attorney at Law) herein (RICO) activities acts and actions fully continue to depriving
both past and present causing the Pro Plaintiff to continue suffrage “Actual
Damages” in excess of $3000.00 U.S. Dollars in Lost of said “Construction tools”
and the “Profession Trade” thereof since November 2007 well into the future of
2015.
72.
Pro Se Plaintiff seeks same
such “Actual Damages” exceeding (7) years Co-Defendant(s) “Edward McCray and
Joyce M. Guy” herein depriving the Pro Se Plaintiff of his “personal property”
namely “Construction tools” in excess of $3000.00 U.S. Dollars and “lost wages”
at a minimums of $48,000.00 U.S. Dollars being a Independent Construction
Contractor “lost wages” per (7) year ongoing lost since date of injury of
November 2007 in the “Actual Theft” of Said Construction tools.
With 6% interest
incurred since date of injury being November 2007 being lost as being described
in paragraph (68) herein Defendant (Attorney at Law) conspire (RICO) with the Co-Defendant(s) “Edward McCray and Joyce M.
Guy” In the ongoing Civil Action suit in Texas State Court Docket No. A-180805
before the 58th Judicial District Court of Jefferson County Texas
Pro Se Plaintiff seeks such
actual damages in a “Summary Judgment motion” just filed in November of 2014
and being heard “oral and argue” before the “Honorable 58th Judicial
District Court of Jefferson County Texas on December 17th 2014 at
8:30 am as this “Honorable 58th Judicial Court
Having full ongoing expert
“subject matter jurisdiction” over the Co-Defendant(s) “Joyce M. Guy” and
“Edward McCray” and all “actual damages” Pro Se Plaintiff seeks therein “State
Court”
73.
Other than
Co-Defendant(s) “Joyce M. Guy” and “Edward McCray” Collectively ongoing (RICO)
Fraudulent activities among other “Federal Subject matter jurisdiction” wrongful
“acts and actions” being committed in concert, collusion, and enjoyed
manipulation and monetary gain derived thereof with Defendant as the Pro Se
Plaintiff herein “Federal Questions” being raised before the “Honorable
Justice” as to the Defendant and Co-Defendant(s) collective criminal/civil
corrupted scheming uncivil behavior being committed
Against the Pro Se
Plaintiff civil rights, peace, will, and dignity in a Civil Suit in common Law
in connection with the Defendant Antoine L. Freeman J. D. Attorney at Law Texas
Bar No. 24058299 defense thereof.
which this “United
States Eastern District Court of Texas having full expert “Honorable Justice”
Subject Matter” over such among other things (RICO) activities described herein
full
And the further full
knowledge Defendant (Attorney at Law) executed in full wrongful conspire involvement
being of a “Legal expert” to commit to among other things “obstruction of
justice”, corrupted, misleading, manipulation” and fraud commitment upon the 58th
Judicial District Court of Jefferson County Texas in the public professional trade
“among all things”
The “fiduciary
capacity” of a legal “Attorney at Law” and “Officer of the Court” in and For
the State of Texas.
74.
Cause of Actions
Pro Se Plaintiff herein
“States”, “Affirm” and “Declare” further before the “Honorable Justice” a Cause
of Actions exist for “Intentional Infliction of Emotional Distress” against
Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 and
Co-Defendant(s) “Joyce M. Guy and Edward McCray”.
Pro Se Plaintiff herein
Incorporated and state all Defendant (Attorney at Law) and Co-Defendant(s) herein
enjoyed collectively their “Intent” scheming fraudulent manufactory purpose in wanting
the Pro Se Plaintiff herein to suffer, extreme agony, heartache, distraint, Accompany substantially massive monetary loss
of “tools and services” in the Construction profession,
75.
Humiliation, Defamation,
and crushing legal defeat to inflict “excessive mental anguish” as a result of
their combine craft complex ongoing conspire (RICO) elements, and fraud on the
court to execute the same (RICO) objective
All of which being
past, present, and further derive thereof Pro Se Plaintiff suffrage such future
(7) years of ongoing “mental intent contempt” of the Defendant and
Co-Defendant(s) enforced legal corrupted strong hold over the “common law”
rights of the Pro Se Plaintiff
Defendant Antoine L.
Freeman J. D. Attorney at Law Texas Bar No. 24058299 and Co-Defendant(s) “Joyce
M. Guy and Edward McCray”.
Civilly accomplish with strong corrupted concealment motive
not to be “confused or construed” with a simple attorney mistake by Defendant
(Attorney at Law) a combine collective “cause of action” before the “Honorable
Justice” for continual past, present, and future “Intentional Infliction of
Emotional Distress”.
76.
Cause of Actions
Pro Se Plaintiff herein
“States”, “Affirm” and “Declare” further before the “Honorable Justice” a Cause
of Actions exist for “Declaratory Judgment” of the Honorable Court against
Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 and against
Co-Defendant(s) “Joyce M. Guy and Edward McCray” as to all of the “material subject
matter” fully declared past, present and future Before the Honorable Justice
herein
Of the Defendant and
Co-Defendant(s) Collective conclusive, conspire, concert, agreements, engagement,
and execution, pilot, maneuver, manipulated, scheme upon (RICO) actions and dealing,
Among other extreme
behavior in fraudulent Corruption of The 58th Judicial District Court
System to induce, and perpetrate such Fraud upon the Court for a period in
excess of (19) Months as each so stated, affirm, and declared statement of “material
facts”, “events” and “circumstances” described fully herein this Complaint
77.
Put an end to a doubt
as to the “gross civil intention” of “Antoine L. Freeman J. D. An “Attorney”, direct at the Pro Se Plaintiff
“Civil Liberties” for a cause of action for “Declaratory Judgment” is made enter
into the “Honorable Justice” decision, and final announcement of the Court
Records against said Defendant.
78.
Put an end to a doubt as to the “gross civil
intention” of “Joyce M. Guy” and “Edward McCray” and their extreme scheming
corrupted fraudulent behavior in “patter and practices” of Mutable (RICO) Fraudulent
Scheming Enterprising Endeavors
Co-Defendant(s)
Collective conclusive conspire agreements, engagement, and execution, pilot,
maneuver, manipulated, scheme upon (RICO) actions and mutable fraudulent
underhanded dealing(s),
Among other extreme
outrageous behavior in fraudulent Corruption of “among others” The 58th
Judicial District Court System to induce, and perpetrate such Fraud upon the
Court for a period in excess of (19) Months
As each so stated,
affirm, and declared statement of “material facts”, “events” and
“circumstances” described fully herein this Complaint direct at the Pro Se
Plaintiff “Civil Liberties” a cause of
action for “Declaratory Judgment” is made enter into the “Honorable Justice”
decision, and final announcement of the Court Records against said Co-Defendant(s)
Collectively.
79.
Pro Se Plaintiff herein
“States”, “Affirm” and “Declare” further before the “Honorable Justice” a Cause
of Actions exist for ‘Treble Damages” made enter into the “Honorable Justice”
decision, and final announcement of the Court Records against said Defendant
Antoine L. Freeman J.
D. Attorney at Law Texas Bar No. 24058299 and Co-Defendant(s) “Joyce M. Guy”
and Edward McCray” Collectively for their combine “wicked”, monstrous,
appalling, atrocious, disgraceful, corrupted behavior direct at the Pro Se
Plaintiff “Civil Liberties” .
80.
Wherefore Pro Se Plaintiff Louis
Charles Hamilton II Respectfully Moves the Honorable Court Justice, to Award to
the Pro Se Plaintiff “Declaratory Judgment” against Antoine
L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 and Co-Defendant(s)
“Joyce M. Guy” and Edward McCray” Collectively in favor of the Pro Se Plaintiff.
81.
Wherefore Pro Se Plaintiff Louis
Charles Hamilton II Respectfully Moves the Honorable Court Justice, to Award to
the Pro Se Plaintiff “Actual Damages” against Antoine L.
Freeman J. D. Attorney at Law Texas Bar No. 24058299 for fraudulent conspire
against Pro Se Plaintiff “personal property” namely “Construction Tools” Pro Se
Plaintiff Personal property Lost in tool(s) is in excess of $3093.00 dollars
Award further
with full 6% interest rate incurred since date of injury from November 16th
2007 continual on into 2015 in
excess of at a rate of (7) years and continual counting in favor of the Pro Se
Plaintiff 6% interest incurring.
82.
Wherefore Pro Se Plaintiff Louis
Charles Hamilton II Respectfully Moves the “Honorable Court Justice”, to Award
to the Pro Se Plaintiff “Actual Damages” against Antoine L.
Freeman J. D. Attorney at Law Texas Bar No. 24058299 for fraudulently conspire
against Pro Se Plaintiff as described herein this complaint for “Actual
Damages” of “Lost wages” and “Loss of earning capacity” incurred in the “Continual
Actual Theft” and “further executed fraudulent conspirers activities
Derive thereof” and fully committed,
manipulated, scheme against by Defendant Antoine L. Freeman J.
D. Attorney at Law Texas Bar No. 24058299 herein in the “expert legal
professional capacity” as a “Attorney of Law”
Civilly in a Suit in
“common Law” against the Pro Se Plaintiff “personal
property” namely “Construction tools”, involving Pro Se Plaintiff Special Trade,
Skill and Profession thereof, in excess of $48,000.00 U.S. Dollars per year in
lost wages Being a accumulated rate now in excess of $336,000.00 U.S. Dollars for
the past (7) years “Lost wages” and “Lost earning capacity” Pro Se Plaintiff
endure suffrage thereof.
“Award” further with full 6% interest
rate incurred since date of injury from November 16th 2007 continual
on into 2015 in excess of at a rate of (7) years past and continual counting in
favor of the Pro Se Plaintiff 6% interest incurring.
83.
Wherefore Pro Se Plaintiff Louis
Charles Hamilton II Respectfully Moves the “Honorable Court Justice” for
damages in the amount of the Honorable Court Justice for the Plaintiff suffrage
of “Intentional Infliction of Emotional Distress” and “Mental Anguish” in
Excess of the Jurisdictional amount of $75,000.00 U.S. Dollars against Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 in Favor
of the Pro Se Plaintiff.
84.
Wherefore Pro Se Plaintiff Louis
Charles Hamilton II Respectfully Moves the “Honorable Court Justice” for
damages in the amount of the Honorable Court Justice for the Plaintiff suffrage
of “Intentional Infliction of Emotional Distress” and “Mental Anguish” in
Excess of the Jurisdictional amount of $75,000.00 U.S. Dollars against Co-Defendant(s) “Joyce M. Guy”
and Edward McCray” in favor of the Pro Se Plaintiff.
85.
Wherefore Pro Se Plaintiff Louis
Charles Hamilton II Respectfully Moves the “Honorable Court Justice” for Award
of “Treble Exemplary Damages” Statue of the “Honorable Court Justice” against
Defendant Antoine L. Freeman J. D. Attorney at
Law Texas Bar No. 24058299 in favor of the Pro Se Plaintiff.
86.
Wherefore Pro Se Plaintiff Louis
Charles Hamilton II Respectfully Moves the “Honorable Court Justice” for Award
of “Treble Exemplary Damages” Statue of the “Honorable Court Justice” against
Co-Defendant “Joyce M. Guy” and Edward McCray” Collectively in favor of the Pro
Se Plaintiff.
87.
Wherefore Pro Se Plaintiff Louis
Charles Hamilton II Respectfully Moves the “Honorable Court Justice” for
damages in the amount of the Honorable Court Justice for the Plaintiff suffrage
of Defamation of the Pro Se Plaintiff Construction Reputation in Excess of the
Jurisdictional amount of $75,000.00 U.S. Dollars against Co-Defendant(s) “Joyce
M. Guy” and “Edward McCray” collectively in favor of the Pro Se Plaintiff.
88.
Wherefore Pro Se Plaintiff Louis
Charles Hamilton II Respectfully Moves the “Honorable Court Justice” for accumulative, compensatory, consequential, continuing,
expectation damages, foreseeable, Future, incidental, indeterminate, reparable,
lawful, proximate, prospective, special, speculative, substantial, Awards in Excess
of the Jurisdictional amount of $75,000.00 U.S. Dollars against Co-Defendant(s)
“Joyce M. Guy” and “Edward McCray” collectively in favor of the Pro Se
Plaintiff for (RICO).
89.
Wherefore Pro Se Plaintiff Louis
Charles Hamilton II Respectfully Moves the “Honorable Court Justice” for accumulative, compensatory, consequential, continuing,
expectation damages, foreseeable, Future, incidental, indeterminate, reparable,
lawful, proximate, prospective, special, speculative, substantial,
Awards in Excess of the Jurisdictional amount of
$75,000.00 U.S. Dollars against Defendant Antoine L. Freeman J.
D. Attorney at Law Texas Bar No. 24058299 in favor of the Pro Se Plaintiff for
(RICO).
90.
Wherefore Pro Se Plaintiff Louis
Charles Hamilton II Respectfully Moves the “Honorable Court Justice” for a
Order the Defendant and Co-Defendant(s) collectively pay all court cost of this
U.S. Civil Court Action.
91
Wherefore Pro Se
Plaintiff Louis Charles Hamilton II Respectfully Moves and Request the “Honorable Court Justice” for any further,
Just, proper, Damages, Orders, and Awards The “Honorable Court Justice” Deems
favorable for the behalf of Pro Se Plaintiff “Louis Charles Hamilton II”
herein.
By, _______________________________
Louis Charles Hamilton II
Pro Se Plaintiff
P.O. Box 17524
Sugar Land Texas 77496
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