22.
Defendant Antoine L.
Freeman J. D. Attorney at Law Texas Bar No. 24058299 filed an original answer
on behalf of the Co-Defendant(s) and then later making false discovery
procedure claiming to the Honorable Judge Bob Wortham on or about 11th
day of September 2009 in a reply motion for sanction against said “Attorney”
for violations of Texas Rules of Civil Procedure 193.1 by failing to respond to
Pro Se Plaintiff’s Discovery Request
” Defendant Antoine L.
Freeman J. D. Attorney at Law Texas further making factual material claims in
court filed documents and before the Honorable Court in a hearing his only “Legal obligation” was to
provide Co-Defendant(s) “Joyce Guy and
Edward McCray” involving in this civil case A-180805 in Jefferson County
Texas was to draft a (Simple) General denial on behalf of the described “Co-Defendants”
behalf being filed on December 18th 2007 in Jefferson County Clerk
of Court records in order Co-Defendant(s) collectively do not be filed for a
default Judgment against them for the Civil Complaint.
23.
Pro Se Plaintiff herein
States, Affirm and Declare before the “Honorable Justice” Defendant Antoine L.
Freeman J. D. Attorney at Law Texas Bar No. 24058299 told a bald face “Lie” to
“Judge Bob Wortham” to avoid “monetary sanctions” against him for his (Indeed) violate
of Rule 193.1
Defendant in his capacities as a “Attorney of
Law” no less “kept secretly” in his possession, custody and Control for a
period of over (3) years while being actual the “Attorney of Record” in this
civil matter safely Hidden from the “Honorable 58th Judicial Court” proceeding
All of Pro Se Plaintiff
first round of Chief Discovery request document(s) Request for Disclosure and “Request
for Admissions” pursuant to Rule 198 of the Texas Rules of Civil Procedure to
include Pro Se Plaintiff First set of Interrogatories” pursuant to 197 of the
Texas Rules of Civil Procedure at which Defendant Antoine
L. Freeman J. D. “Attorney at Law” Texas Bar No. 24058299 finally admitted to
the Pro Se Plaintiff (alone)
The “actual physical existences” after 3 years and counting Defendant
“Attorney at Law” omitted of being in such possession, custody and control while
keeping such discovery request of the Pro Se Plaintiff secretly hidden from the
“Court Proceedings” Moreover” especially Hidden From “Judge Bob Wortham” Judicial
studying of the civil case at hand before his Honorable Court proceeding
At which Defendant Antoine
L. Freeman J. D. “Attorney at Law” providing proof of all discovery
document and material facts derive thereof and their now existences being dated
proof on or about October 14, 2009 when
these discovery document(s) “Request for Admissions and “Interrogatories” among
other legal documents was finally being place in the U.S. mail and forwarded
back to the Pro Se Plaintiff herein who made the discovery request over 2 and ½
years ago.
24.
Pro Se Plaintiff herein
States, Affirm and Declare before the “Honorable Justice” Defendant Antoine L.
Freeman J. D. Attorney at Law Texas Bar No. 24058299 cleverly crafty abusing his
“attorney/client privileges, all work doctrine documents derive thereof;
And all known
communications between “Attorney and Client”
Namely Defendant Antoine
L. Freeman J. D. and Co-Defendant(s) “Joyce Guy and Edward McCray” herein to “Grand
style” deceive the “Honorable Court” from having any “Legal Knowledge Via Pro
Se Plaintiff herein “direct discovery request” and “Investigation” fully focus on among other
things Co-Defendant(s)
“Joyce Guy and Edward McCray”
Collectively in the
past did in fact submit numerous Hurricane relief damages claims being in the
form of construction contractor’s estimates to their “Insurance Companies” and
possibly FEMA for relief of damages caused by Hurricanes Rita, Humberto, and
Ike for the property located at 448 DeQueen blvd. in Port Arthur, Texas.
To include Property located at 5050 east 7th
Street in Port Arthur Texas, and Property Located at Blk 4 Lot. 10 Lake View in
Jefferson County Texas all own and in the possession, custody, and control of
the Co-Defendant(s)
As Pro Se Plaintiff
making claims before the 58th Judicial District Honorable Court of
Co-Defendant(s) “Joyce Guy and Edward
McCray” past fraudulent “practice and patterns” thereof after the corrupted
hostile “acts and actions” directed at the Pro Se Plaintiff herein as being described
in paragraph (17-24) above.
25.
Pro Se Plaintiff herein
States, Affirm and Declare before the “Honorable Justice” Defendant Antoine L.
Freeman J. D. Attorney at Law Texas Bar No. 24058299 having full prior
knowledge that existence of a “property lien” was enforced by SWMJ Construction
Inc. filed on June 18th 2009 in Jefferson County Clerk Office
Being against
Co-Defendant(s) “Joyce Guy and Edward McCray” as it was relating to “among
other things” “Material Evidence” Pro Se Plaintiff sought history showing Co-Defendant(s)
making other Fraudulently scheme of things involving monetary relief of damages caused by
Hurricanes Rita, Humberto, and Ike for the property located at 448 DeQueen
blvd. in Port Arthur, Texas. There after already ripping off the Pro Se
Plaintiff in 2007 storm season.
26.
Pro Se Plaintiff herein
States, Affirm and Declare before the “Honorable Justice” Defendant Antoine L.
Freeman J. D. Attorney at Law Texas Bar No. 24058299 having a Profession eye on
the civil damages this discovery would affect Defendant(s) presumed innocent
standing before the Honorable Judge Bob Wortham conspire with “obstruction of
Justice” to continue to commit to conceal this “material evidence” from the
Plaintiff when it was required to be produce in Pro Se Plaintiff Discovery Request
devise.
27.
Pro Se Plaintiff herein
States, Affirm and Declare before the “Honorable Justice” Defendant Antoine L.
Freeman J. D. Attorney at Law Texas Bar No. 24058299 also having “insider information
and communications” with Co-Defendant(s) “Joyce Guy and Edward McCray” conspire
further with “obstruction of Justice” to continue to commit to conceal this
“material evidence” that Co-Defendant(s) “Joyce Guy and Edward McCray” was in fact in the legal process of
having the old Home torn down while the ongoing civil actions was still pending
before the 58th District Court of Jefferson County Texas to include
Co-Defendant(s) “Joyce Guy and Edward
McCray”
Collectively having a “New Home” secretly being built at
the cost of $76,000.00 U.S. Dollars on a
“Federal Grant” kept 100% secret from the Pro Se Plaintiff Discovery and The State
Court while this Civil Suit in common Law had commence in 2007 as was well
ongoing out of control at this point under (RICO).
As Defendant himself Antoine
L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 confirm and described
in Pro Se Plaintiff First Set of “Interrogatories” 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 fraudulently
obtain being in fact a “Federal Housing
Grant” on the behalf of “Texas Department of Housing & Community
Affairs”
Pro Se Plaintiff herein
“States”, “Affirm” and “Declare” further before the “Honorable Justice” Co-Defendant(s) herein making further
fraudulent claims before said “Texas Department of Housing & Community
Affairs” that Pro Se Plaintiff was the primary cause of damages to the old home
derive thereof for Co- Defendant(s) “Joyce
Guy and Edward McCray” needing a “New Home” based upon poor,
Unsatisfactory contractor “workmanships” and “craftsmanship” being
committed by Pro Se Plaintiff Louis Charles Hamilton II herein for the
$10,800.00 U.S. Dollars Contract already sub-mitted to previous “Insurance
Company” by Co-Defendant(s) in regards to Hurricane Humberto storm related
damages.
28.
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 having a
Profession legal eye on the “civil damages” this Pro Se Plaintiff discovery request
would affect Co- Defendant(s) “Joyce Guy and Edward McCray
Presumed innocent
standing before the Honorable Judge Bob Wortham clear back in 2008 long before
Co-Defendant(s) “Joyce Guy and Edward McCray further fraudulently obtain a “New Home” secretly being built at
the cost of $76,000.00 on a Federal
Grant Defendant Antoine L. Freeman J. D. Attorney at Law conspire further with
“obstruction of Justice” to conceal the destruction of the old home And the new
home being built
Defendant Antoine L. Freeman J. D. Attorney at
Law further conspire and work in concert to assure no delays ever being a
factor in the construction of the New Home” Located at 448 DeQueen Blvd. in
Port Arthur Texas would be primary cause if the “Honorable Judge” Bob Wortham,
of 58th Judicial District Court of Jefferson County Texas would in
all facts and circumstances reach Pro Se Plaintiff discovery document(s)
containing “Material Facts” of among other things while this ongoing civil suit
still pending a “Property Lien” already previously in Forced against
Co-Defendant(s) collectively as described in paragraph (25) above
To include a “New Home” secretly being built under
the noise of the Pro Se Plaintiff herein and the “Honorable Judge” Bob Wortham, during this pending civil action Docket
No. A-180805 at the cost of $76,000.00
on a “Federal Grant” as the secretly
destruction of the older home took place
once being
“Official Dwelling” to
this ongoing Civil Suit involving the dwelling in 2007 located at 448 DeQueen
Blvd. in Port Arthur Texas, Now secretly destroyed in 2009 before the Honorable
58th Judicial District Court of Jefferson County, Texas ongoing
civil court case.
29.
Pro Se Plaintiff herein
“States”, “Affirm” and “Declare” further before the “Honorable Justice” Co-Defendant
“Joyce Guy and Edward McCray” secretly filed on June 18th 2009
transfer of property over to the “Texas Department of Housing & Community
Affairs” at the Jefferson County Clerk Office File #2009022762 during this
ongoing civil action with the Defendant collusion to keep all of this
absolutely secretly claiming under
“Attorney/Client Privileges”, Product of Work
Doctrine and Communications made between Attorney and Client absent the fact
this is very material facts in a ongoing civil suit against the Co-Defendant(s)
collectively under the legal defense of Attorney at Law criminally withhold
such discovery as request to release such favorable Document, Material facts,
and circumstances.
30.
Pro Se Plaintiff herein
“States”, “Affirm” and “Declare” further before the “Honorable Justice”
Co-Defendant “Joyce Guy and Edward McCray” secretly filed on June 18th
2009 Fraudulent “Financing Statement” at the Jefferson County Clerk Office File
#2009022763 to obtain from “Texas Department of Housing & Community
Affairs” $76,000.00 on a “Federal Grant” as the secretly
destruction of the older home took place
during this ongoing “Civil Suit”
31.
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
having full knowledge of all this transfer of the Home, and the destruction of
the older one and all circumstance involved thereof being secretly conspire
further fraudulently in the capacitates of a “Attorney at Law” with the
Co-Defendant(s)
To achieve the same fraudulently
monetary objective(s) gain being $76,000.00 “New Home” on a “Federal Grant”
shamefully submitted Before the “Texas Department of Housing & Community
Affairs” by Co-Defendant(s) after already “Greedy Squandering” all of the Numerous
Insurance Funding” from each previously Hurricane “Rita”, “Humberto”, and “IKE”
related storm damages on the dwelling located at 448 DeQueen Blvd. in Port
Arthur Texas.
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 had a
duty to disclose all material facts as described herein and regardless of his “Attorney/Client
defense of the Co-Defendant(s)
Defendant Antoine L.
Freeman J. D. Attorney at Law Texas Bar No. 24058299 was obligated to conform
with the Texas Rules of Civil procedures in Discovery phase of a Civil Suit in
common law within the State of Texas
Regardless of it
criminal/civil fall out affect being properly in placement upon the
Co-Defendant numerous fraudulent acts and actions discovery of a shocking
further investigation involving “among other things” the actual designed “Fraud
of Contractors” related to “Insurance Company” Scams and scheme of things the
Co-Defendant(s) monetary calculated and concocted.
32.
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 at no
time did the Defendant file any notice with the court from the time frame of December
18th of 2007 throughout December 11th 2009 request for
“Motion For Withdrawal of Counsel” exactly 7 days shy of two years
Defendant Antoine L. Freeman J. D. Attorney at
Law Texas Bar No. 24058299 was retain to commit to numerous fraudulent acts and
actions involving withholding all discovery material during this entire (2)
year time frame and shield all of Co-Defendant(s) mutable fraudulent
indiscretions of Corrupted Illegal (RICO) Business dealing within Jefferson
County Texas being instituted by the Co-Defendant(s) .
33.
Pro Se Plaintiff herein
“States”, “Affirm” and “Declare” further before the “Honorable Justice” Pro Se
Plaintiff herein because of the many “hostile” acts and actions direct at the
Pro Se Plaintiff civil rights, peace and dignity by the Co-Defendant(s) herein
Pro Se Plaintiff conducted
a Special Exclusive in-depth Investigation into the Co- Defendant(s) “Joyce Guy
and Edward McCray” to provide the Honorable 58th Judicial Court of
Jefferson County Texas”,
Solid proof of the
Co-Defendant(s) collective History of corrupted “pattern and practices”
involving “fraudulent monetary scheme of things Nature” to” legally discovery”
all of the following ongoing corrupted in design acts and in one primary case being
a actual “Illegal Medical Enterprise” for the elderly disable senior citizens
within in Jefferson County Texas
34.
Co- 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 Co-Defendant(s) collectively herein as records do in fact
“indicate” and on file with the “Jefferson County clerk”
35.
Pro Se Plaintiff herein
“States”, “Affirm” and “Declare” further before the “Honorable Justice” the
Co-Defendant(s) “Joyce Guy and Edward McCray”, filed with
the Jefferson County Clerk #2009022763 “Financing statement” to obtain the “Texas Department of Housing &
Community Affairs” $76,000.00 on a “New Home Federal Grant”
“However” Co-Defendant(s) “Joyce M. Guy” omitted and refused
to provide correctly all factual income detail in this “Financing Statement” of
the Assumed Name Business 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
In which this is in facts and circumstances a “illegal medical business” for the
disable elderly senior citizens of Jefferson County Texas has never had a HCSSA license on filed with the State of
Texas nor was a HCSSA license ever attempted to be correctly filed with the
State of Texas which all of this was ongoing from the dates of May 5th1997
throughout January 7th 2010 for a period of 13 years of “Earn Income” with cash being paid to all “employees”
when it was order shut down by the State of Texas Department of Aging and
Disability Services until a real licensed being obtain.
Pro Se
Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable
Justice” on December 1st of 2009 is when the (Pro Se Plaintiff)
filed a formal complaint with “Texas Department of Aging and Disability
Services” in regard to this “Illegal” Medical Business” namely “G and G
Service Company”
P.O. Box 515,
416 DeQueen Blvd. in Port Arthur Texas of
Co-Defendant(s) “Joyce M. Guy” (Actually) this medical business operations of G
and G Service Company being secretly conducted on a (Vacant Lot) J
Pro Se
Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable
Justice” as a result of Pro Se Plaintiff “Investigation” Co-Defendant(s) “Joyce
M. Guy” was order in Person as Pro Se Plaintiff was on his cell phone by the
“State of Texas” “Texas Department of Aging and Disability Services” to shut down
said “Illegal medical business” until a real HCSSA license is obtain with the
State of Texas.
36.
Pro Se
Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable
Justice” at this time frame Defendant Antoine L. Freeman J. D. Attorney at Law
Texas Bar No. 24058299 was fully aware of the “Texas Department of Aging and
Disability Services shutting down said “Illegal medical business”
“G and G
Service Company” until a real HCSSA license is obtains with the State of Texas
which Defendant Antoine L. Freeman J. D. “Attorney at Law” understood directly
Pro Se Plaintiff himself being the direct cause for “Illegal medical business” G
and G Service Company being closed against Co-Defendant(s) while this civil
suit was ongoing in the 58th Judicial District Court of Jefferson
County Texas
Defendant
(Attorney at Law) herein conspire further to protect the Co-Defendant(s) from
any further civil/criminal fall outs there past history might dictate in Fraud
scheme of things as described herein to the point Defendant conceal all of the
Pro Se Plaintiff Discovery request document(s) throughout the years of 2007,
2008 and 2009 when Texas law of Civil procedure require a reply well within 30
days of receiving said discovery request.
Defendant
(Attorney at Law) herein told “Judge Bob Wortham” he was only retain to file a
“General Denial” (Only) while secretly conceal all of the Pro Se Plaintiff
Discovery request document throughout the years of 2007, 2008 and 2009 to assure
Co-Defendant(s) “Joyce Guy and Edward McCray” fully protected from any present
and future civil/criminal fall outs occurring
Based upon
Pro Se Plaintiff Investigations into the Mutable Corrupted Business “patterns
and practices of the Co-Defendant(s) herein to include but not limited to The
Pro Se Plaintiff knew Co-Defendant “Edward McCray” seriously engage in “sales”
of a “Crack Cocaine” Industry and having mutable arrest.
37.
Pro Se Plaintiff herein
“States”, “Affirm” and “Declare” further before the “Honorable Justice” Special
Exclusive in-depth Investigation into the Co- Defendant(s) “Joyce Guy and
Edward McCray” further reveal J Can Company 1807 East 7th Street Port Arthur Texas
(Office) located at 448 DeQueen Blvd. in Port Arthur Texas 77640 being owned by
the Defendant(s) “Joyce Guy and Edward McCray”, assumed name filed on April 11th
2008 Jefferson County Clerk records #72594
1807 East 7th
street in Port Arthur Texas is actually a “Vacant Lot” which has been raided by
the PAPD Dept. (Police) several times for engaging in “illegal Scrap Industry”
“Moreover” once all
“Illegal Scrap Metal” other then used Cans being recycle and obtain in the City
of Port Arthur Texas city limits by Defendant “Edward McCray”, by the business
J Can Company being now introduced as “Scrap Metal” in connection with “Cars
and Pieces” business Located in Beaumont Texas (Office) also located at 448
DeQueen Blvd. in Port Arthur Texas 77640
Making the final “Legal
sales” of all “illegal scrap” obtain in the City of Port Arthur Texas city
limits by Defendant “Edward McCray”,
“Moreover” Pro Se Plaintiff Louis Charles
Hamilton II herein (Fully) quite “elementary sure and certain” after prior raid
by the (PAPD) Police into “illegal scrap” of J Can Company that this “many
years of “baffling exchange” transfer rate of
“Illegal scrap” from Port Arthur Texas City Limits has been
confusing the (PAPD) Police in the exchange rate form now “legal scrap” derived
in “Beaumont Texas” from J Can Company “Namely”, “Cars and Pieces” business in
Beaumont Texas being now major illegal scrap metal “money laundering” “Earn
Income” system for Co-Defendant (Edward McCray) derived from this “criminal
endeavor.
To include but not limited to, upon
information, belief and personally witness Co-Defendant “Edward McCray” usage
of “Vacant Lot” being J Can Company to secretly continue engaging in the sales
of a “Crack Cocaine Industry”.
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