(11)
Pro Se Plaintiff, declares, affirm, and state further before the “Honorable Justice” Defendant himself Antoine L. Freeman J. D. (Attorney at Law) herein legally was acting as “Attorney of Record on or about the dates of August 28th 2009 and September 11th 2009
“However Legally Underhanded” during the same “time frame” of Defendant Antoine L. Freeman J. D. (Attorney at Law) representation of civil suit No. A-180805
on or about June 18th 2009 Co-Defendant(s) Joyce M. Guy and Edward McCray herein collectively by and throughout their “Attorney of Record” being Defendant (Attorney at Law) herein himself conspire together with the additional ongoing fraudulent activities of
Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein whom now had conspire, executed and commence further (RICO) Fraud Activities and engage in the actual concealment of the “identifying property deeds” being a party to a Breach of Construction Contract with the Pro Se Plaintiff Louis Charles Hamilton II herein
being filed in Texas State Court Complaint docket No. A180805 and Co-Defendant(s) “Joyce M. Guy and Edward McCray” during their ongoing Legal Retain Hire Top Gun Representation with Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299
Transfer of said Property located at 448 DeQueen Blvd. in Port Arthur Texas (Block) 172, (Lot) 1-2 to “Texas Department of Housing & Community Affairs” as Filed in Jefferson County Clerk Records # 2009022762, for a $76,000.00 Federal Housing Grant, as being described in Pro Se Plaintiff attached exhibit (C) herein “Jefferson County Texas Property Search Index”
(12)
Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein further on June 18th 2009 while involved in this (RICO) activities as being described in paragraph (13) above filed a “fraudulent financing statement” in Jefferson County Clerk Records instrument # 2009022763
in the connection thereof for fraud activities engagement of the “Texas Department of Housing & Community Affairs” for a monetary gain of in excess of said $76,000.00 U.S. Dollars Federal Housing Grant
After the Co-Defendant(s)“Joyce M. Guy and Edward McCray” herein already squandering all of the Home Owner Insurances funds, FEMA Funds designated for “actual building repairs” of said Property located at 448 DeQueen Blvd. in Port Arthur Texas (Block) 172, (Lot) 1-2
Being as a result of Hurricanes damages from Hurricanes “Rita”, Humberto, and “Ike” as described in Pro Se Plaintiff attached exhibit (B) herein 58th Judicial District Court of Jefferson County Texas “Court Order” and the Pro Se Plaintiff Louis Charles Hamilton II being a Party thereof docket No. A-180805
During this entire discovery phase time frame of the Defendant Antoine L. Freeman J. D. (Attorney at Law) which commenced on or about April 2nd 2008 and April 11, 2008 in all factual circumstances and events leading up to a required Court Order being filed by the 58th Judicial District Court of Jefferson County Texas and enforced as described in Pro Se Plaintiff exhibit (B) attached herein
Was fully required after a year plus dates for Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein to produce such “Property Deeds” to said Property located at 448 DeQueen Blvd. in Port Arthur Texas (Block) 172, (Lot) 1-2 well into 2015 still no compliance from Defendant and Co-Defendant(s) collectively.
(13)
As they Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein already having been so served a “Motion for Production of Document” for copies of said “Property Deeds” showing actual ownership of dwelling located at 448 DeQueen Blvd. in Port Arthur Texas by and through said “Attorney of Record”
being Defendant Antoine L. Freeman J. D. (Attorney at Law) herein on August 12th 2009 to produce such copies of Property Deeds to the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas
Meanwhile the said “Attorney of Record” Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar. No 24058299 boldly slipping in and out of a “legal self induced coma of some sorts of understanding of the Civil Laws of the State of Texas” in his extreme and outrageous (RICO) “Obstruction of Justice”
conspired, concert hostile representation of civil suit No. A-180805 with the already corrupted Co-Defendant(s) “Joyce M. Guy and Edward McCray”
herein on many, many numerous fraudulent counts as being described and detailed in the Pro Se Plaintiff complaint on filed with the “United States Clerk of Court” Cause No. 1:14-CV-592
”The Main Defendant” Antoine L. Freeman J. D. (Attorney at Law) actually physically appear in his dated (RICO) “Attorney at Law” presentation on the behalf of Co-Defendant(s) “Joyce M. Guy and Edward McCray”
herein on or about the dates of first August 28th hearing before the Honorable 58th Judicial District Court of Jefferson County Texas
As being fully described in Pro Se Plaintiff attached Exhibit (D) filed herein The 58th Judicial District Court of Jefferson County Texas Docket report Civil Cause No. A-180805
While said Defendant Antoine L. Freeman J. D. (Attorney at Law) already in legal possession, custody, and control over said discovery documents of
Interrogatories, Request for Admission, and Request for Disclosure mailed in accordance with the
Texas Rules of Civil Procedures 194.2, 197, and 198, during this time frame of on or about April 2nd 2008 and April 11, 2008 request (30) days thereafter for a respond of some sorts which this “Obstruction of Justice” (RICO) scheme of things
Went clearly unobstructed throughout the dates of on or about June 18th 2009 before the 58th Judicial District Court of Jefferson County Texas
whereby the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein legally transfer said Property located at
448 DeQueen Blvd. in Port Arthur Texas (Block) 172, (Lot) 1-2 to the “Texas Department of Housing & Community Affairs” for said $76,000 Federal Housing grant.
(14)
Notwithstanding “SWMJ CONSTRUCTION INC.” filed a “Mechanics Lien” on June 18th 2009 on said Property located at 448 DeQueen Blvd. in Port Arthur Texas (Block) 172, (Lot) 1-2
said property being a party to civil suit in common law since 2007 with the Pro Se Plaintiff herein as filed into Jefferson County Texas Clerk records instrument #2009022761
As this “Mechanics Lien” further being respectfully described in Pro Se Plaintiff Louis Charles Hamilton II attached exhibit (D) herein before the “Honorable Justice”.
(15)
Meanwhile the said “Attorney of Record” Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar. No 24058299 still (Stupidity) conspiring to boldly cutting his very own “brake lines” carrying on in his none stop
(RICO) furtherance’s activities by continue engaging ongoing well into the time frame there after the official dates of June 18th 2009
When the said Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein legally transfer said Property located at 448 DeQueen Blvd. in Port Arthur Texas (Block) 172, (Lot) 1-2 to the
“Texas Department of Housing & Community Affairs” for future fraudulent activities of said $76,000 Federal Housing grant.
And “SWMJ CONSTRUCTION INC.” now being identified herein filed a “Mechanics Lien” on June 18th 2009 on said Property located at 448 DeQueen Blvd. in Port Arthur Texas (Block) 172, (Lot) 1-2
the said same property being a party to civil suit in common law since 2007 involvement with the Pro Se Plaintiff “Louis Charles Hamilton II herein.
(16)
Defendant “himself” Antoine L. Freeman J. D. (Attorney at Law) Texas Bar. No 24058299 herein on September 11th 2009 there after the 9/11 World Trade Center Memorial was conducted in front of the Jefferson County Texas Courthouse,
Made his grand (RICO) resurfacing reappearance (Attorney at Law) act II for the hearing on 9/11/2009
as being described in Pro Se Plaintiff exhibit (D) herein (2) months and exactly 20 some odd days later thereafter when Co-Defendant(s) Joyce M. Guy and Edward McCray herein
legally transfer said Property located at 448 DeQueen Blvd. in Port Arthur Texas (Block) 172, (Lot) 1-2 to the “Texas Department of Housing & Community Affairs” for said Fraud of $76,000 Federal Housing grant.
Thereafter Defendant “himself” Antoine L. Freeman J. D. (Attorney at Law) Texas Bar. No 24058299 herein already in legal possession, custody, and control of
discovery documents of Interrogatories, Request for Admission, and Request for Disclosure in accordance with the Texas Rules of Civil Procedures 194.2, 197, and 198,
During this time frame of on or about April 2nd 2008 and April 11th , 2008 throughout the dates of on or about (Now) in the
“new time frame of” September 11th 2009 when Defendant Antoine L. Freeman J. D.(Attorney at Law) herein now commencing as acting presently as “Attorney of Record”
On this 9/11/2009 “Live Hearing Court Date” before the 58th Judicial District Court of Jefferson County Texas as being described in Pro Se Plaintiff attached exhibit (C) herein
The 58th Judicial District Court of Jefferson County Texas Docket Report
(17)
Notwithstanding simple “material facts and circumstances” Defendant “himself” Antoine L. Freeman J. D. (Attorney at Law) Texas Bar. No 24058299 herein
and Co-Defendant(s) Joyce M. Guy and Edward McCray herein collectively already being furtherance in conspire (RICO) “Obstruction of Justice”
fraudulent activates namely in the concealment and refusal to comply with all of said discovery request
For the entire year time frame of April of 2008 throughout April of 2009 and finally submitted and responding to the Pro Se Plaintiff discovery request well into the New Year of November 13th 2009
this addition of “Obstruction of Justice” is being provided as Proof before the Honorable Justice”
By and through the legal representation of on again and off again slipping in and out of a “legal coma of some sorts” Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299
in his extreme outrageous (RICO) conspire representation of the entire civil suit Docket No. A-180805 in full concert, collusion,
and corruption assistance with the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein
Resurface as on again acting “Attorney of Record” at this time frame of September 11th 2009 Defendant “himself” Antoine L. Freeman J. D. (Attorney at Law) herein
as proof being described in Pro Se Plaintiff exhibit (E) attached herein “Namely” The 58th Judicial District Court of Jefferson County “Ledger report”
for Civil Suit in Common Law Docket No. A-180805
As Pr Se Plaintiff Louis Charles Hamilton II herein attached exhibit (E) 100% sound “Meat-n-Potatoes” legal proof being submitted for a showing before the “Honorable Justice”
the actual entire legal status of the “Attorney of Record” acts and rogue actions directed at the Pro Se Plaintiff herein from the starting dates of December 18th 2007
and his (Attorney at Law) continue wrongful “Obstruction of Justice” type engagement in this (RICO) corrupted conspire activities affairs of some sort in concert with the Co-Defendant(s) collectively
Some additional (2) months and exactly 20 some odd days later thereafter
when Co-Defendant(s) Joyce M. Guy and Edward McCray herein already legally transfer said Property located at 448 DeQueen Blvd. in Port Arthur Texas (Block) 172, (Lot) 1-2 to the
“Texas Department of Housing & Community Affairs” for said $76,000 Federal Housing grant on June 18th 2009.
(18)
To include but not limited to the factual hostile and bold circumstance and legal events thereafter Defendant “himself” Antoine L. Freeman J. D. (Attorney at Law) Texas Bar. No 24058299 herein during the time frame of “August 28th 2009 already being in legal possession, custody, and control over
Pro Se Plaintiff Motion for Production of Documents
For Production of said “Property Deeds” which is a party to the Texas State Civil Court action in Common Law Cause No. A-180805 and both “Defendant and Co-Defendant(s)” collectively flat out refusal to Produce such
“Property Deeds” well into 2015 after a Court order was even obtain on May 10th 2010 for the production of said Property Deeds.
To include but not limited to the factual hostile and bold circumstance and legal events thereafter Defendant “himself” Antoine L. Freeman J. D. (Attorney at Law) Texas Bar. No 24058299 herein
during the time frame of “April 2nd 2008 and April 11, 2008 well into November 13th 2009 when “Defendant and Co-Defendant(s)” collectively
Already enjoying many (RICO) “Obstruction of Justice” tactics and engage furtherance in “pilferage and plundering” the “Texas Department of Housing & Community Affairs” for said in excess of the $76,000 Federal Housing grant.
Thereafter Defendant “himself” Antoine L. Freeman J. D. (Attorney at Law) Texas Bar. No 24058299 herein
executed and used the United States of America “innocent mailing system” and all court records and computer systems derive thereof this (RICO) Fraud and “Obstruction of Justice” scheme of things.
To include Defendant (Attorney at Law) herein execute even furtherance this fraudulent “Skilled at Fraud Law” to his advantages corrupted “scheme of things” for the legal behalf of
the Co-Defendant(s) Joyce M. Guy and Edward McCray herein
Collection to obtain all ill-gotten Pirate monetary gains as fully described in Texas States Court before the 58th Judicial District Court of Jefferson County Texas
and before The “Honorable United States Justice”
“The Honorable Zack Hawthorn United States Magistrate Judge”
Present entertainment and examination herein now in “Justice” against among others the “Civil Rights”, “Peace”, “Dignity” of the Pro Se Plaintiff “Louis Charles Hamilton II herein
a legal citizen and United States Naval Veteran within the “State of Texas” and “The United States of America”.
“To include but not limited to” adding “insult to injury” actual damages being inflicted wrongfully to the earning capacity of the Pro Se Plaintiff “Louis Charles Hamilton II herein
being legally represented as an “Independent Construction Contractor” in this ongoing 2015 (RICO) scheme of things corrupted heist since November of 2007 of the Defendant and Co-Defendant(s) collectively herein
(19)
In addition to include but not limited to “Actual damages” in excess of $3085.00 U.S. Dollars of the Pro Se Plaintiff Entire Independent Contractor Company Construction tools being in a state of
“Theft of Property” in this “Breach of Construction Contract” civil action in first filed in Texas State Court
now such loss continue (RICO) style under the direction of the hands of the Defendant for the legal wrong behalf of the Co-Defendant(s) ) Joyce M. Guy and Edward McCray collectively described correctly herein in this now infamous ongoing into 2015
(RICO) fashionable complex scheme of things involved with the Co-Defendant(s) Joyce M. Guy and Edward McCray herein collectively
conspire with the leadership of “Retain for Hire” Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar. No 24058299 herein
Being quite “fraudulently skillful, and legally in the professional capacity as an “Attorney at Law” dealing with among other things Specialist in “Fraud & Insurance litigation”
(20)
Being crafty apply against the Pro Se Plaintiff Louis Charles Hamilton II herein in a civil suit in common law within Texas State Court
thus now Pro Se Plaintiff respectfully providing all such (RICO) and “Obstruction of Justice” ongoing activities since 2007 subject matter now to the official handling Jurisdiction before the “Honorable Justice”
of the entitled above United States District Court for the Eastern District of Texas namely “the “Honorable Zack Hawthorn United States Magistrate Judge”
A endless ongoing (RICO) “Court Room Drama sorts of scheme of things since activated in November 17th 2007 with continue (RICO) acts and actions of activities involving among other things, past
Hurricanes “Rita, “Humberto” and “Ike” the Co-Defendant(s) causing among other things to the Pro Se Plaintiff herein “Direct Loss” of all tools and of lost wages in excess of $48,000.00 U.S. dollars
for a time frame exceeding now seven (7) years and counting into 2015 in collusion, concert and guidance’s with Defendant (Attorney at Law) herein
With this extreme “buck legal wild” cruel inflicted, unwanted financial coup, and hardship being (RICO) fashion nicely imposed by “Commander in Attorney at Law Chief”
The Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar. No 24058299 himself herein
And for the “Legal financial wrongful benefit and “Civil behalf” of the Co-Defendant(s) Joyce M. Guy and Edward McCray herein collectively
in a Civil Suit in Common Law within the State of Texas Jefferson County Docket No. A-180805.
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