Thursday, December 18, 2014

MOTION TO FREEZE DOCUMENTS, ASSETS, OF DEFENDANT ANTOINE L. FREEMAN J.D., "Attorney at Law" et al U.S. CAUSE No.1:14-CV-592

Pro Se Plaintiff

(Brief)

(7)

“Good and sufficient cause and reasoning exist why procedure other then notice of motion is necessary, for a Order to show cause,

Temporary Restraining Order, Order to Secure Relating to the destruction, concealment or alteration of all book keeping records,

court documents, banking records, computer records, Insurance records, Business records as described in the complaint on file with the United States Clerk of Court office herein

Namely all book keeping records, court documents, banking records, computer records, Insurance records, Business records being further set forth herein

from the dates of November 17th 2007 throughout December 18th 2014 for the Defendant Antoine L. Freeman J. D. (Attorney at Law) herein

in his extreme and outrageous representation of Co-Defendant(s) “Joyce M. Guy and Edward McCray” against the Pro Se Plaintiff herein civil suit in common law filed cause No. A-180805

with Pro Se Plaintiff Motion for Production of Document(s) to Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 attached herein

as Pro Se Plaintiff Exhibit (A) before this Honorable United States District Court For The Eastern Division of Texas Beaumont Division appearing before

“The Honorable Zack Hawthorn Magistrate Judge"

as being the exact evidentiary records Pro Se Plaintiff request brought forth before Justice.

(8)

“Good and sufficient cause and reasoning exist why procedure other then notice of motion is necessary, for a Order to show cause, Temporary Restraining Order, Order to Secure evidence Relating to the destruction, concealment or alteration of all book keeping records,

court documents, banking records, computer records, Insurance records, Business records as described in the complaint on file with the United States Clerk of Court office herein

Namely all book keeping records, court documents, banking records, computer records, Insurance records, Business records, construction estimates,

FEMA, Property lien records, property deeds records and all records in relationship to the exact time frame damages caused by

Hurricanes “Rita”, “Humberto” and “Ike” to the property located at 448 DeQueen Blvd. in Port Arthur, Texas

being further set forth herein prohibiting any further attempts at the destruction, concealment or alteration by the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein

being “chief” defendant(s) in a civil suit in common law filed cause No. A-180805

*Pro Se Plaintiff “Louis Charles Hamilton II” herein move quite extra respectfully as requesting the “Honorable Justice Zack Hawthorn Magistrate Judge” having crystal clear examination of Pro Se Plaintiff Exhibit (B)

Order of the 58th Judicial District Court of Jefferson County Texas filed on May 10th 2010 at 11:46 am

Ordered that Co-Defendant(s) “Joyce M. Guy and Edward McCray” shall produce all records and construction estimates for damages caused as a result of Hurricanes “Rita”, “Humberto” and “Ike” to the property located at 448 DeQueen Blvd. in Port Arthur, Texas and as of December 18th 2014 well into the year of 2015

Co-Defendant(s) “Joyce M. Guy and Edward McCray” are in complete refusal to submit of said exhibit (B) Order of the 58th Judicial District Court of Jefferson County Texas filed on May 10th 2010 at 11:46 am to produce said documents, records, and construction estimates as described in exhibit (B)

Notwithstanding Co-Defendant(s) “Joyce M. Guy and Edward McCray” are in complete 100% refusal also to submit to said exhibit (B) Order of the 58th Judicial District Court of Jefferson County Texas filed on May 10th 2010 at 11:46 am

To produce copies of deeds, property deeds or any other such physical document in Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein collective possession, custody and control that shows actual ownership of the property of the dwelling located at 448 DeQueen Blvd., in Port Arthur Texas (Block) 172, Lot 1-2

With Pro Se Plaintiff “Louis Charles Hamilton II” Exhibit (B) filed herein before this Honorable United States District Court For The Eastern Division of Texas Beaumont Division
Appearing before “The Honorable Zack Hawthorn Magistrate Judge” as being the exact evidentiary records Pro Se Plaintiff request brought forth before Justice.

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