In The United States District Court
For The Eastern Division of Texas
Beaumont Division
Louis Charles Hamilton II
Pro Se Plaintiff
Vs.
Antoine L. Freeman J. D.
Defendant
Joyce M. Guy
Edward McCray
Co-Defendant(s)
Court Order Cause No. 1:14-CV-592
Came on to be Considered Pro Se Plaintiff’s Louis Charles Hamilton II
Application for a order to show cause why a (TRO) Temporary Restraining Order, and Order Freeze all assets of Defendant(s)
Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299
and Co-Defendant(s) Joyce M. Guy and Edward McCray herein collectively being enforced against all described Defendant(s).
And after review of the files, records, exhibit(s), and hearing oral arguments from all Plaintiff/Defendants parties involved on this Motion for a
(TRO) and requesting an Order to Freeze all assets standing before the “Honorable Court Justice” entertainment.
“Honorable Court Justice” Zack Hawthorn” United States Magistrate Judge being of the opinion that said Application for a order to show cause why a
(TRO) Temporary Restraining Order,
To protect all material evidence from being Destroying, concealment, alter, hide, screen, obscure, mask, disguise,
demolish, liquidate, erase, and eliminating as material evidences being subject matter before jurisdiction of This United States District Court, Eastern Division of Texas,
And requesting accompanying Order Freeze all assets of Defendant(s) Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299
And Co-Defendant(s) Joyce M. Guy and Edward McCray herein collectively” is with merit and should be granted, it is therefore
1.
Ordered that Plaintiff’s Application for a order to show cause why a (TRO) Temporary Restraining Order,
to protect all material evidence being subject matter before jurisdiction of This United States District Court, Eastern Division of Texas,
Is Granted and fully being enforced against Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299
and Co-Defendant(s) Joyce M. Guy and Edward McCray herein collectively”
2.
Ordered that Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 Freezing all records, correspondence, notes, phone records, recording,
communications, and other documents concerning or relating to any correspondence or communications
with Co-Defendant(s) Joyce M. Guy and Edward McCray from the dates of November 17th 2007 throughout December 1st 2015.
(3)
Freezing all records, correspondence, notes, communications, and other documents that concern or relate to any conversations,
discussions, requests for advice, or any matter relating to the above-captioned case.
(4)
Freezing all records, correspondence, notes, communications, and other documents concerning or relating to any correspondence or communications with any
Defendant, or Defendants or with any person or persons initially named as Defendants in this case regarding “Hamilton vs. Freeman et al filed February 2nd 2010 U.S. Cause No. 1:2010-CV-00055
(5)
Freezing all records, correspondence, notes, communications or other documents which are relevant to the allegations of this complaint,
and any and all records, correspondence, notes, communications or other documents which may lead to such relevant evidence.
(6)
Freezing all desk calendars, appointment books, journals, logs, and diaries which concern or relate to the Defendant,
in the performance of job description, duties, instructions, assignments, or evaluations of Co- Defendant(s) Joyce M. Guy and Edward McCray.
(7)
Freezing all records, correspondence, notes, communications, and other documents concerning or relating to the circumstances under which Defendant acquired employment from the Co-Defendant(s) Joyce M. Guy and Edward McCray, including, but not limited to,
Defendant job description, duties, his qualifications to perform those duties, and freezing any and all evaluations prepared by anyone about how he performed those duties for the behalf of the Co-Defendant(s) collectively herein.
(8)
Freezing all records showing the Defendant qualifications to perform those duties as an “Attorney at Law” in and for the State of Texas.
(9)
Freezing all records, correspondence, notes, communications, and other documents concerning or relating to any private hire authority working for Defendant behalf
“investigating the circumstances” under which Defendant were retain after acquired employment from the Co-Defendant(s) Joyce M. Guy and Edward McCray.
(10)
Freezing all records, and all Documents of Defendant “Attorney and Law”, contracts concerning or relating to Monetary retain
“Attorney at Law” Payments of services Defendant received from Co-Defendant(s) Joyce M. Guy and Edward McCray.
(11)
Freezing all of Defendant “Attorney and Law” Contracts with clients namely Co-Defendant(s) Joyce M. Guy and Edward McCray in cause No. A-180805.
(12)
Freezing all documents of Defendant “Attorney and Law” related to files, documents, letters, motions, certificate of mailing services, correspondence,
notes, communications, phone records, being received in cause No. A-180805 from Pro Se Plaintiff Louis Charles Hamilton II to the Defendant for the behalf of the Co-Defendant(s) Joyce M. Guy and Edward McCray.
(13)
Freezing all of Defendant “Attorney and Law” Contracts for hire of services with clients namely Co-Defendant(s) Joyce M. Guy and Edward McCray in U.S. Cause No. 1:2010-CV-00055
(14)
Freezing all Documents of Defendant “Attorney and Law” entire cause No. for each and every case load for every client Defendant office has legally represent in a civil court of law in and for the State of Texas from the exact dates of December 18th 2007 throughout December 18th 2014
(15)
Freezing all Documents Defendant “Attorney and Law” herein related to files, documents, letters, correspondence, notes, communications, phone records, Defendant contacted another Attorney at Law office to take over in cause No. A-180805 or
Defendant staff made such requested and or made such inquiry for the behalf of the Co-Defendant(s) Joyce M. Guy and Edward McCray.
(16)
Freezing all Documents Defendant “Attorney and Law” herein related to files, documents, letters, correspondence, notes, communications, phone records, Defendant contacted the 58th Judicial District Court Honorable Judge Bob Wortham,
And or his staff requesting to be removed as acting “Attorney of Record” from the cause No. A-180805 on or before the dates of November 13th 2009
or having another Attorney at Law office to take over in cause No. A-180805 as showing Defendant (Attorney at Law)
Herein made such requested and or made such inquiry for the behalf of the Co-Defendant(s) Joyce M. Guy and Edward McCray on or before the dates of November 13th 2009.
(17)
Freezing all Documents Defendant “Attorney and Law” herein related to files, documents, letters, correspondence, notes, communications, phone records,
employment for hire Attorney at Law contracts Defendant acquired employment from the Co-Defendant(s) Joyce M. Guy and Edward McCray other then in cause No. A-180805 and U.S. Cause No. 1:2010-CV-00055
(18)
Freezing all Documents Defendant “Attorney and Law” herein relating to the exact Identity of each,
and all staff member of the Defendant Law Office from the dates of November 17th 2007 throughout 2015 with each staff member day time telephone number and correct mailing address.
(19)
Freezing all Documents Defendant “Attorney and Law” herein relating to the exact monetary payment
and contract thereof the Defendant received from Co-Defendant(s) in cause No. A-180805 to file a “General Denial” to Pro Se Plaintiff Complaint.
(20)
Freezing all Documents Defendant “Attorney and Law” herein relating to the exact monetary payment and “Attorney/Client contract thereof the Defendant received from Co-Defendant(s) in cause No. A-180805
To appear at a hearing on the dates of August 28th 2009 to respond to Pro Se Plaintiff Complaint and all circumstance for the legal behalf of the Co-Defendant(s) Joyce M. Guy and Edward McCray herein on hearing dates of August 28th 2009.
(21)
Freezing all Documents Defendant “Attorney and Law” herein relating to the exact monetary payment and Attorney/client contract thereof the Defendant received from Co-Defendant(s) in cause No. A-180805 to appear at a hearing on the dates of September 11th 2009
To respond to Pro Se Plaintiff Complaint and all circumstance for the legal behalf of the Co-Defendant(s) Joyce M. Guy and Edward McCray herein on hearing dates of September 11th 2009.
(22)
Freezing all Documents Defendant “Attorney and Law” herein relating to any of Pro Se Plaintiff “Discovery Request for Interrogatories, Request for Admission, and Request for Disclosure in accordance with the Texas Rules of Civil Procedures 194.2, 197, and 198,
in Defendant possession, custody and legal control from the dates of April 2nd 2008 and April 11, 2008,
throughout the dates of October 14th 2009 which Defendant supply some sort of respond during this time frame of (1) year and (5) months and counting days Defendant not responding.
(23)
Freezing all Documents Defendant “Attorney and Law” herein relating to the exact monetary payment and Attorney/client contract thereof the Defendant represented the Co-Defendant(s) Joyce M. Guy and Edward McCray herein
legal behalf in any criminal/civil cases other then cause No. A-180805 and U.S. Cause No. 1:2010-CV-00055
(24)
Freezing all Documents Defendant “Attorney and Law” herein relating to the exact ledger of cause No. A-180805
resulting from business transactions and principal book keeping and computer filing system for all documents, records, contracts, and banking records.
(25)
Freezing all Documents Defendant “Attorney and Law” herein relating to the exact “certificate of mailing services”
Defendant received (Legal Court Documents) in cause No. A-180805 from Pro Se Plaintiff herein for the behalf of the Co-Defendant(s) Joyce M. Guy and Edward McCray herein.
(26)
Freezing all Documents Defendant “Attorney and Law” herein relating to the business transactions, dealings, and or relationship between the Defendant
“Attorney at Law” with the Co-Defendant(s) Joyce M. Guy and Edward McCray herein other than a Attorney/client relationship between the dates of 1980 throughout 2015.
(27)
Freezing all Documents Defendant “Attorney and Law” herein relating to the business transactions, dealings,
(IRS) records showing the Annually Income received for the Defendant Law Office herein from the dates of November 17th 2007 throughout December 2015.
(28)
Freezing all Documents Defendant “Attorney and Law” herein relating to the Defendant having another “Attorney/Client Relationship other then in cause No. A-180805 showing Defendant did not actually respond to discovery request for Interrogatories, Request for Admission,
And Request for Disclosure in accordance with the Texas Rules of Civil Procedures 194.2, 197, and 198, in Defendant possession, custody and legal control
for other Clients retain for Defendant “Legal Services” other than the Co-Defendant(s) Joyce M. Guy and Edward McCray herein.
(29)
Freezing all records showing the Defendant staff qualifications to perform those duties acting on behalf of Defendant “Attorney at Law” herein Law Offices in and for the State of Texas from the dates of November 17th 2007 - 2015.
(30)
Freezing all of Defendant “Attorney and Law” entire cause No. Ledger showing for each and every case load for the Defendant “Law office”
he has legally represent in a civil court in a suit in common law in and for the State of Texas from the exact dates of December 18th 2007 throughout December 18th 2014 showing each cause No.
“The exact Courthouse in Texas whereby Defendant represented, ledger showing of each documents and motions received
and filed response thereof per each cause No., with Production of Documents on all return Defendant certificate of mailing services to “opposition counsel or Pro Se (Person or Persons)”.
(31)
Freezing all Documents, Birth records, Church records, Hospital (DNA) records all of Defendant “Attorney and Law” herein
having descended from a common ancestor or constituting a people, clan, tribe, or family, relative or kinsman with the Co-Defendant(s) Joyce M. Guy and Edward McCray herein.
(32)
Freezing all of Defendant “Attorney and Law” herein entire assets in Law office located at 3629 Professional Dr. Port Arthur Texas 77642
(34)
Freezing all of Defendant “Attorney and Law” herein entire assets in Law office located at 3723 Gulfway Dr. Port Arthur Texas 77642
(35)
Freezing all of Defendant “Attorney and Law” herein entire assets in “Deed” Professional Development Block 2 Lot 3
“SBD Keith Marroquin” as being described in Pro Se Plaintiff attached exhibit (M) “Jefferson County Texas” search Index #2011035793
(36)
Freezing all of Defendant “Attorney and Law” herein entire assets in “Gulf Employee Credit Union
as being described in Pro Se Plaintiff attached exhibit (M) “Jefferson County Texas” search Index #2002005559
(37)
Freezing all of Defendant “Attorney and Law” herein entire assets in “Port Arthur Teachers Federal Credit Union
as being described in Pro Se Plaintiff attached exhibit (M) “Jefferson County Texas” search Index #2004004187
(38)
Freezing all of Defendant “Attorney and Law” herein entire assets as being described in Pro Se Plaintiff attached exhibit (M)
“Jefferson County Texas” search Index herein all such person and person(s)
(39)
As identified having (any) interests in all entities owned, in whole or in part, or controlled by, related to, or associated or
affiliated with Defendant Antoine L. Freeman J. D. (Attorney at Law) herein “Namely” “Freeman Antoine, Freeman Antoine L,
Freeman Antoine L Sr., Freeman Antoinette C & EX, Black James M and Moor Leslie M Jr.
(40)
Freezing all Assets” of Defendant (Attorney at Law) herein there after providing a “verified written described accounting” and “personal financial statement” of Defendant Antoine L. Freeman J. D. (Attorney at Law) herein as•set plural noun: assets:
“Deeds”, Banking accounts presently held, Property, Stock, Bonds, (IRA), Commercial Real estate, Companies, Investments, estates, livestock, cattle, horses, Rental Property(s), landholding, chattel,
Valuable Art collection, investment banking, (money) to use, by purchase or expenditure, in something offering potential profitable returns, as interest, income, gold investment.
(41)
Freezing all records in G and G Service Company P.O. Box 515, 416 DeQueen Blvd. in Port Arthur“ Business records”,
banking records, personal banking records, staff records, (IRS), computer records, insurance records, ledgers, tax records, from the dates of 1997-2015
(42)
Freezing all records in J Can Company 1807 East 7th Street Port Arthur Texas (Office) located at 448 DeQueen Blvd. in Port Arthur Texas 77640
“ Business records”, banking records, personal banking records, staff records, (IRS), tax records, computer records, insurance records from the dates of 2008-2015
(43)
Freezing all records in E and J Collectibles located at 448 DeQueen Blvd. in Port Arthur Texas 77640
*note this company not listed on Pro Se Plaintiff attached exhibit (C) herein records contain at “Jefferson County Texas Search Index”
However it “do exist” on the Internet as being two companies and is in “physical operation”
as Public Advertisement claims open to the public in Jefferson County Texas contact Co-Defendant “Joyce M. Guy” (409) 330-0485.
Business records”, banking records, personal banking records, staff records, (IRS), tax records, computer records, insurance records, from the dates of 1997-2015
(44)
Freezing all records in “Paragon Business Inc.” Lot 10 Block 18 (Jefferson) Chaison ADD
Business records”, banking records, personal banking records, staff records, (IRS), tax records, computer records, insurance records from the dates of 2001-2015
(45)
Freezing all records in “Cars and Pieces” office located in Beaumont Texas and all records at office located at 448 DeQueen Blvd. in Port Arthur Texas 77640
Business records”, banking records, personal banking records, staff records, (IRS), tax records, computer records, insurance records from the dates of 2001-2015
(46)
Freezing all records in DSW Homes relating to Co-Defendant(s) Joyce M. Guy and Edward McCray herein
(47)
Freezing all records in SWMJ Construction Inc. relating to Co-Defendant(s) Joyce M. Guy and Edward McCray herein
(48)
Freezing all records in “Texas Department of Housing and Community Affairs” relating to Co-Defendant(s) Joyce M. Guy and Edward McCray herein
(49)
Freezing all records in North America Popular Banco Texas relating to Co-Defendant(s) Joyce M. Guy and Edward McCray herein
(50)
Freezing all records during “Hurricane “Rita”, “Ike” and “Humberto” related Construction storm damages to the property located at 448 DeQueen Blvd in Port Arthur Texas
Business records”, banking records, personal banking records, Home owner Insurance Records, FEMA records, Contractor Construction records, and recovery repair records.
(51)
Freezing all records during “Hurricane “Rita”, “Ike” and “Humberto”
related Construction storm damages to the property located at 5050 east 7th street in Port Arthur Texas
Business records”, banking records, personal banking records, Home Owner Insurance Records, FEMA records, Contractor Construction records, recovery repair records.
(52)
Freezing all records during “Hurricane “Rita”, “Ike” and “Humberto”
related Construction storm damages to the property located at SBD “Lakeview”, Block 4 Lot 10 Jefferson County Texas
Business records”, banking records, personal banking records, Home Owner Insurance Records, FEMA records Contractor Construction records, recovery repair records.
(53)
Freezing all of Co- Defendant Joyce M. Guy and Edward McCray “collectively” herein
entire assets in G and G Service Company P.O. Box 515, 416 DeQueen Blvd. in Port Arthur“77640
(54)
Freezing all of Co- Defendant Joyce M. Guy and Edward McCray “collectively” herein
entire assets in J Can Company 1807 East 7th Street Port Arthur Texas (Office) located at 448 DeQueen Blvd. in Port Arthur Texas 77640 “
(55)
Freezing all of Co- Defendant Joyce M. Guy and Edward McCray “collectively” herein
entire assets in E and J Collectibles located at 448 DeQueen Blvd. in Port Arthur Texas 77640
(56)
Freezing all of Co- Defendant Joyce M. Guy and Edward McCray “collectively” herein
entire assets in “Paragon Business Inc.” Lot 10 Block 18 (Jefferson) Chaison ADD
(57)
Freezing all of Co- Defendant Joyce M. Guy and Edward McCray “collectively” herein entire assets in “Cars and Pieces”
Office located in Beaumont Texas and office located at 448 DeQueen Blvd. in Port Arthur Texas 77640
(58)
Freezing all of Co- Defendant Joyce M. Guy and Edward McCray “collectively” herein
entire assets in the property located at 5050 east 7th street in Port Arthur Texas
(59)
Freezing all of Co- Defendant Joyce M. Guy and Edward McCray “collectively” herein
entire assets in the property located at SBD “Lakeview”, Block 4 Lot 10 Jefferson County Texas
(60)
Freezing all of Co- Defendant Joyce M. Guy and Edward McCray “collectively” herein
entire assets in the property located at 1807 east 7th street Port Arthur Jefferson County Texas
(61)
Freezing all of Co- Defendant Joyce M. Guy and Edward McCray “collectively” herein
entire assets in the property located SBD Port Arthur City Block 210, Lot 8 Jefferson County Texas
(62)
Freezing all of Co- Defendant Joyce M. Guy and Edward McCray “collectively” herein
entire assets in the property located at SBD Port Arthur City Block 94, Lot 11 Jefferson County Texas
(63)
Freezing all of Co- Defendant Joyce M. Guy and Edward McCray “collectively” herein
entire assets in the property located at 416 DeQueen Blvd. Port Arthur Jefferson County Texas
(64)
Freezing all of Co- Defendant Joyce M. Guy and Edward McCray “collectively” herein
entire assets in the property located at 448 DeQueen Blvd. Block 172 Lot 1-2 in Port Arthur Jefferson County Texas
(65)
Freezing all of Co- Defendant Joyce M. Guy and Edward McCray “collectively” herein
entire assets in the property located at Rev Ransom Howard Street in Port Arthur Jefferson County Texas Property ID #89824 (Commercial Vacant Lot)
(66)
Freezing all of Co- Defendant Joyce M. Guy and Edward McCray “collectively” herein
entire assets as being described in Pro Se Plaintiff attached exhibit (C) “Jefferson County Texas” search Index herein all such person and person(s) to include but not limited to
As identified having (any) interests in all entities owned, in whole or in part, or controlled by, related to, or associated or affiliated with Co- Defendant Joyce M. Guy and Edward McCray “collectively” herein
“Namely” “Willie Jones, Dorothy Cooley, Norma Guy, U Guy Sr., Joyce Johnson Guy, Sarah D. West,
Gladys Carpenter, Janet L. Hart, Edward E. McCray, Edward McCray, Edward Eugene McCray Sr., Horse Grant, Allen Guy, Joyce Johnson Guy.
(67)
Freezing all Assets” of Co-Defendant “Joyce M. Guy and Edward McCray” “collectively” herein
there after providing a “verified written described accounting” and “personal financial statement” of Co-Defendant “Joyce M. Guy and Edward McCray”, “collectively” ,herein as•set plural noun: assets:
“Deeds”, Banking accounts presently held, Property, Stock, Bonds, (IRA), Commercial Real estate, Companies, Investments, estates, livestock, cattle, horses, Rental Property(s), landholding, chattel,
Valuable Art collection, investment banking, (money) to use, by purchase or expenditure, in something offering potential profitable returns, as interest, income, gold investment.
(68)
Ordered that “The United States Marshall” services shall served notice of this (TRO) Temporary Restraining Order, and Order Freeze all assets upon Co-Defendant “Joyce M. Guy and Edward McCray” collectively,
Occupants of the dwelling located at 448 DeQueen Blvd., in Port Arthur Texas that a Temporary Restraining Order,
and Order Freeze all assets is fully being enforced against them and on the Property located at 448 DeQueen Blvd. in Port Arthur Texas
(69)
Ordered that “The United States Marshall” services shall execute, secure the Temporary Restraining Order,
And “The United States Marshall” services shall execute, retrieves and secure this Order Freeze all assets upon Co-Defendant “Joyce M. Guy and Edward McCray” collectively,
Against all Personal and Business banking accounts, “Deeds”, Banking accounts presently held, Property,
Stock, Bonds, (IRA), Commercial Real estate, Companies, Investments, estates, livestock, cattle, horses, Rental Property(s), landholding, chattel,
Valuable Art collection, investment banking, (money) to use, by purchase or expenditure, in something offering potential profitable returns, as interest, income, gold investment.
(70)
Ordered that Defendant(s) Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 prohibited from any acts of
Destroying, concealment, alter, hide, screen, obscure, mask, disguise, demolish, liquidate, erase, and eliminating all material evidences supporting all subject matter herein and all assets.
(72)
Ordered that Co-Defendant(s) Joyce M. Guy and Edward McCray collectively prohibited from any acts of
Destroying, concealment, alter, hide, screen, obscure, mask, disguise, demolish, liquidate, erase, and eliminating all material evidences supporting all subject matter herein and all assets.
(73)
Ordered that Defendant(s) Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299
Immediately License “Suspended and Prohibited” from practicing law in and for the State of Texas, Until further notice of the “Honorable Justice”.
Executed on this ________ Day of ____________________ 2015
___________________________________
Honorable Justice Zack Hawthorn
United States Magistrate Judge
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