Sunday, January 25, 2015

Louis Charles Hamilton II PLAINTIFF MOTION FOR WRIT OF ATTACHMENT No. A-180805

  
No. A-180805
Louis Charles Hamilton II Plaintiff
IN THE 58TH JUDICIAL DISTRICT COURT OF JEFFERSON COUNTY, TEXAS 
V.
Joyce Guy & Edward McCray ET AL            
Defendants. 
Writ of Attachment
Comes Now Before the Honorable 58th District Court the Pro Se Plaintiff, Louis Charles Hamilton II,
Motion before the Honorable Court, for a “Writ of Attachment”, being enforced on the Property(s) located at
1. SBD Port Arthur City Block 210 Lot 8
2. SBD Port Arthur City Block 94 Lot 11
3. SBD Lakeview Block 4 Lot 10
4. Lot 10 Block 18 Jeff Chaison ADD (Paragon Business Inc.)
As described in Pro Se Plaintiff attached exhibit(s) (A1-A2) herein “Jefferson County Texas Property search Index of the Defendant “Joyce M. Guy and Edward McCray”
And for just cause the Pro Se Plaintiff state as Follows:
1. Defendant(s) “Joyce Guy and Edward McCray” having “Actual Damages” being owed to the Plaintiff in the Amount of $11,024.00 with full 6% interest rate incurred since date of injury November 16th 2007 To include but not limited to the “Actual Theft” of the Plaintiff entire Construction Company set of tools in excess of $3093.00 Dollars
2. Defendant(s) “Joyce Guy and Edward McCray” having “Actual Damages” being owed to the Plaintiff in the Amount of $336,000.00 minimal lost wages and lost earning capacity” per year with full 6% interest rate incurred since date of injury November 17th 2007
3. This do not include, or exempt any exemplary, intentional infliction, mental anguish, physical assault & battery upon the Plaintiff person, just awards and damages the Pro Se Plaintiff may be entitled in addition to Actual damages as described in Paragraph (1) and (2) above.
Defendant(s) further collectively seeks to fully abscond Justice of this Honorable Court” to avoid paying “any real damages ever” for such “Thievery” and their combine extreme and outrageous conduct as described by the Plaintiff now ongoing over 7 years “Joyce Guy and Edward McCray” collectively caused “among other things” Pro Se Plaintiff extreme hardship and financial ruin suffrage of his “Independent Construction Company”
Pro Se Plaintiff State, Affirm and Declare this entire case civil suit in common law with the State of Texas Docket No. A-180805 is a complete package “Complex Fraudulent” scam and scheme of things of the 58th Judicial District Court of Jefferson County Texas as fully described in Pro Se Plaintiff attached exhibit (A) herein namely: Hamilton v. Freeman et al
Filed: December 3, 2014 as 1:2014cv00592
Defendant: Joyce M Guy, Antoine L Freeman, Edward McCray
Plaintiff: Louis Charles Hamilton, II
Cause of Action: Violation of Civil Rights
Court: Fifth Circuit › Texas › Texas Eastern District Court
Type: Other Statutes › Racketeer Influenced and Corrupt Organizations

With court records of the 58th Judicial District Court being supporting exhibit(s) on Filed with the U.S. Clerk of Court in support of the Pro Se Plaintiff Motion and (TRO) order to Freeze all records, documents and Assets of the described Defendant “Joyce M. Guy and Edward McCray” herein and the former Attorney of record Antoine L. Freeman, J.D. Texas Bar No. 24058299
Defendant(s) collectively own the described numerous additional “properties” with clear deeds which are not consider their primary “homestead” as that being of 448 DeQueen Blvd. in Port Arthur Texas
Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves the Honorable Court herein for a “Writ of Attachment”, being enforced on the additional Property(s) located at
5. SBD Port Arthur City Block 210 Lot 8
6. SBD Port Arthur City Block 94 Lot 11
7. SBD Lakeview Block 4 Lot 10
8. Lot 10 Block 18 Jeff Chaison ADD (Paragon Business Inc.)
Against Defendant(s) “Joyce M Guy and Edward McCray” herein in favor of the Pro Se Plaintiff being fully recorded in the Court records at the “Clerk of Court” office of Jefferson County Texas
This “Writ of Attachment” being fully enforced to cover any and all Civil Monetary Judgment(s) as assigned by the “Honorable 58th Judicial District Court of Jefferson County Texas” herein to physically seize the said “attachment ownership property(s) and dwelling described as:
9. SBD Port Arthur City Block 210 Lot 8
10. SBD Port Arthur City Block 94 Lot 11
11. SBD Lakeview Block 4 Lot 10
12. Lot 10 Block 18 Jeff Chaison ADD (Paragon Business Inc.)
To include but not limited to the “Jefferson County Sherriff’s Office to fully secure and evict, all unknown “Person and or Person(s)” having, possession, custody, and control over the described
“Attachment ownership property(s)” of the Defendant(s) “Joyce M. Guy and Edward McCray” being physically removed them from the “Ownership Property(s)”, and execute further sales thereof said Properties to cover all Judgment cost of the “Honorable Court”.
And covering any and all Sherriff’s Office Cost derived thereof in the Execution of this “Writ of Attachment” and any other cost Sherriff’s Office incurred for such sales as required by the court during this civil action as directed by this Honorable Court.
Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves, Prays,
The Honorable Court for any further, just, proper devise to secure Plaintiff “Writ of Attachment”
Until this Civil Dispute has reach a Full, Final and Complete Judgment render Before This Honorable 58th District Court of Jefferson County Texas
Notice of Motion
To: Defendant(s) “Joyce Guy and Edward McCray”
Take Notice: That a Civil Hearing before the Honorable 58th District Court of Jefferson County Texas is set at 9:00 am February 19th 2015
By the Pro Se Plaintiff Louis Charles Hamilton II herein
For the “Honorable Court” to view and reach a Judgment, on this “Writ of Attachment”

By, _______________________________
Louis Charles Hamilton II
Pro Se Plaintiff
P.O. Box 17524
Sugar Land Texas 77496

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