(8)
Pro
Se Plaintiff being further set forth Declares, Affirm, and State further before the
“Honorable U.S. Justice” Defendant Antoine L. Freeman J. D. (Attorney at Law)
Texas Bar No. 24058299 and Co-Defendant(s)
“Joyce M. Guy” and Edward McCray”
collectively herein on or there after filed in District Court of Jefferson
County Texas March 14th 2008 1:48 pm having full discover request of
the Pro Se Plaintiff as described
To: Chief Defendant Antoine L. Freeman J. D.
(Attorney at Law) Texas Bar No. 24058299 pursuant to rule 194, request for
disclosure Pro Se Plaintiff attached exhibit (R) herein
With
certificate of mailing services attached and * filed also in District Court of
Jefferson County Texas March 14th 2008 1:48 pm
To: Chief Defendant Antoine L. Freeman J. D.
(Attorney at Law) Texas Bar No. 24058299 Plaintiff Motion for Production of
Documents being Pro Se Plaintiff attached exhibit (S) herein
(9)
Pro
Se Plaintiff being further set forth Declares, Affirm, and State further before the
“Honorable U.S. Justice” Defendant Antoine L. Freeman J. D. (Attorney at Law)
Texas Bar No. 24058299 and Co-Defendant(s) “Joyce M. Guy” and Edward McCray”
collectively herein in exhibit(s) (A) and (B)
Already
on file with the U.S. Clerk of Court maintain having knowledge possession,
custody and control of Pro Se Plaintiff discovery was during the exact time
frame of April 2nd 2008 and
April 11th, 2008 which was fraudulent statements made before the
58th Judicial District Court by
Defendant/Attorney of Record/ Antoine
L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 and Co-Defendant(s)
collectively herein in comparison to Pro Se Plaintiff exhibit (R) and (S)
attached herein showing “among other things” the actual request for copies of
the “Property Deeds” the exact precise time frame which is a material issue in
this civil action in common law to be on record of this civil action in March
of 2008,
(10)
Which Pro Se Plaintiff being further
set forth Declares, Affirm, and State further before the
“Honorable U.S. Justice” Defendant Antoine L. Freeman J. D. (Attorney at Law)
Texas Bar No. 24058299 and Co-Defendant(s) “Joyce M. Guy” and Edward McCray”
collectively herein on June 9th 2009 1 year and 2 months in direct
refusal to produce said property deeds
Completely there after conspire, plotted
instead of producing the Property deed before the Honorable Court and to the
Pro Se Plaintiff continue engaged in real (RICO) enterprise scheme of things
and “Transfer of Lien” and “Property Deeds”, for the said dwelling located at
448 DeQueen Blvd in Port Arthur Texas to the
“Texas Department of Housing and Community
affairs” Loan No. 2727 File No. 1219-2102152 CFDA 14.228 Community Development
Block Grant Program (“CDBG”) Hurricanes Katrina, Rita and Wilma in the Gulf of
Mexico 2005
Federally Declared Disaster Funding
under Department of Defense Appropriations Act, 2006 CDBG Disaster Recovery
Program (Homeowner Assistance Program “HAP”)
Or (Sabine Pass Restoration Program
“SPRP”) Awarding Federal Agency: United States Department of Housing and Urban
Development TDHCA Federal Award Number: B-06-DG-48-0002 Federal Award Year
(Year of Award from HUD to TDHCA): 2006 TDHCA Award Year: 2007
As
being described in Pro Se Plaintiff attached exhibit herein (Q) for $75,500.00
U.S. Housing Grant in unpaid “Principal and Interest” with a date of Maturity being
June 8th, 2012 when this civil suit in common law A-180805 commenced
in December 26th 2007 and Co-Defendant(s) already (RICO) fashion
obtain funds for Hurricane Rita,
Humberto
and Ike for covering cost of needed repair from previously storm damages as all
of this was for private use other than actual home repairs as already legally
described be the Pro Se Plaintiff herein providing additional proof for the
“Honorable
U.S. Justice” a not so ordinary state case of Fraud but a grand 2005- 2014 (RICO)
enterprise endeavor scheme of things well into future designed, and careful
craftiness by
Chief
Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299
herein to among other things appear in a live court hearing on August 28th
2009 win the (TRO) hearing the Co-Defendant did in fact squander her mother
insurance repair funds and disappear again claiming he “Attorney of Record” was
never even there before the 58th Judicial District Court he not the “Attorney
of record to win a Motion for sanctions while being
100% the retain expert skilled in Fraud Attorney
fully rouge, hostile, and criminal in holding out on all “discovery phase” as
already described against him legally.
To the point Pro Se Plaintiff attached exhibit
(S) namely Plaintiff Motion for Production of Documents filed herein never ever
even been answered as of this undersigned date.
(11)
Which
Pro Se Plaintiff being further set forth Declares, Affirm, and State further before the
“Honorable U.S. Justice” Defendant Antoine L. Freeman J. D. (Attorney at Law)
Texas Bar No. 24058299 and Co-Defendant(s) “Joyce M. Guy” and Edward McCray”
collectively herein working further fraudulent together,
“Hand in hand” smiling in monetary victory as
now being provided a document first time in Texas history an extra greedy not
so a ordinary state case of Fraud but a grand (RICO) fraudulent enterprise endeavor
scheme of things well into future designed, and careful craftiness by
Chief Defendant Antoine L. Freeman J.
D. (Attorney at Law) Texas Bar No. 24058299 herein to engage now at this point
after all fraudulent cover up all of the Fraud scheme of things as being
described in paragraph
(1)-(6) above against the property located at
5050 east 7th street in Port Arthur Texas to achieve another grand (RICO)
enterprise endeavor scheme of things well into future designed, and careful
craftiness against once again
“Texas Department of Housing and Community
affairs” Loan No. 5866 File No. 1219-2355082 CFDA 14.228 Community Development
Block Grant Program (“CDBG”) Hurricanes Katrina, Rita and Wilma in the Gulf of
Mexico 2005
Federally Declared Disaster Funding under
Department of Defense Appropriations Act, 2006 CDBG Disaster Recovery Program
(Homeowner Assistance Program “HAP”)
Or (Sabine Pass Restoration Program
“SPRP”) Awarding Federal Agency: United States Department of Housing and Urban
Development TDHCA Federal Award Number: B-06-DG-48-0002 Federal Award Year
(Year of Award from HUD to TDHCA): 2006 TDHCA
Award Year: 2007 to obtain on May 28th 2010 in excess of $54,839.31
U.S. Dollars
“Construction Housing Grant” in unpaid
“Principal and Interest” with a date of Maturity being well calculated and
executed into 2015
(12)
Which Pro Se Plaintiff being further
set forth Declares, Affirm, and State further before the
“Honorable U.S. Justice” Defendant Antoine L. Freeman J. D. (Attorney at Law)
Texas Bar No. 24058299 and Co-Defendant(s) “Joyce M. Guy” and Edward McCray”
collectively
(RICO) scheme of things in the direct
refusal of the actual request in discover request dated back in March 14th
2008 with a Court Order further following for such a Production of said “property
deeds” now being Pro Se Plaintiff attached exhibit (L) herein dated May 10th
2010 notwithstanding factual events and circumstances said
Property deeds being officially “free
and clear” from the “Texas Department of Housing and Community affairs” Loan
No. 2727 File No. 1219-2102152 CFDA 14.228 Community Development Block Grant
Program (“CDBG”) Hurricanes Katrina, Rita and Wilma in the Gulf of Mexico 2005 as
filed and recorded April 22nd 2014 at 12:38 pm
As described in Pro Se Plaintiff
attached exhibit (T) herein namely “Property Deeds” of the Co-Defendant(s)
Joyce M. Guy and Edward McCray” herein dated April 22nd 2014for the dwelling
located at 448 DeQueen Blvd in Port Arthur Texas
(13)
With the Co-Defendant(s) Joyce M. Guy and
Edward McCray” herein fraudulent “Financing Statement” dated June 18th
10:20 am filed as Pro Se Plaintiff attached exhibit (U)
And Co-Defendant(s) Joyce M. Guy and Edward
McCray” herein Termination of Fraudulent Financing Statement Amendment dated
July 22nd 2013 2:01 pm filed as Pro Se Plaintiff attached exhibit
(V)
(14)
Which Pro Se Plaintiff being further
set forth Declares, Affirm, and State further before the
“Honorable U.S. Justice” Defendant Antoine L. Freeman J. D. (Attorney at Law)
Texas Bar No. 24058299
And Co-Defendant(s) “Joyce M. Guy” and
Edward McCray” collectively further (RICO) scheme of things is involved in not being
honest and providing full disclosure all of the actual Business being owned and
all income derive thereof
“Namely” G & G services and E and
J collectable in order to obtain fraudulent from the “Texas Department of
Housing and Community affairs” said Loan No. 2727 File No. 1219-2102152 CFDA
14.228 Community Development Block Grant Program (“CDBG”) Hurricanes Katrina,
Rita and Wilma in the Gulf of Mexico 2005 in excess of $72,500.00
Being directly in violation of 18 U.S.C. § 1001 : US Code -
Section 1001: Statements or entries generally
(a) Except as otherwise provided in this section, whoever, in any matter within the jurisdiction of the executive, legislative, or judicial branch of the Government of the United States,
knowingly and willfully - (1) falsifies, conceals, or covers up by any trick, scheme, or device a material fact;
(2) makes any materially false, fictitious, or fraudulent statement or representation; or
(3) makes or uses any false writing or document knowing the same to contain any materially false, fictitious, or fraudulent statement or entry;
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